United States Department of Agriculture

Final Environmental Impact Statement

for Revision of the Inyo National Forest 

Land Management Plan

Volume 1: Chapters 1 through 4, 

Glossary, References, and Index 

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

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

administering USDA programs are prohibited from discriminating based on race, color, national origin, 

religion, sex, gender identity (including gender expression), sexual orientation, disability, age, marital 

status, family/parental status, income derived from a public assistance program, political beliefs, or reprisal 

or retaliation for prior civil rights activity, in any program or activity conducted or funded by USDA (not 

all bases apply to all programs). Remedies and complaint filing deadlines vary by program or incident. 

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

Braille, large print, audiotape, American Sign Language, etc.) should contact the responsible Agency or 

USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay 

Service at (800) 877-8339. Additionally, program information may be made available in languages other 

than English. 

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

AD-3027, found online at http://www.ascr.usda.gov/complaint_filing_cust.html and at any USDA office or 

write a letter addressed to USDA and provide in the letter all of the information requested in the form. To 

request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA 

by: (1) mail: U.S. Department of Agriculture, Office of the Assistant Secretary for Civil Rights, 1400 

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

program.intake@usda.gov. USDA is an equal opportunity provider, employer and lender.

NOTE: If you need assistance with the accessibility of this document, please contact the Pacific Southwest 

Region Office at (707) 562-9121.

Cover Photo: Fall colors of an aspen stand at North Lake, Inyo National Forest. Photo by L. Murphy
Final Environmental Impact Statement 

for Revision of the

Inyo National Forest

Land Management Plan

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

and Esmeralda and Mineral Counties, Nevada

Lead Agency: USDA Forest Service

Cooperating Agencies: Environmental Protection Agency 

Inyo County 

Responsible Official: Tammy Randall-Parker, Forest Supervisor

Inyo National Forest 

351 Pacu Lane

Bishop, CA 93514

For Information Contact: Leeann Murphy, Resource Staff Officer

Inyo National Forest 

351 Pacu Lane 

Bishop, CA 93514

lbmurphy@fs.fed.us

760-873-2404

Send Objections to: Objections-Pacificsouthwest-RegionalOffice@fs.fed.us OR

Reviewing Officer, Randy Moore, Regional Forester, 

Pacific Southwest Region

1323 Club Drive 

Vallejo, CA 94592, 

Objections or objection content specific to the 

identification of species of conservation concern will 

be forwarded to the Glenn Casamassa, Associate 

Deputy Chief of the Forest Service.

Date Objections Must Be Received: Within 60 days following publication of the legal notice 

in the newspaper of record, The Inyo Register. Objectors 

should check the Inyo Register and the Inyo National 

Forest’s land management planning webpage for the 

legal notice publication date. It is the objector’s 

responsibility to calculate the end of the 60-day 

objection filing period to ensure timely submission. See 

the cover letter and the Inyo National Forest’s land 

management planning webpage for more information on 

the objection process and requirements.
Abstract 

This final environmental impact statement documents the analysis of five alternatives (A through 

D, including B-modified) developed by the Forest Service to revise the land and resource 

management plan, as amended, for the Inyo National Forest (1988). The revised land 

management plan would provide for the programmatic management of approximately 2 million 

acres administered by the Inyo National Forest. The alternatives are described in more detail in 

chapter 2. Alternative A is the no-action alternative, and would keep in place the management 

direction from the Inyo National Forest’s land and resource management plan, as amended. 

Alternative B-modified is a modified version of the draft revised plan (alternative B) and it is the 

preferred alternative. 

Alternatives B, B-modified, C, and D address three revision topics that reflect the purpose and 

needs for the revised plan: (1) to reduce the risk of large high-intensity wildfires to communities 

and assets; increase the ability to manage wildfires to meet resource objectives; and reduce smoke 

impacts to communities; (2) to restore the resilience of vegetation and aquatic and riparian 

ecosystems to fire, drought and climate; restore wildlife and plant habitat and diversity; and 

reduce the risk of wildfire impacts to species and wildlife habitat; and (3) to provide sustainable 

and diverse recreation opportunities that consider population demographic characteristics; reflect 

desires of local communities, avoid overcrowding and use conflicts, and minimize resource 

damage; and protect cultural resources. In addition, three areas identified as a need for change in 

the notice of intent are addressed but plan direction does not change between alternatives: (1) to 

incorporate plan direction for lands transferred to the Inyo National Forest under the National 

Forest and Public Lands of Nevada Enhancement Act; (2) to address benefits to people and 

communities; and (3) to address tribal relations and uses. These areas are incorporated in various 

ways throughout the alternatives.

Alternatives B through D address new information and concerns that emerged during the 

implementation of the current forest plan. Each alternative complies with Federal laws, 

regulations, and policies. These alternatives also address significant issues (unresolved conflicts 

with the proposed action) that were identified from comments received during our public 

engagement sessions and the formal 30-day scoping period.

The Forest Service will use the pre-decisional administrative review process, also referred to as 

the “objection process” 1 described in the 2012 Planning Rule (36 CFR 219, subpart B). This 

process gives an individual or entity an opportunity for an independent Forest Service review and 

resolution of issues before a final plan is approved. Subpart B identifies who may file objections 

to a plan revision, the responsibilities of the participants in an objection, and the procedures that 

apply to the review of the objection. Section 219.53 of the Planning Rule describes who may file 

an objection. Individuals and entities who have submitted substantive formal comments related to 

this plan revision during the opportunities for public comment for this decision may file an 

objection.

 1 National Forest System Land and Resource Management Planning: Final Rule and Record of Decision. Federal 

Register Vol. No. 77, April 9, 2012, pages 21161-21276. Available online at: https://federalregister.gov/a/2012-7502
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

i

Contents

Preface............................................................................................................................................xi

Chapter 1. Purpose of and Need for Revising the Inyo National Forest Land Management 

Plan..................................................................................................................................................1

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

About the Inyo National Forest................................................................................................1

Regulatory Direction................................................................................................................3

Plan Revision under the 2012 Planning Rule.......................................................................3

Forest Plan Content..................................................................................................................4

Plan Components.................................................................................................................4

Other Plan Content...............................................................................................................5

Purpose of and Need for Revising the Forest Plan ......................................................................5

From Needs for Change to Revision Topics............................................................................6

Revision Topic 1: Fire Management....................................................................................6

Revision Topic 2: Ecological Integrity................................................................................7

Revision Topic 3: Sustainable Recreation and Designated Areas.......................................7

The Revised Plan .........................................................................................................................7

Decision Framework....................................................................................................................7

Public Participation......................................................................................................................8

Issues......................................................................................................................................10

Issues that Served as the Basis for Alternative Development............................................10

Chapter 2. Alternatives, Including the Proposed Action .........................................................15

Introduction................................................................................................................................15

Alternatives Considered in Detail..............................................................................................15

Alternative Development and Refinement Process ...............................................................15

Alternative B......................................................................................................................15

Alternative B-modified ......................................................................................................15

Alternative C......................................................................................................................16

Alternative D......................................................................................................................16

Features Common to Alternatives B, B-modified, C, and D.................................................17

Species of Conservation Concern ......................................................................................17

Tribal Relations and Uses..................................................................................................18

Partnerships........................................................................................................................18

Wild and Scenic Rivers......................................................................................................19

Nevada Enhancement Act Lands.......................................................................................19

Scenic Integrity ..................................................................................................................19

Invasive Species.................................................................................................................21

Climate Change..................................................................................................................21

Alternative A: Existing Plan Direction..................................................................................21

Revision Topic 1: Wildland Fire Management..................................................................21

Revision Topic 2: Ecological Integrity..............................................................................22

Revision Topic 3: Sustainable Recreation and Designated Areas.....................................24

Alternative B: Draft Revised Plan .........................................................................................25

Revision Topic 1: Wildland Fire Management..................................................................25

Revision Topic 2: Ecological Integrity..............................................................................27

Revision Topic 3: Sustainable Recreation and Designated Areas.....................................30

Alternative B-modified: Preferred Alternative for the Revised Plan.....................................31

Revision Topic 1: Wildland Fire Management..................................................................32
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

ii

Revision Topic 2: Ecological Integrity ..............................................................................33

Revision Topic 3: Sustainable Recreation and Designated Areas.....................................38

Alternative C..........................................................................................................................40

Revision Topic 1: Wildland Fire Management..................................................................40

Revision Topic 2: Ecological Integrity ..............................................................................41

Revision Topic 3: Sustainable Recreation and Designated Areas.....................................43

Alternative D..........................................................................................................................43

Revision Topic 1: Fire Management..................................................................................44

Revision Topic 2: Ecological Integrity ..............................................................................44

Revision Topic 3: Sustainable Recreation and Designated Areas.....................................46

Alternatives Considered but Eliminated from Detailed Study...................................................47

Eliminated Alternative 1: Restore over half of the landscape within 10 to 15 years.............47

Eliminated Alternative 2: Include all areas identified by the public as recommendations 

for additions to the National Wilderness Preservation System..............................................48

Eliminated Alternative 3: Identify critical aquatic refuges around all areas of high 

aquatic species diversity ........................................................................................................52

Eliminated Alternative 4: Evaluate an alternative that has minimal active management 

and “let nature take its course” ..............................................................................................52

Eliminated Alternative 5: Apply the Aquatic Conservation Strategy from the 2001 

Sierra Nevada Forest Plan Amendment.................................................................................53

Eliminated Alternative 6: Consider the document “National Forests in the Sierra 

Nevada: A Conservation Strategy” as an alternative.............................................................54

Eliminated Alternative 7: Allow existing motorized and mechanized uses to continue in 

recommended wilderness.......................................................................................................55

Comparison of Alternatives.......................................................................................................55

Comparison of Management Areas by Alternative................................................................55

Chapter 3. Affected Environment and Environmental Consequences...................................77

Introduction................................................................................................................................77

The Relationship between Forest Plans and Site-specific Activities.....................................77

Science and Assumptions Used in the Environmental Analyses...........................................77

How this Chapter is Organized..............................................................................................78

Agents of Change: Climate, Fire, Insects, and Pathogens .........................................................79

Climate Change......................................................................................................................79

Background........................................................................................................................79

Recent Past and Current Trends.........................................................................................80

Projected Future Trends in Climate and Hydrology ..........................................................80

Fire Trends.............................................................................................................................81

Background........................................................................................................................81

Analysis and Methods........................................................................................................81

Affected Environment........................................................................................................84

Environmental Consequences to Fire Trends ....................................................................90

Insects and Pathogens............................................................................................................98

Background........................................................................................................................98

Analysis and Methods........................................................................................................99

Affected Environment......................................................................................................101

Environmental Consequences to Insects and Pathogens..................................................104

Combined Effects of Climate, Fire, Insects, and Pathogens................................................107

Terrestrial Ecosystems.....................................................................................................107

Revision Topic 1: Fire Management........................................................................................110

Introduction..........................................................................................................................110
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

iii

Wildland Fire Management .................................................................................................111

Background......................................................................................................................111

Analysis and Methods......................................................................................................116

Affected Environment......................................................................................................118

Environmental Consequences of Fire Management ........................................................120

Air Quality...........................................................................................................................144

Background......................................................................................................................144

Analysis and Methods......................................................................................................145

Affected Environment......................................................................................................148

Environmental Consequences to Air Quality...................................................................149

Revision Topic 2: Ecological Integrity ....................................................................................160

Background..........................................................................................................................160

Terrestrial Ecosystems.........................................................................................................160

Terrestrial Vegetation Ecology........................................................................................160

Terrestrial Ecosystem Processes and Functions...............................................................205

Climate, Ecological Vulnerability and Adaptation..........................................................245

Aquatic and Riparian Ecosystems .......................................................................................258

Water Quality, Water Quantity, and Watershed Condition .............................................258

Aquatic and Riparian Ecosystem Integrity ......................................................................285

Wildlife, Fish and Plants......................................................................................................314

Introduction......................................................................................................................314

At-risk Terrestrial Species ...............................................................................................326

At-risk Aquatic Species...................................................................................................389

At-risk Plant Species........................................................................................................444

Revision Topic 3: Sustainable Recreation and Designated Areas...........................................476

Sustainable Recreation and Scenery ....................................................................................476

Sustainable Recreation.....................................................................................................476

Scenery.............................................................................................................................507

Partnerships..........................................................................................................................514

Analysis and Methods......................................................................................................514

Affected Environment......................................................................................................514

Environmental Consequences to Partnerships.................................................................515

Heritage Resources..............................................................................................................517

Background......................................................................................................................517

Analysis and Methods......................................................................................................518

Affected Environment......................................................................................................518

Environmental Consequences to Heritage Resources......................................................522

Designated Wilderness ........................................................................................................526

Background......................................................................................................................526

Analysis and Methods......................................................................................................526

Affected Environment......................................................................................................527

Environmental Consequences to Existing Designated Wilderness..................................529

Recommended Wilderness ..................................................................................................533

Analysis and Methods......................................................................................................534

Affected Environment......................................................................................................534

Environmental Consequences of Recommended Wilderness..........................................537

Eligible and Suitable Wild and Scenic Rivers.....................................................................549

Background......................................................................................................................549

Analysis and Methods......................................................................................................550

Affected Environment......................................................................................................551

Environmental Consequences to Eligible and Suitable Wild and Scenic Rivers.............552
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

iv

Pacific Crest National Scenic Trail......................................................................................555

Background......................................................................................................................555

Analysis and Methods......................................................................................................557

Affected Environment......................................................................................................559

Environmental Consequences..........................................................................................565

Analytical Conclusions....................................................................................................571

Tribal Relations and Uses........................................................................................................571

Background..........................................................................................................................571

Analysis and Methods..........................................................................................................573

Indicators and Measures ..................................................................................................573

Assumptions.....................................................................................................................574

Affected Environment..........................................................................................................575

Environmental Consequences to Tribal Relations and Uses ...............................................575

Consideration of Climate Change in Alternatives ...........................................................575

Consequences Common to all Alternatives.....................................................................576

Consequences Common to Alternatives B, B-modified, C, and D..................................577

Consequences Specific to Alternative A..........................................................................577

Consequences Specific to Alternatives B and B-modified ..............................................578

Consequences Specific to Alternative C..........................................................................579

Consequences Specific to Alternative D..........................................................................580

Cumulative Effects...........................................................................................................581

Analytical Conclusion......................................................................................................581

Forest Benefits to People and Communities............................................................................583

Forest Products and Management........................................................................................583

Background......................................................................................................................583

Analysis and Methods......................................................................................................584

Affected Environment......................................................................................................586

Environmental Consequences..........................................................................................588

Production Livestock Grazing .............................................................................................595

Background......................................................................................................................596

Analysis and Methods......................................................................................................601

Affected Environment......................................................................................................602

Environmental Consequences..........................................................................................605

Wild Horses and Burros Territory Management..................................................................612

Goal (DA-WHT-GOAL) .................................................................................................612

Potential Management Approach.....................................................................................612

Background......................................................................................................................613

Analysis and Methods......................................................................................................615

Affected Environment......................................................................................................617

Environmental Consequences..........................................................................................617

Economic Conditions...........................................................................................................620

Background......................................................................................................................620

Analysis and Methods......................................................................................................620

Affected Environment......................................................................................................621

Environmental Consequences to Economic Conditions..................................................627

Social Conditions.................................................................................................................639

Background......................................................................................................................639

Analysis and Methods......................................................................................................640

Affected Environment......................................................................................................645

Environmental Consequences to Social Conditions (All Alternatives)...........................650

Other Required Disclosures.....................................................................................................661
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

v

Unavoidable Adverse Effects ..............................................................................................661

Irreversible and Irretrievable Commitments of Resources..................................................661

Short-term Uses and Long-term Productivity......................................................................661

Laws Requiring Consultation ..............................................................................................661

Chapter 4. Preparers, Consultation, and Coordination.........................................................663

Preparers and Contributors.......................................................................................................663

Responsible Officials...........................................................................................................663

Interdisciplinary Team Members.........................................................................................663

Support to the Interdisciplinary Team .................................................................................669

Inyo National Forest ........................................................................................................669

Pacific Southwest Region of the Forest Service ..............................................................669

Pacific Southwest Region, Remote Sensing Laboratory .................................................670

Consultation and Coordination ................................................................................................670

Tribes and Tribal Organizations..........................................................................................670

Federal, State, County, and Local Agencies and Organizations..........................................671

Cooperating Agencies......................................................................................................671

Federal Agencies and Representatives.............................................................................671

State Agencies..................................................................................................................672

County Governments and Agencies.................................................................................672

Local Agencies and Organizations ..................................................................................672

Others...................................................................................................................................673

Agencies, Organizations, and Persons Sent Copies of the Final Environmental Impact 

Statement..................................................................................................................................675

Glossary ......................................................................................................................................677

References...................................................................................................................................691

Index............................................................................................................................................747

Tables

Table 1. Management areas by alternative............................................................................................56

Table 2. Summary of alternatives by revision topic..............................................................................57

Table 3. This table represents a brief summary of consequences for the major topics addressed in 

this final environmental impact statement ............................................................................63

Table 4. Estimated amounts of restoration activities by alternative per decade....................................83

Table 5. Summary comparison of proposed restoration levels by alternative.......................................91

Table 6. Summary of expected changes in fire burned area, large fire size, likelihood of large 

fires, and fire intensity and fire type with projected climate trends by alternative ...............91

Table 7. Percentage change in likelihood of large fires by alternative and ecological/elevational 

zone.......................................................................................................................................92

Table 8. Key forest insect and pathogen species of the southeastern Sierra Nevada: “H” indicates 

relatively high ability to kill host trees; “L” indicates secondary or lower ability to kill 

host trees; and “O” indicates occasional hosts......................................................................98

Table 9. Summary of percentage of area at risk by basal area loss categories for the Inyo National 

Forest ..................................................................................................................................104

Table 10. Example highly valued resources and assets (HVRAs) and their relative importance 

values..................................................................................................................................117

Table 11. Comparative ranking of alternatives by fire management indicators and measures...........141

Table 12. Summary of approach to wildfire risk management by alternative.....................................144

Table 13. Table displaying air basin baseline annual emissions in tons per year and emissions 

under alternative A..............................................................................................................151
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

vi

Table 14. Emissions from treatments under alternative B measured in tons per year and compared 

to the air basin baseline ...................................................................................................... 152

Table 15. Emissions under alternative B-modified in tons per year compared to the air basin 

baseline............................................................................................................................... 154

Table 16. Emissions from treatments under alternative C measured in tons per year and compared 

to the air basin baseline ...................................................................................................... 155

Table 17. Emissions under alternative D in tons per year compared to the air basin baseline ........... 156

Table 18. Summary of air quality indicators and effects by alternative ............................................. 158

Table 19. Area in acres by ecological zone or vegetation group, rounded to the nearest thousand 

acres.................................................................................................................................... 161

Table 20. The indicators, measures and criteria for evaluating the current condition and 

consequences for the Sierra Nevada montane zone (and dry mixed conifer) 

composition ........................................................................................................................ 166

Table 21. The indicators, measures and criteria for evaluating the current condition and 

consequences for eastside ecological zones and vegetation types...................................... 167

Table 22. Acres of major vegetation types, Inyo National Forest1 ..................................................... 169

Table 23. Area in acres in different hardwood vegetation types rounded to the nearest hundred 

acres.................................................................................................................................... 169

Table 24. Comparison of current conditions to desired conditions vegetation types and ecological 

zones1

.................................................................................................................................. 171

Table 25. Comparison of current conditions to desired conditions, vegetation types and 

ecological zones in the Kern River drainage1..................................................................... 171

Table 26. Revised forest plan desired conditions for vegetation across all vegetation types ............. 182

Table 27. Revised forest plan desired conditions by ecological zone and major vegetation types..... 182

Table 28. Similarity to vegetation composition and structure desired conditions for Sierra Nevada 

montane zone by alternative ............................................................................................... 187

Table 29. Similarity to vegetation composition and structure desired conditions for Sierra Nevada 

montane zone by alternative and location relative to the fire protection zones.................. 189

Table 30. Similarity to vegetation composition and structure desired conditions for eastside 

shrublands and woodlands zone by alternative .................................................................. 189

Table 31. Similarity to vegetation composition and structure desired conditions for the Kern 

River Drainage by alternative............................................................................................. 189

Table 32. Application of large tree plan components across strategic fire management zones, 

alternatives B and B-modified............................................................................................ 193

Table 33. Indicators, criteria and thresholds used to analyze environmental consequences for the 

old forests (Sierra Nevada montane zone only).................................................................. 209

Table 34. Indicators, criteria and thresholds used to analyze environmental consequences for 

complex early seral forest (Sierra Nevada montane zone only)......................................... 209

Table 35. Characteristics from the National Forest Sustainability Framework used in the analysis.. 212

Table 36. Summary of the similarity of current conditions to desired conditions for major 

indicators of terrestrial function by ecosystem type ........................................................... 212

Table 37. Summary of current condition of fire regime integrity by vegetation type in the Inyo 

National Forest ................................................................................................................... 215

Table 38. Overall ecosystem sustainability conditions by characteristic from National Forest 

Sustainability Report* by major vegetation types for the Inyo National Forest................. 221

Table 39. Fire regime integrity for vegetation types by alternative .................................................... 222

Table 40. Plan direction on large tree densities by location in alternative B...................................... 229

Table 41. Summary of conditions for characteristics of integrated sustainability by alternative ....... 244

Table 42. Climate vulnerability of major vegetation types in the plan area ....................................... 248

Table 43. Climate vulnerability of select species or species groups in the plan area ......................... 249

Table 44. Rating of the amount of application climate adaptation strategies by alternatives (e.g., 

low indicates a low degree of application)......................................................................... 250

Table 45 Water, aquatic, and riparian restoration activities by alternative per decade....................... 263
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

vii

Table 46. Impaired (303(d)-listed) waterbodies within or adjacent to the Inyo National Forest ........265

Table 47. Number of and percentage of HUC 12 watersheds by condition class on the Inyo 

National Forest....................................................................................................................267

Table 48. Water, aquatic and riparian restoration activities by alternative per decade .......................288

Table 49. Summary of critical aquatic refuges (conservation watersheds in alternative BModified) and watershed conditions on the Inyo National Forest......................................289

Table 50. Critical aquatic refuge name and acres in alternative A......................................................299

Table 51. Acres of conservation watersheds under alternative B-modified........................................304

Table 52.Proposed wilderness areas within Cottonwood-Crooked Creek Headwaters conservation 

watershed ............................................................................................................................305

Table 53. Number of federally threatened, endangered, proposed or candidate species by listing 

status and taxa for the Inyo National Forest .......................................................................317

Table 54. Number of species of conservation concern by taxa ...........................................................318

Table 55. Summary of the rationale that a Regional Forester’s animal sensitive species did not 

meet the established criteria as a species of conservation concern.....................................321

Table 56. Summary of the rationale that a Regional Forester’s plant sensitive species did not 

meet the established criteria as a species of conservation concern.....................................322

Table 57. Federally designated terrestrial threatened, endangered, proposed, and candidate 

species and critical habitat that occur in the Inyo National Forest plan area ......................331

Table 58. Federally designated terrestrial threatened, endangered, proposed, and candidate 

species and critical habitat that do not occur in the Inyo National Forest plan area and 

are not analyzed in detail ....................................................................................................331

Table 59. Terrestrial wildlife species of conservation concern for the Inyo National Forest..............331

Table 60. Acres of Sierra Nevada bighorn sheep critical habitat herd units in wilderness and total 

acres on the Inyo National Forest .......................................................................................337

Table 61. Mammal and bird species of conservation concern, ecological zones or types, key 

ecological conditions, and primary stressors or threats to persistence (primary stressors 

not under Forest Service are not necessarily discussed further) .........................................340

Table 62. Terrestrial invertebrate species of conservation concern, ecological zones or types, key 

ecological conditions, and primary stressors or threats to persistence (primary stressors 

not under Forest Service are not necessarily discussed further) .........................................351

Table 63. Federally designated aquatic species and critical habitat that occur in the Inyo National 

Forest plan area...................................................................................................................391

Table 64. Aquatic species of conservation concern ............................................................................392

Table 65. Aquatic vertebrate species of conservation concern, ecological conditions, and primary 

stressors and threats to persistence on the Inyo National Forest.........................................409

Table 66. Aquatic invertebrate species of conservation concern ecological conditions, and 

primary stressors/threats to persistence on the Inyo National Forest..................................412

Table 67. Federally designated plant species and critical habitat........................................................447

Table 68. Plant species diversity by floristic geographic province, region, and subdivisions1 ...........448

Table 69. Distribution of whitebark pine on the Inyo National Forest and in California....................451

Table 70. Inyo National Forest plant species of conservation concern and threats by principal 

habitat type..........................................................................................................................452

Table 71. Known threats to plant species of conservation concern, as documented in best 

available scientific information*.........................................................................................457

Table 72. Existing recreation opportunity spectrum classes...............................................................479

Table 73. Miles of system roads by maintenance level.......................................................................481

Table 74. Miles of trails by designated and allowed uses...................................................................482

Table 75. Developed recreation sites ..................................................................................................483

Table 76. Visitor participation in recreation activities on the Inyo NF in 2011 National Visitor 

Use Monitoring surveys......................................................................................................485

Table 77. Forest visitation numbers (in thousands).............................................................................486
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

viii

Table 78. Existing (alternative A) and desired (alternatives B and B-modified, C, D) recreation 

opportunity spectrum classes in acres and percentage of national forest by alternative..... 488

Table 79. Recreation opportunity spectrum settings of recreation zones in alternative B-modified 

(acres and percentage of forest).......................................................................................... 495

Table 80. Comparison of indicators by alternatives ........................................................................... 505

Table 81. Cross-walk between visual management system and scenery management system 

terminology ........................................................................................................................ 508

Table 82. Desired scenic integrity objectives in acres and percentage of national forest by 

alternative ........................................................................................................................... 513

Table 83. Comparison of indicator by alternative............................................................................... 517

Table 84. Number of heritage sites by type ........................................................................................ 521

Table 85. Number of heritage site determinations and number of historic landmarks under the 

National Register of Historic Places (NRHP) .................................................................... 521

Table 86. Percentage of area in fire management zones for areas in designated wilderness, 

alternative A ....................................................................................................................... 530

Table 87. Percentage of area in fire management zones for areas in designated wilderness, 

alternatives B, B-modified, and D...................................................................................... 531

Table 88. Percentage of area in fire management zones for areas in designated wilderness, 

alternative C ....................................................................................................................... 532

Table 89. Recommended wilderness additions adjacent to existing designated wilderness in 

alternatives B and B-modified............................................................................................ 535

Table 90. Recommended wilderness additions adjacent to existing designated wilderness in 

alternative C ....................................................................................................................... 535

Table 91. Recommended wilderness not adjacent to existing designated wilderness in alternative 

C ......................................................................................................................................... 536

Table 92. Percentage of area in fire management zones for areas in recommended wilderness, 

alternatives B and B-modified............................................................................................ 542

Table 93. Percentage of area in fire management zones for areas in recommended wilderness, 

alternative C ....................................................................................................................... 544

Table 94. Total miles of rivers in the National Wild and Scenic River System by managing entity 

and classification, nationwide ............................................................................................ 551

Table 95. Comparison of past and current wild and scenic river eligibility review findings in 

miles for the Inyo National Forest...................................................................................... 554

Table 96. Number of miles of Inyo National Forest System trails and miles of Pacific Crest Trail 

within and outside of designated wilderness...................................................................... 560

Table 97. Section and thru-hike permits issued for the Pacific Crest Trail 2013-2016 ...................... 560

Table 98. Wind renewable energy summary (number) by Bureau of Land Management in 

California, October 2015.................................................................................................... 563

Table 99. Wind renewable energy summary (acres) by Bureau of Land Management in 

California, October 2015.................................................................................................... 564

Table 100. Solar renewable energy summary by Bureau of Land Management in California, Oct 

2015.................................................................................................................................... 564

Table 101. Acres of each recreation opportunity spectrum class in the Pacific Crest Trail 

Management Area .............................................................................................................. 565

Table 102. Acres of Pacific Crest Trail corridor inside and outside of designated wilderness........... 566

Table 103. Miles of motorized roads and trails within the Pacific Crest Trail Corridor (outside 

wilderness).......................................................................................................................... 566

Table 104. Acres of scenic integrity objectives within the Pacific Crest Trail Corridor, Inyo 

National Forest ................................................................................................................... 568

Table 105. Percentage of cover type (California wildlife habitat relationship) of lands suitable for 

timber production for alternatives B and B-modified......................................................... 586

Table 106. Percentage of cover type (Regional Dominance Type) of lands suitable for timber 

production for alternatives B and B-modified.................................................................... 586
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

ix

Table 107. Projected 10-year timber harvest volumes (million cubic feet) by product type and 

alternative ...........................................................................................................................588

Table 108. Projected 10-year harvest area in acres by management practice and alternative.............589

Table 109. Ten-year discounted cost estimates for mechanical, prescribed fire and managed fire 

activities in each plan revision alternative ..........................................................................590

Table 110. Comparison of critical aquatic refuge and conservation watershed management areas 

within active and vacant grazing allotments.......................................................................610

Table 111. Economic health surrounding the Inyo National Forest....................................................623

Table 112. Estimates of the economic contributions, 2012.................................................................625

Table 113. Summary of short-term and long-term potential effects on key national forest benefits 

by alternative ......................................................................................................................629

Table 114. Percentage of minority populations and people living below the poverty level in the 

area of influence for the Inyo National Forest ....................................................................649

Figures

Figure 1. Map of the Inyo National Forest, which constitute the plan area for revising the forest 

plan for this national forest .....................................................................................................2

Figure 2. Location of Nevada Enhancement Act Lands on the Inyo National Forest...........................20

Figure 3. Map of changes in the predicted burned area in the next mid-century, 2035 to 2064, 

compared to 1961 through 1990 ...........................................................................................86

Figure 4. Predicted change in large fire size from recent (1961 to 1990) rates based on three 

climate models......................................................................................................................87

Figure 5. Line graphs showing the expected change in large fire size with different future climate 

and vegetation restoration scenarios.....................................................................................88

Figure 6. Bar graph showing the change in large fire size by mid-century (2035-2064) compared 

to “baseline” conditions (1961-1990) displayed by ecological zone and level of 

modeled restoration based on the GFDL model and A2 emissions scenario........................88

Figure 7. Percent change in area burned at high severity (defined as greater than 50 percent 

overstory mortality) with future trends in climate ................................................................90

Figure 8. Photo of dead and dying whitebark and lodgepole pines on June Mountain Ski Area, 

2009 ....................................................................................................................................102

Figure 9. Drought and insect-related mortality through 2017 in the eastern Sierra Nevada based 

on aerial detection surveys..................................................................................................103

Figure 10. Conceptual diagram of the interaction between climate, fire, insects and pathogens, 

and vegetation.....................................................................................................................108

Figure 11. The wildfire management continuum................................................................................115

Figure 12. Historic ignitions and acres burned by cause: 1996-2016, Inyo National Forest...............119

Figure 13. Map showing the location of the strategic fire management zones for alternative A........121

Figure 14. Map showing the location of the strategic fire management zones for alternative B ........123

Figure 15. Map showing the location of the strategic fire management zones for alternatives Bmodified and D ...................................................................................................................125

Figure 16. Map showing the location of the strategic fire management zones for alternative C ........126

Figure 17. Proportion of the Inyo National Forest within each zone in alternative A.........................127

Figure 18. Proportion of the Inyo National Forest within each zone in alternatives B.......................130

Figure 19. Proportion of the Inyo National Forest within each zone in Alternatives B-modified 

and D...................................................................................................................................133

Figure 20. Proportion of the Inyo National Forest within each zone in alternative C.........................133

Figure 21. Risk location by alternative or comparison of the magnitude of net value change by 

strategic fire management zone ..........................................................................................139

Figure 22. Risk source by alternative or comparison of the magnitude of net value change by 

strategic fire management zone ..........................................................................................140
Contents

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

x

Figure 23. Map of air pollution control districts (APCDs) and Air Quality Management District 

(AQMD) in and around the Inyo National Forest .............................................................. 146

Figure 24. Graph displaying modeling results of particulate matter emissions from wildfires 

under differing treatment scenarios at mid-century (Hurteau et al. 2014). The baseline 

and mid-century simulations represent a 5-10 percent restoration scenario. See table 5 

for a comparison of restoration levels by alternative.......................................................... 149

Figure 25. Ecological/vegetation zones groups on the Inyo National Forest...................................... 162

Figure 26. Major ecosystem types from the Terrestrial Ecological Unit Inventory, Inyo National 

Forest.................................................................................................................................. 170

Figure 27. Recently dead and dying Jeffrey pines in eastside pine stand on the Inyo National 

Forest.................................................................................................................................. 174

Figure 28. Occurrences of cheatgrass in vegetation plots, Inyo National Forest................................ 180

Figure 29. Landscape ecological fire resilience by restoration scenarios........................................... 188

Figure 30. Map of fire return interval departure, Inyo National Forest .............................................. 214

Figure 31. Floristic geographic subdivisions...................................................................................... 449

Figure 32. Recreation opportunity spectrum (ROS) categories within sustainable recreation zones 

in alternative B-modified.................................................................................................... 496

Figure 33. The Pacific Crest National Scenic Trail ............................................................................ 556

Figure 34. John Muir Trail usage (which uses the same trail tread as the Pacific Crest Trail for 

most of its route)................................................................................................................. 561

Figure 35. Inyo National Forest animal unit months (AUMs) from 2006 through 2016.................... 600

Figure 36. Census county divisions that intersect the Inyo National Forest administrative 

boundary............................................................................................................................. 644
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

xi

Preface

This final environmental impact statement and supporting documents (the planning record of the 

environmental analysis) are on file at the Supervisor’s Office of the Inyo National Forest and at 

the Pacific Southwest Regional Office of the Forest Service in Vallejo, CA. Electronic copies of 

this document and other planning documents are available on the website for the Inyo National 

Forest plan revision.2 This final environmental impact statement is organized as follows:

Volume 1

Chapter 1. Purpose of and Need for Revising the Inyo Land Management Plan. This section 

discusses the background of the proposal, explains the purpose of and need for revising the land 

management plan (also referred to as “forest plan”), and briefly describes the action proposed to 

satisfy the purpose and need. It summarizes public participation in the environmental review 

process and lists preliminary environmental and social issues identified during the scoping 

period.3

Chapter 2. Alternatives, Including the Proposed Action. This section discusses the proposed 

action (revised forest plan), no action, and a range of reasonable alternatives. It also explains why 

other alternatives were dismissed from further consideration. It includes a summary comparison 

of the environmental impacts of the proposal and the alternatives in comparative form, sharply 

defines the issues and provides a clear basis for choice among options by the decisionmaker and 

the public.

Chapter 3. Affected Environment and Environmental Consequences. This section documents 

the environmental consequences of implementing the proposed action and alternatives. It 

describes the affected environment for each subject of analysis as a baseline against which the 

impacts of alternatives are measured. The description of the environment is followed by 

disclosure of the potential direct, indirect, and cumulative effects of implementing the proposed 

action and each of the alternatives.

Chapter 4. Consultation and Coordination. This section lists the credentials of those who 

prepared this environmental impact statement and identifies the agencies, government officials, 

and selected other parties who were consulted regarding the proposed action.

Glossary. This section provides a glossary of terminology.

References. This section reports full citations for the sources cited in the text.

Index. This section provides page numbers for various topics related to the analysis

Volume 2 - Appendix

This volume contains evaluations of timber suitability (appendix A), wilderness (appendix B), 

and wild and scenic rivers (appendix C), range management (appendix D), consistency with other 

planning efforts (appendix E), species of conservation concern persistence analysis (appendix F), 

and the aquatic and riparian strategy (appendix G).

 2 http://www.fs.usda.gov/detail/r5/landmanagement/planning/?cid=stelprdb5444003

3 The time during which a proposed action has been provided to the public for review and comment so that the scope of 

issues related to the proposed action can be determined.
Preface

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

xii

Volume 3 – Response to Comments

This volume contains comments received on the draft documents (environmental impact 

statement and plan) and responses to those comments. 

Volume 4 - Maps

This volume contains maps of the different alternatives as they relate to each resource analyzed. 

The maps follow the order of the various analysis sections in chapter 3.
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

1

Chapter 1. Purpose of and Need for

Revising the Inyo National Forest

Land Management Plan

Introduction

We, the U.S. Department of Agriculture, Forest Service, are proposing to revise the land and 

resource management plan (or “forest plan”), as amended, for the Inyo National Forest. We have 

prepared this environmental impact statement in compliance with the National Environmental 

Policy Act and its implementing regulations. This environmental impact statement discloses the 

potential effects of a proposed revision of the Inyo National Forest Land and Resource 

Management Plan (USDA Forest Service 1988b, 1988c, 1992).

As part of a select group of national forests, the Inyo initiated plan revision in 2012 along with 

the Sierra and Sequoia National Forests to implement the newly adopted planning rule. The three 

national forests released one draft environmental impact statement in 2016. Managers initiated the

process of revising their plan in 2012 as part of a select group of national forests to implement the 

newly adopted planning rule. Due to the changed condition with drought-induced tree mortality 

on the west slope of the Sierra Nevada range, and the need to reconsider plan direction and 

potential new needs with the changed condition, we decided to provide supplemental analysis for 

the Sierra and Sequoia National Forests plan revision effort and produce a final environmental 

impact statement and land management plan for the Inyo National Forest. 

About the Inyo National Forest

The Inyo National Forest is located in eastern California, with a small portion in Nevada (figure 

1). The Inyo includes the crest and eastern escarpment of the Sierra Nevada Mountains from 

Mono Basin to the Kern Plateau, plus the Glass, White, and Inyo Mountain Ranges. The Inyo 

encompasses approximately 2 million acres, including about 56,481 acres of private and State 

lands and 26,711 acres of the Sierra National Forest and Humboldt-Toiyabe National Forests, 

which are administered by the Inyo National Forest. The Inyo contains 116,200 acres of Mono 

Basin National Forest Scenic Area and the 29,000-acre Ancient Bristlecone Pine Forest National 

Protection Area (a botanical special interest area). Other land managers in the region include the 

Bureau of Land Management and the Los Angeles Department of Water and Power.

Forty-six percent of the Inyo, (964,360 acres) consists of nine designated wilderness areas, either 

wholly or partially within the administrative boundary of the national forest. These areas include: 

Ansel Adams (shared with the Sierra National Forest), Boundary Peak, Golden Trout (shared with 

the Sequoia National Forest), Hoover (shared with the Humboldt-Toiyabe National Forest), Inyo 

Mountains (shared with Bureau of Land Management), John Muir (shared with the Sierra), 

Owens River Headwaters, South Sierra (shared with the Sequoia), and White Mountains 

Wildernesses.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

2

Figure 1. Map of the Inyo National Forest, which constitute the plan area for revising the forest plan for 

this national forest
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

3

The Inyo National Forest Supervisor’s Office is centrally located in Bishop, California. The Inyo 

has four administrative ranger districts. The northern ranger districts, Mono Lake and Mammoth, 

are managed together as the “north zone.” The southern ranger districts, White Mountain and 

Mount Whitney, are managed together as the “south zone.” The Inyo National Forest comprises 

portions of Inyo, Mono, Madera, Fresno and Tulare Counties in California and Esmeralda and 

Mineral Counties in Nevada. The communities within and adjacent to the Inyo are relatively 

small and discrete. Key communities adjacent to the Inyo include Lee Vining, June Lake, 

Mammoth Lakes, Bishop, Big Pine, Independence, and Lone Pine.

Regulatory Direction

In 1976, National Forest Management Act4 directed the Forest Service to develop land and 

resource management plans (hereafter referred to as “forest plans”) and use the direction in them 

to manage the natural resources and human uses of each national forest. The National Forest

Management Act and its implementing regulations5 require every national forest to revise its land 

management plan: every 10 to 15 years; when conditions or demands in the area covered by the 

plan have changed significantly; when changes in agency policies, goals, or objectives would 

have a significant effect on forest level programs; and when monitoring and evaluation indicate 

that a revision is necessary.

The Inyo National Forest completed their first forest plan in 1988. The current plan has 

incorporated several amendments, including the 2004 Sierra Nevada Forest Plan Amendment, the 

2007 Sierra Nevada Forests Management Indicator Species Amendment, and other local 

amendments. 

In addition to the National Forest Management Act, there are many other laws and regulations 

that apply to management of the national forests including, but not limited to, the Clean Air Act, 

Clean Water Act, Endangered Species Act, and National Historic Preservation Act. These laws are 

generally not repeated or referenced in a forest plan unless there is an issue that merits citing 

direction in the law. Additional direction and policy for management of national forests are 

provided in executive orders, the Code of Federal Regulations, and the Forest Service directives 

system, the latter of which consists of Forest Service manuals and Forest Service handbooks. 

Such direction is also not repeated in a forest plan.

Plan Revision under the 2012 Planning Rule

In 2012, the U.S. Department of Agriculture issued a new rule for forest planning. The 2012 

Planning Rule emphasizes that forest plans are to guide management of the national forests so they 

are ecologically sustainable and contribute to social and economic sustainability. The national 

forests are managed to provide ecosystems and watersheds with ecological integrity and diverse 

plant and animal communities. In addition, they are managed to have the capacity to provide 

people and communities with ecosystem services and multiple uses that provide a range of social, 

economic, and ecological benefits for the present and into the future. 

 4 Public law 94-588

5 See 36 CFR 219
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

4

The 2012 Planning Rule describes three phases to the planning process: 

• assessment; 

• development, amendment, or revision of forest plans; and 

• monitoring6

In 2013 we completed a Bio-regional Assessment (USDA Forest Service 2014b)) of the 

conditions and trends of resources, uses, and public interests that are common across the Sierra 

Nevada. This was followed by individual national forest assessments to frame the larger context 

for the Inyo, Sequoia, and Sierra National Forests in relation to the rest of the national forests in 

the Sierra Nevada (from the Sequoia National Forest all the way to the Modoc National Forest 

near the Oregon border).

Public involvement efforts helped us identify the needs for changing our plan as well as a 

proposed action and alternatives for developing the plan. Although we have planned the 

monitoring program as part of our proposed action, it will not be implemented until after the forest 

plan is revised.

Forest Plan Content

Forest plans provide a framework for integrated resource management and for guiding project 

and activity decisionmaking. Plans themselves do not compel any action, authorize projects or 

activities, or guarantee specific results. Instead, they provide the vision and strategic direction 

needed to help managers create a national forest that is ecologically, socially, and economically 

sustainable.

The revised plan includes “plan components” and “other content.” Once approved, any 

substantive changes to plan components will require a plan amendment. Administrative changes 

may be made for corrections of clerical errors or conformance of the plan to new statutory or 

regulatory requirements, or other plan content as described in 219.7(f). The public is notified of 

all plan amendments and administrative changes before they become effective.

Plan Components

A forest plan is a general framework to guide the national forest staff when they propose, analyze, 

and decide on projects and activities. The five required components of a forest plan are desired 

conditions, objectives, standards, guidelines, and suitability of lands. A plan may also include 

goals as an optional component.

• A desired condition is a description of specific social, economic, or ecological 

characteristics of the plan area, or a portion of the plan area, toward which management of 

the land and resources should be directed. This description is specific enough to allow 

progress toward achievement to be determined but does not include a completion date. 

• An objective is a concise, measurable, and time-specific statement of a desired rate of

progress toward one or more desired conditions. Objectives are based on reasonable 

foreseeable budgets.

 6 See the Planning Rule at 36 CFR 219.6; 219.7; 219.12; and 219.13.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

5

• A standard is a mandatory constraint on project and activity decisionmaking, established 

to help achieve or maintain the desired condition, to avoid or mitigate undesirable effects, 

or to meet applicable legal requirements. 

• A guideline is a constraint on project and activity decisionmaking that allows for departure 

from its terms (more flexibility), as long as the purpose of the guideline is met. Guidelines 

are established to help achieve or maintain the desired condition or conditions, to avoid or 

mitigate undesirable effects, or to meet applicable legal requirements.

• Suitability of lands is determined for specific lands within the plan area. The lands are 

identified as suitable or not suitable for various uses or activities based on desired 

conditions applicable to those lands. The suitability of lands is not identified for every use 

or activity. A plan’s identification of certain lands as suitable for a use is not a commitment 

to allow such use but only an indication that the use might be appropriate. If a plan 

identifies certain lands as not suitable for a use, then that use or activity may not be 

authorized unless a change in the plan is made.

• A goal describes an outcome that is not at the sole control of a national forest, such as the 

result of a partnership.

Other Plan Content

Other content in the forest plan consist of background information, general descriptions of areas 

to provide context to plan components, identification of watersheds that are a priority for 

maintenance and restoration, proposed and possible actions, and potential management 

approaches. Potential management approaches describe the principal strategies and program 

priorities each national forest intends to employ to carry out projects and activities under the plan. 

Potential management approaches may discuss potential processes such as analysis, assessment, 

inventory, project planning, or project monitoring.

The proposed plan monitoring program is based on the practice of adaptive management, which 

is broadly recognized as critical for managing natural resources. The adaptive management cycle 

includes: identifying the desired conditions (forest plan); activities to help us get there (projectlevel implementation); monitoring whether we are achieving the results we intended (monitoring 

program), and using those evaluations to improve our implementation activities or to amend the 

forest plans.

Purpose of and Need for Revising the Forest Plan

The purpose of revising the forest plan is to meet the legal requirements of the National Forest 

Management Act and the provisions of the 2012 Planning Rule. There is a need to revise the 

existing forest plan to: (1) address the changing social and environmental conditions over time, 

and public issues described below; and (2) guide natural resource management activities on the

Inyo National Forest for the next 10 to 15 years.

The need for plan revision is directly correlated to seven overarching “needs for change” we 

identified during iterative pre-revision collaborative dialogues, meetings, tribal forums, studies 

and assessments (see the “Public Participation” section on page 8). The needs are: benefits to 

people and communities; tribal relations and uses; sustainable recreation; fire; ecological 

integrity; lands and designated areas. These efforts involved our forest plan revision team of 

interdisciplinary resource specialists and many public groups, organizations, agencies, officials, 

and individuals.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

6

The Inyo assessment identified recent changes in ecological, economic, and social conditions and

trends (USDA Forest Service 2013a, 2014a, 2014e). Broader issues were identified in the “Bioregional Assessment” (USDA Forest Service 2014b) and “Science Synthesis” (Long, QuinnDavidson, and Skinner 2014b). Using the information in these reports, the Inyo National Forest 

examined the current conditions and trends of ecosystems, ecosystem services, and benefits to 

people. Although the staff at the Inyo National Forest determined that much of the existing 

management direction contained in the forest plan is adequate to provide sustainable, integrated 

resource management, they identified several emphasis areas of management direction potentially 

needing change (USDA Forest Service 2014c, 2014d, 2014g).

While the forest plan revision effort is based on the need for change, we also took advantage of 

the opportunity to incorporate emerging climate change information, reclassify current standards 

and guidelines as desired conditions or other plan components where appropriate, and reduce 

duplication of Forest Service Handbook and Manual direction and existing laws, regulations, and 

policies.

From Needs for Change to Revision Topics

Each emphasis area we identified in the need for change was considered as a potential revision 

topic. Revision topics are used in the environmental impact statement to organize the features of 

the alternatives and to compare and contrast the differences between alternatives.

It is important to note that there is overlap in management direction developed to address each 

revision topic. For example, management direction developed to address needs under revision 

topic 2, ecological integrity, also addresses needs identified under revision topic 1, fire 

management.

Three of the emphasis areas we identified in the need for change were not considered to be 

revision topics because plan direction is the same in alternatives B, B-modified, C, and D. The 

need for change to incorporate plan direction for lands transferred to the Inyo National Forest 

under the National Forest and Public Lands of Nevada Enhancement Act was addressed by 

incorporating plan direction that essentially continued existing management and uses. The need 

for change to address benefits to people and communities and the need for change to address 

tribal relations and uses are both fundamental requirements of the 2012 Planning Rule and were 

incorporated throughout desired conditions and other plan direction. Since these two areas are 

fundamental requirements, the consequences of the alternatives are displayed following the 

revision topics.

Each revision topic listed below provides a brief description and explanation of what the topic is 

and what needs to be revised in the plans to address the topic. Further explanations supporting the 

needs for changing the current plans are described in the project record.

Revision Topic 1: Fire Management

There is a need to reduce the risk of large high-intensity wildfires to communities and assets such 

as recreation sites and infrastructure; increase the ability to manage wildfires to meet resource 

objectives;7 and reduce smoke impacts to communities.

 7 A strategic choice to use unplanned wildfire starts to achieve resource management objectives and ecological 

purposes under specific environmental conditions. Such fires are monitored closely to ensure safe conditions for 

people, property, and other highly valued resources.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

7

Revision Topic 2: Ecological Integrity

There is a need to restore the resilience of vegetation and aquatic and riparian ecosystems to fire, 

drought and climate impacts; restore wildlife and plant habitat and diversity; and reduce the risk 

of large high-intensity wildfire impacts to species and wildlife habitat.

Revision Topic 3: Sustainable Recreation and Designated Areas

There is a need to provide sustainable and diverse recreation opportunities that consider 

population demographic characteristics; reflect desires of local communities; avoid overcrowding 

and use conflicts, and minimize resource damage; protect cultural resources; update direction for 

management of wilderness and wild and scenic rivers; and protect the values of the Pacific Crest 

National Scenic Trail.

The Revised Plan

We prepared the revised Inyo National Forest Land Management Plan in an iterative fashion with 

the public over a 5-year period, beginning with the preparation of the assessments. The draft 

forest plan is designed to provide strategic, program-level guidance for management of the 

national forest, including natural resources and uses, over the next 10 to 15 years. For each of the 

revision topics described above, the plan revision team, in collaboration with the public and other 

agencies developed a proposed revised plan, that:

• provides a context for future, project-level planning;

• identifies strategies to maintain or achieve goals (like desired conditions) over time;

• identifies land areas as generally suitable or unsuitable for various uses;

• identifies standards and guidelines to guide the planning of projects and activities;

• identifies areas with special or unique characteristics;

• provides monitoring and evaluation requirements; and

• emphasizes the use of best available science and adaptive management.

Specific details of the revised forest plan, as it evolved from the public collaborative process and 

internal evaluations that have occurred, are provided in chapter 2 and referenced as “alternative 

B.” A copy of the revised forest plan is provided as a companion document to this environmental 

impact statement.

Decision Framework

The responsible official for this proposed action is the Forest Supervisor of the Inyo National 

Forest. After reviewing the results of the analysis evaluated in the final environmental impact 

statement, the responsible official will issue a record of decision, in accordance with agency 

decisionmaking procedures8 that will:

• disclose the decision (identify the selected alternative) and reasons for the decision,

• discuss how public comments and issues were considered in the decision, and

 8 40 CFR 1505.2
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

8

• discuss how all alternatives were considered in reaching the decision, specifying which one 

is the environmentally preferable alternative.9

Approval of the revised plan will identify management areas and will include recommendations 

for areas that can only be designated by statute, such as wilderness and wild and scenic rivers.

Public Participation

The Inyo National Forest provided opportunities for public participation throughout the plan 

revision process. We used both formal and informal collaboration methods to prepare for and 

carry out plan revision. We developed a “Collaboration, Tribal and Public Involvement Plan” to 

guide interactions with other agencies and the public.

Early Public Engagement Sessions – Informal collaboration began even before the final 

Planning Rule was released with a “Sierra Cascades Dialog” public engagement session held in 

Sacramento, California on the topic of “Preparing for Forest Planning” in December 2011. This 

was followed with additional dialog sessions on collaborative planning, adaptive management 

and recreation, social and economic opportunities and impacts, and monitoring.

Based upon input from the public during the Sierra Cascades Dialog meeting in 2011, the Forest 

Service Pacific Southwest Research Station produced a science synthesis (Long, QuinnDavidson, and Skinner 2014c) to examine the current science for a set of topics that were 

determined to have changed since the 1996 Sierra Nevada Ecosystem Project10 (Centers of Water 

and Wildland Resources 1996 (Resources 1996)). In addition, although not required, a BioRegional Assessment (USDA Forest Service 2014b) was prepared to provide the context for 

examining resources across the entire Sierra Nevada range.

Continued Public Engagement Sessions – In 2013, we held one Sierra Cascades Dialog session 

to discuss the science synthesis and two dialog sessions to discuss the Bio-Regional Assessment. 

To allow the public to directly provide information about conditions and trends for 18 resource 

topics outlined in the 2012 Planning Rule, we prepared both the Bio-Regional Assessment and the 

national forest assessments using an open wiki site called the “Living Assessment.” We used 

public input received between January and September 2013 to create the Bio-Regional 

Assessment (USDA Forest Service 2014b), and the Inyo National Forest Assessment (USDA 

Forest Service 2013a). 

Notice to Initiate Plan Revision – Following the assessments, we issued a notice to initiate plan 

revision on December 26, 2013 and developed a preliminary document outlining the need for 

changing the forest plans. We held tribal forums and public workshops in mid- to late-January 

2014 in Bishop to present and collect feedback on the preliminary need for change. Based on 

public feedback, we revised the need for change and presented an updated version along with 

draft desired conditions. We collected feedback at another set of tribal forums and public 

workshops in mid-June of 2014 in Bishop.

 9 Environmentally preferable alternative is defined in 36 CFR 220.3.

10 The Sierra Nevada Ecosystem Project was requested by Congress as a scientific review of the remaining old growth 

in the national forests of the Sierra Nevada in California, and a study of the entire Sierra Nevada ecosystem by an 

independent panel of scientists, with expertise in diverse areas related to the issue.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

9

Notice of Intent and 30-day Scoping Comment Period – A notice of intent to revise the Inyo, 

Sequoia, and Sierra forest plans and to prepare an environmental impact statement was published 

in the Federal Register11 on August 29, 2014, initiating a 30-day public scoping period. We 

circulated a detailed proposed action along with the notice of intent. The detailed proposed action 

provided potential plan components and other plan content focused on the revision topics of the 

purpose and need to revise the plans. Tribal forums and public meetings were held in Fresno, 

Porterville, and Bishop in mid-September 2014 to provide an update on the revision process and 

seek public input on the development of alternatives for the draft environmental impact 

statement.

During the 30-day comment period, we received approximately 7,317 emails and letters from 

individuals, agencies, organizations, Tribes and governments commenting on the purpose and 

need and proposed action. Of the comments received, approximately 6,603 represented form 

letters. All comments received were sorted, grouped by subject and analyzed to determine 

concerns and issues. In mid-November 2014, we held a set of tribal forum and public meetings in 

Fresno, Porterville, and Bishop to share a preliminary summary of the comments received and an 

initial set of conceptual alternatives.

Other public involvement occurred as required by the planning rule related to developing the list 

of species of conservation concern, evaluating the suitability of lands, and developing the 

monitoring program.

90-day Comment Period on Inyo, Sequoia, and Sierra Draft Environmental Impact 

Statement – A notice of availability to comment on the Inyo, Sierra, and Sequoia forest plans and 

environmental impact statement was published in the Federal Register12 on May 27, 2016, 

initiating a 90-day public comment period. The public comment period ended on August 29, 

2016. Tribal forums and public meetings were held in Fresno, Porterville, and Bishop in August 

2016 to provide information and seek public input on the draft revised forest plans and the draft 

environmental impact statement.

During the comment period, we received a total of 32,837 emails and letters from individuals, 

agencies, organizations, Tribes and governments commenting on the draft environmental impact 

statement. Of these letters, 900 were designated as unique letters and 2,980 were determined to be 

duplicate submissions. Twenty-nine sets of form letters were received, reflecting a total of 28,982 

form letters received. All comments received were sorted, grouped by subject and analyzed to 

determine concerns and issues.

The Comment Analysis and Response Application (CARA) system, was used to organize and do 

an initial analysis of the letters. Letters were categorized into three categories: unique, form, and 

form plus letters. Unique letters, are comments received that have all original content from its 

author. Form letters are comments received that contains one main letter with original content 

from an author that has be submitted by multiple parties replicating the content from the original 

letter. Form plus letters are comments received that are a mix of the two previous categories. 

Form plus letters are comments that have content from the original form letter but also contains 

unique content from the party submitting the letter. CARA assigned each letter, regardless of 

category, a unique numerical identifier (called a letter number). Letters that were received via 

 11 79 FR 51536

12 79 FR 51536
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

10

email or regular mail are scanned and uploaded into the CARA system to ensure all comments are 

assigned a letter number.

Each unique and form plus letter was read and reviewed, and each unique form letter was read 

and reviewed. The review of letters had five phases: comment coding, develop issue statements, 

development of possible resolution actions, responding to comments, and incorporating final 

resolutions into final documents. Each phase is discussed below.

Letters categorized by the CARA system were reviewed and coded by the Regional Forest Plan 

Revision Team (revision team). The revision team divided the letters among team members and 

reviewed them to identify specific comments as substantive concerns, issues, problems or 

disputes with information presented in the Draft Inyo, Sierra, and Sequoia Forest planning 

documents. This identification of substantive comments is referred to as coding comments. Coded 

comments were selected and labeled by subject matter and assigned an individual number 

connecting the comment to the letter it originated. Coded comments with similar subject matters 

were then grouped and developed into issue statements. Responses to coded comments, 

synthesized into concise statements and organized in a manner to reflect the public concerns was 

conducted by the revision team.

The revision team worked with staff, regional office directors, and forest supervisors to consider 

public comments, assess options, develop potential resolutions, and determine a preferred 

alternative for the final environmental impact statement. 

After analysis of the comments and the substantial nature of the changed condition in the 

southern Sierra and the consequences to management needs, the revision team decided split the 

Inyo National Forest plan revision effort from the Sequoia and Sierra efforts as described 

previously.

Consultation with Federally Recognized Indian Tribes – The responsible official for the Inyo 

National Forest regularly met with federally recognized Indian Tribes to discuss the plan revision 

process and to engage in consultation as needed.

A description of the public participation process for forest plan revision can be found in the Forest 

Plan Revision Collaboration, Tribal and Public Involvement Plan in the project record.

Issues

The public, local and county governments, and State and Federal agencies submitted comments in 

response to the notice of intent during the 30-day scoping comment period and at public 

meetings. We reviewed all the comments to identify issues and frame their associated cause-andeffect relationships. We then separated the issues into two groups: significant and nonsignificant. 

Significant issues are those used to develop alternatives and modify the proposed action. 

Nonsignificant issues are identified as those: (1) outside the scope of the proposed action; 

(2) already addressed by law, regulation, the proposed revised plan, or other higher level decision; 

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

factual evidence.

Issues that Served as the Basis for Alternative Development

There are two broad categories of issues: (1) ecosystem or wildlife issues, and (2) management or 

use issues. Each category is followed by numbered issue topics, each of which are followed by a 
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

11

summarized issue statement and a description of the many concerns we heard during public 

comments and engagement sessions about the issue.

Ecosystem or Wildlife Issues

Issue 1: Ecological Resilience, Wildlife Habitats, and Wildfire

The amount, type, and location of thinning to improve ecosystem resilience to large, highintensity wildfires and to reduce the threat of wildfires to communities may not provide adequate 

habitat for wildlife species that use forests with large trees and dense canopy cover.

There is concern about the type and extent of management activities included in the proposed 

action for restoring ecological resilience, particularly mechanical thinning. Based on perceptions 

of current vegetation conditions and resilience, some respondents stated the proposal is too 

aggressive, while others stated the restoration proposal is not aggressive enough. Some believe a 

more active management approach using thinning of trees and removing fuels to restore 

ecological resilience will impact too much of the dense forest that provides wildlife habitats in the 

short term. They prefer to use more prescribed burning and more carefully managed wildfires 

instead of mechanical thinning, and to limit mechanical thinning to only when needed closest to 

communities. Others think a more active management approach that substantially increases the 

areas thinned will reduce impacts from large, high-intensity wildfires and ensure that the forests 

are resilient to climate change. They believe that active management may have short-term 

impacts but is needed to provide long-term sustainability of wildlife habitat and other ecosystem 

services.

Issue 2: Forest Resilience and Forest Density

The limitations on effectively treating enough areas to reduce the density of trees and the level of 

fuels because of concerns for wildlife habitats will leave too much of the forest at risk of loss or 

unacceptable damage from wildfires or insect attacks during droughts exacerbated by climate 

change.

There is a concern that there are too many tightly packed trees in much of the current forests, 

which makes them susceptible to being attacked and killed by bark beetles and other insects when 

trees are stressed by droughts. The density of trees and high level of fuels that have accumulated 

also makes it easier for fire to spread quickly into tree crowns where it can kill more trees than 

would be expected under more natural conditions. Public concern is that overemphasizing 

wildlife habitat needs conflicts with the need to improve resilience and sustainability of the forest.

Issue 3: Fuels Treatments and Fire Management

The amount of prescribed fire and managed wildfire used to meet resource objectives may not be 

sufficient to restore fire in frequent-fire ecosystems. The amount of fire restored to the landscape 

may not be achievable without reducing existing fuels before treatment.

There is general agreement about the need to restore fire as an ecosystem function more widely 

on the national forest. There is a concern that in most areas, unless existing fuels are reduced 

beforehand, it will be difficult to conduct prescribed burning because the fire will burn hotter than 

desired and will have too great a potential to escape control. There is also a concern that many 

prescribed burns may not be accomplished because fire managers would need to wait for optimal 

weather where the conditions for burning and risks are acceptable. Similarly, the concern is that 

wildfires that might be suitable for managing to meet resource objectives will continue to be 
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

12

suppressed unless there are strategic pre-treated locations to provide confidence that the fire can 

be safely managed without undue risks to communities or unacceptable impacts to resources.

Issue 4: Watershed Restoration

The amount of watershed restoration in the proposed revised plans may not keep pace with the 

increased stresses to aquatic and riparian systems from drought and climate change.

There is a concern that with climate change and drought, aquatic and riparian ecosystems are 

under increasing stress and in need of restoration to increase their resilience. Stresses include the 

threats of uncharacteristically large wildfires that affect large portions of watersheds and riparian 

areas, decreases in available water and a resulting increase in water temperature due to increased 

forest density where more trees draw water to grow, and drying of meadows and unique features 

like fens and springs. Since aquatic and riparian systems are an essential component to sustain 

ecosystem integrity, the concern is that without an increased pace and scale of restoration to 

address these stressors, aquatic ecosystems will continue to degrade with less water and warmer 

water temperatures that may make it difficult or impossible for aquatic organisms to survive.

Issue 5: Protecting Aquatic Diversity

The proposed revised plans may not adequately protect areas of high aquatic species diversity.

There is a concern that if we don’t identify and provide additional protection to areas of high 

aquatic species diversity, they may be adversely affected by the pace and scale of restoration. 

Maintaining and improving the resilience of these areas of concentrated species diversity is 

thought to be important as an adaptive strategy to address climate change.

Management or Use Issues

Issue 6: Recommended Wilderness

The proposed revised plans offer an opportunity to manage more areas as recommended 

wilderness to protect them from development for future generations. However, recommending 

additional wilderness areas in the proposed revised plans might unnecessarily prohibit and 

further geographically constrain management activities and uses, including tribal uses that 

would otherwise be allowed.

The 2012 Planning Rule and Forest Service directives provide direction during forest plan 

revision on a process to inventory and evaluate lands that may be identified as recommended for 

inclusion in the National Wilderness Preservation System. During the 30-day scoping comment 

period, some individuals and groups identified areas to consider in the wilderness inventory and 

suggested they become recommended wilderness areas. They asked that these or other additional 

areas be proposed for wilderness designation to protect the values that they attach to wilderness 

areas. Other people requested that no additional areas be proposed for wilderness designation 

because this would prevent them from participating in the activities that they currently enjoy 

within those areas. In particular, Tribes, tribal groups and organizations, and traditional cultural 

practitioners expressed concern that access and use of sites where resources are gathered and 

ceremonies are held may be restricted if areas are managed as wilderness. There is also a concern 

that sacred sites and cultural resources may be damaged or vandalized if recreation use increases 

with wilderness designation. Some commenters felt wilderness designation could also limit 

management activities that provide economic benefits while reducing the risks of uncharacteristic 

wildfire, insect, and disease disturbances.
Chapter 1. Purpose of and Need for Revising the Inyo, Land Management Plan

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

13

Issue 7: Smoke

Increasing the amount of prescribed burning, and allowing the management of wildfires to meet 

resource objectives would produce more smoke that might impact human health and affect the 

tourism-based and resource-based economies of counties and rural communities.

Recent very large wildfires in Sierra Nevada national forests have demonstrated that smoke can 

affect not only local communities but also communities far from the fire. Smoke can affect 

human health and recreation opportunities. These impacts may affect other uses of the national 

forest and can be substantial for communities dependent upon a recreation-based economy. There 

is a concern that increasing the amount of prescribed burning and managing more wildfires to 

meet resource objectives will produce too much smoke that will affect human health and, if not 

carefully planned and managed, it could affect local economies.

Issue 8: Forest Products

The amount of forest management activities and forest product outputs may not adequately 

contribute to sustaining local and regional industry infrastructure needed to accomplish 

restoration objectives.

Many commenters emphasized the importance of economic and social contributions of the 

national forest to the surrounding communities. One concern is the importance of maintaining 

infrastructure (such as mills, roads, equipment, and skilled labor force) in local communities, so 

that the Forest Service can draw upon that infrastructure to accomplish restoration goals as well 

as contribute to the economic and social well-being of communities.

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

15

Chapter 2. Alternatives, Including the Proposed Action

Introduction

This chapter describes the proposed action for revising the existing forest plans and alternatives to 

the proposed action. We have developed and analyzed five alternatives in this environmental 

impact statement; the proposed action is referenced as alternative B, the preferred alternative is 

Alternative B-modified. Alternatives are described by the different ways they address the revision 

topics and the relevant needs for change. The alternatives provide a framework for analyzing 

different ways of guiding land and resource management activities, achieving the purpose and 

need and addressing the issues described in chapter 1. The key purpose of this chapter is to 

describe the alternatives and present the effects of the alternatives in comparative and summary 

form, so that the differences between each alternative can be readily discerned. The details of 

alternative B-modified are provided in the final “Land Management Plan for the Inyo National 

Forest.”

Alternatives Considered in Detail

Five alternatives are analyzed in this environmental impact statement: the no-action alternative 

(alternative A), which represents the existing plan (as amended), and four other alternatives: 

alternative B (draft forest plan), alternative B-modified (final forest plan), and alternatives C and 

D, which respond to the needs for change and issues identified from public involvement. The 

alternatives present a range of analysis options, as required by National Environmental Policy Act 

regulations.13

Alternative Development and Refinement Process

Alternative B

Alternative B, the proposed action, was developed to address the needs for changing the forest 

plan (as identified in chapter 1), as well as to carry forward existing forest plan direction that is 

still relevant. Information we gathered from the public and Tribes during the collaborative process 

consisted of public comments, the Bio-Regional Assessment, an individual national forest 

assessment, and the Forest Service Pacific Southwest Research Station’s Science Synthesis. All of 

this information contributed to refining the needs for change and creating a proposed action for 

revising the forest plan, as well as to developing the other alternatives. 

Alternative B-modified

Alternative B-modified is fundamentally alternative B with modifications to respond to public 

comments and to refine the concepts originally presented in the draft forest plan. The alternative 

responds to Issue 3: Fuels Treatments and Fire Management by correcting the underlying data 

used in the modeling of fire zones to better represent refinement of fire management zones. The 

model inputs were also changed in the form of removing the visual quality input and the northern 

goshawk habitat, constraining the California spotted owl habitat, and reassigning areas of low 

 13 See 40 CFR 1502.14
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

16

elevation sagebrush to the general protection zone rather than restoration zone to protect 

sagebrush habitat from negative fire effects. 

The alternative responds to Issue 4: Watershed Restoration and Issue 5: Aquatic Diversity by 

replacing the concept of critical aquatic refuges with conservation watersheds. New plan 

components were written for the conservation watersheds to provide for long-term maintenance 

and restoration of functioning watersheds providing habitat for the persistence of species of 

conservation concern. The plan was reformatted to display all the plan components associated 

with aquatic, riparian, and watershed resources in one area to better reflect a cohesive aquatic 

strategy.

The sustainable recreation direction was modified to provide more developed and cohesive plan 

direction. The concept of “places” (descriptive management areas without plan components) was 

replaced with a three-zone approach to recreation management. The desired recreation 

opportunity spectrum was mapped and plan components developed, to manage the recreation 

setting and built environment. A winter recreation opportunity spectrum map was developed to 

reflect winter over-snow settings. 

The final plan and environmental impact statement also made changes to the area considered for 

timber suitability. Additional eligible sections of wild and scenic rivers were added between the 

draft and final statements along with refined boundaries for proposed wilderness areas, and those 

areas were removed from the area considered for timber suitability. Additionally, riparian 

conservation areas were removed from the area of timber suitability.

Alternative C

Alternative C was developed to address Issues 1, 3 and 5, emphasizing prescribed fire as a 

management tool, rather than mechanical thinning and harvest. Management would focus on 

treating small-diameter trees using mechanical and hand treatment methods instead of removing 

trees across a range of tree diameters, and on follow-up prescribed burning within treated areas.

Mechanical treatments in alternative C would emphasize vegetation and fuel reduction treatments 

in the wildland-urban intermix defense zone to minimize the threat of large high-intensity 

wildfires to communities and there would be less fuel reduction treatment in wildland areas. The 

treatments in the wildland-urban intermix defense zone would focus on implementing and 

maintaining a pattern and intensity of effective fuel reductions to lower the intensity of wildfires 

immediately adjacent to communities. Alternative C also emphasizes greater salvage logging 

restrictions and maintenance of important habitat structures in complex early seral habitat.

Alternative C adds the most critical aquatic refuges. Direction for riparian conservation areas 

remains similar to alternative B, but would not include the exception to allow mechanical 

thinning within riparian conservation areas to facilitate burning there.

Alternative C includes the most area of recommended wilderness of all alternatives including 

many areas the public identified for consideration. It also includes the most areas that would be 

managed as critical aquatic refuges, including many areas the public identified for consideration. 

Alternative C also increases the size of the management area for the Pacific Crest National Scenic 

Trail to include areas that offer iconic views to better provide for scenic values of the trail.

Alternative D

Alternative D was developed to address Issues 2, 3, and 8 by increasing the intensity of 

treatments and the area where fuels are pre-treated using mechanical methods in combination 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

17

with strategic treatment locations to favor larger landscape prescribed burns. This approach 

allows for prescribed burning across larger landscapes and provides more opportunity to manage 

wildfires to meet resource objectives. It allows removal of more trees, which helps managers 

more rapidly address desired conditions to reduce stand density and drought-related stress on 

residual large and old trees, and improve overall resilience of vegetation.

Alternative D emphasizes strategic mechanical thinning and prescribed burning treatments in the 

community wildfire protection zone, closest to communities, and the general wildfire protection 

zone, where fires can originate and have a high probability of reaching communities, to minimize 

the threat of large high-intensity wildfires. Alternative D also treats more area within the wildfire 

restoration zone increasing the potential to manage wildfires to meet resource objectives. 

Alternative D also addresses Issue 6 by not recommending any additional areas for wilderness 

designation. Critical aquatic refuges are the same as alternative B. Direction for riparian 

conservation areas remains the same as alternative B.

Issue 4, concern regarding the pace and scale of watershed restoration, is addressed by having the 

greatest amount of stewardship project opportunities related to the increased amount of 

mechanical fuel reduction. Issue 7, concern regarding the potential of smoke to affect local 

community health and economic sustainability, is addressed by increasing the amount of 

mechanical fuel reduction prior to prescribed burning and by increasing the opportunity to 

manage wildfires to meet resource objectives through the use of strategically located treatments 

and larger landscape prescribed burning.

Features Common to Alternatives B, B-modified, C, and D

Species of Conservation Concern

The National Forest Management Act requires the Forest Service 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.” As such, the 2012 Planning Rule requires the 

Forest Service to maintain or restore ecological sustainability, integrity, and diversity as the 

primary approach to species conservation. In addition, the rule requires plan components to 

provide the ecological conditions to maintain a viable population of species of conservation 

concern. A viable population is defined as one “that continues to persist over the long term with 

sufficient distribution to be resilient and adaptable to stressors and likely future environments.” 

Species of conservation concern are those species that are known to occur within the plan area 

and for which there is a substantial concern about the species’ capability to persist over the long 

term in the plan area. As required by the Planning Rule and agency directives, the Regional 

Forester has identified a list species of conservation concern for the Inyo National Forest, which 

does not vary by alternative. These species are listed in the section “Wildlife, Fish and Plants.”

Alternatives B, B-modified, C, and D (also referred to as “the revised plan alternatives”) identify 

vegetation desired conditions designed to provide overall ecological integrity, including habitat 

for all associated species, and specifically to ensure they provide the ecological conditions 

necessary to maintain viable populations of species of conservation concern within the plan area. 

A guideline was developed to protect trees from removal that are used for nesting, denning, or 

roosting by at-risk species. This extends to some adjacent trees that provide necessary shade or 

other important habitat conditions. In addition, a guideline was developed to consider at-risk 

species early in the environmental planning process.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

18

The revised plan alternatives identify desired conditions, standards, and guidelines for special 

habitats that represent small-scale habitat or vegetation types that support many at-risk plants and 

animals. These special habitats have plan direction to increase their consideration in project 

design and to help maintain and improve key ecological conditions that support several plant 

species of conservation concern.

For some species of conservation concern, species-specific plan components have been developed 

or carried forward from the existing plans and are the same across alternatives. These species 

include Lahontan cutthroat trout, Paiute cutthroat trout, golden trout, and Sierra marten. Speciesspecific plan components related to willow flycatcher and great gray owl are not carried forward 

from the existing plans. 

Willow Flycatcher 

Species-specific plan direction for willow flycatcher is not being carried forward into plan 

revision. Current direction includes survey requirements and livestock grazing direction for 

occupied sites. However, there is no overlap of occupied sites and livestock grazing; therefore, 

additional species-specific plan direction is not necessary.

Great Gray Owl 

Great gray owl is known to forage on the Inyo National Forest but there are no known nest sites. 

Great gray owl is a species of conservation concern in the plan area, but there are no speciesspecific plan components. There is a species-specific potential management approach to conduct 

additional surveys using established protocols to follow up on reliable sightings of the owl. 

Sierra Marten and Pacific Fisher

Species-specific plan direction for Sierra marten and Pacific fisher incorporates recent mapping 

of Pacific fisher and marten core habitat and information from the “Science Synthesis and 

Climate Adaptation Strategy for the Sierra Nevada.” Much of fisher core area 1 and marten core 

habitat overlaps with wilderness or inventoried roadless areas and would have limited 

management. Additional desired conditions and guidelines address management of core habitats 

to restore and maintain habitat quality and resilience to climate change. A limited operating 

period minimizes disturbance to fisher in core area 1 but allows some exemptions for beneficial 

activities. Although plan direction related to other species varies by alternative and may also 

affect marten and fisher habitat, the revised plan alternatives include plan direction to incorporate 

Sierra marten and Pacific fisher core habitat and conserving the key habitat characteristics.

Tribal Relations and Uses

Desired conditions, goals, and potential management approaches in the revised plan alternatives 

address and encourage working with Tribes to manage resources of tribal importance. Plan 

components focus on management of some sites for tribal uses such as oak stand improvements 

for acorn gathering, management of pine stands for piaga (Pandora moth) on the Inyo National 

Forest, and other gathering site improvements and considerations.

Partnerships

An emphasis on increasing workforce capacity through the use of partnerships and volunteerism 

is included in plan direction in the revised plan alternatives. A variety of strategies and tools 

would be used to increase the use of private, public, and tribal partnerships and volunteers. 

Partnerships and volunteers could assist with improving and maintaining recreation trails, 

recreation and administrative sites and other types of infrastructure, providing information and 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

19

interpretive services, as well as participating in ecological restoration that would include restoring 

meadows and other archeological, cultural, and ecological features. Partnerships may also provide 

additional funding or other resources to increase the types and levels of services offered and to 

support an increased pace and scale of ecological restoration. In each alternative, the type of 

partnership or volunteer emphasis may shift; however, the ability to maintain and increase 

partnerships and volunteerism will continue to exist.

Wild and Scenic Rivers

A new plan component is added for management of rivers identified as eligible for inclusion in 

the National Wild and Scenic River System as well as for rivers that have been found to be 

suitable in previous wild and scenic river studies and have previously been recommended by the 

Forest Service for inclusion in the National Wild and Scenic River System. The standard applies 

protection measures for these rivers until a decision is made through an Act of Congress or a 

suitability evaluation determines that an identified eligible river is not suitable. The wild and 

scenic river eligibility evaluation identified an additional 160 miles of eligible rivers or segments 

on the Inyo National Forest.

Nevada Enhancement Act Lands 

The Inyo National Forest acquired approximately 44,600 acres of lands through the National 

Forest and Public Lands of Nevada Enhancement Act of 198814 (see figure 2). These lands have 

been managed consistent with the Bureau of Land Management’s Tonopah Management Plan and 

would be fully incorporated into the Inyo forest plan. Desired recreation opportunity spectrum 

classes and scenic integrity objectives are assigned to these lands reflecting the current 

management condition.

Scenic Integrity

Scenic character would be managed using the direction of the Scenery Management System, 

which replaces the older Visual Management System in the existing forest plans. The Scenery 

Management System provides a systematic approach to inventory, analyze, and monitor scenic 

resources on National Forest System lands. It recognizes that landscapes are not static so 

objectives for scenery are grounded by naturally changing and evolving conditions that are 

described in the scenic character. The scenic character stability of the landscape becomes an 

element considered in implementing the management objectives related to restoration. This 

context ensures that objectives for scenery are linked to ecological changes rather than managing 

for a specific condition into perpetuity. Converting to the Scenery Management System advances 

the contemporary paradigm that both natural and cultural (built element) features are part of 

scenic character and contribute to “sense of place.” Scenic integrity objectives describe the 

minimum thresholds for the management of the scenery resource, ranging from very high scenic 

integrity objectives to low. Scenic integrity objectives reflect changes in public perceptions and 

the importance of viewing scenery as well as integrating scenery resources with the overall 

management of the landscape. Sustainable recreation concepts are integrated into plan direction 

for restoration projects to improve and protect scenic character and contribute to improved scenic 

stability.

 14 Public Law 100-550 - Oct. 28, 1988; 102 Stat. 2749
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

20

Figure 2. Location of Nevada Enhancement Act Lands on the Inyo National Forest
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

21

Invasive Species

The direction for invasive species is primarily focused on noxious weeds in alternative A. For the 

revised plan alternatives, the direction was updated and expanded to recognize the threats to 

ecosystem resilience from all nonnative invasive aquatic and terrestrial plants and animals likely 

to cause harm to ecosystems. There is an emphasis on managing invasive species by including 

objectives that increase the amount of area with nonnative invasive plants treated.

Climate Change

The Forest Service is addressing climate change in a variety of ways, from reducing the impacts 

of the operations of facilities to encouraging reduced impacts from permitted activities. The 

desired conditions for the revised plan alternatives include adaptations for climate change where 

relevant. An example is the climate adaptation strategy of providing for habitat connectivity to 

allow animals to move across the national forest more easily. Although they are not specifically 

addressed in the current forest plans, many of these strategies can and are considered during 

ongoing project development.

Alternative A: Existing Plan Direction

Under alternative A, the existing plans, as amended, would continue to guide management of the 

Inyo National Forest. An electronic copy of the existing forest plan is provided on the Forest Plan 

Revision website.15

The following sections discuss existing plan direction as it relates to each of the revision topics 

and needs for change.

Revision Topic 1: Wildland Fire Management

Strategic Fire Management Zones

Current forest plan management focuses hazardous fuel reduction treatment in the wildland-urban 

intermix defense zone and threat zone as a priority. In the defense zone (the area closest to 

structures and communities), there are fewer restrictions on the intensity of thinning (See chapter 

3, “Wildland Fire Management” section for more information and volume 3 for maps of the 

strategic fire management zones).

Managing Wildfire to Meet Resource Objectives

The current forest plan encourages the restoration of fire to the ecosystem through increased use of 

prescribed fire and by allowing management of some wildfires when they can meet resource objectives 

defined by the forest plan. The existing plan provides general direction for resource objectives 

related to vegetation conditions, but they do not explicitly identify resource objectives to be 

accomplished using wildfire as a natural process.

Smoke and Air Quality

Prescribed fire is coordinated with adjacent land management agencies to ensure that State or 

Federal standards for ambient air quality are not exceeded.

 15 http://www.fs.usda.gov/detail/r5/landmanagement/planning/?cid=stelprdb5444003
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

22

Revision Topic 2: Ecological Integrity

Terrestrial Ecosystems

Ecosystem Resilience and Adaptation to Climate Change

Current plan direction focuses on vegetation management and fuel conditions at the stand or 

patch scale and it does not explicitly provide a framework for increasing landscape-level 

treatments. Plan direction is generally prescriptive, with specific requirements and limitations on 

the diameter sizes of trees that can be removed and requirements to retain certain amounts of tree 

canopy cover. The landscape management approach is to strategically place fuel reduction 

treatments to interrupt the spread of large wildfires. However, because many areas are 

inaccessible due to steep terrain or distance from roads, and the current plan includes singlespecies-specific habitat management direction that limits treatment options, this approach has 

proven difficult to implement. This has left some wildlife habitats vulnerable to damage or loss 

from large high-intensity fires. The current forest plan describes the need to address stand density of 

forests to reduce the risk of trees dying due to stresses related to prolonged droughts, but single-speciesspecific habitat management direction limits the amount of treatment that can occur.

Old Forests

The current forest plan contains desired conditions for old forest emphasis areas and provides 

standards and guidelines to generally retain all large trees and to minimize treatments within 

patches of dense-canopy forests with larger trees wherever they occur. The desired conditions for 

old forest emphasis areas provide for high levels of horizontal and vertical canopy diversity, and 

variability in size, species composition, and structure of roughly even-aged vegetation groups 

generally less than 5 acres in size. However, these desired conditions conflict in part with the 

desired conditions and standards and guidelines for the California spotted owl, Sierra marten, and 

Pacific fisher, which generally favor retaining large contiguous areas of denser canopy cover and 

limit the ability to create a lot of horizontal and vertical canopy diversity. In some cases, the 

prescriptive plan direction for one species conflicts with direction for another species, which can 

limit the restoration of habitats as the most restrictive direction is applied to projects.

Wildlife and Plant Habitat Diversity

Risks to terrestrial habitat are mitigated in part by using restoration treatments (such as thinning, 

prescribed fire, and wildfires managed to meet resource objectives) at a landscape scale with the 

intent of reducing the impact of future large, high-intensity wildfires on key habitats each species 

needs. Despite the intent, the combination of protections for individual species often results in the 

inability to treat enough of the landscape to reduce the risks to habitat from wildfire.

Aquatic and Riparian Ecosystems

The current forest plan provides direction for an aquatic management strategy with desired 

conditions, goals, and a set of standards and guidelines organized around a set of riparian 

conservation objectives that includes delineation of riparian conservation areas around streams, 

rivers, lakes, meadows and a variety of other wetland types, and a set of critical aquatic refuges. The 

current standards and guidelines generally limit disturbance and impacts within riparian 

conservation areas and critical aquatic refuges and call for consideration of impacts to aquatic and 

riparian systems and resources.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

23

Critical Aquatic Refuges

The current plan identifies a set of critical aquatic refuges focused on areas with threatened and 

endangered species or areas of other species with population concerns. The direction that applies 

to riparian conservation areas, the buffer area around streams, rivers, lakes, meadows, bogs, and 

other wetland types, applies to the critical aquatic refuges. There are 17 critical aquatic refuges on

the Inyo National Forest.

Watershed Resilience to Climate Change

The desired conditions for aquatic and riparian ecosystems in the current plan does not 

specifically consider the change in temperature and precipitation related to climate change and 

other climate stressors to aquatic systems. Desired conditions do not exist connecting the 

condition of upland vegetation with the condition of aquatic and riparian ecosystems.

At-risk Species

At-risk species in alternative A consist of federally listed species under the Endangered Species 

Act and Forest Service sensitive species. The current forest plan employs an approach to species 

management that has a particular focus on providing habitats for species associated with old 

forest ecosystems and with aquatic and riparian systems, two of the issue areas identified in 2001 

as needing new or amended plan direction. The current plan uses an approach primarily focused 

on limiting management activities within areas identified for wildlife management, especially 

protected activity centers for California spotted owl, northern goshawk, and great gray owl; home 

range core areas for California spotted owl; and den and rest sites for Sierra marten and Pacific 

fisher.

Bi-State Greater Sage-Grouse 

Under the current forest plan, the Inyo National Forest would continue to follow the “Inyo 

National Forests Sage-Grouse Interim Management Policy” (USDA Forest Service 2012c)

pending a forest plan amendment to better address the bi-state greater sage-grouse. In any plan 

amendment developed for sage-grouse, the Inyo National Forest would consider management 

direction that addresses current threats and, where feasible and applicable, would amend the plan 

to be consistent with the “Humboldt-Toiyabe National Forest Greater Sage-Grouse Bi-State 

Distinct Population Segment Forest Plan Amendment” to better achieve consistency across 

national forest boundaries. The Inyo National Forest would also continue to consider 

management direction and emphasize management actions that are consistent with the “Bi-State 

Action Plan: Past, Present, and Future Actions for the Conservation of the Greater Sage-Grouse, 

Bi-State Distinct Population Segment.”

California Spotted Owl 

Species-specific plan direction for California spotted owl in the current plan provides for 300-

acre protected activity centers designated around territorial locations and intended to provide 

sufficient habitat to support nesting owls. A surrounding home range core area encompassing an 

additional 700 acres surrounding the protected activity center, is identified to provide sufficient 

foraging and roosting habitat to support the home range needs of California spotted owls. 

Great Gray Owl 

The current plan includes designation of a protected activity center and standards and guidelines 

that provide for follow-up surveys, a limited operating period during the breeding season, and 

maintenance of herbaceous vegetation. However, there is no known nesting of this species on the 

Inyo National Forest.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

24

Pacific Fisher

Under the current forest plan, the Southern Sierra Fisher Conservation Area is adjacent to but 

does not include the Inyo National Forest. Species-specific plan direction provides for 700 acre 

den site buffers around verified birthing and kit rearing dens with limited operating periods, 

minimizing fuels treatments to the extent possible and mitigating other disturbances. There are no 

known denning or birthing sites on the Inyo National Forest.

Sierra Marten 

The current forest plan includes direction for establishing 100 acre den site buffers around den 

sites and minimizing disturbance and activities near den sites.

Sierra Nevada Bighorn Sheep and Nelson Desert Bighorn Sheep

The current forest plan contains direction to maintain and improve habitat, promote 

reestablishment to historic ranges, manage livestock where it poses a disease risk to bighorn 

sheep, mitigate impacts from recreation (Sierra Nevada Bighorn), and mitigate impacts of 

minerals extraction activities in bighorn sheep winter range.

Willow Flycatcher 

The current plan includes standards and guidelines that guide livestock management by defining 

three categories of site occupancy: occupied willow flycatcher sites, historically occupied willow 

flycatcher sites, and conditionally occupied willow flycatcher sites.

Yosemite Toad 

The current plan includes standards and guidelines that exclude livestock grazing within toadoccupied areas during the Yosemite toad breeding and rearing season. A standard and guideline 

allows waiver of the livestock exclusion if a site-specific management plan is approved and 

incorporated into allotment plans and relevant special-use permits.

Revision Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation

The existing plan direction was based on recreation uses and recreation demand existing and 

projected from the late 1970s and 1980s when forest plans were first developed. The emphasis of 

the current plan is on improving recreation opportunities by focusing on the maintenance, 

development, adaptation, or alteration of dispersed and developed recreation sites consistent with 

the recreation opportunity spectrum class of the area. There is an emphasis to continue existing 

partnerships and volunteerism and to evaluate opportunities to develop new partnerships and 

volunteers to increase the amount of trails and facilities managed to desired standards.

Scenery

In the current plan, scenic character is managed using the 1986 Visual Management System and 

associated visual management objectives, which do not include specific guidance for designing 

projects to improve scenic character and scenic character stability within the desired landscape 

character.

Designated Wilderness

General management direction exists but many designated wilderness areas have wilderness 

management plans that provide more specific management guidance.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

25

Pacific Crest Trail

The current forest plan manages the Pacific Crest National Scenic Trail according to direction 

provided by a 1982 Comprehensive Management Plan (USDA Forest Service 1982) and direction 

is focused on the trail tread and immediate surroundings. Most of the Pacific Crest Trail is within 

existing wilderness areas except for 5 miles on the Inyo National Forest. In this area, there is 

limited specific plan direction to guide activities adjacent to the trail that may impact the scenic 

and recreational values of the trail.

Alternative B: Draft Revised Plan

Alternative B is the draft revised forest plan, which was developed in collaboration with the 

public, other agencies, government officials, and Native American Tribes to respond to the need 

for change emphasis areas. As described in chapter 1, the draft forest plan was adjusted from what 

was initially produced to address issues and feedback received by the public to date. 

Alternative B provides a management direction framework to improve ecological fire resilience 

and restore fire as an ecosystem process. The draft forest plan establishes strategic fire 

management zones and emphasizes active management in the form of harvest, mechanical 

thinning, and prescribed burning to support the use of wildfire (natural ignitions) for resource 

benefit where it can be safely managed. The draft forest plan balances the need for a greater focus 

on landscapes and processes with protection for wildlife with the need for more active 

management. The draft plan addresses the fact that a prescriptive, single-species approach to 

forest management has significant limitations in terms of achieving long-term sustainability and 

diversity of ecosystems in the face of stressors and climate change, especially in areas closest to 

communities and where there are high concentrations of assets and values important to people. 

Management approaches are adjusted for scenery and recreation settings to integrate with 

restoration activities at a landscape scale and address adapting sites and infrastructure to the needs 

of shifting demographics, budgets, and climate change. Specifically, the draft forest plan strives 

to streamline and simplify standards and guidelines to allow for increasing the pace and scale of 

restoration projects designed to reduce the risks associated with large, high-intensity wildfires, 

drought, insect outbreaks, and climate change. The draft plan also strives to improve watershed 

conditions within the community wildfire protection zone and the general wildfire protection 

zone while providing for overall species diversity and the persistence of at-risk species, 

supporting recovery of federally listed species, and improving recreation sustainability.

The draft forest plan retains much of the direction from the existing forest plan; however, the 

draft forest plan differs in a number of fundamental ways that are aimed at allowing forest 

management to be more adaptable over time and to be able to adjust to site-specific conditions. 

Some concerns raised during the public scoping comment period were incorporated into the draft 

plan, either by modifying existing language or by adding new language. The following sections 

describe how alternative B responds to each of the revision topics.

Revision Topic 1: Wildland Fire Management

Strategic Fire Management Zones

Direction in the draft forest plan would replace the current two distance-based land allocations in 

the wildland-urban intermix and the remaining areas that are not wildland-urban intermix with 

four management areas based on a fire risk analysis consistent with the National Cohesive Fire 

Strategy (see chapter 3, “Wildland Fire Management” section for more information and volume 3 

for maps of the strategic fire management zones). 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

26

• The Community Wildfire Protection Zone would replace the wildland-urban intermix 

defense zone of alternative A and includes larger geographic areas where wildfire would 

likely threaten communities. This zone is based on modeling potential spread and intensity

of wildfires that have a very high likelihood of burning into and negatively impacting 

communities and community assets. Due to variations in the potential of fire, this zone is 

irregular in shape unlike the uniform shape of the wildland-urban intermix defense zone of 

alternative A. Draft plan direction emphasizes active management using thinning and 

prescribed fire to reduce fuels within this zone. Most wildfires would be actively 

suppressed to protect communities and assets, although in some instances, wildfires may be 

managed to meet resource objectives if environmental and fuel conditions allow and when 

it could be done in a safe manner. Environmental conditions consist of a combination of 

temperature, relative humidity, wind speed/direction, and airmass stability. These factors 

influence vegetation moisture and fire behavior and are determined annually during the preplanning phase of fire management (see chapter 3, “Fire Management” section for more 

details). Plan direction identifies community buffers in close proximity to structures where 

fuel conditions, snags, and logs would be managed to facilitate safe wildfire operations.

• The General Wildfire Protection Zone would replace the wildland-urban intermix threat 

zone of alternative A; it is irregular in shape, covering a larger area. This zone is based on 

modeling potential spread and intensity of wildfires that have a very high likelihood of 

burning toward and negatively impacting communities and assets as well as negatively 

impacting natural resources in the zone. Draft forest plan direction emphasizes active fuel 

reduction treatments along ridgetops, roads, and other natural and manmade features that 

can serve as strategic anchor points for larger prescribed burns and to create areas of low 

fuel that can be used to manage wildfires. Due to the high likelihood of wildfire occurring 

in this zone and possibly spreading into the community wildfire protection zone, wildfires 

would most often be suppressed to reduce the threat to communities and assets. In some 

instances, wildfires could be managed to meet resource objectives if environmental and fuel 

conditions allow and when it could be done in a safe manner. Environmental conditions 

consist of a combination of temperature, relative humidity, wind speed and direction, and 

airmass stability. These factors influence vegetation moisture and fire behavior and are 

determined annually during the pre-planning phase of fire management.

• The Wildfire Restoration Zone would be a new zone that identifies areas with low to 

moderate risk for communities and structures and other resource values. This zone is based 

on modeling potential spread and intensity of wildfires that can pose a mix of positive and 

negative effects to resources and some isolated assets. Thinning or prescribed burning may 

be needed before wildfires can safely be managed to meet resource benefits. Proposed plan 

direction emphasizes active fuels management treatments in strategic locations to enable 

larger prescribed burns and to aid wildfire management that focuses on restoring fire to the 

ecosystem. Many wildfires in this zone would be managed to meet resource objectives 

under specific environmental and fuel conditions and when it could be done in a safe 

manner, although in some instances wildfires may be suppressed. Environmental conditions 

consist of a combination of temperature, relative humidity, wind speed and direction, and 

airmass stability. These factors influence vegetation moisture and fire behavior and are 

determined annually during the pre-planning phase of fire management.

• The Wildfire Maintenance Zone would be a new zone that identifies areas with very low 

risk. This zone is based on modeling potential spread and intensity of wildfires that pose 

mostly a positive effect to resources. The wildfire maintenance zone is typically in the 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

27

higher elevations, wilderness, and remote areas where mechanical treatments are often not a 

management option, thus restoring the role of fire is important to achieve ecological 

sustainability. Most wildfires in this zone would be managed to meet resource objectives 

under specific environmental and fuel conditions and when it could be done in a safe 

manner. Environmental conditions consist of a combination of temperature, relative 

humidity, wind speed and direction, and airmass stability. These factors influence 

vegetation moisture and fire behavior and are determined annually during the pre-planning 

phase of fire management. Prescribed burning would be used here where it increases the 

opportunity to manage wildfires and restore fire-adapted ecosystems.

Managing Wildfire to Meet Resource Objectives

Forest plan direction would provide desired conditions and resource objectives that allow 

unplanned wildfire starts to be managed to meet resource objectives when conditions allow and it 

is safe to do so across the national forest. The conditions and opportunities to manage wildfires 

would vary by strategic fire management zone and plan direction would emphasize designing 

projects to reduce fuels in strategic locations to increase opportunities to manage unplanned 

wildfire starts in this way.

Smoke and Air Quality

Forest plan direction for prescribed fire and managing wildfires to meet resource objectives 

would emphasize considering the impacts of smoke locally and regionally.

Revision Topic 2: Ecological Integrity

Terrestrial Ecosystems

Ecosystem Resilience and Adaptation to Climate Change

Draft forest plan direction would incorporate the concepts of ecological restoration expressed in 

recent scientific publications such as “An Ecosystem Management Strategy for Sierran MixedConifer Forests” (North, Stine, O’Hara, et al. 2009) and “Managing Sierra Nevada Forests” 

(North 2012b). The draft forest plan creates a management framework that allows an increase in 

the amount of restoration treatments using thinning, prescribed fire, and wildfires managed to 

meet resource objectives to make progress toward desired conditions across the landscape.

Proposed plan direction would emphasize mechanical thinning and prescribed burning around 

communities and recreation areas and other forested areas. The draft forest plan increases emphasis on 

restoration of sagebrush ecosystems, especially to benefit the greater sage-grouse as described for “Atrisk Species” on page 29.

Draft forest plan direction emphasizes treating along key roads and ridges and connecting natural 

openings like rock outcrops that can make it easier to implement larger prescribed burns and manage or 

suppress fires. Treatments would focus on drier sites near the roads and ridges where restoration would 

move vegetation toward desired conditions.

To address climate change, the draft forest plan includes desired conditions and direction for improving 

resilience to climate change in all vegetation types. In subalpine and alpine systems there is additional 

direction that focuses on the unique threats that these usually long-lived and slow-growing ecosystems 

(such as bristlecone pine) face as temperature and precipitation patterns change. The draft plan includes 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

28

direction to manage for increased risk of insects and diseases and changed fire patterns and cycles in 

these ecosystems.

The draft forest plan added desired conditions for old forests, including the desired densities of 

large trees and large snags, and the desired proportion of the landscape that should be in old forest 

conditions. They include direction to increase the resilience of old forests and large or old trees to 

drought, climate change, and large, high-intensity wildfires, which acknowledges that the 

variation of forest types requires some flexibility in determining the best approach to improve 

resilience on the ground. 

Complex Early Seral Habitat

The draft forest plan would include plan components to provide for key characteristics that are 

important to the ecological integrity of complex early-seral habitats after large fires or in large 

areas where trees have been killed by drought, insects, pathogens, wind or other events. This 

includes desired conditions for complex habitat characteristics, wide-spread distribution of snags, 

logs, and live trees, while considering the need for other resource objectives such as hazard tree 

removal, reforestation, and strategic fuel treatments.

Wildlife and Plant Habitat Diversity

The draft forest plan adopts the approach to species management of providing for ecological 

diversity and ecological integrity of habitat as the primary means to ensure the persistence of 

most species. Like the existing plan, the draft forest plan contributes to the recovery of federally 

listed threatened and endangered species and does not jeopardize proposed or candidate species, 

including the incorporation of relevant provisions of the “Draft Interim Recommendations for the 

Management of California Spotted Owl Habitat on National Forest System Lands” (USDA Forest 

Service 2015c) in the form of plan components. Proposed objectives moderately increase 

restoration treatments to trend terrestrial habitat toward the desired conditions at a moderate pace.

There is an increased emphasis on restoring fire as an ecosystem process in fire-adapted 

ecosystems with frequent fire-return intervals (in ponderosa and Jeffrey pine, and mixed conifer 

stands). Additional desired conditions for vegetation provides for increased habitat heterogeneity 

for multiple species at both the fine scale as well as at landscape scales. Specific desired 

conditions and guidelines for individual vegetation types, old forest, and sagebrush provide 

ecological integrity of habitat for multiple species.

Aquatic and Riparian Ecosystems

Riparian Conservation Areas

Proposed direction for riparian conservation areas is nearly identical to that contained in the existing 

plan, except for the following changes. The draft forest plan:

• Streamlines and consolidates direction that is similar in nature resulting in fewer plan 

components;

• Removes direction that repeats laws, regulations, or policies; 

• Drops the term “riparian conservation objectives” because of the potential for confusion 

with plan component “objectives;” and

• Modifies direction to allow prescribed burn ignitions and, where necessary, mechanical and 

hand treatments to restore ecological integrity and improve the resilience of riparian 

ecosystems to fire, drought, and climate change.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

29

Critical Aquatic Refuges

The Inyo National Forest draft forest plan adds one additional critical aquatic refuge to their 17 

existing refuges. The Forest Service evaluated all the proposed locations presented during 

scoping, and considered areas where at-risk aquatic species and/or biodiversity hotspots were 

present on national forest lands. 

Watershed Resilience to Climate Change

The desired conditions for aquatic and riparian ecosystems in the draft forest plan recognizes 

changes in temperature and precipitation related to climate change and other climate stressors on 

aquatic systems. Desired conditions are for restored vegetation conditions within watersheds, 

which in turn improves the quantity of water available to improve aquatic systems and to be 

available for other uses. Draft forest plan direction emphasizes improving watershed resilience to 

wildfire and climate change by treating vegetation and reducing fuels over larger areas to lower 

the intensity of wildfires. Restoration emphasizes thinning to reduce the effects of past 

management that has resulted in very dense forests, and mitigating impacts from unmaintained 

roads when they impair watershed function.

At-risk Species

The 2012 Planning Rule defines two categories for at-risk species: (1) species that are federally 

recognized threatened, endangered, proposed, and candidate species; and (2) species of 

conservation concern. Species of conservation concern are native, known to occur in the plan 

area, and species with a substantial concern for their capability to persist over the long term in the 

plan area. The 2012 Planning Rule requires plan components to provide the ecological conditions 

necessary to contribute to the recovery of federally listed threatened and endangered species, 

conserve proposed and candidate species, and maintain a viable population of each species of 

conservation concern within the plan area.

As part of the plan revision process, coarse-filter plan components such as desired conditions 

were developed that describe the desired outcomes and conditions for terrestrial vegetation, 

riparian habitats and features, and aquatic habitats and features within the plan area. For most atrisk species, meeting and maintaining these desired conditions within the plan area and applying 

other standards or guidelines would help provide the habitat and key ecological conditions that 

would provide for their persistence and viability within the plan area. For a few species, 

additional species-specific plan components (desired conditions, standards, guidelines, and goals) 

were developed to better provide the habitats and key ecological conditions that provide for 

persistence and viability within the plan area.

The list of species of conservation concern identified by the Regional Forester for which the draft 

forest plan direction has been developed is described in the “Wildlife, Fish and Plants” section. 

Bi-State Greater Sage-Grouse 

Species-specific plan direction is added for the bi-state greater sage-grouse on the Inyo National 

Forest. The draft forest plan direction is based on the existing “Inyo National Forest Sage-Grouse 

Interim Management Policy (USDA Forest Service 2012c)” and, where appropriate, additional 

management direction has been developed consistent with the “Humboldt-Toiyabe National 

Forest Greater Sage Grouse Bi-State Distinct Population Segment Forest Plan Amendment.” The 

draft Inyo forest plan also includes management direction and emphasize management actions 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

30

that are consistent with the “Bi-State Action Plan: Past, Present, and Future Actions for the 

Conservation of the Greater Sage-Grouse, Bi-State Distinct Population Segment.” 

California Spotted Owl 

Species-specific plan direction for California spotted owl provides for 300-acre protected activity 

centers designated around territorial locations and intended to provide sufficient habitat to support 

nesting owls. A surrounding home range core area encompassing an additional 700 acres 

surrounding the protected activity center, is identified to provide sufficient foraging and roosting 

habitat to support the home range needs of California spotted owls. 

Great Gray Owl

Great gray owl is known to forage on the Inyo National Forest but there are no known nest sites. 

Great gray owl is a species of conservation concern on the plan area, but there are no speciesspecific plan components. There is a species-specific potential management approach to conduct 

additional surveys using established protocols to follow up reliable sightings of the owl.

Sierra Nevada Bighorn Sheep and Nelson Desert Bighorn Sheep

The draft forest plan has similar direction as the current plan.

Yosemite Toad 

The draft forest plan provides forestwide plan direction for at-risk species and therefore provides 

protection for Yosemite toad. 

Revision Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation

Recreation opportunity spectrum classes have been updated and the management approach for 

recreation settings is integrated with ecological restoration approaches. The draft forest plan 

includes desired conditions to manage developed recreation sites for ecological, social, and 

economic sustainability and an objective for fuel treatment restoration activities to protect 

recreation site infrastructure. Management of opportunities, sites, and infrastructure are adjusted 

to respond to changing demographics, budgets, deferred maintenance, and climate change.

Scenery

The draft forest plan direction identifies scenic integrity objectives for the plan area using the 

Scenery Management System. Scenery setting management would be integrated with ecological 

integrity and restoration to improve scenic character stability within the desired landscape 

character. The draft forest plan includes plan components that require desired scenic integrity 

objectives be considered in the design of restoration projects.

Recommended Wilderness

The draft forest plan would make a preliminary administrative recommendation to include four 

additional areas in the National Wilderness Preservation System (South Sierra; Piper Mountain 

Addition; White Mountains East; and White Mountains West). These are also referred to as 

“recommended wilderness areas.” All four areas are adjacent to existing designated wilderness 

area boundaries and total 37,039 acres. 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

31

Pacific Crest Trail

The forest plan would create a management area allocation for the Pacific Crest National Scenic 

Trail by defining a corridor of the visual foreground landscape zone (up to one-half mile from the 

centerline of the trail where visibility is not obscured by terrain) as defined by the Scenery 

Management System. Management area-specific desired conditions, standards, and guidelines 

and a management approach would be included to protect the nature, purposes, and resource 

values of the trail from degradation by activities and development.

Alternative B-modified: Preferred Alternative for the Revised Plan

Alternative B-modified was developed to address public comments received on the draft forest 

plan. Key changes to alternative B that are now incorporated into alternative B-modified include: 

(i) development of new direction for the aquatic strategy including the identification of 

conservation watershed areas; (ii) development of sustainable recreation areas and associated plan 

components; (iii) additions and subtractions to the species of conservation concern list; and 

(iv) incorporation of the forest rangeland livestock grazing plan components.

Alternative B-modified is the preferred alternative for the revised forest plan. This alternative

provides a management direction framework to improve ecological resilience to high-severity fire

and restore fire as an ecosystem process. The revised forest plan establishes strategic fire 

management zones and emphasizes active management in the form of harvest, mechanical 

thinning, and prescribed burning to support the use of wildfire (natural ignitions) for resource 

benefit where it can be safely managed. The revised forest plan balances the need for a greater 

focus on landscapes and processes with protection for wildlife with the need for more active 

management. The revised forest plan addresses the fact that a prescriptive, single-species 

approach to forest management has significant limitations in terms of achieving long-term 

sustainability and diversity of ecosystems in the face of stressors and climate change, especially 

in areas closest to communities and where there are high concentrations of assets and values 

important to people. Management approaches are adjusted for scenery and recreation settings to 

integrate with restoration activities at a landscape scale and address adapting sites and 

infrastructure to the needs of shifting demographics, budgets, and climate change. Specifically, 

the revised forest plan strives to streamline and simplify standards and guidelines to allow for 

increasing the pace and scale of restoration projects designed to reduce the risks associated with 

large, high-intensity wildfires, drought, insect outbreaks, and climate change. Standards and 

guidelines also strive to improve watershed conditions within the community wildfire protection 

zone and the general wildfire protection zone while providing for overall species diversity and the 

persistence of at-risk species, supporting recovery of federally listed species, and improving 

recreation sustainability.

The revised forest plan retains much of the direction from the existing forest plan; however, the 

revised forest plan differs from the existing plan in a number of fundamental ways that are aimed 

at allowing forest management to be more adaptable over time and to be able to adjust to sitespecific conditions. Some concerns raised during the public scoping comment period as well as 

those received on the draft plan were incorporated into the revised plan, either by modifying 

existing language or by adding new language. The following sections describe how alternative Bmodified responds to each of the revision topics.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

32

Revision Topic 1: Wildland Fire Management

Strategic Fire Management Zones

Alternative B-modified was created to correct errors to highly valued resources and assets 

(HVRAs) and make adjustments to the potential wildland fire operational delineation units 

(PODs), both variables used in the wildland fire risk assessment. The changes in HVRAs 

included correcting data errors in the asset HVRAs, constraining the California Spotted Owl 

HVRA, removing the northern goshawk HVRA, and removing the visual resource HVRA. POD 

boundaries were remapped to include contiguous areas of low-elevation sagebrush. POD-level 

adjustments were made to assign the final zone classification to general protection rather than 

restoration or maintenance (see supporting document, Strategic Fire Management Zones, FEIS 

updates in the project file).

Direction in the revised forest plan would replace the current two distance-based land allocations 

in the wildland-urban intermix and the remaining areas that are not wildland-urban intermix with 

four management areas based on a fire risk analysis consistent with the National Cohesive Fire 

Strategy using the modifications mentioned above (see chapter 3, “Wildland Fire Management” 

section for more information and volume 3 for maps of the strategic fire management zones). 

• The Community Wildfire Protection Zone would replace the wildland-urban intermix 

defense zone of the current plan (alternative A) and includes larger geographic areas where 

wildfire would likely threaten communities. This zone is based on modeling potential 

spread and intensity of wildfires that have a very high likelihood of burning into and

negatively impacting communities and community assets. Due to variations in the potential 

of fire, this zone is irregular in shape unlike the uniform shape of the wildland-urban 

intermix defense zone of the current plan. The forest plan direction emphasizes active 

management using thinning and prescribed fire to reduce fuels within this zone. Most 

wildfires would be actively suppressed to protect communities and assets, although in some 

instances, wildfires may be managed to meet resource objectives if environmental and fuel 

conditions allow and when it could be done in a safe manner. Environmental conditions 

consist of a combination of temperature, relative humidity, wind speed and direction, and 

airmass stability. These factors influence vegetation moisture and fire behavior and are 

determined annually during the pre-planning phase of fire management. Revised plan 

direction identifies community buffers in close proximity to structures where fuel 

conditions, snags, and logs would be managed to facilitate safe wildfire operations.

• The General Wildfire Protection Zone would replace the wildland-urban intermix threat 

zone of the current plan; it is irregular in shape, covering a larger area. This zone is based 

on modeling potential spread and intensity of wildfires that have a very high likelihood of 

burning toward and negatively impacting communities and assets as well as negatively 

impacting natural resources in the zone. The revised forest plan direction emphasizes active 

fuel reduction treatments along ridgetops, roads, and other natural and manmade features 

that can serve as strategic anchor points for larger prescribed burns and to create areas of 

low fuel that can be used to manage wildfires. Due to the high likelihood of wildfire 

occurring in this zone and possibly spreading into the community wildfire protection zone, 

wildfires would most often be suppressed to reduce the threat to communities and assets. In 

some instances, wildfires could be managed to meet resource objectives if environmental 

and fuel conditions allow and when it could be done in a safe manner. Environmental 

conditions consist of a combination of temperature, relative humidity, wind speed and 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

33

direction, and airmass stability. These factors influence vegetation moisture and fire 

behavior and are determined annually during the pre-planning phase of fire management.

• The Wildfire Restoration Zone would be a new zone that identifies areas with low to 

moderate risk for communities and structures and other resource values. This zone is based 

on modeling potential spread and intensity of wildfires that can pose a mix of positive and 

negative effects to resources and some isolated assets. Thinning or prescribed burning may 

be needed before wildfires can safely be managed to meet resource benefits. Revised plan 

direction emphasizes active fuels management treatments in strategic locations to enable 

larger prescribed burns and to aid wildfire management that focuses on restoring fire to the 

ecosystem. Many wildfires in this zone would be managed to meet resource objectives 

under specific environmental and fuel conditions and when it could be done in a safe 

manner, although in some instances wildfires may be suppressed. Environmental conditions 

consist of a combination of temperature, relative humidity, wind speed and direction, and 

airmass stability. These factors influence vegetation moisture and fire behavior and are 

determined annually during the pre-planning phase of fire management.

• The Wildfire Maintenance Zone would be a new zone that identifies areas with very low 

risk. This zone is based on modeling potential spread and intensity of wildfires that pose 

mostly a positive effect to resources. The wildfire maintenance zone is typically in the 

higher elevations, wilderness, and remote areas where mechanical treatments are often not a 

management options, thus restoring the role of fire is important to achieve ecological 

sustainability. Most wildfires in this zone would be managed to meet resource objectives 

under specific environmental and fuel conditions and when it could be done in a safe 

manner. Environmental conditions consist of a combination of temperature, relative 

humidity, wind speed and direction, and airmass stability. These factors influence 

vegetation moisture and fire behavior and are determined annually during the pre-planning 

phase of fire management. Prescribed burning would be used here where it increases the 

opportunity to manage wildfires and restore fire-adapted ecosystems.

Managing Wildfire to Meet Resource Objectives

Revised forest plan direction would provide desired conditions and resource objectives that allow 

unplanned wildfire starts to be managed to meet resource objectives when it is safe to do so 

across the national forest. The conditions and opportunities to manage wildfires would vary by 

strategic fire management zone and plan direction would emphasize designing projects to reduce 

fuels in strategic locations to increase opportunities to manage unplanned wildfire starts in this 

way.

Smoke and Air Quality

Revised forest plan direction for prescribed fire and managing wildfires to meet resource 

objectives would emphasize considering the impacts of smoke locally and regionally.

Revision Topic 2: Ecological Integrity

Terrestrial Ecosystems

Ecosystem Resilience and Adaptation to Climate Change

Revised forest plan direction would incorporate the concepts of ecological restoration expressed 

in recent scientific publications such as “An Ecosystem Management Strategy for Sierran MixedConifer Forests” (North, Stine, O’Hara, et al. 2009) and “Managing Sierra Nevada Forests” 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

34

(North 2012b). The revised plan creates a management framework that allows an increase in the

amount of restoration treatments using thinning, prescribed fire, and wildfires managed to meet 

resource objectives to make progress toward desired conditions across the landscape.

Revised plan direction would emphasize mechanical thinning and prescribed burning around 

communities and recreation areas and other forested areas. The revised plan increases emphasis on 

restoration of sagebrush ecosystems, especially to benefit the greater sage-grouse as described for “Atrisk Species” on page 29.

Revised forest plan direction emphasizes treating along key roads and ridges and connecting natural 

openings like rock outcrops that can make it easier to implement larger prescribed burns and manage or 

suppress fires. Treatments would focus on drier sites near the roads and ridges where restoration would 

move vegetation toward desired conditions.

To address climate change, the revised forest plan includes desired conditions and direction for 

improving resilience to climate change in all vegetation types. In subalpine and alpine systems there is 

additional direction that focuses on the unique threats that these usually long-lived and slow-growing 

ecosystems (such as bristlecone pine) face as temperature and precipitation patterns change. The 

revised plan includes direction to manage for increased risk of insects and diseases and changed fire 

patterns and cycles in these ecosystems.

The revised forest plan added desired conditions for old forests, including the desired densities of 

large trees and large snags, and the desired proportion of the landscape that should be in old forest 

conditions. They include direction to increase the resilience of old forests and large or old trees to 

drought, climate change, and large, high-intensity wildfires, which acknowledges that the 

variation of forest types requires some flexibility in determining the best approach to improve 

resilience on the ground. 

Complex Early Seral Habitat

The revised forest plan would include plan components to provide for key characteristics that are 

important to the ecological integrity of complex early-seral habitats after large fires or in large 

areas where trees have been killed by drought, insects, pathogens, wind or other events. This 

includes desired conditions for complex habitat characteristics, wide-spread distribution of snags, 

logs, and live trees, while considering the need for other resource objectives such as hazard tree 

removal, reforestation, and strategic fuel treatments.

Wildlife and Plant Habitat Diversity

The revised forest plan adopts the approach to species management of providing for ecological 

diversity and ecological integrity of habitat as the primary means to ensure the persistence of 

most species. Like the existing plan, the revised forest plan contributes to the recovery of 

federally listed threatened and endangered species and does not jeopardize proposed or candidate 

species, including the incorporation of relevant provisions of the “Draft Interim 

Recommendations for the Management of California Spotted Owl Habitat on National Forest 

System Lands” (USDA Forest Service 2015c) in the form of plan components. 

Proposed objectives moderately increase restoration treatments to trend terrestrial habitat toward

the desired conditions at a moderate pace. There is an increased emphasis on restoring fire as an 

ecosystem process in fire-adapted ecosystems with frequent fire-return intervals (in ponderosa 

and Jeffrey pine, and mixed conifer stands). Additional desired conditions for vegetation provides 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

35

for increased habitat heterogeneity for multiple species at both the fine scale as well as at 

landscape scales. Specific desired conditions and guidelines for individual vegetation types, old 

forest, and sagebrush provide ecological integrity of habitat for multiple species. As a change 

from the draft plan, revised plan components have been included for invasive species that set 

standards and guidelines and establish goals to address working with other agencies, Tribes, and 

researchers.

Aquatic and Riparian Ecosystems

The revised forest plan identifies how the water, watershed, riparian conservation area, and 

conservation watershed direction are integrated and how the use of these components; restoration 

efforts; and monitoring provide an overall aquatic and riparian strategy for the Inyo National 

Forest. These elements work together to achieve desired conditions across the plan area.

Riparian Conservation Areas

Riparian conservation areas are designed to protect, restore, or enhance water quality and the 

ecological health and function of aquatic and riparian ecosystems and associated resources. These 

management area designations were based on the 2004 Sierra Nevada Forest Plan Amendment 

and the revised plan direction for riparian conservation areas is nearly identical to that contained in 

the existing plan, except for the following changes. The revised plan:

• Streamlines and consolidates direction that is similar in nature resulting in fewer plan 

components;

• Removes direction that repeats laws, regulations, or policies; 

• Drops the term “riparian conservation objectives” because of the potential for confusion 

with plan component “objectives;” and

• Modifies direction to allow prescribed burn ignitions and, where necessary, mechanical and 

hand treatments to restore ecological integrity and improve the resilience of riparian 

ecosystems to fire, drought, and climate change.

Conservation Watersheds

Management of conservation watersheds emphasizes long-term prioritization for watershed 

maintenance and restoration to provide for persistence of species of conservation concern. 

Conservation watersheds are intended to be a network of watersheds that have been determined to 

have a functioning or functioning at-risk rating based on the Watershed Condition Framework; 

provide for connectivity and refugia for species of conservation concern; and provide high quality 

water for beneficial uses downstream. In conservation watersheds, long-term restoration and 

maintenance may occur over multiple planning cycles. 

Considering public comments, best available science, relevant approaches on other national 

forests, and other species-specific conservation measures, we are removing management of 

current critical aquatic refuges and using conservation watersheds to reflect watersheds with a 

diversity of species of conservation concern. Even though critical aquatic refuges are no longer 

included in the revised forest plan, at-risk species will be managed either through plan direction 

or through policy, law, and regulations, including species conservation and recovery plans. 

Conservation watersheds benefit species found in them, providing better resilience and habitat 

connectivity in the face of large-scale disturbance.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

36

There are many benefits of using conservation watersheds. Critical aquatic refuges sought to 

protect remnant species populations, and while important, our goal is to ensure species 

persistence, which could best be accomplished by ensuring habitat resiliency in the face of largescale unpredictable events. Conservation watersheds provide well-distributed refugia for more 

species, and also create suitable ecological conditions across larger landscapes. Restoration goals 

were not explicit in critical aquatic refuges but they are explicit in conservation watersheds. 

Finally, developing a network of refugia among subbasins and establishing connectivity is a goal 

in the design of conservation watersheds.

Priority Watersheds

Priority watersheds are a short-term, geographically focused approach to restore all habitat types. 

Priority watersheds use restoration projects that could be completed within a 5- to 7-year period. 

Once completed, Inyo staff may shift restoration efforts to a new priority watershed. Priority 

watersheds may be designated within conservation watersheds to maintain or improve conditions.

Watershed Resilience to Climate Change

The desired conditions for aquatic and riparian ecosystems in the revised forest plan recognizes 

changes in temperature and precipitation related to climate change and other climate stressors on 

aquatic systems. Desired conditions are for restored vegetation conditions within watersheds, 

which in turn improves the quantity of water available to improve aquatic systems and to be 

available for other uses. Revised forest plan direction emphasizes improving watershed resilience 

to wildfire and climate change by treating vegetation and reducing fuels over larger areas to lower 

the intensity of wildfires. Restoration emphasizes thinning to reduce the effects of past 

management that has resulted in very dense forests, and mitigating impacts from unmaintained 

roads when they impair watershed function.

At-risk Species

The 2012 Planning Rule defines two categories for at-risk species: (1) species that are federally 

recognized threatened, endangered, proposed, and candidate species; and (2) species of 

conservation concern. Species of conservation concern are native, are known to occur in the plan 

area, and are species with a substantial concern for their capability to persist over the long term in 

the plan area. The 2012 Planning Rule requires plan components to provide the ecological 

conditions necessary to contribute to the recovery of federally listed threatened and endangered 

species, conserve proposed and candidate species, and maintain a viable population of each 

species of conservation concern within the plan area.

As part of the plan revision process, coarse-filter plan components such as desired conditions 

were developed that describe the desired outcomes and conditions for terrestrial vegetation, 

riparian habitats and features, and aquatic habitats and features within the Inyo National Forest 

plan area. For most at-risk species, meeting and maintaining these desired conditions and 

applying other standards or guidelines help provide the habitat and key ecological conditions to 

provide for their persistence and viability within the plan area. For a few species, additional 

species-specific plan components (desired conditions, standards, guidelines, and goals) were 

developed to better provide the habitats and key ecological conditions for persistence and 

viability within the plan area. This includes components for all “at-risk species.”

Based on public comment and more thorough analysis of best available science, the Regional 

Forester reevaluated the species of conservation concern list. Some species were added to the list 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

37

while other species were removed from the Regional Forester’s 2016 list. The latter was due to 

reevaluation of species occurrence in the plan area and the best available scientific information 

determined to be insufficient information to have substantial concern for the species capability to 

persist over the long term in the plan area. Species the Regional Forester added to the list include: 

• Pacific fisher (Pekania pennant)

• California spotted owl (Strix occidentalis occidentalis)

• great gray owl (Strix nebulosa)

• Mt. Pinos sooty grouse (Dendragapus fuliginosus howardi)

• dune horsebrush (Tetradymia tetrameres)

• many-flowered thelypodium (Thelypodium milleflorum)

• rabbit-ear rockcress (Boechera pendulina)

• Virgate halimolobos (Transberingia bursifolia ssp. virgata)

The species removed from the previous list include: 

• Fringed myotis bat (Myotis thysanodes vespertinus), 

• Townsend's big-eared bat (Corynorhinus townsendii townsendii), 

• American peregrine falcon (Falco peregrinus anatum), 

• Sierra skipper (Hesperia miriamae), 

• White Mountains skipper (Hesperia miriamae longaevicola), 

• Atronis fritillary (Speyeria mormonia obsidiana), 

• Denning's cryptic caddisfly (Cryptochia denningi), 

• California sallfly (Sweltsa resima)

• Coyote gilia (Alicia triodon)

• Hidden rockcress (Boechera evadens)

• Alpine slender buckwheat (Eriogonum microthecum var. alpinum)

• Lake Tahoe serpentweed (Tonestus eximius)

The complete list of species of conservation concern identified by the Regional Forester for 

which the revised forest plan direction has been developed is described in the “Wildlife, Fish and 

Plants” section and in the rationale documents for animals and plants (USDA Forest Service

2018a, 2018b), including the reasons species were added or removed from the 2016 list. 

Bi-State Greater Sage-Grouse 

Species-specific plan direction is added for the bi-state greater sage-grouse on the Inyo National 

Forest. The proposed plan direction is based on the existing “Inyo National Forest Sage-Grouse 

Interim Management Policy (USDA Forest Service 2012c)” and, where appropriate, additional 

management direction has been developed consistent with the “Humboldt-Toiyabe National 

Forest Greater Sage Grouse Bi-State Distinct Population Segment Forest Plan Amendment.” The 

revised forest plan also includes management direction and emphasizes management actions that 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

38

are consistent with the “Bi-State Action Plan: Past, Present, and Future Actions for the 

Conservation of the Greater Sage-Grouse, Bi-State Distinct Population Segment.”

California Spotted Owl 

Species-specific plan direction for California spotted owl in the current plan provides for 300-

acre protected activity centers designated around territorial locations intended to provide 

sufficient habitat to support nesting owls. This alternative replaces home range core areas with an 

one thousand acre circular territory surrounding the activity center to provide sufficient foraging 

and roosting habitat to support the home range needs of California spotted owls. 

Great Gray Owl

Great gray owl is known to forage on the Inyo National Forest but there are no known nest sites. 

Great gray owl is a species of conservation concern on the plan area, but there are no speciesspecific plan components. There is a species-specific potential management approach to conduct 

additional surveys using established protocols to follow up reliable sightings of the owl.

Sierra Nevada Bighorn Sheep and Nelson Desert Bighorn Sheep

The revised plan direction is the same as the draft plan with clarifications related to disease risk 

from domestic livestock. The clarifications include: direction for continued use of a risk 

assessment approach, added direction to assess disease risk from recreational pack goats, and 

added direction to evaluate recreation impacts where potential conflicts to Sierra Nevada bighorn 

sheep are identified.

Yosemite Toad 

Forestwide plan direction for at-risk species provides protection for Yosemite toad. 

Rangeland Livestock Grazing

Forestwide grazing plan components are incorporated in the revised forest plan. These plan 

components are not changing from the 1988 Land and Resource Management Plan, Forest Plan 

Amendment 6 Forestwide Range Utilization Standards. Additional specifics of how the range 

utilization standards are determined can be found in appendix E of this document.

Revision Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation

During public comments on the draft environmental impact statement, the public emphasized the 

alternatives (alternatives B, C, and D) for sustainable recreation were insufficient, difficult to 

understand, and unclear as to what effect the direction would have on resources and uses. Some 

public comments suggested a zone approach to manage recreation and support sustainable use. 

We developed alternative B-modified to respond to the many comments we received from the 

public. 

In alternative B-modified, the concept of recreation places in alternatives B, C, and D is replaced 

by a zone concept and incorporates the recreation opportunity spectrum. The result is a 

management approach that incorporates three different zones, which span a continuum from areas 

of more concentrated recreation to areas of remote, less-concentrated, low-density recreation. 

This approach focuses management where it is most intensely needed, and manages recreation 

differently from one place to another, based on a zone’s particular resource needs. Within these 

zones, the landscapes would be managed for sustainable, balanced, multiple uses rather than for 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

39

specific sites or places for specific types of use. This alternative provides a framework for future 

management actions with regards to recreation management and resource protection and works 

toward a sustainable balance among the three spheres of environmental, social, and economic 

conditions.

The recreation management zones are:

Destination Recreation Area – This zone provides the most developed recreation areas in the 

national forest. The public will find high-densities of recreation users with a variety of activities 

available. These areas emphasize facilities such as roads, parking lots, and restrooms. The 

recreation opportunity spectrum settings here are primarily roaded natural with some semiprimitive motorized and semi-primitive nonmotorized classes.

General Recreation Area – Multiple uses (beyond recreation) are most evident in this zone. 

These areas are working landscapes where fuelwood gathering, vegetation management, 

livestock grazing, electrical transmission infrastructure, geothermal, and mining may occur. 

Some landscapes may or will be modified to meet social, economic, and ecological objectives. 

The recreation opportunity spectrum settings are primarily rural, with a mix of semi-primitive 

motorized and semi-primitive nonmotorized classes.

Challenging, Backroad Recreation Area – This zone provides expanses of undeveloped 

landscapes suited for dispersed recreation. These are natural landscapes with few amenities, 

limited management, low visitor use, low density of visitors, and limited Forest Service 

presence. Motorized and nonmotorized recreation is often challenging due to terrain, and few 

roads and trails. The recreation opportunity spectrum settings are semi-primitive motorized, 

semi-primitive nonmotorized, and roaded natural classes to support remote recreation with little 

development. 

Scenery

The revised forest plan direction identifies scenic integrity objectives for the plan areas using the 

Scenery Management System. Scenery setting management would be integrated with ecological 

integrity and restoration to improve scenic character stability within the desired landscape 

character. The revised forest plan includes plan components that require desired scenic integrity 

objectives be considered in the design of restoration projects.

Recommended Wilderness

Alternative B-modified would make a preliminary administrative recommendation to include four 

additional areas in the National Wilderness Preservation System (South Sierra; Piper Mountain 

Addition; White Mountains East; and White Mountains West). These are also referred to as 

“recommended wilderness areas.” All four areas are adjacent to existing designated wilderness 

area boundaries and total 37,039 acres. 

Pacific Crest Trail

The revised forest plan would create a management area allocation for the Pacific Crest National 

Scenic Trail by defining a corridor of the visual foreground landscape zone (up to one-half mile 

from the centerline of the trail where visibility is not obscured by terrain) as defined by the 

Scenery Management System. Management area-specific desired conditions, standards, and 

guidelines and a management approach would be included to protect the nature, purposes, and 

resource values of the trail from degradation by activities and development.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

40

Mono Basin National Forest Scenic Area

The revised forest plan includes desired conditions for the Mono Basin National Forest Scenic 

Area. These components were carried forward from the current area’s comprehensive 

management plan into the revised forest plan and do not represent a change in plan direction.

Alternative C

Alternative C emphasizes wilderness values and a passive management approach to restore fire as 

an ecosystem process, primarily using prescribed fire and natural disturbance processes (such as 

managing wildfire for resource benefit) to achieve landscape-level desired conditions.

Alternative C was developed to address concerns about whether the forest plan provides adequate 

short-term protections for wildlife habitat. Like alternative B, alternative C includes plan 

components for conserving key characteristics associated with the ecological integrity for postfire, complex early seral habitat. Also, additional critical aquatic refuges are identified around 

areas of high aquatic species diversity.

Revision Topic 1: Wildland Fire Management

Strategic Fire Management Zones

In alternative C, the fire management zones consist of a combination of existing plan direction 

and new zones created from the results of the wildland fire risk assessment. The distance-based 

wildland-urban intermix defense zone around communities would remain the same as in the 

existing plan. The maintenance zone is created using the same risk-based methodology used to 

create the wildfire maintenance zones as alternative B-modified and D. The general wildfire zone 

consists of the restoration zone, general wildfire protection zones, and portions of the community 

wildfire protection zone. The modifications in alternative B-modified to correct errors to highly 

valued resources and assets (HVRAs) and adjust potential wildland fire operational delineation 

units (PODs) were also applied when creating zones for Alternative C (see chapter 3, “Wildland 

Fire Management” section for more information and volume 3 for maps of the strategic fire 

management zones).

• Similar to the existing plan, the Wildland-Urban Intermix Defense Zone, closest to 

communities, would remain a high priority for hazardous fuel reduction treatment to reduce 

the intensity of wildfires in these areas. Maintenance treatments using prescribed fire 

instead of mechanical treatments would be the preferred management method whenever 

possible.

• The General Wildfire Zone consists of the wildfire restoration zone, general wildfire 

protection zone, and portions of the community wildfire protection zone. Wildfires that 

occur in the general wildfire zone where fuel conditions are close to desired conditions may 

be managed to meet resource objectives when environmental and fuel conditions allow and 

when it could be done in a safe manner. Environmental conditions consist of a combination 

of temperature, relative humidity, wind speed and direction, and airmass stability. These 

factors influence vegetation moisture and fire behavior and are determined annually during 

the pre-planning phase of fire management. There would be less strategic treatment using 

mechanical methods as a precursor to larger prescribed burns.

• Similar to alternatives B, B-modified, and D, the Wildfire Maintenance Zone in alternative 

C identifies areas with very low risk based on modeling potential spread and intensity of 

wildfires that pose mostly a positive effect to resources. In this zone, restoring the role of 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

41

fire is important to achieve ecological sustainability and most wildfires in this zone would 

be managed to meet resource objectives under specific environmental and fuel conditions 

and when it could be done in a safe manner. Environmental conditions consist of a 

combination of temperature, relative humidity, wind speed and direction, and airmass 

stability. These factors influence vegetation moisture and fire behavior and are determined 

annually during the pre-planning phase of fire management. Prescribed burning would be 

used here where it increases the opportunity to manage wildfires and restore fire-adapted 

ecosystems.

Managing Wildfire to Meet Resource Objectives

Like alternatives B, B-modified, and D, alternative C would provide desired conditions and resource 

objectives that allow wildfires to be managed to meet resource objectives when conditions allow 

and it is safe to do so across the forest. The conditions and opportunities to manage wildfires 

would vary by strategic fire management zone, and plan direction for the wildfire maintenance 

zone would be the same as for alternatives B and B-modified. Species-specific plan direction to 

provide for habitat conditions for certain wildlife species would override direction for strategic 

treatments designed to increase the opportunity to manage wildfires to meet resource objectives.

Smoke and Air Quality

Alternative C would include the same guidance for designing projects to minimize the impacts of 

smoke on communities as alternatives B and B-modified.

Revision Topic 2: Ecological Integrity

Terrestrial Ecosystems

Ecosystem Resilience and Adaptation to Climate Change

Alternative C is designed to manage the forest landscape to minimize short-term impacts on 

habitats from management activities while accepting the risk of large high-intensity wildfires that 

could affect mature and old forests. Alternative C focuses vegetation and fuel reduction 

treatments within the wildland-urban intermix defense zone and seeks to restore vegetation 

desired conditions in the larger landscape with limited, strategic use of mechanical thinning and a 

heavier emphasis on the use of prescribed fire and wildfire managed primarily for resource 

objectives where safe and consistent with desired conditions. Alternative C would not use the 

focused landscapes approach described in alternatives B and D.

Like alternative B, alternative C adds desired conditions for old forests, including the desired 

densities of large trees and large snags, and the desired proportion of the landscape that should be 

in old forest conditions. It includes direction to increase the resilience of old forests and large or 

old trees important to wildlife habitats to drought, climate change, and large, high-intensity 

wildfires by restoring landscape heterogeneity that emulates patchy habitat that results from 

active, low- to mixed-severity wildfire.

Complex Early Seral Habitat

Like alternative B, alternative C would include plan components to provide key characteristics 

that contribute to the ecological integrity of complex early-seral habitats after large fires. 

However, alternative C would generally limit post-fire management to cutting burned trees that 

are a hazard to people and leaving them in place unless they pose a substantial hazard as downed 

logs. Direction in alternative C would vary from alternative B to leave most burned areas to 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

42

recover naturally with no direct management action (no planting), even after very large fires. 

Where possible, efforts to treat half of the burned areas with prescribed fire would be planned 10 

years after the initial fire to reduce accumulations of fuels and to maintain a frequent fire interval 

as a part of forest succession.

Wildlife and Plant Habitat Diversity

Desired conditions and other plan components for California spotted owl, Sierra marten, and 

Pacific fisher habitat would result in landscape conditions in the upper end of the moist mixedconifer vegetation desired conditions. This is in contrast to alternatives B and D which would 

strive for desired conditions within the natural range of variation for all habitat types. Prescribed 

burning would be the preferred method of treatment.

Aquatic and Riparian Ecosystems

Proposed direction for riparian conservation areas and critical aquatic refuges is nearly identical 

to that contained in alternative B, with the following changes.

Critical Aquatic Refuges

Alternative C would add 8 new critical aquatic refuges on the Inyo National Forest. Management 

direction would be the same as in alternative B.

Watershed Resilience to Climate Change

Alternative C would differ from alternative B because it would not modify current direction to 

allow prescribed fire ignitions and, where necessary, mechanical treatments within riparian 

conservation areas. Alternative C would allow prescribed fire in riparian areas where it was 

historically prevalent to restore desired fuel conditions, to the extent it could occur with limited or 

no mechanical preparation.

At-risk Species

Alternative C emphasizes reducing the short-term consequences of restoration treatments to 

wildlife. For wildlife associated with old forests, as described in revision topic 1, it emphasizes 

retaining larger sized trees, minimizing reductions in forests with existing dense canopy cover, 

and retaining habitat elements such as high densities of large snags and downed logs, and 

retaining larger trees with cavities or deformities that can be used for nests or dens across the 

landscape.

Bi-State Greater Sage-Grouse 

Species-specific plan direction would be added for the bi-state greater sage-grouse the same as 

alternative B, except the objective for acres of sage-grouse habitat maintained, improved, or 

restored would be increased slightly. This increase is due to less competition for funding 

resources with other ecological restoration projects as a result of increased restrictions on 

mechanical thinning.

Great Gray Owl

Direction for great gray owl is the same as alternative B-modified.

Sierra Nevada Bighorn Sheep and Nelson Desert Bighorn Sheep

Direction under alternative C would be the same as alternative B-modified.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

43

Yosemite Toad 

Species-specific proposed plan direction in alternative C for Yosemite toad would be the same as 

alternative A.

Willow Flycatcher

Alternative C would place an emphasis on maintaining and restoring nesting habitat for willow 

flycatchers in the Mono Lake Basin. 

Revision Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation

The range of recreation opportunity spectrum classes would shift with larger areas allocated to 

primitive and semi-primitive nonmotorized recreation settings and less area allocated to 

motorized recreation settings in alternative C. 

Scenery

Alternative C uses the same Scenery Management System as described in alternatives B and Bmodified, the draft forest plan and the revised forest plan. 

Recommended Wilderness

Alternative C would make a preliminary administrative recommendation to include 24 areas 

totaling 315,531 acres that would be recommended into the National Wilderness Preservation 

System. This would include nine areas (70,278 acres) adjacent to existing designated wilderness 

and 15 areas (245,253 acres) that are not.

Pacific Crest Trail

Alternative C would create a management area allocation for the Pacific Crest National Scenic 

Trail by defining a corridor that includes the same visible foreground (up to one-half mile of 

centerline of the trail where visibility is not obscured by terrain) of alternative B and also includes 

lands inventoried as “Scenic Attractiveness A” in the Scenery Management System within the 

trail’s viewshed. 

Alternative D

Alternative D includes an emphasis on an increased pace and scale of restoration in response to 

the issues of improving resilience to fire, drought, climate change, insects, and diseases, while 

enhancing economic and social sustainability. Like the draft forest plan, it emphasizes long-term 

habitat conservation, accepting that short-term impacts to species associated with dense forests 

would be offset by reducing the risk of habitat damage or loss from large high-intensity wildfire. 

However, alternative D eliminates diameter limits, and expands operating periods to allow more 

active management to move vegetation toward desired conditions more than the draft forest plan. 

It emphasizes additional mechanical treatment on strategic ridgetops, roads, and other natural and 

manmade features, and adjacent areas to increase the amount of landscape-scale prescribed 

burning to restore fire in the ecosystem.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

44

Revision Topic 1: Fire Management

Strategic Fire Management Zones

Alternative D uses the same strategic fire management zones and similar direction as the draft 

and revised forest plans of alternatives B and B-modified. The modifications in alternative Bmodified to correct errors to highly valued resources and assets (HVRAs) and adjust potential 

wildland fire operational delineation units (PODs) were also applied when creating zones for 

alternative D. (See chapter 3, “Wildland Fire Management” section for more information and 

volume 3 for maps of the strategic fire management zones.) 

Managing Wildfire to Meet Resource Objectives

Alternative D uses the same approach as alternative B-modified to emphasize an increased 

management of wildfires to meet resource objectives when it is safe to do so. More areas are 

designed and treated using mechanical treatments and prescribed burning to create more 

opportunities to manage wildfires to meet resource objectives safely.

Smoke and Air Quality

The emphasis for managing wildfires to meet resource objectives would consider the impacts of 

smoke locally and regionally as in alternative B-modified. However, the additional opportunity 

for pre-treating areas prior to prescribed burning and additional focus areas treated to trend 

toward desired vegetation conditions would reduce the potential for community smoke impacts 

from uncharacteristic wildfire.

Revision Topic 2: Ecological Integrity

Terrestrial Ecosystems

Ecosystem Resilience and Adaptation to Climate Change 

Alternative D is very similar to the draft forest plan (alternatives B and alternative B-modified) 

except it doubles the pace and scale of restoration to have a greater likelihood of reducing the impact 

of future high-intensity wildfires. It uses the same landscape strategies and approaches as the draft 

forest plan with the following changes:

• Alternative D emphasizes the strategic use of mechanical treatments where it is physically 

and economically feasible to facilitate greater management of wildfire to a greater extent 

than the draft forest plan—both the active use in prescribed burning at greater landscape 

scales as well as through managing wildfires to meet resource objectives when conditions 

allow and when it can be done in a safe manner. There is more emphasis on strategic 

treatment of ridgetops and along strategic road locations in the wildfire restoration zone 

that would facilitate more landscape prescribed burning and serve as anchor points for 

managing wildfires to meet resource objectives.

• On the Inyo National Forest, there would be more areas treated than in the draft plan. 

• Like the draft forest plan, there would be more emphasis on providing variability within 

tree patches during treatments to increase heterogeneity and increasing resilience to 

drought. 

Alternative D would manage old forests the same as the draft forest plan, focusing on increasing 

the resilience of existing areas with old forest conditions and emphasizing landscapes that meet 

desired composition of seral stages and include old forest components throughout. 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

45

Alternative D retains similar direction as the draft forest plan for the management of burned areas 

following a large fire, except it increases the emphasis on salvage for economic return and 

reforestation of portions of large fires that burn at high severity. This includes desired conditions 

for reforestation when needed to address sustainability of forests given the length of time it could 

take to reestablish forests dominated by large and old trees with natural reforestation, forest 

connectivity, and species composition and seed sources considering climate change.

Complex Early Seral Habitat

Like the draft forest plan, alternative D would include plan components to provide for the key 

characteristics that provide for the ecological integrity of complex early seral habitats after large 

fires. This includes desired conditions for complex habitat characteristics, wide-spread 

distribution of snags, logs, and live trees while considering the need for other resource objectives 

such as hazard tree removal, reforestation, and strategic fuel treatments. Alternative D would 

emphasize economic recovery of burned forest while still contributing to desired conditions for 

this habitat.

Wildlife and Plant Habitat Diversity

Alternative D incorporates the same direction regarding at-risk species as the draft forest plan; 

however, plan direction emphasizes restoring enough area across the landscape to increase 

climate adaptation, and reduce the risk of large, high-intensity wildfires to important at-risk 

wildlife species habitat, while also continuing to manage a portion of the landscape as highquality habitat for at-risk species. This alternative accepts some short-term risk to species to 

manage more areas for vegetation desired conditions to provide for greater sustainability of 

habitats over time. Alternative D focuses on the long recovery time for habitats of many at-risk 

species and is designed to lessen the rate of habitats adversely affected by large high-intensity 

wildfires. Restoration treatments would occur at an increased level sufficient to trend terrestrial 

habitat toward the desired conditions at a moderate to high pace.

Aquatic and Riparian Ecosystems

Critical Aquatic Refuges

Alternative D includes the same direction for riparian conservation areas and critical aquatic refuges 

as the draft forest plan.

Watershed Resilience to Climate Change

Alternative D incorporates the same aquatic management strategy direction as the draft forest 

plan. Maintenance and restoration would occur on more roads due to the increased area of 

restoration treatments and increased stewardship opportunity. Restoration would emphasize 

reducing the legacy effects of past management that continue to degrade watershed function, 

especially reducing or eliminating sediment risks from roads and restoring hydrologic 

connectivity of habitat for amphibians and fish.

At-risk Species

Plan direction for species of conversation concern would be the same as the draft forest plan.

Bi-State Greater Sage-grouse 

Like the draft forest plan, species-specific plan direction is added for the Bi-state greater sagegrouse, except the objective for acres of sage-grouse habitat maintained, improved, or restored is 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

46

increased the same as alternative C. This increase is due to increased stewardship funding 

opportunities and an increase in landscape-scale restoration treatments overall.

California Spotted Owl 

This alternative is the same as alternative B-modified. 

Great Gray Owl

Direction for great gray owl in alternative D is the same as alternative B-modified.

Sierra Nevada Bighorn Sheep and Nelson Desert Bighorn Sheep

The direction for alternative D for Sierra Nevada and Nelson Desert bighorn sheep would be the 

same as alternative B-modified and alternative C.

Yosemite Toad 

The standards and guidelines that exclude livestock grazing within areas occupied by Yosemite 

toads during the breeding and rearing season, except where a site-specific management plan is 

developed would change to a new system to determine appropriate management strategies. In the 

new system, either a known Yosemite toad occupied site, designated critical habitat, or the results 

of an empirically derived occupancy probability model would be used in combination with 

meadow habitat conditions to guide a matrix of grazing management strategies. These strategies 

would range from no grazing to the current forestwide grazing standards in the existing forest 

plan.

Revision Topic 3: Sustainable Recreation and Designated Areas

Sustainable Recreation

In alternative D, the range of recreation opportunity spectrum classes would shift with fewer 

areas allocated to primitive and semi-primitive nonmotorized recreation settings and more area 

allocated to motorized recreation settings. Improvements in recreation settings would be 

associated with larger treatment areas to improve landscape resilience to fire and climate change 

rather than emphasizing treatments around individual sites and infrastructure.

Scenery

Alternative D uses the same Scenery Management System as described for the other plan revision 

alternatives.

Recommended Wilderness

Alternative D would not make any additional preliminary administrative recommendations to the 

National Wilderness Preservation System.

Pacific Crest Trail

Alternative D would create a management area allocation for the Pacific Crest National Scenic 

Trail by defining a corridor one-quarter mile from the centerline of the trail. The plan direction 

assigned to the corridor would be the same as the draft forest plan.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

47

Alternatives Considered

but Eliminated from Detailed Study

Federal agencies are required by the National Environmental Policy Act to rigorously explore and 

objectively evaluate reasonable alternatives and to briefly discuss the reasons for eliminating any

alternatives that were not developed in detail (40 CFR 1502.14). Public comments received 

during the plan revision process provided suggestions for the proposed revised plan. Some of

these suggestions may not have been part of identified needs for change, were duplicative of the 

alternatives considered in detail, or were determined to contain components that would cause 

unnecessary environmental harm.

A number of alternatives were considered, but dismissed from detailed consideration for reasons

as summarized in the following paragraphs.

Eliminated Alternative 1: Restore over half of the landscape 

within 10 to 15 years

An alternative was suggested that uses substantially more active vegetation management 

including thinning, selective harvest, and prescribed fire to restore forest resilience to fire, 

drought, insect and pathogen outbreaks, and climate change as quickly as possible. This 

alternative was not considered in detail because it would require more workforce and budget than 

is feasible for the agency given budgets received in recent years. More than half of the landscape 

on the Inyo National Forest is within special designated areas such as wilderness, monuments or 

wild and scenic river corridors that limit or prohibit the use of mechanical equipment. Another 25 

percent of the national forest has limitations on roaded access, such as inventoried roadless areas, 

which limit getting equipment into areas as well as making it difficult to transport staff or workers 

into these areas by motor vehicles. 

There are areas of particularly steep grades where restoration using equipment can be difficult as 

it must be designed to avoid causing unacceptable ecological damage due to accelerated erosion 

risks. There are other areas where sensitive ecological conditions and endangered species exist, 

which requires restraint and caution in how much treatment can occur and how quickly. Scientific 

knowledge is continuing to provide new insights into the biology of at-risk species in these 

forests and there is a concern about balancing rapid change in habitat from active management 

with changes in habitat that may occur without treatment in terms of the consequences to wildlife.

Another limitation to rapid restoration related to forest thinning is the capacity of industry to do 

the work and use materials. Currently there is a limited infrastructure to process the timber 

resulting from restoration efforts. If restoration outpaces infrastructure capacity, then the Forest 

Service costs increase and the agency’s capability to fund restoration will decrease. Therefore, 

there is a limitation on the capability of the Forest Service to restore forests that is directly related 

to the limited capacity of the industry infrastructure.

The alternatives being considered increase the use of prescribed fire over current levels and 

recognize there are limits imposed by air quality restrictions, current forest conditions and forest 

capacity and resources to conduct more prescribed burning. Smoke and its impact on the health of 

rural communities is also a concern and can be a limitation on the number and acres and timing of 

prescribed burning.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

48

One of the identified needs for plan revision is “to improve recreation facilities, settings, 

opportunities and access and their sustainability.” Although it is true that rapidly addressing 

landscape restoration will contribute toward long-term recreation sustainability, during the time of 

rapid restoration there would be a great impact on recreation and the recreation experience, 

whether it would be from more smoke or fire on the landscape from prescribed fire, more crews 

and big trucks, or closed and restricted access to campgrounds while tree cutting and equipment 

operations are going on. The proposed level of restoration would limit the ability to meet the 

purpose and need for recreation as access and recreation opportunity would be substantially 

diminished during the plan period.

Alternatives B and D increase the amount of restoration but the amount would still affect only 

about 20 to 40 percent of the treatable portions of the national forest per decade. The amount of 

restoration accomplished by managing wildfires to meet resource benefits would increase this, 

but it is entirely dependent upon actual wildfires that can only be estimated and not planned. It is 

expected that this pace may adjust in the future if capacity for active management increases.

Eliminated Alternative 2: Include all areas identified by the public 

as recommendations for additions to the National Wilderness 

Preservation System

The responsible official and interdisciplinary team considered an alternative that would 

recommend as wilderness all areas evaluated, or identified by the public. This alternative was 

dismissed from detailed analysis for two reasons:

1. The Forest Supervisor determined that it would be impracticable to manage such a vast 

wilderness area.

2. The impacts to other uses of the lands would be greater than the benefits provided by the 

additional wilderness area. Specifically, recommending all evaluated areas as wilderness 

would conflict with the identified need for change described in Revision Topic 3, “There 

is a need to provide sustainable and diverse recreation opportunities that consider 

population demographic characteristics; reflect desires of local communities, avoid 

overcrowding and use conflicts, and minimize resource damage; protect cultural 

resources.”

Detailed rationale addressing each evaluated or publically identified wilderness polygon is in 

appendix B. The following discussion addresses the overarching reasons that the Forest 

Supervisor dismissed from further consideration an alternative that would include all of these 

polygons.

Context

Currently, 46 percent of the Inyo National Forest is in designated wilderness. Recommending 

additional wilderness areas in the revised plan would prohibit and further geographically 

constrain certain management activities and uses. Specifically, the Wilderness Act states that, 

“there shall be no temporary road, no use of motor vehicles, motorized equipment or motorboats, 

no landing of aircraft, no other form of mechanical transport, and no structure or installation 

within any such area.” 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

49

Background

Various groups and individuals submitted feedback specific to the wilderness inventory and 

evaluation processes, suggesting additional areas that should be included in the preliminary 

administrative recommendations for additions to the National Wilderness Preservation System. 

These areas were considered during the inventory and evaluation following the 2012 Planning 

Rule and associated implementation directives as described in appendix B. For more information, 

see Issue 6 in the Public Participation section of chapter 1.

The Forest Supervisor used the wilderness evaluation narratives and public input to identify 

which specific areas, or portions thereof, to carry forward into the draft environmental impact 

statement analysis in one or more alternatives as recommended wilderness. Although many areas 

suggested by the public were brought forward for analysis in alternatives B and C, not all lands 

included in the inventory or suggested by the public were analyzed in detail. Generally, areas not 

analyzed in detail:

• Lacked wilderness characteristics;

• Had substantially noticeable human impacts;

• Represented a departure from apparent naturalness due to improvements;

• Had pervasive impacts that would influence a visitor’s opportunity for solitude including 

pervasive sights and sounds from outside the area; or

• Were determined to be unmanageable to preserve their wilderness characteristics.

In particular, areas with motor vehicle designations from recent travel management decisions 

were considered but then excluded from polygon boundaries carried forward for analysis in the 

draft environmental impact statement. See appendix B for the full description of the inventory, 

evaluation, and analysis processes and findings.

What Wilderness Provides

Wilderness provides many benefits to those who enjoy recreating in these areas. The purpose of 

the Wilderness Act is, “to assure that an increasing population, accompanied by expanding 

settlement and growing mechanization, does not occupy and modify all areas within the United 

States and its possessions, leaving no lands designated for preservation and protection in their 

natural condition, ... to secure for the American people of present and future generations the 

benefits of an enduring resource of wilderness.” It defines wilderness areas as:

• where the earth and its community of life are untrammeled

• undeveloped Federal land retaining its primeval character and influence

• without permanent improvements or human habitation

• protected and managed so as to preserve its natural conditions

It specifically states that wilderness:

1. generally appears to have been affected primarily by the forces of nature, with the imprint 

of man's work substantially unnoticeable;

2. has outstanding opportunities for solitude or a primitive and unconfined type of 

recreation;

3. has at least five thousand acres of land or is of sufficient size as to make practicable its 

preservation and use in an unimpaired condition; and
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

50

4. may also contain ecological, geological, or other features of scientific, educational, 

scenic, or historical value.

Wilderness Management Challenges and Trade-offs

Education, Recreation Management, and Law Enforcement

The Wilderness Act specifies these lands, “shall be administered for the use and enjoyment of the 

American people in such manner as will leave them unimpaired for future use as wilderness, and 

so as to provide for the protection of these areas, the preservation of their wilderness character, 

and for the gathering and dissemination of information regarding their use and enjoyment as 

wilderness.” The Inyo National Forest currently has just two backcountry rangers to cover 

approximately 1 million acres of land. This limits the opportunity for visitor contact to inform, 

educate, and regulate activities, as appropriate. Additionally, with substantial acreage already 

allocated to wilderness, trail maintenance and development is challenging. It is especially difficult 

for forest staff to rebuild major damage to trails because of the lack of roaded access, and the 

inability to use motorized or mechanized equipment.

The Inyo National Forest already has a documented problem with motorized incursion into 

wilderness, based on law enforcement contact. The Inyo recorded 51 incidents of wilderness 

trespass with a motorized vehicle, and one with a bicycle, from 2010 through 2016. These 

incidents were recorded as “ongoing” meaning there was evidence of more than one occurrence 

of trespass at a particular site, such as tire tracks, or vandalized blocking installations. Much of 

this trespass occurs in areas that are within 100 feet of highways, or adjacent to towns and ski 

areas. In many cases, the wilderness trespass was unintentional—the entirety of wilderness 

boundaries can’t be marked, and users are often unaware of the location, existence, or rules of 

wilderness. 

Vegetation, Fire, and Wildlife Habitat Management

Wilderness designation does not preclude vegetation and fuels management, but it does make 

most of the usual management tools unavailable. Therefore, large-scale fuels treatments and 

forest habitat restoration activities would be significantly reduced, and timber production 

activities would not occur in areas recommended for wilderness. When wildfires start or burn into 

wilderness, again, the tools available to manage those fires are limited. Fire managers are able to 

work with these limitations, but they require a different approach from wildfire response in areas 

not recommended or designated as wilderness.

A major wildlife habitat management issue on the Inyo National Forest is pinyon pine 

encroachment on sage-grouse habitat. An existing agreement between the Forest Service and the 

Fish and Wildlife Service emphasizes conifer removal as an important management tool to restore 

sage-grouse habitat and avoid listing this species under the Endangered Species Act. Ongoing, 

large-scale management of conifer encroachment in sagebrush would be not be possible in 

recommended wilderness areas.

Several areas evaluated for wilderness, or proposed by the public, currently contain guzzlers—

artificial, human-built water sources for wildlife. There is a community of hunters and wildlife 

enthusiasts on the Inyo National Forest who maintain these as a way to support and increase 

animal populations. Guzzlers would have to be removed from designated wilderness areas, as 

they are an “imprint of man’s work.”
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

51

Other Uses and Considerations

Existing Wilderness

With nearly half of the acreage of the Inyo National Forest already in wilderness, the areas of the 

national forest that best fit the definition of wilderness are generally already designated as such. 

Appendix B shows the reasons that each polygon suggested was not recommended. In large part, 

the rationales there state that opportunities for solitude and primitive recreation are limited in the 

suggested polygons, mostly because they contain, or are adjacent to roads or motorized trails. 

Existing Transportation System

The table below depicts the mileage of system roads, motorized trails, and unauthorized routes in 

the polygons considered for wilderness in the four alternatives, and in the total wilderness 

inventory and evaluation. This alternative considered, but eliminated, would remove access to as 

many as 3 miles of system roads, 261 miles of motorized trails, and 294 miles of unauthorized 

routes. If all wilderness areas evaluated were recommended, 73 percent of the motorized trails on 

the Inyo National Forest would no longer be available.

Managing wilderness areas that previously contained many miles of motorized routes would be a 

major challenge. Additionally, the motorized use community, which has commented on this 

analysis, as well as on the Inyo National Forest’s 2009 Travel Management Plan have requested 

that we reevaluate unauthorized routes not added to the transportation system in the travel 

planning process. Wilderness recommendation would preclude the addition of these routes to the 

motorized road and trail systems. The Inyo National Forest provides a relatively unique 

opportunity for backcountry motorized recreation, much of which would no longer be available if 

all evaluated polygons were to be recommended as wilderness.

Special Uses and Facilities

Within the polygons evaluated but not recommended as wilderness, there are approximately 28 

facilities managed by the Los Angeles Department of Water and Power. Southern California 

Edison, Pacific Gas and Electric, U.S. Geological Survey, and other agencies and universities also 

manage facilities or conduct research in these polygons. These entities would no longer have 

driving access to their facilities and research sites if all suggested or evaluated polygons were to 

be recommended as wilderness. In some cases, the facilities and research projects would be 

unmanageable without motorized access.

Tribal Uses

Several Tribes commented on the wilderness evaluation, concerned about tribal uses that would 

no longer be possible if the polygons were to become recommended wilderness. Tribal members, 

and especially elders, access areas for hunting, gathering, and engaging in other heritage 

activities, by motor vehicle. Elders pass cultural heritage and knowledge of particular areas of the 

forest to younger generations. Many elders are not able to walk long distances, especially while 

carrying collected plants or animals. Additionally, some heritage activities may not be permissible 

if they leave an “imprint of man’s work” in recommended wilderness areas.

Grazing

Grazing is culturally important in the area of the Inyo National Forest and, according to Inyo 

County, it is also important to the local economy. Of the 52 grazing allotments on the Inyo 

National Forest, 45 have some portion within or touching the wilderness evaluation polygons. 

Grazing is not prohibited in wilderness, but the cost and difficulty of managing grazing is higher 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

52

in wilderness areas. Many local grazing operations are already marginal, and may not be 

economically viable with any additional expense. It is also more difficult for Forest Service staff 

to manage grazing allotments that are not accessible by motor vehicle, and where motorized and 

mechanized tools are not allowed. This may mean fewer visits to, less oversight of, and generally 

less management and maintenance on allotments once they are in recommended wilderness.

Specific Recreation Activities

If all evaluated areas were recommended as wilderness on the Inyo National Forest, two 

additional recreation activities could be affected: climbing and mountain biking. Fixed anchors 

are not allowed in wilderness, and the majority of the climbing community uses these. Mountain 

climbing is a major draw to the Bishop, California area, and a part of its identity. It provides 

substantial economic value through tourism and equipment provision.

Within wilderness evaluation polygons on the Inyo there are 151 miles of nonmotorized trails. 

These are generally open to mountain biking. However, bicycles are considered “mechanized” 

equipment, and therefore prohibited in wilderness areas. Mountain biking is less significant than 

climbing, in terms of community identity and economic value in the area of the Inyo National 

Forest, but it does still contribute to the recreation portfolio. The mountain biking and climbing 

communities have commented about the reduction in their opportunities if more areas of the 

forest were to be recommended wilderness.

Conclusion

Because of the management challenges, trade-offs, and use conflicts described above, the 

responsible official concluded that an alternative recommending all polygons evaluated as 

wilderness was not feasible, did not respond to a need for change, and should not be analyzed in 

detail.

Eliminated Alternative 3: Identify critical aquatic refuges around 

all areas of high aquatic species diversity

An alternative was suggested that identifies 15 areas of high aquatic species diversity on the Inyo 

National Forest and recommended these areas be delineated and managed as critical aquatic 

refuges. These areas were evaluated by staff and all but 7 areas were included in at least one 

alternative considered in detail. Areas not included were because they were either a proposed 

expansion that would not substantially increase the habitat protection of the existing critical 

aquatic refuges, were located primarily on lands owned or managed by others, or were already 

within watersheds that are a priority for maintenance or restoration. The evaluation of each area 

recommended for consideration as a critical aquatic refuge is included in the project record. Since 

these additional proposed critical aquatic refuges would not increase habitat protection, including 

all of them in an alternative would have substantially similar effects as alternative C and therefore 

adding them as part of an alternative was not necessary.

Eliminated Alternative 4: Evaluate an alternative that has minimal

active management and “let nature take its course”

An alternative was suggested that has minimal active management of vegetation and allows 

nature to take its course in shaping the vegetation and conditions in the national forest. It was 

suggested that wildfires would reduce built up fuels and regenerate forests while creating early 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

53

seral habitats for species that depend upon them. It was also suggested that natural mortality 

would thin weakened trees leaving more resources for the remaining trees and vegetation.

However, this type of “hands-off” approach is contrary to the best available science that 

recommends restoration efforts for many of the ecosystems that are outside their natural range of 

variation. Alternatives B, C, and D address long-term vegetation health in the desired condition 

statements of how the various vegetation types on the Inyo National Forest should look and 

function. Management action is necessary to trend these ecosystems toward the desired 

conditions and strengthen ecosystem resilience in the face of expected climate changes in the 

western United States.

This alternative also would not meet the requirements of the 2012 Planning Rule, which requires 

plans to be developed that are ecologically, socially, and economically sustainable. This 

alternative also would not achieve various aspects of the purpose and need. For example, this 

alternative would not: 

• improve ecosystem resilience to fire and climate change;

• decrease the threat of large, undesirable fires;

• increase the ability of forests to store and sequester carbon;

• improve ecological conditions for the California spotted owl and restore and maintaining 

greater sage-grouse habitat on the Inyo National Forest;

• support local economies by maintaining levels of forest product and biomass production 

that support an economically-viable forest products industry, and encourages local hiring; 

• support economic opportunities in tribal communities; incorporate traditional ecological 

knowledge; and increase collaboration with the agency to meet restoration goals; or

• improve recreation facilities or improve and protect scenic character.

Because this alternative is not in alignment with the best available science of the best methods of 

achieving desired conditions and it does not meet the stated needs for revision it was not analyzed 

in detail.

Eliminated Alternative 5: Apply the Aquatic Conservation Strategy

from the 2001 Sierra Nevada Forest Plan Amendment

An alternative was suggested that requested the revised plans incorporate the aquatic conservation 

strategy from the 2001 Sierra Nevada Forest Plan Amendment (USDA Forest Service 2001c) as 

plan direction. The fundamental principle of the 2001 Sierra Nevada Forest Plan Amendment 

aquatic management strategy was “to retain, restore, and protect the processes and landforms that 

provide habitat for aquatic and riparian-dependent organisms, and produce and deliver highquality waters for which the national forests were established.” For the aquatic management 

strategy to function as a comprehensive strategy there are a suite of interrelated actions that work 

together to manage and conserve aquatic habitats. These actions include: 

• a description of the desired condition of aquatic, riparian, and meadow habitats developed 

from the aquatic management strategy goals; 

• an array of land allocations (such as critical aquatic refuges and riparian areas) that 

delineate aquatic, riparian, and meadow habitats and emphasize specific actions in these 

areas; 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

54

• a set of standards and guidelines that specify appropriate land uses and activities within 

different land allocations; 

• ecosystem analysis that enables managers to collect and evaluate relevant data and 

information over nested geographic zones (such as watersheds within river basins) for the 

purpose of considering current landscape conditions and results in appropriate, site-specific 

management decisions, including restoration of degraded areas; and

• an adaptive management program that includes monitoring and research activities intended 

to assess planned management activities and provide information needed to adjust future 

management activities, as appropriate.

The 2001 Sierra Nevada Forest Plan Amendment aquatic management strategy was incorporated 

into the 2004 Sierra Nevada Forest Plan Amendment (USDA Forest Service 2004d), which 

amended the existing forest plan with only a few changes directed at clarifications and 

simplifications to eliminate repetition of law, regulation, and policy in forest plan direction. These 

changes were analyzed in the 2004 Sierra Nevada Forest Plan Amendment, which is the current 

plan. The current plan is analyzed in detail (alternative A), and therefore, the essential 

components of the original 2001 aquatic management strategy are analyzed. 

Eliminated Alternative 6: Consider the document “National Forests 

in the Sierra Nevada: A Conservation Strategy” as an alternative

A group of respondents submitted a Conservation Strategy for National Forests in the Sierra 

Nevada with the request that it be analyzed as an alternative in detail. The Conservation Strategy 

contains several concepts and strategies related to sustainability and resilience of forests within 

the Sierra Nevada. Some of these concepts are already in place under the current forest plans 

(such as community fire planning, various collaborative efforts, and completion of travel 

analysis), some will be incorporated into the planning process and documents (such as a science 

consistency review will be conducted before the final environmental impact statement is 

prepared), and others are largely consistent with the draft forest plan. In most instances where the 

draft forest plan is not in agreement with the Conservation Strategy, concepts and direction 

similar to those in the Conservation Strategy are included as part of another alternative (C or D) 

that was analyzed in detail.

The Multiple Use Sustained Yield Act16 states “it is the policy of the Congress that the national 

forests are established and shall be administered for outdoor recreation, range, timber, watershed, 

and wildlife and fish purposes.” Similarly, the 2012 planning regulations require that plans 

“provide for social, economic, and ecological sustainability.”17 This is accomplished by including 

plan components, including standards and guidelines, “to guide the plan area’s contribution to 

social and economic sustainability.”18 While the Conservation Strategy would meet many of the 

requirements for ecological sustainability, it does not adequately meet the requirements of the 

Multiple Use Sustained Yield Act or the Planning Rule requirements for social and economic 

sustainability because it does not include plan components for sustainable recreation, range, 

timber and other renewable and nonrenewable energy and mineral resources. 

 16 Public Law 86-517

17 36 CFR 219.8

18 36 CFR 219.8 (b)
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

55

For these reasons, we concluded that a detailed analysis of an alternative based on the 

Conservation Strategy was not needed.

Eliminated Alternative 7: Allow existing motorized and 

mechanized uses to continue in recommended wilderness

Public feedback on the recommended wilderness inventory and evaluation asked the Forest 

Service to consider an alternative that allowed existing motorized and mechanized recreation 

activities to continue in recommended wilderness areas. Although Forest Service policy does 

allow decisionmakers to consider allowing existing uses to continue, they can do so “only if such 

uses do not prevent the protection and maintenance of the social and ecological characteristics 

that provide the basis for wilderness designation.”19 Cole and Hall (Cole 2010) found that by 

controlling the setting (environmental, social, and managerial conditions), managers influence the 

nature and quality of [wilderness] experiences to a substantial degree. 

The use of motorized and mechanized transportation in recommended wilderness areas affects the 

wilderness characteristic of undeveloped settings where wilderness is essentially without 

permanent improvements or modern human occupation. In addition, the use of motorized and 

mechanized transport is not compatible with the desired condition of a primitive recreation 

opportunity, which, specifically in designated wilderness, has largely been interpreted as travel by 

horse, foot, and canoe (Landres et al. 2005). Also the presence, volume, and type of other users 

and the sounds and smells associated with motorized vehicles can affect solitude.

Some national forests have taken a management approach to allow motorized and mechanized 

transportation to continue in recommended wilderness areas as long as the ecological and social 

characteristics are protected and maintained. This requires monitoring of a number of factors 

including level of existing use at the time of recommendation, levels of use over time (increase, 

decrease, or neutral), and the effects of the continued use on wilderness character over time. This 

is a challenging monitoring effort in a fiscally constrained environment.

Because of the potential impacts to wilderness character, which may prevent the protection and 

maintenance of the social and ecological characteristics that provide the basis for future 

wilderness designation, and the difficulty of monitoring continued motorized and mechanized 

uses in recommended wilderness, this alternative was eliminated for detailed analysis.

Comparison of Alternatives

This section compares how the alternatives are different with respect to the issues to be resolved 

and their key indicators and management areas. In addition, forest plan objectives are also 

compared across alternatives.20

Comparison of Management Areas by Alternative

Table 1, table 2 and table 3 describe management areas or designated areas applicable by 

alternative. In alternative A, areas with specific plan components were called land allocations, 

which is the equivalent to the 2012 Planning Rule definition for a management area. The 

management areas for wilderness, wild and scenic rivers, and the Pacific Crest National Scenic 

 19 Forest Service Handbook 1909.12, chapter 74.1

20 Note: For the Sequoia National Forest, all tables in this section refer to the portion of the national forest outside of 

the Giant Sequoia National Monument.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

56

Trail are also designated areas. Table 1 indicates which other designated areas occur. Some 

management areas such as wilderness, wild and scenic rivers, and the Pacific Crest National 

Scenic Trail are also designated areas included in the table.

Table 1. Management areas by alternative

Management Area Alternative A Alternative B

Alternative 

B-modified Alternative C Alternative D

Wildland-urban Intermix 

Defense Zone (acres) 21,940 Not applicable Not applicable 21,940 Not applicable

Wildland-urban Intermix 

Threat Zone (acres) 191,616 Not applicable Not applicable Not applicable Not applicable

Community Wildfire 

Protection Zone (acres) Not applicable 170,572 116,146 Not applicable 116,146

General Wildfire 

Protection Zone (acres) Not applicable 371,596 559,513 Not applicable 559,513

Wildfire Restoration Zone 

(acres) Not applicable 568,685 533,233 Not applicable 533,233

General Wildfire Zone 

(acres) Not applicable Not applicable Not applicable 1,155,557 Not applicable

Wildfire Maintenance 

Zone (acres) Not applicable 872,106 774,070 805,462 774,070

General Forest - “Other” 1,769406 Not applicable Not applicable Not applicable Not applicable

Designated Wilderness 

(acres) 967,039 967,039 967,039 967,039 967,039

New Recommended 

Wilderness (acres) 0 37,029 37,029 325,359 0

Designated Wild and 

Scenic Rivers (miles) 90 90 90 90 90

Existing Recommended 

Wild and Scenic Rivers 

(miles)

16.5 16.5 16.5 16.5 16.5

Eligible Wild and Scenic 

Rivers (miles) 128.3 241.2 241.2 241.2 241.2

Pacific Crest National 

Scenic Trail (miles) 86 86 86 86 86

Pacific Crest National 

Scenic Trail Corridor 

(acres)

116 39,973 39,973 130,350 22,053

Critical Aquatic Refuges 

(acres) 170,600 191,567 0 322,518 191,567

Conservation Watersheds 0 0 387,678 0 0

Challenging Backroad 

Area (Low Use) 0 0 543,938 0 0

General Forest 

Recreation Area 

(Mixed/Moderate Use)

0 0 327,622 0 0

Destination Recreation 

Area (High Use) 0 0 45,585 0 0
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

57

Table 2. Summary of alternatives by revision topic

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Fire 

Management

Management focuses 

hazardous fuel reduction 

treatment in two distancebased areas surrounding 

the wildland-urban intermix 

defense zone and wildlandurban intermix threat zone. 

Naturally ignited wildfires 

are evaluated on a case-bycase basis to determine if 

they can be managed to 

meet resource objectives.

Replaces alternative A 

zones with four 

management areas based 

on a fire risk assessment 

consistent with the National 

Cohesive Fire Strategy:

community wildfire 

protection zone, general 

wildfire protection zone, 

wildfire restoration zone, 

and wildfire maintenance 

zone.

Strong emphasis on 

managing naturally ignited 

wildfires in the wildfire 

maintenance zone and 

strongly encouraged in 

wildfire restoration zone 

where some mechanical 

and burning treatments may 

be needed first.

Same as alternative B 

except errors were 

corrected to highly valued 

resource and assets 

(HVRAs) and made

adjustments to the potential 

wildland fire operational 

delineation units (PODs), 

both variables used in the 

wildland fire risk 

assessment. The changes 

in HVRAs included 

correcting data errors in the 

asset HVRAs, defining the 

California Spotted Owl 

HVRA, removing the 

northern goshawk HVRA, 

and removing the visual 

resource HVRA. POD 

boundaries were remapped 

to include contiguous areas 

of low elevation sagebrush. 

POD level adjustments 

were made to assign the 

final zone classification to 

general protection rather 

than restoration or 

maintenance.

Emphasis on managing 

naturally ignited wildfires to 

achieve resource objectives 

for resource benefits same 

as alternative B.

Fire management zones 

consist of a combination of 

alternative A distancebased wildland-urban 

interface defense zone and 

the alternative B risk-based 

wildfire maintenance zone. 

The remainder of the Inyo

would be called the general 

wildfire zone.

The modifications in 

alternative B-modified to 

correct errors to HVRAs 

and adjust PODs were also 

applied when creating 

zones for Alternative C.

Emphasis on managing 

naturally ignited wildfires in 

the wildfire maintenance 

zones same as alternative 

B. In the general wildfire 

zone, naturally ignited 

wildfires strongly 

encouraged but prescribed 

burning may be needed 

first.

Fire management zones 

and approach to managing 

naturally ignited wildfires 

same as alternative B.

The modifications in 

alternative B-modified to 

correct errors to HVRAs 

and adjust PODs were also 

applied when creating 

zones for alternative D.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

58

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Ecological 

Integrity –

Vegetation 

management

Management emphasis on 

short-term retention of 

mature forest habitat for old 

forest associated wildlife 

species. 

Vegetation and fuels 

management treatments 

prioritized in the wildlandurban intermix and 

elsewhere in a roughly 

geometric pattern of 

strategically placed area 

treatments. 

In the wildland-urban 

interface defense zone (the 

area closest to structures 

and communities), there are 

fewer restrictions on the 

intensity of thinning. 

There is a forestwide 

standard and guideline 

limiting tree removal to less 

than 30 inches in diameter.

Management emphasis on 

restoration of vegetation 

desired conditions based on 

natural range of variation 

and habitat elements for atrisk species. 

Treatments continue to 

reduce fire risk near 

communities. Strategically 

located mechanical and 

prescribed burning 

treatments along roads and 

ridges are designed to 

support larger landscapescale prescribed burning 

and greater opportunity to 

manage wildfires to meet 

resource objectives.

Forestwide direction for 

limiting removal of trees 

larger than 30 inches in 

diameter applies to the 

wildfire restoration zone and 

wildfire maintenance zone. 

Elsewhere, desired 

conditions for number of 

large trees by vegetation 

type guides retention levels.

Similar to alternative B 

except 133,490 acres (7% 

of total acres in the plan 

area) will be reclassified 

from Maintenance or 

Restoration Fire 

Management Zone to the 

General Wildfire Protection 

Zone. Nearly all these acres 

are located in lower 

elevations of the sagebrush 

vegetation type, where the 

primary restoration 

approaches will rely on 

methods other than wildfires 

managed to achieve 

resource objectives. Some 

adjustments also made to 

account for infrastructure. 

Forestwide direction for 

limiting removal of trees 

larger than 30 inches in 

diameter clarified to allow 

some removal for ecological 

restoration and to benefit 

old forest conditions.

Use of fire to meet desired 

conditions provides 

direction for managing longterm functionality of aquatic, 

riparian, and terrestrial 

systems in conservation 

watersheds and also 

provides flexibility with the 

intent to increase the pace 

and scale of restoration in 

riparian areas, meadows, 

and streams.

Mechanical treatments are 

focused on the wildlandurban interface defense 

zone, with limited 

mechanical treatment 

elsewhere. There is an 

emphasis on prescribed 

burning as the primary 

restoration method and an

emphasis on managing 

wildfires to meet resource 

objectives where feasible.

Forestwide direction for 

limiting removal of trees 

larger than 30 inches is 

same as alternative A 

except in the portion of the 

Inyo with California spotted 

owl habitat where smaller 

diameter limits exist in 

suitable habitats.

Management emphasis is 

similar to alternative B but 

there is more focus on 

increasing the area treated 

to improve the long-term 

sustainability and resilience 

of forests and watersheds.

Desired conditions for 

number of large trees by 

vegetation type guides 

retention levels forestwide. 

There are no diameter limits 

for removing large trees. 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

59

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Ecological 

Integrityaquatic and

riparian 

resources

(critical aquatic 

refuges, 

conservation 

watersheds and 

riparian 

conservation 

areas)

Identifies riparian 

conservation areas, a buffer 

area around streams, rivers, 

lakes, meadows, bogs, and 

other wetland types. The 

riparian conservation area 

is wider for perennial 

streams than for intermittent 

and ephemeral streams and 

can be adjusted smaller or 

larger based upon site 

conditions. 

Prescriptive standards and 

guidelines avoid, minimize 

or mitigate activities and 

actions that could adversely 

affect riparian vegetation or 

aquatic conditions. 

Identifies a set of 17 critical 

aquatic refuges focused on 

areas with threatened and 

endangered species or 

areas of other species with 

population concerns. The 

direction that applies to 

riparian conservation areas 

applies to the critical 

aquatic refuges.

Direction is functionally 

similar to that contained in 

alternative A, except for: 

a) streamlining and 

consolidating direction;

b) removal of direction that 

repeats laws, regulations, or 

policies; 

c) changing “riparian 

conservation objectives” 

from Sierra Nevada Forest 

Plan Amendment to other 

plan components for 

consistency with 2012 

Planning Rule 

requirements; and

d) modifying the direction to 

allow prescribed burn 

ignitions and, where 

necessary, mechanical and 

hand treatments to restore 

ecological integrity.

One additional critical 

aquatic refuge would be 

added to the 17 in 

alternative A.

Similar direction for riparian 

conservation areas as 

alternative B with some 

clarification, refinements, 

and reorganization.

Switches approach of 

managing 17 small 

scattered critical aquatic 

refuges that provide for 

aquatic species with

approach managing 4 larger 

conservation watersheds.

Conservation watersheds 

are a subset of watersheds 

that are prioritized to 

provide for persistence of 

both plant and animal atrisk species (biodiversity 

focus) as well as other 

beneficial uses of water. 

Because of their scale, they 

provide cumulative 

beneficial effects on 

connectivity, integrity, and 

refugia for at-risk species in 

the face of large-scale 

unpredictable events.

Direction for riparian 

conservation area and 

critical aquatic refuges 

would be the same as 

alternative B.

Adds 8 new critical aquatic 

refuges to the 17 in 

alternative A. 

Alternative D includes the 

same direction for riparian 

conservation areas and 

critical aquatic refuges as 

alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

60

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Ecological 

integrity –

wildlife

Plan direction for 

management of federally 

listed species and Regional 

Forester designated 

sensitive species.

Limited forest plan direction 

for management of 

sagebrush and sage-grouse 

habitat. Management 

guided by agreements to 

implement direction in 

interagency action plans.

Direction for forest 

management primarily 

focused on the short-term 

retention of dense canopy 

cover and restricts removal 

of large trees to provide 

mature forest habitat for 

species like the California 

spotted owl and Sierra 

marten.

2012 Planning Rule 

manages for at-risk species, 

which are federally listed 

species and species of 

conservation concern. 

Species of conservation 

concern are designated by 

the Regional Forester and 

replace Regional Forester 

sensitive species.

Adds specific forest plan 

direction focused on 

restoration of sage-grouse 

habitat

The Draft EIS alternative 

mistakenly dropped plan 

direction for California 

spotted owl and great gray 

owl. The Final EIS corrects 

this error and applies the 

same plan direction 

developed for the Sequoia 

and Sierra National Forests 

in the Draft EIS for 

alternative B but limits it to 

the same spatial area on 

the Inyo National Forest as 

in alternative B-modified.

The at-risk species 

approach is the same as 

alternative B.

Modifies some of the 

strategic fire management 

zones from alternative B to 

reclassify areas dominated 

by sagebrush to the general 

wildfire protection zone to 

limit impact of fire on sagegrouse habitat. (Fire 

suppression of most fires in 

sagebrush helps prevent 

cheatgrass invasion.) 

Refines the plan direction 

for California spotted owl 

from alternative B to reflect 

the limited amount of 

suitable habitat adjacent to 

the Sierra and Sequoia 

National Forests. Modifies 

plan direction for the great 

gray owl from alternative B 

to drop direction for predefined protected activity 

centers to allow 

establishment of necessary 

protective measures based 

upon other forestwide 

direction for at-risk species.

The at-risk species 

approach is the same as 

alternative B.

Increased restoration of 

sage-grouse habitat similar 

to alternative B.

Retains emphasis on shortterm habitat protection for 

California spotted owl and 

Sierra marten in forested 

habitats by applying the 

same direction developed 

for the Sequoia and Sierra 

National Forests for 

alternative C to the same 

limited area as alternative 

B.

Same as alternative B.

Recommended 

Wilderness

No additional recommended 

wilderness areas

Makes a preliminary 

administrative 

recommendation to include 

4 additional areas in the 

National Wilderness 

Preservation System (South 

Sierra; Piper Mountain 

Addition; White Mountains 

East; and White Mountains 

West); 37,029 acres.

Same as alternative B Alternative C would make a 

preliminary administrative 

recommendation to include 

24 additional areas totaling 

325,352 acres in the 

National Wilderness 

Preservation System.

No additional recommended 

wilderness areas
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

61

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Wild and 

Scenic River 

Eligibility

Includes current inventory 

of 128.3 miles of wild and 

scenic rivers.

The updated miles 

determined to be eligible for 

inclusion in the National 

Wild and Scenic Rivers 

System is approximately 

241.2 miles.

Same as alternative B. Same as alternative B. Same as alternative B.

Pacific Crest 

Trail

The current forest plan 

manages the Pacific Crest 

Trail according to direction 

provided by a 1982 

Comprehensive 

Management Plan and 

direction is focused on the 

trail tread and immediate 

surroundings

Width of management area 

is 6 feet.

Creates a management 

area allocation for the 

Pacific Crest Trail by 

defining a corridor of the 

visual foreground landscape 

zone as defined by the 

Scenery Management 

System, (up to one-half mile 

from the centerline on both 

sides of the trail where 

visibility is not obscured by 

terrain).

Width of management area 

is up to one-half mile of 

each side of centerline.

Creates a management 

area and sets direction the 

same as in alternative B.

Creates a management 

area allocation for the 

Pacific Crest Trail by 

defining a corridor that 

includes the same visible 

foreground (up to one-half 

mile of centerline of the trail 

where visibility is not 

obscured by terrain) as

alternative B and also 

includes lands inventoried 

as “Scenic Attractiveness A” 

in the Scenery Management 

System within the trail’s 

viewshed.

Width of management area 

up to 4 miles each side of 

centerline of trail.

Creates a management 

area allocation for the 

Pacific Crest Trail by 

defining a corridor onequarter mile from the 

centerline of the trail. The 

plan direction assigned to 

the corridor would be the 

same as alternative B.

Width of management area 

one-quarter mile each side 

of centerline.

Scenery 

Management

Scenic character is 

managed using the 1986 

Visual Management 

System.

Identifies scenic integrity 

objectives for the plan areas 

using the Scenery 

Management System.

Same as alternative B Same as alternative B Same as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

62

Revision Topic Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Sustainable 

Recreation 

and 

Recreationbased 

Management 

Areas

The emphasis is on 

improving recreation 

opportunities by focusing on 

the maintenance, 

development, adaptation, or 

alteration of dispersed and 

developed recreation sites 

consistent with the 

recreation opportunity 

spectrum class of the area.

Recreation opportunity 

spectrum classes are 

updated to reflect existing 

management and to 

consider recommended 

wilderness. The 

management approach for 

recreation settings is 

integrated with ecological 

restoration approaches.

A concept of “places” is 

used to guide management 

efforts to sustain scenery, 

settings and opportunities. 

The concept of recreation 

places in alternatives B, C, 

and D is replaced by a zone 

concept and integrates with 

the settings described by 

the recreation opportunity 

spectrum. 

The three zones span a 

continuum from areas of 

more concentrated 

recreation to areas of 

remote, less-concentrated, 

low density recreation.

Similar to alternative B 

except the range of 

recreation opportunity 

spectrum classes would 

shift based on 

recommended wilderness 

areas.

Similar to alternative B 

except the range of 

recreation opportunity 

spectrum classes would 

shift with fewer areas 

allocated to primitive and 

semi-primitive nonmotorized 

recreation settings and 

more area allocated to 

motorized recreation 

settings due to 

recommended wilderness.

Production 

Livestock

Grazing

Grazing direction includes 

1988 Forest Plan and 1995 

Forest Plan Amendment 6 –

Forestwide Range 

Utilization Standards. 

Amendment 6 references 

some outdated methods 

and includes process and 

protocols for determining 

allowable grazing utilization 

standards as part of forest 

plan direction.

Several updates to existing 

management direction as 

compared to Alternative A. 

Amendment 6 (1995) 

removed from forest plan. 

Process and protocols 

would be located in a 

technical guide residing 

outside the plan called 

“Forest Supplement to 

Rangeland Analysis and 

Planning Guide.” [2012 

planning rule guidance 

suggests methodologies for 

assessment processes not 

be included in plan content.

Same as Alternative B Same as Alternative B Same as Alternative B

Timber 

Suitability

85,025 acres suitable for 

timber production

72,234 acres suitable for 

timber production

Same as alternative B 70,608 acres suitable for 

timber production

Same as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

63

Table 3. This table represents a brief summary of consequences for the major topics addressed in this final environmental impact statement

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Agents of 

Change

Combined 

effects of 

climate, fire, 

insects, and 

pathogens

Relatively low to moderate 

restoration treatment rates 

will somewhat reduce the 

combined impacts of climate 

change, fire, insects, and 

pathogens, but only in a 

limited number of treated 

areas within the larger 

landscape. Conservation of 

moderate to high-density 

canopy cover in late seral 

forest habitat would result in 

low resilience to highintensity fires, drought and 

temperature increases.

Moderate restoration 

treatment rates will reduce 

the combined impacts of 

climate change, fire, insects, 

and pathogens in more 

areas than in alternative A. 

Treated forest, sagebrush, 

and pinyon juniper 

ecosystems will have 

enhanced capacity to resist 

the interactive effects of 

multiple stressors. This 

alternative emphasizes 

climate adaptation strategies 

across larger landscapes. 

Similar to alternative B but 

with a marginally lower 

combined impact of climate 

change, fire, insects, and 

pathogens due to slightly 

higher restoration treatment 

rates. 

Similar to alternative A, but 

with greater resilience to 

combined stressors resulting 

from higher fire restoration 

(prescribed fire, wildfire 

managed for resource 

objectives) treatment rates.

Similar to alternative B but 

has greater amount of 

restoration treatment across 

the landscape, resulting in 

the lowest combined impacts 

of climate change, fire, 

insects, and pathogens. 

Treated forest, sagebrush, 

and pinyon juniper 

ecosystems will have a 

higher capacity to resist the 

interactive effects of multiple 

stressors.

Wildland Fire 

Management

Does not proactively analyze 

fire risk with a spatial risk 

assessment, which limits the 

restoration and maintenance 

of landscapes through 

managing wildfire to meet 

resource objectives, and the 

safe and effective fire 

responses due to the 

uncertainty of the location of 

assets and resource at risk. 

This results in limits to the 

restoration and maintenance 

of landscapes through the 

use of wildfire, both with 

strategically located 

prescribed burning and 

wildfires managed to meet 

resource objectives.

Risk assessment provides 

information that reduces 

uncertainties and allows 

forest and fire managers to 

have more latitude to 

proactively plan and restore 

the landscape by managing 

wildfire to meet resource 

objectives and using 

prescribed fire. 

Applies risk management 

explicitly and has the 

greatest amount of 

ecological restoration that 

reduces risk and provides 

resource benefits. This 

greater amount of projects 

and the enhancement of 

strategic fire management 

features would provide the 

greatest likelihood of 

implementing large 

prescribed fires or managing 

wildfires to meet resource 

objectives.

Same as alternative B, but 

there is a reduced amount of 

low elevation sagebrush in 

the Wildfire Restoration 

Zone. Instead, most low 

elevation sagebrush is 

changed to the General 

Wildfire Protection Zone. 

This will reduce the negative 

impacts of wildfires on 

sagebrush where expansion 

of cheatgrass is a risk. 

This alternative uses a more 

simplified 3-zone approach 

that will make it more difficult 

and uncertain to make fire 

management decisions that 

minimize the negative 

impacts of wildfires on highvalued resources and assets 

(HRVAs). This alternative 

emphasizes the use of 

prescribed fire and limits 

mechanical treatment of 

medium and large conifers 

for vegetation management. 

This could limit the amount 

of projects and the 

enhancement of strategic fire 

management features to 

meet resource objectives. 

Same as alternative Bmodified.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

64

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Air Quality Increases in emissions and 

other cumulative effects 

would make long-term 

attainment of emissions

goals unlikely under 

alternative A.

Restoration activities would 

increase emissions and 

affect air quality in the short 

term, but the degree of 

increase is dependent on the 

amount of treatment. In the 

long-term, restoration 

activities would reduce 

emissions from wildfires. 

Same as alternative B Same as alternative B 

except emissions, given the 

focus on managed and 

prescribed fire for 

restoration, would have the 

potential for higher expected 

short-term emissions. To the 

extent that prescribed 

burning and wildfires 

managed to meet resource 

objectives occur, a reduction 

in wildfire smoke would 

make long-term attainment 

of visibility goals more likely 

than under alternative A but 

less likely than under 

alternatives B-modified, B 

and D.

Same as B except, given the 

highest pace and scale of 

restoration activity, in the 

long-term alternative D has

the greatest potential to 

reduce emissions from 

wildfires. The restoration 

treatments would result in 

the greatest reduction in 

wildfire emissions. This 

alternative has the greatest 

likelihood of long-term 

attainment of visibility.

Terrestrial 

Ecosystems

Sierra Nevada 

zones and 

habitats

Fewer opportunities for 

restoration including use of 

wildfire to achieve resource 

objectives results in slower 

return to desired conditions 

than in the plan revision

alternatives. 

Somewhat higher restoration 

rates across larger 

landscapes primarily through 

increased use of wildfire to 

meet resource objectives. 

Results in better adaptive 

capacity, but large highintensity fire is likely to 

continue. There will be 

moderated effects in treated 

landscapes.

Same as alternative B Increased emphasis on 

prescribed fire and wildfire 

managed for resource 

objectives, which may result 

in increased restoration. 

Because of lower level of 

mechanical treatment in 

these habitat types, there 

may be fewer opportunities 

to manage wildfire for 

resource objectives. 

Similar to alternative B 

except with greater rates of 

restoration toward desired 

conditions in vegetation 

structure and composition.

Terrestrial 

Ecosystems

Great Basin

zones and 

habitats

Lower rates of restoration 

than the plan revision

alternatives and slower to 

achieve desired conditions 

across these habitat types.

Increased rates of treatment 

compared to the current plan 

would move these habitat 

types toward desired 

conditions across the 

landscape. Main effects 

would be to achieve less 

dense and more 

heterogeneous structure, 

and reduce nonnative 

invasive plants. These 

changes would increase the 

resilience to drought, insects 

and pathogens, climate 

change, and fire.

Same as alternative B There would be greater 

mechanical restoration 

treatment rates in sagebrush 

than in alternatives B and Bmodified. Great Basin 

habitats other than 

sagebrush would only have 

slightly more restoration than 

in the current plan and would 

be slower to reach desired 

conditions.

Given the higher pace and 

scale of restoration, this 

alternative would be 

expected to move the 

greatest amount of 

sagebrush shrublands 

toward the desired 

conditions, especially in 

areas of sage-grouse 

habitat. Other Great Basin 

habitats, like pinyon-juniper, 

would progress toward 

desired conditions at a 

slightly higher rate than 

under alternative B.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

65

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Terrestrial 

Ecosystems

Landscape 

Connectivity

Provides low to moderate

connectivity for forestassociated and other wildlife 

species under both shortand long-term horizons. 

Alternative A promotes lower

restoration treatment rates 

and lacks some 

management approaches 

that are specifically focused 

on habitat linkage and 

dispersal corridor areas.

Provides for moderate levels 

of short- and long-term 

habitat connectivity, 

especially for forestassociated species such as 

marten. Includes a greater 

number of management 

approaches focused on 

maintaining habitat linkages 

than alternative A.

Same as alternative B Provides the greatest shortterm connectivity but at the 

cost of higher exposure or 

sensitivity to 

uncharacteristically severe 

fire, climate change, and 

other stressors that reduce 

long-term habitat 

connectivity.

Supports somewhat greater

long-term habitat 

connectivity than alternative 

B, but at the cost of 

significantly reduced shortterm habitat connectivity 

resulting from elevated 

mechanical and prescribed 

fire treatment rates in the 

next 10 to 20 years.

Terrestrial 

Ecosystems

Old Forest

Same as alternative B 

except there would be 

slightly lower levels of 

benefit from restoration 

because treatments would 

be less intense and less 

extensive.

There would be slightly more 

old forests restored to

desired tree densities, 

heterogeneity, tree canopy 

cover, fire regime integrity, 

and fire as an ecosystem 

process. This would restore 

old forests toward conditions 

reflecting the natural range 

of variation. In treated areas, 

large, old trees would have

substantially increased 

resilience to moisture stress, 

drought, insects and 

pathogens, ozone, and 

large, high-intensity fires.

There would also be reduced

vulnerability to future 

drought, insect, and 

pathogen-related large tree 

mortality because the 

greatest intensity of forest 

thinning across large areas 

and greater levels of fire 

restoration would occur.

Same as alternative B Same as alternative B 

except there would be 

slightly lower levels of 

benefit from restoration 

because treatments would 

be less intense and less 

extensive.

Same as alternative B 

except there would be 

somewhat higher restoration 

treatment rates and 

associated expected benefits 

to old forest structure and 

resilience.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

66

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Terrestrial 

Ecosystems

Complex Early 

Seral Forest

There is a low to moderate

increase in complex early 

seral forest in alternative A. 

The proportion of complex 

early seral forest will be 

slightly higher than the 

natural range of variation.

There is a moderate

increase in complex early 

seral forest that is greater 

than alternative A but less 

than alternative C. Specific 

plan components in 

alternative B provide for 

greater protection of 

complex early seral forest. 

The proportion of complex 

early seral forest will be 

more similar to natural range 

of variation than alternative 

A.

Same as alternative B The increase in complex 

early seral forest would be 

the highest in alternative C. 

The proportion of complex 

early seral forest may be 

within or exceed the natural 

range of variation in some 

forest landscapes.

Same as alternative B

Aquatic and 

Riparian 

Ecosystems

Management direction does 

not explicitly address climate 

change. Riparian 

conservation areas provide 

ecological connectivity 

across larger landscapes.

Proposes the fewest number 

of meadows maintained, 

enhanced or improved and 

has more restrictive 

constraints on use of 

restoration tools.

There would continue to be 

limited restoration of riparian 

vegetation and limited ability 

to adequately reduce fuel 

volumes in riparian 

conservation areas. As a 

result, aquatic habitat under 

this alternative would be at a 

greater risk to degradation 

from untreated stressors and 

large-scale disturbances.

This alternative addresses

ecological connectivity, 

species diversity and 

resilience to climate change

more explicitly and includes 

direction that will help reduce

fuel loads, restore fire, and 

manage riparian vegetation 

species composition, 

structure, and function, while 

reducing soil disturbance. 

Direction emphasizes 

desired conditions and 

management of riparian 

conservation areas to 

provide flexibility of 

management using a variety 

of tools.

More meadows would be 

maintained, enhanced or 

improved than in alternative 

A.

Restoration activities create 

a fire regime more aligned 

with historic patterns, thus 

improving riparian area 

resilience to fire.

Same as Alternative B, but 

incorporates a larger 

landscape approach by 

using conservation 

watersheds. It replaces 17 

critical aquatic refuges 

(typically 10,000-40,000 

acres each) with four 

conservation watersheds 

(typically larger than 80,000 

acres) in areas prioritized for 

conservation of at-risk 

species, their habitats, and 

headwaters providing highquality water for beneficial 

uses. 

Complementary approach 

among riparian conservation 

areas, conservation 

watersheds, and forestwide 

direction for at-risk species 

and watersheds provides 

protections and allows 

latitude and flexibility to 

increase the pace and scale 

of restoration in riparian 

areas, meadows, and 

streams. 

Alternative C adds 8 critical 

aquatic refuges. It would 

have fewer disturbances to 

the riparian conservation 

areas than alternatives B 

and D with more restrictions 

on mechanical treatments 

overall.

Maintains, enhances or 

improves more meadows 

than alternative A and would 

move vegetation toward 

desired conditions and 

reduce the ingrowth of 

conifers. 

Similar to alternative B 

except that the high number 

of treatments proposed 

translates into a higher risk 

of short-term disturbance to 

aquatic species and 

temporary disturbance to 

aquatic habitat conditions 

from mechanical and 

prescribed fire treatment 

actions until the habitat 

recovers.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

67

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Water Quality 

and Quantity, 

and Watershed 

Condition

Water Quality

No change in current 

management direction and 

therefore continued trends in 

water quality are expected.

Emphasizes a long-term 

approach through increased 

pace and scale of ecological 

restoration across the 

landscape and reduces the 

overall risk of high-intensity 

wildfire. Short-term impacts 

would be similar to 

alternative A because 

riparian conservation areas 

would be carried forward and 

best management practices 

would minimize these 

impacts. 

Same as alternative B. Similar to alternative B in 

effects except alternative C 

includes more recommended 

wilderness, and therefore 

would use less mechanical 

pre-treatments. As a result, 

restoration activities may not 

be applied to the extent 

needed, which could lower 

long-term benefits to water 

quality compared to other 

plan revision alternatives. 

Same as alternative B 

except that alternative D 

best reduces the overall risk 

of high-intensity wildfire over 

the long-term, thus 

potentially providing the 

most long-term benefits.

Water Quality 

and Quantity, 

and Watershed 

Condition

Water Quantity

Would likely maintain 

shallow groundwater at 

current levels if not for the 

changing climate trending 

toward warmer and drier 

conditions in the Sierra 

Nevada. Even if precipitation 

remains the same, more rain 

and less snow would reduce 

recharge and storage and 

increase runoff. Combined 

with greater 

evapotranspiration, the 

precipitation provides less 

soil moisture for healthy 

forest vegetation, soil 

infiltration, and recharging 

the shallow groundwater.

Would reduce 

evapotranspiration at a 

landscape scale and would 

likely increase the 

opportunities for infiltration 

across many watersheds.

Same as alternative B Same as alternative A Same as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

68

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Water Quality 

and Quantity, 

and Watershed 

Condition

Watershed 

Conditions

Would take longer to restore 

the fire regime and forest 

health at a landscape level.

Alternative B would move 

the national forest towards 

desired conditions at a faster 

pace than alternatives A and 

C through restoration of fire 

regimes and improving forest 

health at a landscape level. 

Long-term water quality and 

quantity are closely linked to 

these indicators. 

Similar to alternative B. In 

addition, conservation 

watersheds represent a 

long-term prioritization for 

maintenance and restoration 

of watersheds and 

particularly focus on aquatic 

resources and water quality. 

This alternative will maintain 

and in some cases improve 

the functional rating of some 

Watershed Condition 

Framework indicators such 

as but not limited to, fire 

regime, wildfire, water 

quality, and riparian/aquatic 

habitat over the long term. 

Restoration of fire regimes 

and restoring forest health at 

a landscape level would be 

achieved at a faster pace 

than alternatives A or C.

Same as alternative B but 

would take longer than to 

restore fire regime and forest 

health at a landscape level.

Alternative D restoration 

treatments would provide 

benefits to maintaining water 

and soil quality and 

watershed condition over the 

long term as compared to 

the other alternatives. 

Alternative D would increase 

the pace and scale of acres 

of riparian vegetation 

improved and meadows 

restored compared to 

alternative A. The pace and 

scale is similar to 

alternatives B and Bmodified for restoration of 

fire regimes and restoring 

forest health. 

Wildlife, Fish 

and Plants

At-risk Terrestrial 

Species

Continues to manage 

federally listed species 

through project-level 

consultation and 

consideration of recovery 

actions in approved recovery 

plans.

Manages for Regional 

Forester sensitive species 

through project-level design 

and analysis of 

consequences.

Continues to manage limited 

amounts of sagebrush 

habitats for sage-grouse 

through project level actions 

identified in the Bi-State 

Action Plan.

Has the most limited ability 

to mitigate the continuing 

increase in large, highintensity wildfires and build 

Stronger emphasis on 

coordination with U.S. Fish 

and Wildlife Service and CA 

Department of Fish and 

Wildlife for implementing 

species protection and 

recovery than alternative A. 

Stronger protection for Sierra 

Nevada bighorn sheep 

reduces the risk of disease

transmission.

Manages for species of

conservation concern 

through combination of 

ecosystem and some 

species-specific plan 

components to provide

ecological conditions and 

reduce impacts from threats. 

More sagebrush habitats 

improved for sage-grouse 

than alternative A.

Effects similar to alternative 

B for federally listed species. 

Consequences for species of 

conservation concern similar 

to alternative B. 

Emphasis on sagebrush 

restoration similar to 

alternative B, but strategic 

fire management zones 

changed to recognize 

foothills sagebrush as 

general wildfire protection 

zone where most fires will be 

suppressed to protect 

sagebrush habitats.

Similar to alternative B in the 

pace and scale to restore 

resilience at a large 

landscape scale. 

Effects similar to alternative 

B for federally-listed species.

Substantially increases the 

amount of sagebrush 

restoration, but some 

mechanical restoration may 

be slightly more difficult to 

implement with new 

recommended wilderness in 

the Glass Mountains. 

Direction allows some nonconforming uses for 

restoration to be allowed in 

recommended wilderness.

Similar to alternative A in the 

limited ability to mitigate the 

continuing increase in large, 

high-intensity wildfires and 

build adaptive capacity of 

ecosystems to climate 

change. Alternative C is 

Effects similar to alternative 

B for federally-listed species.

Amount of sagebrush 

restoration for sage-grouse 

the same as alternative C 

but not as restricted using 

mechanical treatments in the 

habitats near the Glass 

Mountains.

Similar to alternative B 

except that the pace and 

scale of restoration proposed 

under alternative D is 

expected to more quickly 

achieve resilience of the 

landscape to large-scale 

disturbances (such as insect 

outbreaks, high-severity 

wildfire effects, and droughtrelated tree mortality), 

thereby providing a greater 

long term benefit to 
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

69

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

adaptive capacity of 

ecosystems to climate 

change. Therefore, presents

a greater risk to the quantity 

and condition of habitat to 

contribute to the recovery of 

threatened and endangered 

species, conservation of 

proposed species, and 

support the persistence of 

species of conservation 

concern.

Alternative B is designed to 

achieve desired conditions in 

less time than alternative C 

by focusing on restoring 

large landscapes using a 

variety of tools, decreasing

the expected amount of 

crown fire and moving highseverity fire effects toward 

natural range of variation. 

The treatment pace and 

scale is expected to move 

the landscape to moderate 

fire resilience within the first 

10 years of plan adoption.

Alternative B provides a 

more cautious approach 

than alternative D by 

tempering the pace of 

restoration. Habitat for these 

species would continue to be 

at risk due to large, highintensity wildfires.

better than alternative A at 

addressing climate change.

terrestrial wildlife habitat 

quantity and condition. 

However the management 

approach has greater 

potential for short-term 

impacts to achieve improved 

habitat condition.

Wildlife, Fish 

and Plants

At-risk aquatic 

species

Limited implementation of 

restoration is expected to 

leave many areas containing 

native at-risk aquatic species 

vulnerable to impacts like 

sedimentation from large 

uncharacteristic fires. 

Expanded direction related 

to invasive species should 

benefit aquatic species 

across all plan revision

alternatives. 

While the negative effects of 

large-scale wildfires are 

expected to be significantly 

reduced, the increased pace 

of treatments translates into 

a higher risk of short-term 

disturbance to aquatic 

species and habitat 

conditions from mechanical 

and prescribed fire treatment 

actions until the habitat 

recovers. In the long term,

the direction is expected to 

improve the resilience of the 

overall landscape to wildfire, 

result in more long-term 

The emphasis in this 

alternative is building larger 

landscape-scale resilience to 

unpredictable events, to help 

species adapt. Connectivity 

in this and all alternatives is 

achieved through riparian 

conservation areas, and in

this alternative through 

conservation watersheds 

provides increased upland 

connectivity for species.

Additional direction to 

provide for at-risk species 

has been added where 

needed to complement the 

landscape scale approach. 

Direction focuses on 

restoration aimed to maintain 

or improve connectivity and 

refugia.

The additional critical aquatic 

refuges are intended to 

provide species protections

but their management 

direction is restrictive, which 

could affect pace and scale 

of restoration in habitats 

important for at-risk aquatic 

species. 

The emphasis on low- and 

medium-intensity fires 

across the landscape would 

improve long-term potential 

for improved habitat for 

aquatic species. Short-term 

impacts from mechanized 

treatments from grounddisturbing activities would be 

likely on the aquatic systems 

but it is expected there 

would be long-term benefits 

to these habitats.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

70

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

beneficial effects to aquatic 

species, and better promote 

the long-term sustainability 

of aquatic habitats and 

greater ability of these 

habitats to adapt to climate 

change.

Wildlife, Fish 

and Plants

At-risk Plant 

Species

The current forest plan for 

the Inyo National Forest 

does not include direction 

calling for the development 

of a whitebark pine 

conservation and restoration 

strategy. Inyo manages for 

whitebark pine as a sensitive 

species. Provides the 

necessary ecological 

conditions to maintain viable 

populations of plant species 

of conservation concern by 

relying primarily on projectlevel surveys and mitigations 

of adverse effects.

Restoration activities aimed 

at maintaining a viable 

population of whitebark pine 

would provide for the 

persistence of that species. 

Species monitoring from the 

regional ecology program 

would assist with developing 

management strategies. 

Alternative B would have 

more beneficial short- and 

long-term effects for 

whitebark pine than 

alternative A, due to the 

emphasis on forest 

restoration. 

Provides long-term benefits 

to plant species of 

conservation concern habitat 

extent and quality, resulting 

from ecological and 

hydrologic restoration, 

invasive species control, 

recommendation of 

wilderness that would protect 

some species of 

conservation concern plants, 

and from the emphasis on 

ecosystem resilience to 

climate change. Would also 

provide for persistence of 

plant species of conservation 

concern that occur in special 

habitats and address 

identified threats to special 

habitats.

Similar direction to 

alternative B (very minor 

editorial changes). 

Restoration effects are 

similar to alternative B.

Some potential for more 

impacts in destination 

recreation areas but design 

of projects still emphasizing 

conservation of species.

Same as B-modified. Same as B-modified
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

71

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Sustainable 

Recreation

Recreation 

development 

and visitor use

Does not provide an 

integrated and adaptive 

approach to managing and 

operating sustainable 

recreation facilities, 

protecting sensitive 

resources or managing 

visitor use. Potential 

negative impacts to visitor 

expectations and 

experiences would be the 

highest without responding 

to visitor conflict, crowding, 

or changing uses.

Increased restoration 

activities means all plan 

revision alternatives provide 

greater potential to improve 

long-term sustainability of 

recreational opportunities 

and settings (even with

short-term impacts). This 

alternative more effectively 

addresses recreation 

development than alternative 

A, but does not provide 

specific direction for an 

integrated and adaptive 

approach. Visitor use will 

continue to increase and 

because direction is based 

on recreation opportunity 

spectrum alone, but 

approach would be less 

adaptive. Visitor experiences 

and expectations could be 

negatively impacted without 

specific direction that 

prioritizes where staff 

manages visitor use and 

facilities. 

Designation of Sustainable 

Recreation Zones provides 

direction to effectively 

manage recreation 

development in a changing 

environment. It recognizes 

there will be new and 

changing uses; and it uses 

an adaptive and integrated 

approach to designing and 

managing recreation 

infrastructure while 

protecting resources. 

Sustainable Recreation 

Zones provide the most

benefits to managing visitor 

use and ensuring quality

visitor experiences and 

expectations would be met 

while protecting natural and 

cultural resources. Visitor 

use would be managed 

adaptively to prevent 

impacts to other resources.

Same as alternative B Same as alternatives B and 

C 

Recommended 

Wilderness

Potential effects 

on recreation 

settings and 

opportunities, 

access, and 

recreation 

management

No impact to existing 

motorized or mechanized 

(mountain bike) 

opportunities; however, 

without new wilderness 

recommendations, there 

would not be additional longterm social or ecological 

benefits derived 

recommendations, and no 

increase in wilderness 

recreation opportunities for 

nonmotorized users.

No impact to existing 

motorized or mechanized 

(mountain bike) 

opportunities; however, 

wilderness additions would 

limit future development of 

mountain bike and offhighway vehicle 

opportunities. There would 

be expanded wilderness 

recreation opportunities for 

nonmotorized users seeking 

backcountry day-use and 

overnight opportunities.

Same as alternative B The most beneficial to 

nonmotorized recreation 

opportunity settings. Some 

existing mountain bike use 

would be affected where 

recommended wilderness 

areas include existing 

mechanized trails. Would 

have greatest impact to 

limiting future development 

of mountain bike and offhighway vehicle 

opportunities.

The trade-off to the 

increased pace and scale of 

restoration activities is that 

there would not be additional 

long-term social and 

ecological benefits in the 

absence of recommending 

new wilderness areas. 

These lands could be 

susceptible to uses that 

would be incompatible with 

wilderness designation if 

kept in the existing 

management status, even 

though currently managed 

as inventoried roadless 

areas.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

72

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Recommended 

Wilderness

Potential effects 

on vegetation, 

fire, wildlife 

habitat, and 

watershed 

management

A full suite of management 

tools would be available to 

conduct fuels, fire 

management, and 

restoration activities; 

however, without

recommending wilderness 

areas, there would not be 

additional social and 

ecological benefits.

Large-scale fuels treatments 

and restoration activities 

would be more limited in 

areas recommended for 

wilderness; however, the 

ecological and social 

benefits of adding adjacent 

wilderness areas would 

outweigh the management 

challenges of conducting 

fuels and vegetation 

management activities. The 

impacts of managing sagegrouse habitat on wilderness 

character would be minimal 

given the small amount of 

habitat inside the wilderness 

addition.

Similar to alternative B, 

except there would be 

beneficial effects to 

Cottonwood-Crooked Creek 

Headwaters Conservation 

Watershed in the proposed 

White Mtn. east and west 

additions. Future 

development would be 

prohibited, which would 

maintain the watershed 

condition rating of relevant 

indicators. 

The challenges of managing 

habitat for sage-grouse and

conducting other restoration 

activities would outweigh the 

potential ecological benefits 

in this alternative due to the 

large amount of 

recommended wilderness 

acres recommended. A lack 

of restoration activities due 

to these management 

challenges could ultimately 

put resources at risk within 

recommended wilderness.

A full suite of management 

tools would be available to 

conduct fuels, fire 

management, and 

restoration activities at an 

increased pace and scale; 

however, there would not be 

additional ecological or 

social benefits derived from 

recommending wilderness 

areas. 

Recommended 

Wilderness

Potential effects 

on other uses 

No adverse impacts would 

occur since no wilderness

would be recommended.

No adverse impacts to water 

rights, water uses, grazing, 

Tribal uses, or mining claims 

since these uses would be 

allowed to continue in 

recommended wilderness. 

The tradeoff would be that 

wilderness recommendation

could increase the cost and 

complexity of maintaining 

facilities or uses because of 

the need to use 

nonmotorized access and 

nonmechanized means of 

maintenance. As a result, 

the annual operating costs 

for these uses would have 

the potential to increase. The 

extent of potential cost 

increases is uncertain at 

programmatic level.

Management of 

recommended wilderness 

would prohibit access by 

motorized vehicle and 

mechanized equipment for 

Same as alternative B Same as alternative B, but

annual operating costs 

would have the potential to 

increase to the greatest 

extent under alternative C

due to greater amounts of 

recommended wilderness.

The extent of potential cost 

increases is uncertain at 

programmatic level.

Same as alternative A
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

73

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

maintenance of stock water 

developments, salt 

placement and potentially 

restrict installation of new 

range improvements (water 

troughs) and could increase 

costs for ranchers.

Recommended 

Wilderness

Wilderness 

Character

No impacts since no new 

wilderness recommended

The impacts of managing 

sage-grouse habitat on 

wilderness character would 

be minimal given the small 

amount of habitat inside the 

addition.

Same as alternative B Would likely be impacts to 

wilderness character from 

restoration activities required 

to adequately maintain sagegrouse habitat and conduct 

other restoration activities,

which would likely impact the 

untrammeled quality of 

wilderness character

because conifer removal and 

prescribed fire activities 

would be evident, at least for 

short-term periods.

No impacts since no new 

wilderness recommended

Pacific Crest 

National Scenic 

Trail Corridor 

No changes Provides protection for the 

resources, qualities, values, 

and associated settings and 

primary uses of the Pacific 

Crest National Scenic Trail.

No system roads or trails are 

proposed to be closed or 

changed in management or 

use on trail related to the 

Pacific Crest Trail Corridor.

Since there are no existing 

permits for recreation events 

on the Pacific Crest Trail, 

there would be no 

displacement of permittees. 

The prohibition of new 

events would decrease the 

potential for displacement of 

and conflict with the primary 

Pacific Crest Trail users, 

hikers (including individual 

trail runners) and 

equestrians. Three miles of

the Pacific Crest Trail

Same as alternative B Same as alternative B but 

given the number of acres in 

the management area, 

provides the most protection 

for the resources, qualities, 

values, and associated 

settings and primary uses of 

the Pacific Crest National 

Scenic Trail. 

Same as alternative B
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

74

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

outside of wilderness would 

be closed to recreation 

events. Recreation events 

could occur on the remaining 

587 miles of trails outside of 

wilderness on the Inyo.

Forest Products Would continue 

management at current 

levels of mechanical 

treatments, with limited 

improvements in forest 

health and resilience to 

disturbance agents and 

climate change at the project 

(stand) level. Landscape 

resilience would continue to 

decline.

Could potentially increase 

pace and scale of 

mechanical treatments from 

the existing conditions, 

incrementally improving 

forest health and resilience 

to disturbance agents and 

climate change. Would 

increase fuelwood 

availability.

Same as alternative B Would decrease the pace 

and scale of mechanical 

treatments from the existing 

conditions thereby 

decreasing forest products 

production; however, small 

improvements in forest 

health and resilience would 

be expected to occur in the 

short term at the project 

(stand) level, similar to 

alternative A.

Would increase pace and 

scale of mechanical 

treatments from the existing 

conditions, improving forest 

health and resilience to 

disturbance agents and 

climate change. However, 

the absence of infrastructure 

may limit achievement of 

desired objectives. Would 

increase fuelwood 

availability.

Production 

Livestock 

Grazing

Gradual improvement in 

ecological conditions in 

allotments likely to continue 

in this and the plan revision 

alternatives based on current 

direction. 

Modernizes current direction 

and analysis procedures 

(now found as a technical 

guide outside of the plan) to

provide modest 

improvements in riparian 

conservation areas and 

resilience to disturbance and 

climate change at the 

allotment level.

Same as alternative B Same as alternative B Updates same as alternative 

B. There would be no effects 

related to recommended 

wilderness. 

Economic 

Conditions

The continuation of current 

management activities in the 

face of current resource 

conditions (such as

vegetation) and trends is 

expected to result in more 

disruptive events, such as 

uncharacteristic wildfire, and 

additional declines in forest 

health. This could have 

adverse short- and long-term 

effects on economic benefits 

to local communities, and 

could affect opportunities in 

terms of recreation and other 

economic benefits. 

Alternative B would have 

long-term beneficial effects 

on economic conditions in 

local communities and on 

the Inyo National Forest. In 

the short term, there is the 

potential for disruption to 

some of these benefits from 

increased activities.

Same as alternative B Alternative C would have 

some long-term beneficial 

effects on economic 

conditions in local 

communities and on the 

Inyo’s benefits to people’s 

lives. However, there is a 

long-term loss of the 

opportunities for developing 

local biomass industries as a 

result of this alternative.

Would be similar to 

alternative B. The increased 

pace and scale of restoration 

could potentially provide 

even greater benefits;

however, it could also lead to 

potential increases in the 

short-term adverse effects 

resulting from these 

restoration activities.
Chapter 2. Alternatives, Including the Proposed Action

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

75

Resource Alternative A Alternative B Alternative B-modified Alternative C Alternative D

Social 

Conditions

Contributes to sustaining a 

diverse set of forest-related 

values in the long term, but 

is not as integrated as the 

plan revision alternatives.

Supports a diverse set of 

forest-related values in the 

long term through increased 

ecological restoration that 

moves forest conditions 

closer to ecosystem desired 

conditions and fire-resilient 

landscapes. By moving 

toward these desired 

conditions, aesthetic, 

biodiversity, cultural, 

economic, learning, 

recreation, and well-being 

values are sustained over 

the long term.

Same as alternative B Values are more at risk to 

negative impacts over the 

long term given limited 

ecological restoration 

treatments.

Same as alternative B.

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

77

Chapter 3. Affected Environment and Environmental 

Consequences

Introduction

This chapter summarizes the physical, biological, social, and economic environments of the plan 

area and the potential environmental consequences that may occur in those environments by 

implementing each alternative. It also presents the scientific and analytical basis for the 

comparison of alternatives presented in chapter 2. In some cases where indicated, more detailed 

information, including methodology, assumptions, and effects analyses, can be found in the 

specific resource supplemental report located in the planning record located at the Pacific 

Southwest Regional Office, Vallejo, California.

The Relationship between

Forest Plans and Site-specific Activities

The focus of this analysis is to examine the implications or longer term environmental 

consequences of managing the Inyo National Forest under the programmatic framework provided 

by the draft revised forest plan and alternatives. Forest plans do not authorize, fund, or carry out 

any project or activity described in the effects analyses. Instead, they provide a programmatic 

framework that guides site-specific actions that may be carried out in the future.

Because a land management plan does not authorize or mandate any site-specific projects or 

activities (including ground-disturbing actions), there can be no direct effects. The draft forest 

plans set the stage for what future management actions are needed to achieve desired outcomes 

(for example, desired conditions and objectives), and provide the sideboards (such as suitability, 

standards, and guidelines) under which future activities may occur to manage risks to ecological, 

social, and economic environments. The draft forest plans also identify potential management 

approaches that may be used to help achieve desired conditions. To actually plan and proceed 

with a site-specific project, project-level planning, environmental analysis, and decisions must 

occur. (For example, the forest plan contains direction to thin vegetation and reduce fuels to 

benefit ecosystem resilience; however, a subsequent site-specific analysis and decision must be 

made for each proposal that involves vegetation treatment or fuel reduction activity in a chosen 

area).

Science and Assumptions

Used in the Environmental Analyses

During development of the environmental analyses that follow, the planning team used the best 

available scientific information, which is documented in the planning record. The environmental 

analyses focus on the needs for changing the existing plan and the issues identified through the 

scoping process; they also examine potential effects to programs and resources on the Inyo 

National Forest.

The discussions in chapter 3 refer to the potential for consequences to occur, realizing that in 

many cases, they are only estimates. To estimate the consequences of alternatives at the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

78

programmatic plan level, we must assume that the kinds of resource management activities 

allowed under the prescriptions will occur to the extent necessary to achieve objectives and move 

national forest resources toward the desired conditions of each alternative. This method of 

analysis is useful when comparing and evaluating alternatives on a forestwide basis but it is not to 

be applied to specific locations on a national forest.

Several assumptions made in the analyses of alternatives, include:

• Law, policy, regulations, and applicable best management practices would be followed 

when planning or implementing site-specific projects and activities.

• Plan components (such as desired conditions, objectives, standards, guidelines, and 

suitability of lands) would be followed when planning or implementing site-specific 

projects and activities.

• Goals and potential management approaches would influence collaborative efforts and be 

considered in developing programs of work.

• Plan objectives may be stated as a range (from low to high). The actual level of 

accomplishment would depend on environmental conditions, budgets, and staffing.

• Implementation of a land management plan would facilitate progress toward the attainment 

of desired conditions for each resource. As movement toward or achievement of desired 

conditions is made, forest ecosystems would become healthier and more resilient and 

would continue to provide for species diversity, goods, and services.

• The planning period is 10 to 15 years; other timeframes may be used to compare expected 

future trends. Plans are expected to be revised at least every 15 years.

• Plan monitoring would occur and the land management plan will be amended, as needed.

How this Chapter is Organized

First, a general analysis of environmental consequences of drivers and stressors of climate, fire, 

insects, and pathogens are described since they can affect many resource areas. Then, 

environmental consequences are organized under each revision topic. Finally, an analysis of the 

benefits to people and communities and consequences to tribal relations and uses is provided at 

the end of this chapter to evaluate how the alternatives contribute to economic and social 

wellbeing.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

79

Agents of Change: Climate, Fire, Insects, and Pathogens

Drivers and stressors are recurring events, processes, or actions that affect ecosystems. These 

effects are important to ecosystem condition. For example, fire creates variation in habitat, which 

is important for biodiversity—it keeps vegetation density and surface fuels low and patchier; it is 

a “driver” of ecosystem condition. Fire can be a stressor when it is more severe than usual and 

outside its natural range of variation, occurring either less frequently or more frequently than in 

the past.

The context in which fire occurs is also important. For example, because the scenery around the 

Mammoth Lakes area is important to this place that has great recreational value, high-severity fire

can decrease the scenic character and lower the recreation value. Scenery impacts from fire can 

be short term if they cover small areas and are visually absorbed as vegetation recovers, or they 

can be long term if they cover wide visible expanses dominated by burned forest.

Other important drivers and stressors are insects and pathogens, climate change, and air pollution.

Climate is a fundamental process that strongly influences other drivers and stressors in the Sierra

Nevada, including fire, invasive species, insects, pathogens, water development and diversion, air 

pollution, and land use patterns.

In this section, three aspects of drivers and stressors are covered broadly. These include climate; 

trends in fire with climate; and insects and pathogens. In later sections, we discuss response of 

specific vegetation types, habitats (such as old forest), and ecosystem functions (such as carbon 

storage) to drivers and stressors. Invasive plants are one of the most important, widespread 

stressors on the Inyo National Forest. Invasive animals and insects are increasingly important 

stressors that are addressed in the “Terrestrial Ecosystems,” “Aquatic and Riparian Ecosystems” 

and “Wildlife, Fish and Plants” sections. Fire management is covered in revision topic 1. Air 

pollution impacts are covered in the “Air Resources” section.

Although climate change is an important theme in this section, it is also woven throughout many 

sections in the document because it influences and affects many aspects of national forests. There 

is a specific subsection focused on ecological vulnerabilities to climate and analysis of climate 

adaptation strategies proposed for each alternative at the end of the “Terrestrial Ecosystems” 

section.

Climate Change

Background

Climate change is anticipated to have lasting, large-scale impacts to a variety of ecological, 

social, and economic resources in the national forests of the southern Sierra Nevada. This section 

summarizes current and future trends of climate to form a foundation for other analyses in this 

chapter. Carbon sequestration and greenhouse gas emissions are not covered in this section but 

are addressed in the “Air Resources” and “Terrestrial Ecosystems” sections. The effects of 

climate change on specific social, cultural, and biological resources (such as cultural resources 

and species of special concern) are also covered in each relevant section of this chapter.

This section summarizes the more detailed analysis of climate, ecological vulnerability and 

adaptation found in the final bio-regional and national forest assessments (USDA Forest Service

2013a, 2013d), and the snapshots of the Living Assessment used to develop the final assessments 

(USDA Forest Service 2013e, f).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

80

Recent Past and Current Trends

Mean annual temperatures in the plan area have increased in the last several decades, mostly with 

increased nighttime minimum temperatures (Mallek, Safford, and Sawyer 2012) consistent with 

larger bioregional and global patterns of increasing temperatures (Intergovernmental Panel on 

Climate Change 2014, Safford, North, and Meyer. 2012). Unlike much of the rest of the Sierra 

Nevada, overall precipitation has remained steady at higher elevations (mostly above 7,000 feet) 

but there have been some decreases at lower elevations (Safford, North, and Meyer. 2012). There 

has been a decrease in the amount of snow at low to mid-elevations and an increase in year-toyear variability (wetter wet years and drier dry years). At higher elevations, overall snowfall and 

spring snow water equivalent (amount of water in snowpack) have remained steady in most 

southern Sierra Nevada areas. Changes in temperatures and amounts and timing of precipitation 

have led to earlier peak stream flow rates in most Sierra Nevada streams, with higher spring flows 

and lower summer flows. Warming temperatures are leading to glacial recession across the 

southern Sierra Nevada.

The recent exceptional drought event in California (2012-2015) is unprecedented in the last 1,000 

to 10,000 years for California, especially in southern and central California and including the plan 

area (Griffin and Anchukaitis 2014, Robeson 2015). The exceptional nature of this drought are a 

consequence of consecutive record low levels of precipitation perpetuated by a persistent 

atmospheric ridging system in the North Pacific. Recent evidence suggests that Arctic sea-ice loss 

has increased the potential for a North Pacific atmospheric ridge development that blocks 

precipitation-inducing winter storms from reaching California (Cvijanovic et al. 2017).

Consequently, warming temperature trends associated with climate change may produce more 

extreme drought events in California (such as increased frequency or severity of drought) through 

the alteration of climatic systems over the Pacific Ocean (Cvijanovic et al. 2017). Although there 

is uncertainty inherent in these climatic systems and their effect on precipitation patterns, it is 

clear that climatic warming has exacerbated drought events in California through increased water 

stress associated with decreased soil moisture, increased runoff, and higher rates of 

evapotranspiration (Vose, Miniat, et al. 2016, Vose, Clark, and Luce 2016, Intergovernmental 

Panel on Climate Change 2014).

Projected Future Trends in Climate and Hydrology

Although climate change models vary in their projections for the latter half of the 21st century, all 

predict significant warming in the Sierra Nevada. Most expect precipitation to remain similar or 

slightly reduced compared to today (Safford, North, and Meyer 2012). Most models also agree 

that summers will be drier (causing higher evapotranspiration rates) on average. Although 

snowpack in the higher elevations (higher than 7,500 feet) of the southern Sierra Nevada has 

generally remained steady (or risen) over the past half-century (Meyer, Safford, and Sawyer 

2012), continued warming is likely to decrease snowpack in much of the high southern Sierra 

Nevada.

Most models project a continuously increasing rain-to-snow ratio and earlier runoff dates for the 

next century, especially at higher elevations. Under most climate scenarios, models project higher 

winter-to-early spring runoff and lower spring-to-summer runoff, as higher temperatures hasten 

the onset of snowmelt. This could increase downstream flood potential due to earlier peak flow 

rates and the increased proportion of precipitation falling as rain. If overall precipitation increases 

over time, streamflow volumes during peak runoff will increase even more, leading to notably 

higher flood risk in downstream areas.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

81

Fire Trends

This section summarizes trends in fire with climate and general vegetation conditions. These 

trends are important to understanding conditions and fire effects to terrestrial, riparian and aquatic 

ecosystems, and social and economic conditions.

Background

Fires have been increasingly large and severe throughout the western U.S. (Calkin et al. 2005, 

Westerling, Hidalgo, Cayan, and Swetnam 2006) and California (Miller, Safford, et al. 2009, 

Miller and Safford 2012) over the last several decades. The effects of these fires are often seen by 

people as overwhelmingly negative. In much of the wildlands of the western U.S. and the analysis 

area, fire has played a central role in shaping ecosystems. Both the beneficial and destructive 

aspects of fire are important to understand. The analysis examines different characteristics of fire, 

which can have implications for the wildlands in areas we live in and use.

In this section, the trends in burned area and fire size are addressed in response to climate change 

and scenarios that represent different levels of vegetation restoration. The fire responses to the 

scenarios are used to describe the consequences of the alternatives on large fire size and burned 

area. The impacts of fire to vegetation and other ecological aspects of fire are covered in more 

detail in the “Terrestrial Ecosystems” section. Aspects of fire related to impacts on communities, 

people, and infrastructure (such as water systems or powerlines) are covered in the “Fire 

Management,” “Economic Conditions,” and “Social Conditions” sections. The projected trends in 

fire in this section provide a common basis for assumptions on fire trends for all other analysis 

sections in this document.

Analysis and Methods

This section is based primarily on a quantitative analysis of fire-climate trends conducted by the 

University of California (UC) in Merced as part of a cooperative agreement with the Forest 

Service (Westerling, Milostan, and Keyser. 2015). Other scientific literature used is found in the 

Fire-climate supplemental report.

Climate scientists at UC Merced conducted a study to predict trends in wildfire with climate 

change under a broad range of different levels of vegetation restoration. The predictions are based 

on data from recent and past wildfires, associated vegetation condition, and climate data. The 

methodology was established in previously published research by Westerling and others (Preisler 

et al. 2008, Holmes, Jr, and Westerling 2008, Bryant and Westerling 2014, Preisler et al. 2015).

This research applies a statistical approach to predicting wildfire, in contrast to mechanistic 

models, such as FARSITE. They are well suited for broad analysis that takes into account trends 

in wildfire with climate change.

Scientists made projections of climate using several different climate models, since common 

trends in different models would indicate a more certain trend. The results presented here are 

primarily for the Geophysical Fluid Dynamics Laboratory A2 climate scenario, as well as some 

results from the Centre National de Recherches Météorologiques (CNRM) and Community 

Climate System Model (CCSM) A2 climate scenario (Westerling, Milostan, and Keyser. 2015). 

The differences between wildfire predictions for the selected climate scenarios were small 

compared to the effects of the restoration treatments scenarios. The Geophysical Fluid Dynamics 

Laboratory climate model was emphasized because it yielded mid-century increases in wildfire 

activity between the CNRM and CCSM models.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

82

Vegetation conditions were based on LANDFIRE vegetation condition class data (LANDFIRE 

2012). The conditions are derived from remote sensing data on existing vegetation density and 

species composition and derived differences with historic conditions based on fire history 

research and biophysical models of vegetation type and historic fire regime groups.21 Where there 

is a large departure in historic fire regime (that is, fire patterns and intensities are very different 

from what they used to be) and vegetation conditions are different than what they would have 

been under a historic fire regime, then the condition class is considered “highly departed.” The 

range of classes include:

• vegetation condition class 1: no to low departure;

• vegetation condition class 2: moderate departure; and

• vegetation condition class 3: high departure. 

An example of the conditions would be ponderosa pine or eastside Jeffrey pine that is currently 

dense but historically would have been maintained as open forests due to frequent, historic fire. 

Exploratory analysis revealed that fire patterns (large fire size, extent and burned area) varied 

with vegetation condition class. The vegetation condition class is a broad classification and was 

determined to be well suited to the programmatic plan and array of different combinations of 

individual vegetation desired condition components that would be the result of restoration.

Restoration treatments were modeled by changing potential treatment areas that are currently in 

vegetation condition class 3 or 2 to vegetation condition class 1. This is needed because previous 

exploratory analysis had shown that it was too difficult to discern differences in predicted fire 

trends between more subtle changes in vegetation condition class 3 to class 2 (Westerling 2015). 

The restoration treatments were not modeled in a specific spatial pattern with regards to treatment 

type, intensity, or frequency but as a broad landscape-level pattern to assess impacts at a 

programmatic level. These are referred to as “restoration scenarios” that included different types 

of restoration treatments (such as mechanical thinning or prescribed fire) or their combination 

applied over several decades. The restoration scenarios included 15 percent, 30 percent, 60 

percent, and 100 percent of the area restored, with an emphasis in the Sierra Nevada montane, 

and Great Basin ecological zones that occur on the Inyo National Forest (see “Terrestrial 

Ecosystems” section). Estimated restoration treatment rates by alternative are based on estimated 

values presented in table 4 (next page). The priority was on areas with vegetation heavily 

departed from historic conditions near roads but otherwise was randomly located. More detail on 

the analysis can be found in the final report (Westerling, Milostan, and Keyser 2015).

A summary of fire impacts in the “Affected Environment” section was based on a combination of 

recent observed and future projected changes in fire in the plan area and entire bio-region. Recent 

fire trends were based upon data assembled for the bio-region from the National Fire and Aviation 

Management database and include the time periods from 1961 to 1990. This “historic” baseline 

from 1961 to 1990 was intended to capture recent bioregional wildfire size and severity trends for 

this period that: (1) occurred during a period when active fire suppression and vegetation 

management was in effect (and not representative of the Natural Range of Variation); (2) was 

characterized by lower historic temperatures that preceded most current warming climate trends 

that began in the 1980s; and (3) reflected more accurate and reliable regional climate, hydrology, 

and fire data than earlier decades (primarily 1920-1960). In addition, this time period does not 

take into account very recent large fires, including the Rim and King Fires, but these were 

 21 http://www.landfire.gov/NationalProductDescriptions12.php
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

83

incorporated into the analysis using other information. Future projected changes focus on three 

periods, including early century (2010 to 2040), mid-century (2040 to 2070), and late-century 

(2070-2100) projections. These longer time periods are ideal in the analysis of climate changerelated fire effects in land management planning efforts (Peterson et al. 2011).

Table 4. Estimated amounts of restoration activities by alternative per decade

Type of Restoration Alternative A Alternative B

Alternative Bmodified Alternative C Alternative D

Acres of mechanical 

treatments

(TERR-FW-OBJ-01)

20,000 20,000 - 25,000 At least 

20,000 10,000 - 15,000 25,000 - 30,000

Acres of prescribed 

burning

(TERR-FW-OBJ-02)

18,000 20,000 - 25,000 At least 

20,000 15,000 - 35,000 20,000 - 25,000

Estimated acres of 

wildfires managed to 

meet resource 

objectives

11,300 58,000 64,000 34,000 119,000

Acres of nonnative

invasive plants treated 

(INV-FW-OBJ-01)

n/a 300 300 300 300

Acres of sage-grouse 

habitat maintained, 

improved, or restored

1,500 - 7,450 1,500 - 14,900 Up to 14,900 7,450 - 22,350 7,450 - 22,350

Estimated acres for mechanical treatments and prescribed burning come from fire occurrence and accomplishment 

reporting data (FACTS) for the last 20 years. Estimated acres of wildfires managed to meet resource objectives were also 

derived from FACTS for alternative A. For alternatives B, B-modified C, and D, acres are estimated from modeled natural 

wildfire ignitions with positive outcomes under different Energy Release Component (ERC) percentiles. The positive 

outcomes are measured by the outputs from the wildfire risk assessment (See Chapter 3, Analysis and Methods). Energy 

Release Component is a National Fire Danger Rating System (NFDRS) index related to how hot a fire can burn. It is 

directly related to the potential worst-case total energy released per unit area within the flaming from at the head of a fire. 

The percentile values are determined from historical weather observations and provide the criteria for ranking the severity 

of the burning conditions on a given day: alternatives B and B-modified are less than or equal to 90th percentile; 

alternative C is less than or equal to the 85th percentile; and alternative D is less than or equal to the 95th percentile.

Indicators and Measures

The primary indicators measured in this analysis are burned area, large fire size (greater than 494 

acres), and smoke and carbon emissions. Smoke and particulate emissions are described in the 

“Air Resources” section, and carbon emissions are described in the Carbon Supplemental Report. 

Other important indicators that are based upon inferences on large fire size, burned area, and 

vegetation conditions (like density and fuel levels) include fire intensity, fire type, and large areas 

of vegetation burned at high severity. A combination of a qualitative assessment using scientific 

literature and quantitative analysis using fire behavior modeling and sensitivity analysis of the 

statistical fire-climate model for selected areas were used to make inferences on fire intensity, fire 

type, and occurrence and size of large patches of high severity. 

Fire intensity refers to how hot a fire burns, or the amount of heat per unit area. Fire type refers to 

how the fire burns in relation to the height and type of vegetation it is burning in. A surface fire, 

burns in the understory of forests or shrub lands or chaparral. In contrast, a crown fire burns in the 

tops, or crowns, of trees or shrubs. Fire severity refers to the effects of fire on vegetation or soil or 

other ecosystem components and is often measured at the landscape scale using remote sensing 

data (Miller, Safford, et al. 2009). In vegetation, fires that have higher top kill and high levels of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

84

tree or plant death are considered high severity. See the “Terrestrial Ecosystems” section for more 

details.

Assumptions

The analysis of fire includes several assumptions.

• The use of models predicting fire trends based on past climate-fire patterns may underpredict future trends in fires because the models are based on observations occurring under 

milder fire weather conditions. Because future climate is expected to exceed these 

conditions there is uncertainty in the fire projections.

• Some fires exhibit a fire-atmospheric interaction where the fire influences the local weather 

affecting the fire. There is uncertainty around the extent that this may occur but it can 

dramatically alter fire size, intensity, and large patches of high severity such as seen on the 

Rim Fire 2013 and the King Fire 2014 (Coen et al. 2015) in the central Sierra Nevada. 

These phenomena may be increased with continued drought and climate trends.

• High fire intensity in dry, hot conditions is expected to be reduced to moderate or low 

intensity or a mosaic of intensities when at least 20 to 40 percent of a landscape area is in a 

low or reduced fuel condition. A variety of landscape theory, fire modeling, and fire 

behavior case studies support this (Turner 1989, Parisien, Junor, and Kafka 2007, Parisien 

et al. 2010, Parisien et al. 2012, Fites-Kaufman 2014, Coen et al. 2015, Schmidt, Taylor, 

and Skinner 2008, Collins and Skinner 2014b), although this specific proportion is 

dependent on a number of landscape factors (such as strategic placement of treatments, 

topographic complexity, fire weather conditions) resulting in some level of uncertainty 

within current and future forest landscapes. Based on this information, for this analysis we 

assume that at least 12,000 acres or more needs to have at least 40 percent of its area 

restored to result in changes in fire probability, extent, and large fire size. See Fire-Climate 

supplemental report for more detail.

Affected Environment

Recent Past and Current Trends

Prior to European settlement, fire was widespread throughout the bio-region and California 

(Sugihara et al. 2006, Stephens, Martin, and Clinton 2007). The frequency, spatial pattern, and 

severity varied by ecosystem (van Wagtendonk and Fites-Kaufman 2006, Brooks and Minnich 

2006). Most fires were low to moderate in intensity over large areas. This resulted in a mosaic of 

mostly surface fire, sweeping into the understory shrubs, herbs, small trees, and grasses, with

small clumps or patches of fire making its way into the crowns of trees (crown fire). In montane

chaparral and sagebrush, larger patches of crown fire would occur that reached the tops of the 

plants, killing them outright or top-killing them and stimulating new sprouts. Pinyon-juniper 

forests also typically experienced crown fire. See the “Terrestrial Ecosystems” section for more 

details on the historic and current fire regimes by major ecological zone and vegetation type. 

Overall, in the last century far less area has burned than did historically (Stephens, Martin, and 

Clinton 2007) but the severity has increased (Collins and Skinner 2014c, Mallek et al. 2013).

For thousands of years, Native Americans used fire to manage the landscape for a variety of 

beneficial uses (Anderson 2006). European settlement in the bio-region greatly intensified with 

discovery of gold in the Sierra Nevada in 1848 (Beesley 1996). At the same time, there was 

intensive logging to fuel steam-generated equipment and to build housing, along with extensive 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

85

grazing by livestock. These early settlers affected fire directly and indirectly in numerous ways

(Safford and Stevens 2017). Overall, widespread fire decreased.

Prior to the advent of modern Federal fire suppression policies (1905-1935), fire was more 

widespread and less intense (van Wagtendonk and Fites-Kaufman 2006, Stephens, Martin, and 

Clinton 2007). In the last 45 years, fires have become larger, and larger fires more frequent across 

the western U.S. (Calkin et al. 2005, Westerling and Bryant 2006). In the Sierra Nevada

(including the analysis area), the area burned annually in federally managed forests has increased 

by more than 24,700 acres per decade during this period (Westerling, Milostan, and Keyser. 

2015). Fire size has also changed, especially in recent years where some extremely large fires 

(such as McNally Fire 2002, Rim Fire 2013, and King Fire 2014) have burned, compared to the 

historical record. Since 1990, 9 out of the 10 largest recorded fires have occurred and 8 of those 

have been since 2000 alone (Steel, Safford, and Viers 2015).

Over 100 years of fire exclusion (fire suppression and lack of extensive intentional burning), 

along with other land uses, has changed how fire burns. Now fires burn with higher intensity, 

greater amounts of crown fire, and with larger areas of high severity (Miller, Safford, et al. 2009, 

Miller and Safford 2012, Mallek et al. 2013, Steel, Safford, and Viers 2015). Most recently, some 

fires have moved very rapidly, burning at high intensity in single days across large swaths. This 

includes the Rim Fire on the Stanislaus National Forest and King fire on the Eldorado and Tahoe 

National Forests. These types of fire behavior are more likely when the fire burns over large areas 

with multiple fire fronts and creates its own “fire weather.” Extensively burning areas create their 

own high winds that accelerate the fire and multiple fire fronts burn toward each other (Coen 

2005, Viegas et al. 2012). In the case of the King Fire, the very dry, uniformly dense overstory 

and understory vegetation across large areas combined to create three separate fronts or heads of 

the fire and an actively burning area of over 6,000 acres (Fites-Kaufman 2014). The heat from the 

three separate areas interacted and became one very large, several-miles-wide actively burning 

front and created winds of more than 40 miles per hour in front of the fire. After that, it grew to 

50,000 acres burning intensely and fast. Similar vegetation conditions (such as large areas of 

dense understory and overstory vegetation and fuels) are common and with drought, longer fire 

seasons, and increasing temperatures, very large fires are likely to repeat. It is not certain exactly 

where and when similar fires will occur, but it is highly likely that they will occur and that the 

impacts will be similar to those seen in recent very large fires that burned in similar conditions.

Climate (precipitation and temperature) and fire have always been linked (Swetnam 1993). 

Today, changes in land use and associated changes in vegetation (that is, fewer fire-tolerant 

species and denser vegetation) magnify the effects of a warming climate on fire behavior.

Projected Future Trends

The projected future trends are based primarily on the statistical fire-climate models (Westerling, 

Milostan, and Keyser. 2015).

Burned Area

There has been a trend of increased burn area associated with low winter snowpack in the western 

U.S. in recent decades (Westerling, Hidalgo, Cayan, and Swetnam 2006). Predictions for the 

analysis area and all of the Sierra Nevada are that the burned area will double or quadruple over 

the next 20 to 30 years (Westerling, Milostan, and Keyser. 2015). This would not be detrimental if 

the fires were low intensity, but much of the area is expected to burn at high intensity due to the
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

86

current vegetation density patterns and drier, longer fire season weather. Most of this increase in

burn area and fire intensity is associated with larger fires.

Figure 3 shows a map of changes in the predicted burned area in the next midcentury period, from 

2035 to 2064, compared to 1961 through 1990, a period prior to the advent of widespread very 

large high-intensity wildfires. The change is shown in colors labeled on a scale at the bottom of 

the figure, below the outline map of California. Light green depicts no change or a decrease in the 

amount of burned area. Yellow to orange represents an increase of more than 1 to 2 times the 

amount of burned area. Red colors depict a tripling of burned area, and the darkest maroon colors 

represent a quadrupling of burned area. 

Figure 3. Map of changes in the predicted burned area in the next mid-century, 

2035 to 2064, compared to 1961 through 1990

The greatest increases are expected in the upper montane and subalpine areas. The montane zone, 

where mixed conifer, ponderosa and Jeffrey pine forests occur show double to triple area burned. 

The least changes are in the lowest elevations on the west and east slopes, in the foothills on the 

west, and in the Great Basin sagebrush and pinyon-juniper on the east. These areas are shown in 

orange and still have one and a half to two times the area burned.

Fire Size and Likelihood of Very Large Fires

Average fire size is expected to increase by 13 to 20 percent by mid-century with climate change 

in the absence of additional treatments to restore vegetation and reduce density and surface fuels 

(Westerling, Milostan, and Keyser 2015). The likelihood of very large fires is increasing as well. 

The probability of fires becoming larger than 24,700 acres increases between 23 and 52 percent 

by mid-century. The average size of large fires (larger than 494 acres) is projected to increase 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

87

between 15 and 25 percent in the coming decades. None of these predictions account for the 

growing prevalence of very large fires driven by fire-atmospheric interactions, as discussed 

above. Increases in fire-atmospheric interactions would contribute to an even greater increase in 

the size and probability of large fires.

Figure 4 shows a line graph of the expected change in large fire size with different future climate 

scenarios. This is based solely on changes in climate as no changes in vegetation from restoration 

treatments were included in this calculation. The first graph shows the predicted trends in large 

fire size between 2035 and 2064 for the three different climate models. The blue line is based on 

the Community Climate System model (CCSM). The red line is based on the Geophysical Fluid 

Dynamics Laboratory (GFDL) model and the green line is based on the Centre National de 

Recherches Météorologiques (CNRM) model. The y-axis shows the percent change in large fire 

size, which is predicted to increase by 13 to 20 percent over the time period.

Figure 4. Predicted change in large fire size from recent (1961 to 1990) rates based on 

three climate models

The second line graph in figure 5, shows predicted trends when different amounts of the mid- and 

low-elevation landscapes are modeled as restored (from vegetation condition class 2 or 3 to class 

1).22 There is a predicted trend of increasing large fire size for all restoration scenarios except for 

60 percent, which stays nearly constant with current large fire size, and 100 percent, which shows 

a decrease in large fire size. This is consistent with other research predicting increases in fire with 

climate change, such as Moritz and Stephens 2008.

The amount of predicted change in area burned in large fires varies across the plan area somewhat 

aligned with differences in ecological and elevational zones. The montane and upper montane 

landscapes have the greatest increase in likelihood of large fires, with a 30 to 55 percent increase, 

respectively.

Figure 6 shows predicted trends in area burned in large fires separated out by ecological zone as 

modeled by the Geophysical Fluid Dynamics Laboratory A2 model (or GFDL A2). It is only 

shown for one climate scenario because the relative differences between the ecological zones are 

the same across the other climate models. The increase in probability of large fires remains above 

 22 Using the Geophysical Fluid Dynamics Laboratory or GFDL model
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

88

10 percent for the montane zone until the 60 percent scenario, where the trends decrease for all 

ecological zones except for the upper montane zone. This is because climate will have more

effect on increasing fire in the upper montane zone and most treatments were prioritized in the 

lower elevation zones because this zone is closest to communities that has the most values at risk 

(homes and infrastructure). These lower elevation areas are most deviated from the desired 

condition and natural range of variation.

Figure 5. Line graphs showing the expected change in large fire size with different 

future climate and vegetation restoration scenarios

Figure 6. Bar graph showing the change in large fire size by mid-century (2035-

2064) compared to “baseline” conditions (1961-1990) displayed by ecological zone 

and level of modeled restoration based on the GFDL model and A2 emissions 

scenario.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

89

Fire Intensity, Fire Type, and Severity

Changes in fire extent and large fire size are likely to be correlated with higher intensity and 

higher levels of crown fire. Increased crown fire is expected because of large areas of the 

landscape with dense vegetation and fuels that can cause more intense and larger fires (Collins 

and Skinner 2014a); such fires have the potential for more fire-atmospheric interactions (Coen 

2005, Werth et al. 2011) and predicted drier and warmer fire weather conditions (Westerling, 

Milostan, and Keyser. 2015).Warmer and drier environments cause lower fuel moisture levels and 

more intense fires. Once a crown fire starts, it is likely to spread in nearby areas with dense crown 

fuels. As described above, this can accelerate rapidly and cover very large areas in a short time if 

fire-atmospheric interactions occur (Werth et al. 2011), or if one part of the fire interacts with 

another causing a “mass fire” (Finney and McAllister 2011, Viegas et al. 2012). More information

on potential fire types, including crown fire, are found in the “Terrestrial Ecosystems” section, 

under “Fire Resilience.”

The amount and patch size of high-severity fire is most important for evaluating the consequences 

to ecosystems, particularly in vegetation types that historically had low- and mixed-severity fire 

regimes. High-severity fire is difficult to predict because it depends on the interaction of 

vegetation composition (size and species) and structure, and fire intensity and duration. Available 

research on predicting high fire severity at the landscape scale focuses on statistical analysis of 

fire size with fire severity (Westerling and Keyser 2016a). An analysis of fires and large areas and 

patches of high fire severity in the Sierra Nevada and southern Oregon, (Farris 2015, personal 

communication (Fites-Kaufman 2015) found that there is a correlation between very large fires 

(such as the Rim Fire) and both the amount of and size of large patches of high severity. This may 

partly be because larger fires can have larger patches of high severity whereas smaller fires 

physical can’t. However, short but intense fire runs can burn a lot of area, particularly under 

extreme weather conditions, such as on the Rim and King Fires. Statistical modeling shows that 

high fire severity areas show similar trends with climate to the trends in burned area (Westerling, 

Milostan, and Keyser. 2015, Westerling and Keyser 2016b). The model predicted that fire severity 

was more sensitive to changes in restoration scenarios than burned area alone. In other words, 

with restoration, fire severity declines more sharply than in burned areas.

Modeling of trends in high fire severity with climate change and restoration scenarios by UC 

Merced show increasing total area burned with higher fire severity (greater than 50 percent of 

overstory vegetation killed) and increasing size of high fire severity patches. Figure 7 shows that 

in the map on the left with no fuels treatments, the area burned at high severity is expected to 

increase between 100 and 200 percent across most of the analysis area. The map in the middle 

shows the 30 percent restoration scenario, where most areas show decreases in the trend, but 

overall there is still a 50 to 100 percent increase in predicted area burned at high severity across 

the analysis area. High elevation areas show little change with the restoration scenario because 

most of the areas are in wilderness and wildfire managed to meet resource objectives was not 

modeled. The map on the right shows the 60 percent restoration scenario, where there are large 

landscape areas that show levels less than 20 and 40 percent growth, and some with reductions. 

The reductions are in areas where larger concentrations of simulated restored areas occurred. The 

legend on the bottom ranges from a reduction of -20 percent (green) to an increase of 300 percent 

(dark red) on the right.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

90

Figure 7. Percent change in area burned at high severity (defined as greater than 50 percent 

overstory mortality) with future trends in climate

Environmental Consequences to Fire Trends

The consequences of the alternatives were based largely on the UC Merced fire-climate modeling 

and how the results varied with four different restoration scenarios. Table 5 provides a summary 

comparing restoration levels by alternative and table 6 and table 7 provide an overall summary of 

the consequences of the alternatives on future fire trends.

Each alternative has proposed restoration levels of different treatment types (mechanical, 

prescribed fire, wildfire managed to meet resource objectives) that are described in acres that 

would be treated and fire ignitions that would be managed. These proposed restoration levels fall 

in between the restoration scenarios used in the fire-climate modeling. For example, proposed 

restoration objectives for alternative B (TERR-FW-OBJ-01 to 03; MA-RCA-OBJ-01; SCENFW-OBJ-01; SPEC-SG-OBJ-01) are mostly expressed in ranges that correspond to a restoration 

of 15 to 30 percent of the low and mid-elevation landscape. The proposed restoration levels for 

the alternatives vary by ecological zone. For example, there is little restoration planned in the 

subalpine/alpine zone except for wildfires managed to meet resource objectives. Table 5 below 

describes how the restoration levels in the scenarios were cross-walked to the restoration levels in 

the alternatives for this analysis.

In general, alternative A is represented by the historic “baseline” scenario, with restoration rates 

remaining the same at 5 to 10 percent of the landscape. Alternatives B and B-modified are 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

91

represented by conditions in the 30 percent restoration scenario. Alternative C is represented by 

the range of conditions between the 15 and 30 percent restoration scenarios. Alternative D is 

represented by conditions in the 60 percent scenario. The amount of restoration depends upon the 

location and is described in the narrative below. For example, more remote areas may receive 

higher levels of managed fire, such as the Kern River drainage. In areas where there is a 

prevalence of tree encroachment into sage-grouse habitat and sagebrush, the level of restoration 

will be higher in alternatives that have higher rates of restoration (alternatives B, B-modified, and 

D).

Table 5. Summary comparison of proposed restoration levels by alternative

Restoration Modeling 

Scenario Alternative A

Alternative B

and Alternative 

B-modified Alternative C Alternative D

Current levels (historic or 

baseline scenario; 5-10 

percent)

Yes No No No

15 percent No No Yes No

30 percent No Yes Yes No

60 percent No No No Yes

100 percent No No No No

Table 6 summarizes the expected changes in fire burned area, large fire size, likelihood of large 

fires, and fire intensity and fire type with projected climate trends by alternative. The information

is based primarily upon the analysis by UC Merced (Westerling, Milostan, and Keyser. 2015). 

The values are for the Geophysical Fluid Dynamics Laboratory (GFDL) model which represents 

the median model projections amongst the three climate models described earlier. More details on 

all three simulations are in (Westerling, Milostan, and Keyser. 2015). Table 7 shows the change in 

likelihood of large fires by alternative and by ecological and elevational zone for all areas. Both 

of these tables are referenced in the analysis of environmental consequences by alternative below.

Table 6. Summary of expected changes in fire burned area, large fire size, likelihood of large fires, 

and fire intensity and fire type with projected climate trends by alternative

Indicator Alternative A

Alternative B

and Alternative 

B-modified Alternative C Alternative D

Percent change to 

large fire size 

23 percent 

increase

12 to 17 percent 

increase

Similar to 

alternative A

3 to 12 percent 

increase

Fire intensity and 

type (crown versus

surface fire) in hot, 

dry conditions

High; decreased 

in areas of recent 

large wildfires

High, with some 

limited decrease 

(large prescribed 

fires, managed 

fire areas)

High, except 

decreased in 

limited areas 

(large prescribed 

fire and managed 

fire areas)

Moderate to high, 

Large patches (more 

than 1,000 acres) of 

very high severity 

and intensity (based 

on increases in 

large fire size)

At least 23 to 30 

percent increase

At least 10 to 18 

percent increase

Similar to 

alternative A

At least 4 to 11 

percent increase
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

92

Table 7. Percentage change in likelihood of large fires by alternative and ecological/elevational zone

Ecological/

Elevation Zone Alternative A

Alternative B and 

Alternative Bmodified Alternative C Alternative D

Montane 23 to 31 percent 

increase

3 to 18 percent 

increase

Similar to 

alternative A

10 percent 

increase to 11 

percent decrease

Upper Montane 55 percent 

increase

38 to 43 percent 

increase

Similar but lower 

percent increase 

than B

19 to 38 percent 

increase

Great Basin 14 to 24 percent 

increase

1 to 10 percent 

increase 

Less than A but 

more than B 

1 increase to 6 

percent decrease

Consequences Common to all Alternatives

Although there is uncertainty in all the alternatives about how much prescribed fire and wildfire 

managed to meet resource objectives will occur, we anticipate that management direction would

support planned levels (table 4, page 83). Spring burning is when much of prescribed fire can be 

safely done in the dry and warmer fuel conditions that occur more frequently than in the past. In

all alternatives, there are uncertainties in how much fire would occur for several other reasons. 

First, drier fuel conditions and longer fire seasons decrease the available window to conduct 

prescribed burns to safely meet burn objectives. Second, limited operating periods for deer

fawning and sage-grouse would make spring burning unlikely in many areas in the montane and 

Jeffrey pine areas. Similarly, restrictions on burning in riparian area habitat for federally listed 

species such as yellow-legged frog and Yosemite toad would make spring burning more difficult 

in many areas. Lastly, there are uncertainties about the ability to conduct prescribed burning 

because of air quality constraints. Because of these uncertainties, the amount of restoration using 

prescribed fire may be overestimated for all alternatives.

Increases in visitors to the Inyo National Forest in general are likely to result in more humancaused ignitions. Over 90 percent of wildfires (unplanned ignitions) are ignited by people (see 

“Fire Management” section). Some of the fires with the largest size and highest intensity that 

have occurred in the analysis area and nearby were caused by human ignitions. This includes the 

Rim (2013) and King (2014) Fires in the central Sierra Nevada. The increase in human-caused 

ignitions may result in an increase of fires that become very large, very fast, and burn much of the 

area at very high intensity because of the combined effects of uniformly dense vegetation and 

high fuel loads, warming climate, drought, and invasive grasses.

Consequences Specific to Alternative A

Average annual burned acreage, large fire size, and fire intensity are expected to continue to 

increase under alternative A. Limited amounts of vegetation restoration, including mechanical 

thinning, prescribed fire, and wildfire managed to meet resource objectives would occur in most 

areas. Based upon the projected trends with climate change, burned area would increase by two to 

four times. Much of the change would be in increasingly larger fires. These are likely to have 

large patches of high-intensity fire and high-severity fire effects. This is expected because of 

projected increases in temperature and decreased precipitation, resulting in a longer fire season. 

The greatest changes would be in the montane zone, except in the Kern River drainage (including 

the Kern Plateau). Here, there would be similar patterns of burned area but decreased fire sizes 

and intensities as fires burn into other recent fires from the last 15 years. There would be a 

continued trend of increased fire on the eastside in the pinyon-juniper, sagebrush and desert 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

93

ecosystems. Fire size would continue to increase in these eastside areas, especially where 

extensive invasions of the nonnative cheatgrass or red brome have occurred (sagebrush, pinyonjuniper, xeric shrub and blackbrush vegetation). Nonnative annual grasses are more flammable 

and create more continuous fuel conditions that make fire spread more extensively (Brooks and 

Minnich 2006, Klinger, Brooks, and Randall 2006).

Consequences Specific to Alternative B

In alternative B, there would be an increase in the amount of vegetation restoration that would

reduce the likelihood of large fires, burned area, and large patches of high fire severity (TERRFW-OBJ-01 to 03; MA-RCA-OBJ-01; SCEN-FW-OBJ-01; SPEC-SG-OBJ-01). There would be 

a continued trend of increasing burned area, large fire size, and fire severity with climate trends 

(figure 3, figure 6, figure 7); however, the rate of increase is lower (12 to 17 percent increase) 

than current rates of increase (23 percent) represented by alternative A (figure 6, Table 6). The 

proposed restoration levels would vary with location in the landscape. Treatments would be 

prioritized in the montane, (WRZ potential management approach) sagebrush (SPEC-SG-OBJ01), and pinyon-juniper areas, including around communities (MA-CWPZ-GOAL-01 to 02), and 

other high value areas (TERR-FW-OBJ-01). In addition to restoration objectives, the following

potential management approaches in this alternative emphasize priorities in these areas:

Areas that historically supported more frequent fire, like Jeffrey pine-dominated forests, 

and areas with high existing levels of understory fuels are prioritized for treatment.

Prioritize fuel treatments in areas that pose the greatest threat to communities and highly 

valued resources. 

In some areas, such as Jeffrey pine forests on the Inyo National Forest there would be increases in 

restoration over current levels (table 4, page 83). In these areas, where about 30 percent of the 

area is restored to desired conditions, there would be decreases in fire intensity (Coen et al. 2015), 

high fire severity (Wimberly et al. 2009), and size of large patches of high severity. There may be 

some effect of decreasing large fire size overall when fires burn into treated areas, but this is more 

likely when larger treatments areas are concentrated within a landscape (that is, greater than 

12,000 acres; see analysis assumptions above). Goals (FIRE-FW-GOAL-01 and 03) and potential

management approaches emphasize treating larger landscape areas, using mechanical treatments 

and larger prescribed fires:

Develop landscape scale projects to increase the pace and scale of ecological restoration, 

ecosystem resilience and fire resilience, and to protect the carbon carrying capacity of the 

forest.

Plan vegetation, fuels, and other restoration projects across large landscape areas (e.g., 

greater than 5,000 to 10,000 acres), when it can increase efficiency in planning and 

support partnership-based approaches, such as stewardship contracts.

During ecological restoration treatments, reduce fuels along ridges, roads, or other natural 

or man-made features to aid in the use of large prescribed fires and in managing wildfire, 

including wildfires managed to meet resource objectives.

The ability to conduct treatments within these prioritized areas affects the likelihood that 

sufficient treatments would occur to result in changes in large, high-intensity size and high fire 

severity areas from future fires. There is a moderate level of uncertainty that the levels of 

projected prescribed fire treatments would occur due to smoke management and air quality 

concerns, agency capacity and budgets, and potential impacts to natural and cultural resources 

(for example, limited operating periods established to protect wildlife described above in 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

94

consequences for all alternatives). Without prescribed fire in mechanical treatment areas, it is less 

likely that all of the desired conditions for vegetation would be attained, particularly for 

understory plant diversity, and surface fuels reduction. This may mean that mechanical treatment 

restoration activities are less effective in changing fire behavior and restoring ecological pattern 

and process when these treatments are not combined with prescribed fire (Wimberly et al. 2009).

Changes in fire management toward a risk-based approach (strategic fire management zones, see 

“Fire Management” section) would result in more wildfire that is managed to meet resource 

objectives, especially in the wildfire maintenance zone (MA-WMZ-GOAL-01; MA-WMZ-STD01 to 02) and in some portions of the wildfire restoration zone (MA-WRZ-DC-02 to 03; MAWRZ-GOAL-01); some limited opportunities to manage wildfires to meet resource objectives 

may also be available in the general protection zone under specific conditions. This would result 

in decreased fuels, increased vegetation resilience, and has been shown to reduce future fire size 

and severity (Collins et al. 2009, Ewell, Reiner, and Williams 2012, Vaillant 2009), but most of 

these fires would occur at higher elevations in more remote locations. Implementing the plan 

management strategy of emphasizing ecological restoration along ridges and some roads would

improve the ability to reduce the intensity and spread rate of wildfires, manage fires to meet 

resource objectives, and conduct prescribed fires (MA-CWPZ-GDL-02; MA-GWPZ-GDL-01; 

MA-WRZ-STD-01; MA-WMZ-STD-02). It would contribute to fire suppression success and 

allow more wildfires to be managed to meet resource objectives but to an unknown degree 

because there are other factors influencing fire management decisions including weather, fuel 

conditions (how dry fuels are) and proximity to communities or values at risk (see “Fire 

Management” section).

In alternative B, there would continue to be large, high-intensity fires, with large patches of high 

intensity and severity, driven by fire-atmospheric interactions where fires generate their own 

weather and accelerate winds and fire intensity and spread (Coen et al. 2015). Similar to 

alternative A, large and intense wildfires would continue to expand in sagebrush and pinyonjuniper woodlands, especially where cheatgrass invasion has occurred. However, greater 

effectiveness of vegetation restoration is projected in the sagebrush and pinyon-juniper areas

under alternative B, where model projections show that treating one-third of landscape areas has 

benefits in reducing the likelihood of large fires (figure 7). Nevertheless, there is uncertainty in 

the effects of restoration treatments because continued invasion and establishment of nonnative, 

annual grasses can cause increases in fire spread and fire size in other untreated areas.

Consequences Specific to Alternative B-modified

The consequences of alternative B-modified would be similar to alternative B, but there would be 

a marginally higher restoration treatment rate under alternative B-modified. This is due to the 

higher rates of treatment from wildfires managed to meet resource objectives under alternative Bmodified, which would result in an additional 6,000 acres per decade treated with managed 

wildfire compared to alternative B. This will result in about a 2 percent increase in restoration 

treatment rates for relevant vegetation types on the Inyo National Forest (such as montane forest 

and sagebrush). Although 133,490 acres (or 7 percent of the total acres on the Inyo National 

Forest) under alternative B would be reclassified from the Maintenance or Restoration Fire 

Management Zone to the General Wildfire Protection Zone under Alternative B-modified, nearly 

all of these acres are located in the sagebrush vegetation type, where the primary restoration 

approaches would rely on methods other than wildfires managed to achieve resource objectives 

(prescribed burning and mechanical thinning of encroaching conifers). 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

95

Additional differences between alternatives B and alternative B-modified have negligible or no 

effects on treatment rates in the plan area. These include the removal of riparian conservation 

areas from the suitable landbase for timber production (see appendix A: Timber Suitability and 

Management), development of an aquatic conservation strategy (and designation of associated 

conservation watersheds), and changes to the Species of Conservation Concern list.

Alternative B-modified would result in increased vegetation restoration that would reduce the 

likelihood of large wildfires that contain large patches of high-severity fire. With projected future 

climate trends, there would be a continued trend of increasing burned area, large fire size, and fire 

severity under alternative B-modified due to the effect of increasing temperatures on wildfire 

activity. Similar to alternative B, prioritized treatments in montane forest, sagebrush, or pinyonjuniper woodland, including around communities and other high value areas, would result in the 

greatest reduction in the likelihood of large and severe wildfires under alternative B-modified.

In alternative B-modified, there would continue to be large and intense fires driven by fireatmospheric interactions. Similar to alternative B, cheatgrass invasion would continue in 

sagebrush and pinyon-juniper woodlands following large wildfires, especially in areas of existing

cheatgrass expansion. Continued cheatgrass invasion could cause increases in fire spread and size 

particularly in recently burned sites.

Consequences Specific to Alternative C

The consequences of alternative C would be similar to alternative A but there are uncertainties 

associated with the potential restoration amount and intensity in alternative C (table 4, page 83). 

The proposed area treated with prescribed fire and wildfire managed to meet resource objectives 

would increase and potentially double on the Inyo National Forest under alternative C compared 

to alternative A. Mechanical treatment on the Inyo National Forest would decrease by about 75 to 

100 percent. In addition to changes in the relative amounts of different treatment types, the 

intensity of treatments would be similar to alternative A and less than alternative B. Vegetation 

restoration is likely to be low treatment intensity because of an emphasis on retaining more

vegetation cover and key habitat structures for greater sage-grouse, Pacific fisher, Sierra marten, 

California spotted owl and other wildlife species.

There are fewer strategic fire management zones in alternative C, with more area emphasizing 

restoration of wildfire for resource objectives. However, the fire risks remain the same as in the 

other alternatives so it is expected that fire management decisions would be the same as 

alternative A, except in the wildfire maintenance zone. With this alternative, less area would have 

mechanical restoration and those actions would be less intense in reducing fuels and reducing fire 

risk. Alternative C strives to use more prescribed burning to reduce fuels and achieve desired 

conditions, but the amount of burning may be limited in some areas by the greater difficulty of 

burning areas with higher fuel loading and the same limited operating period constraints listed 

above in consequences common to all alternatives. There would likely be less ecological 

restoration along ridges and some roads using mechanical treatment alone or in combination with 

prescribed fire, which would make it more difficult to manage wildfire to meet resource 

objectives. Fewer acres would be restored in Jeffrey pine, pinyon-juniper, and sagebrush using 

mechanical treatment, prescribed fire, or wildfire managed to meet resource objectives. There 

would continue to be increases in the size and area of large, high-intensity fires, particularly 

where cheatgrass invasion has occurred.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

96

Consequences Specific to Alternative D

Alternative D is proposed to have the greatest level of restoration treatments of all kinds (table 4, 

page 83). Proposed plan direction guiding restoration treatments and fire management would be 

mostly similar to alternative B. Treatment areas in many areas of the Inyo National Forest would 

double. A greater proportional area is also restored (up to 30 percent). These increases in 

restoration are to levels where the fire-climate models predict there would be a leveling off or 

decrease in the current trend of greater likelihood of very large fires (table 6, table 7; Westerling, 

Milostan, and Keyser. 2015). Given the combination of more restored areas that would be less 

susceptible to high-intensity fire, there is expected to be a decrease in the amount of crown fire 

and large patches of high-severity fire trending toward the natural range of variation. There would 

be substantially more ecological restoration of ridges and roads that that can provide more 

opportunities to conduct large prescribed fires in steep areas (like in canyons) and to manage 

wildfire to meet resource objectives. This would increase the likelihood that more area is burned 

under low- to moderate-intensity conditions that decrease fuels, provide ecological benefits and 

further decrease the likelihood of large, high-intensity fires beyond the natural range of variation. 

However, in sagebrush and pinyon-juniper woodlands, large, high-intensity wildfires would be 

expected to occur, especially in areas of cheatgrass invasion. There is uncertainty about how 

much smoke regulations and air quality management would affect this potentially greater amount 

of prescribed fire and wildfires managed to meet resource objectives.

Cumulative Effects

There are cumulative effects spatially, from the management of adjacent landowners, and into the 

future with foreseeable trends in climate, human populations, and fire. Climate trends are 

influenced by many factors outside of the direct influence of projects and indirect influence of the 

plan revision alternatives. Trends in large, high-intensity fires are influenced by restoration 

treatments in adjacent areas and in the numbers and types of ignitions and fire management 

policy. Large adjacent land managers include the National Park Service, managing Sequoia, 

Kings Canyon and Yosemite National Parks, and the Bureau of Land Management. There are also 

large areas of private land next to and within the national forest in the analysis area. The Park

Service emphasizes fire restoration and has cooperated with the Forest Service numerous times 

on management of wildfires to meet resource objectives in the southern Sierra Nevada (Meyer 

2015a). There are also smaller private in-holdings and adjacent private lands where restoration 

treatments may occur. The draft forest plans emphasize an all-lands-management and sharedstewardship approach and this would occur with alternatives B, C and D (FIRE-FW-DC-02 to 03; 

LAND-FW-DC-02; TRIB-FW-DC-02; LOC-FW-DC-01 and 02; FIRE-FW-GOAL-02 to 04; 

LOC-FW-GOAL-01; VIPS-FW-GOAL-01). This includes the following potential management 

approaches:

Work with adjacent land management agencies to identify methods to reduce costs and 

increase effectiveness in restoring fire to the landscape.

Prior to and during the fire season assess conditional thresholds under which desired 

conditions can be met for the strategic fire management zones (see management areas 

section in this chapter). Work with tribes and adjacent landowners to identify areas and 

resources of value considered in the assessments.

Develop a partnership and volunteer strategy to define the types of projects suitable for 

partnership and volunteer opportunities, potential partners and volunteers, and the 

mechanisms for developing partnerships and volunteer agreements.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

97

The cumulative effect has been that on adjacent National Park Service and Sequoia National 

Forest lands there is a high level of restoration that has been accomplished in the last 15 years, 

greatly reducing the probability of large, high-intensity fires in this area. The Bureau of Land 

Management manages fires similarly to the Forest Service although with more of an emphasis on 

fire suppression. Consequently, there has been little wildfire managed to meet resource objectives 

on National Forest System lands near Bureau of Land Management lands. 

Increases in nonnative annual grasses within sagebrush and pinyon juniper vegetation of adjacent 

land ownerships can increase the frequency of large wildfire occurrence onto national forest 

lands. Areas adjacent to the Inyo National Forest managed by the Bureau of Land Management 

and the Los Angeles Department of Water and Power are both at risk of nonnative plant 

invasions, spread, and associated increased fire size. The cumulative effect would be more fires 

burning across jurisdictional boundaries that could increase the total number of large wildfires 

burning on the Inyo National Forest.

Wildfire ignitions may increase in the Sierra Nevada with increased population growth (including 

increased human development in the wildland-urban intermix) and climate change. However, 

future projections in human-caused ignitions and lightning strike density are highly uncertain

(especially the latter). This would have a cumulative effect of increasing the likelihood of large, 

high-intensity fires but to an unknown degree. Although some regions of the western United 

States may experience projected declines in wildfire extent and severity with climate change (due 

to reduced plant productivity in the later 21st century), total burned area and fire severity in the 

Sierra Nevada are likely to increase or remain moderately high through the coming decades 

(Lenihan et al. 2008, Westerling et al. 2011, Parks et al. 2016).

Analytical Conclusions

Under all alternatives, trends in climate remain the same but the landscape vegetation density and 

fuel levels would differ because levels and intensity of restoration differ by alternative. As a result 

of both these factors, the likelihood of large, high-intensity fires differs among alternatives, even 

with climate trends that result in more severe fire weather (table 6). With alternatives B, B 

modified, and D, there is a high likelihood that the trend in large, high-intensity fires may not get 

any worse (table 6). In montane forests, there is a reduction in the likelihood of large highintensity fires with alternatives B and B modified, but the trend is still increasing with climate 

change. 

There is more uncertainty in alternatives B and B modified that larger landscape prescribed 

burning would occur compared to alternative D due to less understory fuels reduction in fewer 

mechanically treated areas. This increases the uncertainty that there would be enough treatment to 

decrease the trend in large fire size or area burned in large fires. In alternatives C and A there is a 

high likelihood that the current trend of increasing occurrence of large, high-intensity fires will 

continue or worsen. In all of the alternatives, any large area (greater than 12,000 acres) that has 

extensive restoration (greater than 40 percent) is likely to have a substantially lower probability of 

large, high-intensity fires and high-severity fire effects (Turner 1989, Wimberly et al. 2009, 

Parisien, Junor, and Kafka 2007, Parisien et al. 2010, Parisien et al. 2012, Fites-Kaufman 2014, 

Coen et al. 2015, Westerling, Milostan, and Keyser. 2015). This situation currently occurs in the 

Kern Plateau and is likely to continue and expand across more of that area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

98

Insects and Pathogens

Background

Native insects and pathogens are an integral part of forest dynamics and process of change in the 

southeastern Sierra Nevada. Naturally occurring pathogens, often called “diseases,” include fungi 

or plants that can play important roles creating cavities or snags used by wildlife. This section 

focuses on the insects and pathogens that affect trees.

Environmental factors such as drought, wildfires, or vegetation conditions strongly influence 

behavior of native insects and pathogens. While native insects and pathogens affect their host

plants to varying degrees, some are considered key species due to their ability to cause 

widespread or severe tree mortality. Species that can kill the most trees, including more than 

seven species of bark beetles, are listed in table 8. 

Table 8. Key forest insect and pathogen species of the southeastern Sierra Nevada: “H” indicates 

relatively high ability to kill host trees; “L” indicates secondary or lower ability to kill host trees; and 

“O” indicates occasional hosts.

Key Pest Species Type Host Trees

Western pine beetle Bark beetle High: ponderosa pine

Mountain pine beetle Bark beetle High: five-needled pines, lodgepole pine

Low ponderosa pine

Jeffrey pine beetle Bark beetle High: Jeffrey pine

Fir engraver Bark beetle High: white fir, red fir

Pinyon ips Bark beetle High: single-leaf pinyon pine

Pine engravers 

(Ips spp.) Bark beetle High: ponderosa pine, Jeffrey pine, 5-needled pines*, 

single-leaf pinyon pine, lodgepole pine

California flatheaded 

borer Wood borer High: Jeffrey pine

Red turpentine beetle Bark beetle Low: ponderosa Pine, Jeffrey pine, 5-needled pines*, 

single-leaf pinyon pine, lodgepole pine

Douglas-fir Tussock 

moth Defoliator High: white fir

Pandora moth Defoliator High: Jeffrey Pine

Dwarf mistletoes Parasitic plant

High: ponderosa pine, Jeffrey pine, sugar pine, 

lodgepole pine, white fir, red fir

Low: 5-needled pines*, single-leaf pinyon pine

Heterobasidion root 

disease Root fungus High: white fir, red fir

Low: ponderosa pine, Jeffrey pine, 5-needled pines*

Black stain root disease Canker fungus High: single-leaf pinyon pine

Armillaria root disease Root fungus

Low: 5-needled pines, lodgepole pine, white fir, red 

fir, incense cedar, giant sequoia, California black oak

Occasional: ponderosa pine, Jeffrey pine

White pine blister rust Canker fungus High: 5-needled pines*

Five-needled pines include sugar pine, whitebark pine, and bristlecone pine

White pine blister rust is a nonnative invasive pathogen that is very deadly to white pines. Bark 

beetles are the leading cause of damage and mortality of trees, and the recent outbreaks across 

western North America are the largest and most severe in recorded history (Bentz 2005). A 2009

update report from Western Forestry Leadership Coalition stated that between 2002 and 2003,
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

99

acres affected by bark beetles increased from 4 million to 10 million acres across the west 

(Coalition 2009). Future projections estimate that bark beetle and other forest insect activity will 

increase due to climate changes such as elevated temperatures, frequent drought, and current high 

risk conditions (ex: dense vegetation) of western forests (Bentz et al. 2010).

In 2011, the Forest Service produced a western bark beetle strategy to develop future prevention 

management strategies to mitigate the widespread epidemic of bark-beetle-killed trees occurring 

all through the western states (USDA Forest Service 2011e). The strategy is based on three 

primary goals: human safety, forest recovery, and long-term forest resiliency. High levels of barkbeetle-killed trees create serious safety concerns, due to the risk of hazardous trees falling on the 

public and damaging property. The rapid loss of trees affects ecosystem integrity, dramatically 

changing the structure and composition of vegetation and distribution of trees. This in turn 

decreases stability of forests, and alters ecological function. After significant bark beetle 

infestations, forest stands may or may not return back to original conditions; dead trees can 

increase wildfire potential; and loss of keystone tree species affect associated wildlife or 

vegetation. Thinning treatments to reduce forest density toward the natural range of variation can

make stands more resilient and reduce the likelihood and amount of trees killed by bark beetles. 

Salvage logging after infestations can recover the economic value of the dead trees, create 

openings for reforestation, and improve overall human safety and recreational opportunities.

Analysis and Methods

Numerous research studies have examined how forest conditions affect the likelihood and level of 

insect and pathogen impacts to trees. This includes measures of stand density, suitable diameter 

classes, or forest composition as potential risk factors for pest attack, especially bark beetles. 

Higher numbers of dying trees are often correlated with areas of densely growing trees for most 

bark beetles and their respective hosts. Drought conditions are included as a factor influencing the

likelihood that attacks will occur.

Despite measures that gauge insect and pathogen activity, discussions of environmental 

consequences of alternatives are qualitative assessments. Insect and pathogen activity viewed at 

forest-level scales is addressed qualitatively because monitoring information is primarily based 

on general trends across the larger forested landscape. The levels of insects and pathogens were 

compared with information on reference conditions, or what is within the natural range of 

variation (Safford and Stevens 2017; see “Terrestrial Ecosystems” section). These are also 

referred to as “background levels.” Little information pertains to presettlement (natural range of 

variation) estimates of insect and pathogen activity and associated tree mortality in the Sierra 

Nevada, including the Inyo National Forest. However, inferences related to insect- and pathogenrelated tree mortality can be drawn from the comparison of recent past, current (contemporary 

forests on the Inyo National Forest and modern reference sites with intact disturbance regimes), 

and projected future conditions.

Indicators and Measures

Effects and impact severity due to forest insects and pathogens are often measured by several 

factors: affected acres, trees killed per acre, or percentage of trees affected. Annual aerial surveys 

are conducted by the Forest Health Monitoring Program under the Forest Service’s State and 

Private Forestry Program, which visibly detects and records areas of dying trees caused by forest 

insects and diseases on the landscape. The Forest Service’s Forest Health Protection Program has 

multiple tools in which to evaluate measures. Numbers of trees dying that are higher than 

background levels are often indicators of increasing pest activity or areas of growing infection by 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

100

diseases. Unusual patterns of dead trees with particular host plants can also indicate pest 

presence. Compilation of acres affected or trees killed can provide indications of trends emerging 

on the landscape.

Forest Health Technology Enterprise has developed computer modeling tools that assess loss 

risks from forest pests based on current stand conditions (USDA Forest Service 2012a). 

Gradations of risk are assessed up to greater than 25 percent basal area lost; considered the 

highest risk over a span of 15 years. Maps of specific locations or forests can be developed,

which assess levels of risk.

Assumptions

Most forest insects and pathogens are native. Current conditions of dense forested stands or 

predominance of shade-tolerant trees have significantly changed forests from the historic range of 

natural variation (Safford 2013, Slaton and Stone 2015a, Slaton 2013b). In general, bark beetles 

target dense stands because trees in these conditions are often stressed or weakened due to high 

competition for water and resources. Drought further stresses trees, triggering increased bark 

beetle attack. These trees are less able to produce defensive resins used to fend off bark beetles 

drilling into the cambium. For ponderosa pines in California, studies determined that stands with 

highest densities are most often first infested (Oliver 1995, Hayes, Fettig, and Merrill 2009). If 

droughts become more frequent, of greater intensity, or last longer in the future, higher levels and 

more wide-spread bark beetle-caused mortality should be expected.

Trees killed by insects and pathogens do provide important contributions to ecosystem function 

when they are at levels within the natural range of variation. Bark beetles and wood boring 

insects provide forage for wildlife such as woodpeckers. Dead trees, standing or down, create 

essential habitat and organic biomass for forests. Trees killed by native insects and pathogens can 

result in small-scale disturbances that keep forests dynamic and regularly changing, by creating 

small openings and increasing heterogeneity (Fettig 2012). Native insects and pathogens are also 

used by Native American Tribes. For example, on the Inyo, Tribes use Pandora moth larvae 

(called piagi) as a traditional food source. Mushrooms, the fruiting bodies of pathogens, are used 

as food and medicine by Native American Tribes as well.

Restoration treatments in forests to reduce tree density can restore forests to conditions similar to 

the natural range of variation’s associated background levels of insect and pathogen-related tree 

mortality (Fettig 2012). Reduced tree density, more varied structure, and diverse tree composition 

will significantly reduce susceptibility of trees to attack and infection and improve individual 

resistance mechanisms (Smith 2007, Fettig et al. 2007). One measure of forest density that is used 

to evaluate susceptibility to bark beetles, is stand density index. This measure is weighted by tree 

size and tree density, so stands containing a higher density of trees and that are dominated by 

small trees have higher index levels. This is partly because more small trees can “crowd” into the 

same space as fewer large trees. Light thinning, and especially thinning limited to small trees,

may not reduce stand density index sufficiently to change conditions that attract bark beetles 

(Oliver 1995). Prescribed fires alone may not reduce stand density index sufficiently if they are 

low intensity and can create situations that make trees more vulnerable to attack in the short term 

(Fettig et al. 2008). However, large wildfires managed to meet resource objectives can result in 

significant reductions in forest density and reduced susceptibility to insect attack (see “Affected 

Environment” section below). This is evident in the current outbreak where lower levels of dying 

trees are occurring on the Kern Plateau where extensive managed fires have occurred in the last 

15 years (Meyer 2015a). Heterogeneity across the landscape can also disrupt the expansion of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

101

insect activity. Variation of tree size, age, or species composition may limit the amount of suitable 

host material and, thus, reduce the number of dying trees (Fettig 2012).

The effects of treatment on insect and pathogen levels and susceptibility vary some by treatment 

type and combinations. Combinations of mechanical and prescribed fires have been found to be 

less attractive to bark beetles than prescribed fire treatments alone, as well as improving overall 

tree health and growth (Feeney et al. 1998, Wallin et al. 2008). Fire may result in heightened bark 

beetle activity due to the nature of injury that fire causes (Davis et al. 2015). Crown and bole 

scorch severity are two of the primary factors used to gauge tree survival but also susceptibility to 

bark beetle attack (Hood et al. 2007, Smith and Cluck 2011). Studies on bark beetle impacts 

followed by prescribed fires have determined that the likelihood of bark beetle infestation 

significantly increases with burning alone (Fettig et al. 2008, Fettig and McKelvey 2010)). 

Therefore, it is important to recognize potential subsequent effects following a burn when drought 

events or underlying resource stress (such as high tree densities) are also present.

Affected Environment

Current forest structural conditions of increased tree densities are considered outside of the 

natural range of variation and prone to insect and pathogen outbreaks beyond background levels. 

Recent and ongoing, widespread, high levels of insect-related tree mortality reflect these 

conditions, magnified by drought (Asner et al. 2015) and temperature increases (Van Mantgem et 

al. 2009). Past management activities have changed forest structure, leading to changes in tree 

species diversity, age classes, and density. Although current levels of tree mortality (and 

associated bark beetle activity) on the Inyo National Forest are within the upper portion of the 

natural range of variation (Allen, Breshears, and McDowell 2015, McDowell et al. 2016), these 

levels are expected to exceed the natural range of variation in the near future as a consequence of 

the effects related to climate change (Allen, Breshears, and McDowell 2015, McDowell et al. 

2016). During the recent extreme drought (2012-2015), levels of drought stress and associated 

tree mortality were orders of magnitude lower on the Inyo National Forest than on the west slope 

of the southern Sierra Nevada in the Sierra and Sequoia National Forests (Preisler et al. 2017).

Bark Beetles

Currently, there are extensive areas of trees with high or very high mortality related to drought, 

increased temperatures, and bark beetle activity in the pinyon forests of the White Mountain and 

Whitney Ranger Districts, and in the whitebark and lodgepole pine forests on all ranger districts

(figure 8 and figure 9; USDA Forest Service 2015a). These levels are greater than what has 

occurred in the last 50 years but there have been other outbreaks and associated increased tree 

mortality. For example, levels of tree mortality in white and red fir have been increasing on the 

Mammoth Ranger District, especially in the area between the Sherwin Mountains near Mammoth 

Lakes and June Lake. Over the past four decades, California has experienced significant drought 

events that have triggered high levels of bark beetle-associated tree mortality. From 1992 to 1994, 

more than 1,430,000 acres of trees (primarily true firs) were killed statewide; in 2002 to 2005, 

over 6,688,400 acres of pines were killed, primarily in southern California forests.

On the Inyo National Forest, the greatest concern is loss of pinyon and keystone high elevation 

species, such as whitebark pine. Since 2006, more than 61,000 acres of whitebark pine, an 

estimated 425,000 trees, have been affected by mountain pine beetle in California. An average of 

over 80 percent of the basal area and 75 percent of canopy cover has been lost in some areas of 

the Inyo National Forest impacted by mountain pine beetle (figure 8; Meyer et al. 2014b, Meyer 

et al. 2016). Pinyon Ips, often in association with black stain root disease, is causing widespread 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

102

mortality where pinyon occurs on Inyo National Forest, most recently in the Inyo and White 

Mountains, John Muir, and Golden Trout Wilderness.

Figure 8. Photo of dead and dying whitebark and lodgepole pines on June 

Mountain Ski Area, 2009

Defoliators

Other insects that cause noticeable and significant damage have been defoliators, insects that eat 

the needles or leaves of trees and can kill the trees when attacks are severe. The native Douglasfir tussock moth cycles in population boom and bust every 7 to 10 years. White firs are its 

primary host, but other neighboring species can be affected if populations are high. From 1996 to 

1999, 44,000 acres in Sequoia-Kings National Park and Sequoia National Forest were defoliated; 

about 5,800 acres were severe (USDA Forest Service 2015a). Pandora moth is infrequent, but 

outbreaks can cause severe localized damage. Both insects become public safety hazards: 

Douglas-fir tussock moth larvae have urticating hairs that cause severe respiratory problems in 

sensitive individuals; Pandora moth larvae can become so numerous on roads or other public 

settings to create treacherous conditions. As mentioned previously, Pandora moth is also a valued 

resource collected by tribal members.

Dwarf Mistletoes and Root Diseases

Dwarf mistletoes and root diseases can have profound long-term effects on forest structure and 

composition. Forest pathogens work slower than insects in killing individual tree hosts by 

extracting water and photosynthates (sugars and other chemical products of photosynthesis), 

crippling and deteriorating tree metabolism and vigor. Infected hosts are thereby more susceptible 

to structural defect related failure or attack by secondary pests that eventually kill the tree. Dwarf 

mistletoes are highly evolved parasitic plants that persist on individual trees for decades causing 

dieback or severely reducing growth and development. Heterobasidion spp. is the most common 

root disease found in the southern Sierra Nevada forests; true firs are highly susceptible to 

Heterobasidion infection. Pinyon pine trees infected with black stain root disease are susceptible 

to mortality from Ips confusus bark beetle.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

103

Figure 9. Drought and insect-related mortality through 2017 in the eastern Sierra Nevada based on 

aerial detection surveys
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

104

Nonnative Insects and Diseases

The most damaging conifer pathogen in California, white pine blister rust was introduced to the 

west coast of North America in 1910 on infected imported plant seedlings. White pines are all 

susceptible to white pine blister rust in laboratory studies, but only sugar pine and western white 

pine have been confirmed with infections so far. Recent surveys of white pine blister rust have 

found very low incidence in the southern Sierra Nevada national forests (Maloney 2011). 

However, preliminary research from Sequoia and Kings Canyon National Parks found a doubling 

to 45 percent white pine blister rust infection levels in western white pines since the initial survey 

conducted in the early 1990s (Cahill 2013). The pathogen has not yet been found on eastside 

forests, but is continually expanding its range as observed in northwestern forests and Rocky 

Mountains. It continues to be a serious threat to white pines as climate conditions change and 

pathogens are easily transported through other pathways.

Expected Trends

Forest Health Monitoring risk maps (USDA Forest Service 2012a) show substantial risk of 

increased tree mortality (greater than 25 percent basal area lost) in the next 15 years due to bark 

beetles and other pest complexes (see maps in the Insect and Pathogen supplemental report). Data 

from these maps are summarized in table 9. 

Droughts may become frequent and prolonged, and mortality will likely be proportional (Smith 

2007). A warming and drying climate is expected to greatly increase the likelihood and risk of 

widespread and elevated insect and pathogen outbreaks (Fettig 2012).

Table 9. Summary of percentage of area at risk by basal area 

loss categories for the Inyo National Forest

Percent Basal Area Loss 

(percent) Percentage of Area at Risk

1-4 10%

5-14 23%

15-24 14%

>25 53%

Environmental Consequences to Insects and Pathogens

Consequences Common to all Alternatives

All forested lands are affected by native insects and diseases. With the exception of a few 

introduced insects and pathogens, forests in the Sierra Nevada have the same insect and disease 

associates they had 100 to 150 years ago. Every tree species has its complement of pest hosts that 

cause natural mortality and generate small-scale ecosystem disturbances. As opportunists when 

favorable conditions arise, bark beetle-associated activity can be expected to increase if current 

forest conditions remain unchanged or limited. If bark beetle attack potential is not mitigated, 

stands categorized as high risk may experience undesirable levels of dead and dying trees during 

times of drought or other conditions that are conducive for insect population growth and 

expansion. Climate change, urbanization, large wildfires, and chronic elevated ozone pollution 

levels all influence forest resilience to insects and pathogens in addition to the proposed 

restoration treatments.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

105

All alternatives have measures to limit the spread and infection of nonnative invasive insects

(including those species not yet present in the Sierra Nevada such as goldspotted oak borer) and 

pathogens. This includes white pine blister rust.

Consequences Specific to Alternative A

Alternative A would have limited areas of restoration (table 4, page 83), including thinning from 

mechanical treatment or moderate intensity prescribed fire that would reduce the risk of bark 

beetle outbreaks. There would continue to be large areas at high risk of bark beetle-caused tree 

mortality beyond desired condition levels. Trees in dense stands, outside of the natural range of 

variation, would continue to experience high tree-to-tree competition for water and other essential 

resources. Water stress from dense, competing trees as well as potential drought, compounded 

with pathogens such as root disease or dwarf mistletoes would combine to further weaken trees, 

inciting secondary insect attacks (beetles). Current elevated levels of tree mortality would be 

likely to continue now or develop again in the near future with drought and temperature increases.

Consequences Specific to Alternative B

In alternative B, more forested acres are proposed to be treated whether with mechanical thinning, 

prescribed fires, and wildfires managed to meet resource objectives (TERR-FW-OBJ-01 to 03; 

MA-RCA-OBJ-01; SCEN-FW-OBJ-01; SPEC-SG-OBJ-01). This reduction of overall tree 

density across the landscape should reduce the likelihood of bark beetle infestations growing to 

epidemic levels within treated areas. This is because increased restoration treatment rates under 

alternative B would reduce stand densities, increase heterogeneity, and restore tree composition to 

conditions aligned with the natural range of variation (TERR-MONT-DC-01TERR-DMC-DC-01

to 06; TERR-RFIR-DC-01 to 07; TERR-PINY-DC-01 to 05; TERR-JEFF-DC-01 to 07; TERRLDGP-01 to 10). Reducing density would reduce moisture stress to individual trees (trees have 

greater capacity to resist insect attack via pitching response) and reduce the likelihood that stands 

would support pathogen spread and insect eruptions. Greater heterogeneity in the forests, species 

diversity, and variations in spacing and structure may limit pathogen spread through root-to-root 

contact or canopy-aided dispersal. In alternative B, increased mechanical treatments along ridges 

and roads would be particularly effective at enhancing the resilience of forest ecosystems to 

undesirable impacts by insects or pathogens, especially in low- to moderate-elevation forests such 

as mixed conifer, ponderosa pine, and Jeffrey pine forests (see management approaches discussed 

in “Fire Trends” section).

Consequences Specific to Alternative B-modified

The consequences of alternative B-modified would be similar to alternative B, but there would be 

a marginally higher restoration treatment rate (specifically mechanical thinning and wildfires 

managed to meet resource objectives) under alternative B-modified. As a consequence, the 

overall susceptibility of treated forest stands (Jeffrey pine and dry mixed conifer) to bark beetle 

attack and outbreaks will be slightly lower in alternative B-modified compared to alternative B. 

Increased treatment rates will result in more stands with reduced stand density, increased 

structural heterogeneity, and other ecological conditions consistent with the natural range of 

variation. As in alternative B, lower stand densities in alternative B-modified would reduce tree 

moisture stress, enhancing the capacity of trees to resist insect attack and potentially reduce 

pathogen incidence in healthy trees.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

106

Consequences Specific to Alternative C

Alternative C would have lower levels of mechanical thinning than alternative A with more 

emphasis on prescribed burning and wildfire managed to meet resource objectives (table 4, page 

83). As a result, there would continue to be high levels of risk to bark-beetle-associated mortality 

unless the burned areas are extensive and of moderate intensity with substantial reduction in tree 

densities. If the focus of mechanical treatments is removing smaller diameter trees, limited 

changes to current forest conditions may serve to perpetuate the risk of insect and pathogen 

outbreaks in many areas. The exception includes the wildland-urban intermix defense zone, 

where mechanical treatment rates under alternative C would be similar to alternative A and some 

reduction in stand density would occur nearest to communities. There may be increased levels of 

bark-beetle infection in areas treated with burning alone, particularly when it occurs in dense 

stands where the trees are already stressed (Fettig et al. 2008, Fettig and McKelvey 2010).

Consequences Specific to Alternative D

Alternative D would have similar consequences as alternatives B and B modified but over 

substantially more area. Increased levels of thinning, prescribed fire and wildfire managed to 

meet resource objectives proposed in alternative D (table 4, page 83) would result in decreased 

levels of bark beetle activity in forest ecosystems. Alternative D would increase the pace and 

scale of forest restoration toward desired conditions and greatly improve forest resilience over 

larger spatial and longer temporal scales. Insect and pathogen outbreaks under this alternative 

would be more limited to localized levels that closer resemble historic conditions (Savage 1994). 

Trees in restored stands would have improved access to water and resources and lower 

competition for water. This would allow trees in restored stands to more rapidly recover after 

drought or wildfire, and gradually adjust if climate conditions continue upward trends (North 

2012b, Fettig et al. 2007). 

Cumulative Effects

There can be cumulative effects resulting from management of nearby lands under different 

ownerships. Insects and pathogens can increase on adjacent lands and spread to national forest 

lands. Similarly, insect and pathogen outbreaks can spread from national forest lands to adjacent 

lands.

There are three different types of land ownership adjacent to national forest lands, each with 

varied capacities and likely forest management approaches that affect insect and pathogens. First, 

there are other Federal lands including Sequoia and Kings Canyon and Yosemite National Parks. 

Second there are urbanized or developed areas. Third, there are larger private land owners that 

actively manage forests including private timberlands and utility companies.

There is an emphasis on prescribed and managed fires and little mechanical thinning in national 

parks. This could result in different elevated mortality levels and potential spread to national 

forest lands, but to date mortality levels have been similar or less (see figure 9). It could be that 

elevated mortality on national forest lands has resulted in elevated mortality levels on national 

park lands.

Forests on small private lands are often very dense, because trees are retained as natural screening 

or shading. There is a higher likelihood of root damage near structures and roads that can increase 

susceptibility to insect and pathogen attack; this may increase the spread to national forest lands 

but the amount of area in this condition is small and limited to some forested areas around 

Mammoth Lakes and June Lake. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

107

Analytical Conclusions

Common consequences for all alternatives are such that (native and invasive) insect and disease 

activity would continue to persist, and effects to trees would occur regardless of treatments under 

all alternatives. The differences lie in the levels of intensity and severity of outbreaks; in 

particular, levels of tree mortality. Eastside and westside forests of the Sierras will experience 

varying degrees of mortality as insects and pathogens continue to target stands of highest risk 

(stands with highest stand densities and greatest moisture stress).

While alternatives B and B modified allow for restoration treatments on the landscape, including 

the use of mechanical thinning, wildfire and prescribed fires, climate change projections indicate 

that warmer, potentially drier temperatures in the next few decades may occur before much of 

that restoration is completed. With the greater rate and amount of restoration, alternative D may 

more rapidly prepare for these conditions. The trend of large-scale wildfires on an annual basis in 

California has increased urgency for developing resiliency and resistance to elevated forest pest 

levels and in current forest structures.

Management direction of alternatives A and C would not sufficiently reduce stand density, 

structure, or microsite conditions that are conducive to bark beetle-associated tree mortality, 

especially during periods of drought (Smith 2007). Ponderosa pine stands in California need 

lower stocking thresholds to prevent losses beyond background levels (Oliver 1995). The level of 

treatments proposed for alternative D followed by alternatives B and B modified would be most 

effective to prevent bark beetles, such as western pine beetle, from reaching regional and bioregional scales as is currently happening in the southern Sierra Nevada.

Combined Effects of Climate, Fire, Insects, and Pathogens

Terrestrial Ecosystems

Climate, fire, insects and pathogens all influence and interact with each other. Various aspects of 

how they influence each other are discussed in the individual subsections above. It is important to 

also consider them as a whole, since they all affect vegetation and are affected by vegetation 

condition. For the forest plans, the primary means of altering ecosystems is management of 

vegetation condition. In this subsection, the cumulative effects and analytical conclusions for 

climate, fire, and insects and pathogens on vegetation condition and management are considered. 

More detail on the combined effects of climate, fire, insects and pathogens is described in the 

Vegetation Resilience supplemental report.

Figure 10 shows how each of these agents of change influence each other and vegetation 

condition. In the diagram, the direction and weight of arrows show how each agent of change and 

vegetation relate to each other. Although the way fire is managed may vary, fire will occur 

regardless at some point in time because the plan areas are dry and fire prone, with regular 

ignition sources (lightning and human-caused).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

108

Figure 10. Conceptual diagram of the interaction between 

climate, fire, insects and pathogens, and vegetation

Starting with vegetation and moving clockwise around the diagram:

• Vegetation is in bold, because this is the only aspect of ecosystems that can be directly 

influenced by forest plan direction. 

• Climate influences vegetation, fire, and insects and pathogens directly through temperature 

and moisture changes. 

• Fire influences vegetation, and vegetation influences fire. The arrow between fire and 

vegetation is bold because there is a strong influence of vegetation on fire and vice versa.

• The arrow that goes from fire to insects and pathogens is thinner because most of the 

influence of insects and pathogens is through the changes it causes in vegetation. However, 

fire can also influence insects and pathogens by potentially making trees more susceptible 

to bark beetle or pathogen activity. Conversely, insects may increase fire severity and 

extreme fire behavior, especially if trees experience high levels of beetle-related mortality 

and are in the red stage (that is, the first few years following beetle attack; Hicke et al. 

2012, Jenkins et al. 2008, Jenkins et al. 2012, Stephens et al. 2018). Recent observations of 

wildfires in the southern Sierra Nevada have confirmed these patterns of increased fire 

behavior (increased torching, fire intensity, and fire spread rates) in areas of recent high 

levels of tree mortality (Reiner et al. 2017).

• The changes insects and pathogens have on vegetation also affects fuels, which then 

influences fire (Hicke et al. 2012, Stephens et al. 2018). Moreover, the density and biomass 

of vegetation (trees) influences insect and pathogen populations and dispersal through the 

availability of host species, especially with drought and climate change (Preisler et al. 

2017, Young et al. 2017). 

These interrelationships illustrate that the effects of climate, fire, vegetation, and insects and 

pathogens are complex, especially in forest ecosystems with a frequent fire regime (Stephens et 

al. 2018). As described above in the previous subsections, there has been and will continue to be a 

trend of warming climate, increased fire, and increased insect, pathogen, and disease levels and 

vegetation-related mortality. Effects on vegetation are magnified where vegetation structure and 

composition are outside the natural range of variation. There is a large proportion of the middle 

and lower-elevation landscapes that are outside the natural range of variation and are highly 

departed from the vegetation desired conditions (see the “Terrestrial Ecosystems” section). 

Denser vegetation has a lower resilience to climate change, fire, insects, and pathogens. 

Composition that has shifted toward dominance of less drought- and fire-tolerant species has 

decreased resilience. Nonnative plant species may increase with climate change and changing 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

109

fire, especially in eastside sagebrush, pinyon-juniper, and desert ecosystems. This is beginning to 

cause a negative feedback with increased nonnative plant invasions causing more fire, which 

causes more invasions.

Analytical Conclusions

Three factors most important in changing ongoing and reasonably foreseeable future effects of 

climate, fire, insects, and pathogens on vegetation condition include the pace, scale, and intensity 

of restoration to change vegetation conditions toward desired conditions. The alternatives vary in 

the pace, scale, and intensity of restoration, particularly in the low and mid-elevation areas 

including mixed conifer, Jeffrey pine, pinyon-juniper, and sagebrush vegetation types. 

Alternative D has the greatest amount of restoration treatment (pace), across the largest area 

(scale; 30 to 60 percent of lower and mid-elevation landscapes dominated by forest, sagebrush, 

and pinyon juniper ecosystems), with the greatest certainty of moving vegetation toward or 

achieving desired conditions (intensity) in treated areas. This would be through extensive 

thinning, prescribed fire and more opportunities for wildfires managed to meet resource 

objectives. Up to half of the landscapes that are most departed from desired conditions (see 

“Terrestrial Ecosystems” section) would be restored within the next 10 years in alternative D and 

be more resilient to fire, climate change (hotter droughts), insects, and pathogens.

Alternatives B and B-modified have the second greatest amount of restoration, but restoration 

efforts would be concentrated in a less extensive portion of the national forest, in about 30

percent of montane forest, sagebrush, and pinyon-juniper woodlands. Some of the prescribed fire 

objectives in alternatives B and B-modified would not be achieved because of more limitations on 

prescribed fire in riparian habitat. Most of the landscape would continue to have low resilience to 

climate change, fire, and insects and pathogens.

Alternatives A and C would likely have the lowest pace, scale, and intensity of restoration 

because they have the least amount of active mechanical and potentially prescribed fire 

treatments. Although there is more planned prescribed fire in alternative C, there would be less 

mechanical treatment and less resulting restoration of ridges and roads that could be used to 

“anchor” off of for large prescribed fires.

Overall, alternative D would alter vegetation conditions to the greatest extent by restoring 

vegetation structure, composition, and function, and limiting the negative impacts of climate 

change, large high-intensity fire, and elevated insect and pathogen levels. Alternative B would 

restore some landscapes to the point where negative impacts of stressors would be moderated, but 

almost half of the landscape (40 to 50 percent) would be still be vulnerable under this alternative.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

110

Revision Topic 1: Fire Management

Introduction

Wildfire has and will continue to affect vegetation and ultimately be a primary driver of change to 

ecosystems in the Inyo National Forest. Wildfire has been a vital part of the Sierra Nevada range 

for centuries. Many of the ecosystems that make up the area in and around the Inyo National 

Forest have been shaped by the way fire moved across the landscape in the past as well as by the 

lack of fire in recent history. The historic role fire plays in reducing fuels was nearly eliminated 

with 100 years of effectively suppressing fires. Fire management has gone through several 

changes over the last few decades; transitioning from a more suppression-focused approach to 

moving toward a more managed approach to restore ecological integrity and provide protection 

for valued natural resources and assets within and around national forests.

Decades of fire suppression, buildup of vegetation and forest debris, and more recently, drought 

and climate change have caused wildfires to grow larger and become more destructive (see the 

“Climate Change” and “Fire Trends” sections). Limited funding for prevention programs and 

many challenges to implement fuel reduction projects have resulted in limited progress toward

reducing the compounding effects of decades of suppression and an increase in the frequency of 

large, high-intensity wildfires. The number and extent of wildfires in the western United States 

each season is driven by natural factors such as fuel availability, temperature, precipitation, wind, 

humidity, and the location of lightning strikes, as well as human factors. It is well known that 

climate fluctuations significantly affect these natural factors, and thus the severity of the western 

wildfire season, at a variety of temporal and spatial scales (Westerling et al. 2003). Unwanted 

wildfires burning at high intensity and under extreme conditions and within the wildland-urban 

intermix have the potential to damage forests and wildlife habitat, negatively affect stream and 

watershed quality, reduce air quality with increased smoke, and destroy homes and communities. 

Other wildfires burning under more desirable conditions (environmental conditions such as a 

combination of temperature, relative humidity, wind speed and direction, and air mass stability 

that influence vegetation moisture and fire behavior) provide an opportunity to be managed to 

meet resource objectives.

The increase in wildfires in western U.S. forests is related to warmer spring and summer 

temperatures, reduced precipitation associated with warmer temperatures, reduced snowpack and 

earlier snowmelts, and longer, drier summer fire seasons in some middle upper elevation forests. 

These conditions can be attributed to climate change (Westerling and Bryant 2008). As the 

climate becomes warmer and drier, vegetation becomes drier, stressed, and more susceptible to 

insects and disease and is more likely to be consumed by fire. Traditionally, fire season in 

California was from May to September. Recently, fires have occurred throughout the year more 

regularly, resulting in an almost year-round fire season. Not only are fires occurring more 

frequently outside of the traditional fire season, they are much more intense causing more severe 

and long-lasting damage to the vegetation and soils. Large-scale and long-duration droughts may 

occur and will increase the potential for fires to burn larger and with higher intensity than desired. 

The result of this type of changing climate is likely to be larger, more damaging wildfires with 

fewer opportunities to manage wildfires to meet resource objectives or to conduct prescribed 

burns.

Increased amounts and duration of smoke produced from large wildfires is likely to continue to 

impact population centers, including those long distances from the fire. Increases in wildfire 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

111

smoke emissions may have detrimental impacts on air quality and, combined with a growing 

population, may result in increased population exposure to unhealthy air pollutants (Hurteau et al. 

2014). Wildfires may occur during times of unfavorable atmospheric conditions resulting in a 

compounded impact. However, substantially increasing the amount of fire restored to the 

landscape will require societal trade-offs, such as accepting more smoke from prescribed fires and 

managed wildfires versus continuing to live with high wildfire risk. When evaluating these 

tradeoffs, the costs to society, such as short-term versus long-term air quality impacts, must be 

considered in the context of doing nothing (Hurteau et al. 2014). Emissions from prescribed fires 

are typically lower than those from wildfires burning the same area (Wiedinmyer and Hurteau 

2010). Prescribed fires are planned with careful consideration of smoke to limit human health 

impacts, impacts to transportation corridors, and smoke-sensitive populations. Atmospheric 

dispersion (how pollutants disperse throughout the atmosphere) influences smoke behavior. By 

limiting the amount of fuels available to wildfires, impacts to air quality from future wildfires will 

likely be reduced. Since wildfires that are managed to meet resource objectives burn over many 

days, they may burn during unfavorable conditions such as during high ozone days; however, 

long-term benefits exist as fuels available for future wildfires are diminished. See the “Air 

Resources” section for more information.

Wildfire suppression costs have increased significantly over the last decade (Ecology, Fire, and 

Conservancy 2015). This fact, coupled with decreasing or static budgets for fuels management, 

presents serious challenges to fire managers and increases the risk of continued large and highintensity wildfires. A way to address these issues is to use a risk-based approach to guide the 

future management of wildfire. This is discussed further in the next section. 

Wildland Fire Management

Background

Wildland fire management includes the strategies and actions used both before and during 

wildfires. Management of wildland fire (wildfire and prescribed fire) influences whether fire 

effects are beneficial or cause negative impacts to values such as water quality, air quality, 

habitat, recreation areas, timber resources, or communities. Fire management begins with preplanning; using tools to aid in the decision-making process. These tools include pre-season 

meetings with partners, monthly and seasonal outlooks for climate patterns, fuel moisture trends, 

energy release component trends, smoke dispersion forecasts, fire behavior modeling, and risk 

assessments. Using these tools, decision makers identify the current and expected conditions for 

the season, communicate with partners, and are prepared when deciding what wildfire response to 

use. Wildfire responses include a spectrum of strategies (often referred to as “suppression 

strategies”) that include full suppression, confine and contain, and monitoring. Full suppression is 

a management action used to extinguish or confine an unwanted wildfire at its discovery. Confine 

and contain is a strategy that uses natural or constructed barriers or burn out of unburned areas to 

slow or stop fire spread. Monitoring is an active strategy that involves monitoring the fire 

behavior, weather, and smoke while creating contingency plans for different outcomes of fire 

spread. 

Managing Wildfires to Meet Resource Objectives

The term used for naturally ignited wildfires that are managed to reduce fuels and improve 

ecosystem health is “manage wildfires to meet resource objectives.” This term is used throughout 

the document. Human-caused fires and trespass will be managed to achieve the lowest cost and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

112

fewest negative consequences with primary consideration given to firefighter and public safety 

and without consideration to achieving resource benefit (FSM 5130.3). 

Managing a fire to meet resource objectives is active management, not passive, using a confine 

and contain or monitoring strategy. Managing wildfires to meet resource objectives is a strategic 

choice to use unplanned lightning-caused ignitions to achieve resource management objectives 

and ecological purposes under specific environmental conditions. Environmental conditions 

consist of a combination of temperature, relative humidity, wind speed and direction, and airmass stability. These factors influence vegetation moisture and fire behavior and are determined 

annually during the pre-planning phase of fire management. The benefits of managing wildfires 

to meet resource objectives include reducing fuels so that future fires burn in that area with lower 

intensity, lower impacts, and reduced smoke, are more manageable, and pose less threat to 

communities. Managing wildfires to meet resource objectives allows fire to resume its natural 

role in the ecosystem under pre-identified objectives and conditions. By allowing this to occur, 

the results are a healthier ecosystem. Fire can create a diversity of habitats, cycle nutrients back 

into the soil, and reduce dense areas of vegetation, which improves vegetation health.

Fuel Reduction Treatments

Fuel reduction treatments include prescribed fire and mechanical treatments which are designed 

to change the amount, configuration, and spacing of live and dead vegetation. Prescribed fires are 

fires intentionally ignited by management actions in accordance with applicable laws, policies, 

and regulations to meet specific objectives. Mechanical treatments are changes made to

vegetation composition and structure (by cutting, thinning, or pruning) and changes made to 

forest fuels to reduce fire hazard. Mechanical treatments are often followed up with prescribed 

burning. The costs, environmental impacts, and effectiveness of different fuel treatment types 

vary. The desired outcomes of fuel reduction treatments are less intense fire behavior and reduced 

severity during wildfires, moving the area toward the natural range of variation, less tree 

mortality after a fire, and reduced amounts of smoke. Strategically located fuel reduction 

treatments also provide more opportunities to proactively manage the size and costs of future 

wildfires.

The Challenges of Wildfire Management

Managing wildfires can be difficult because of smoke impacts, proximity to human communities, 

and liability and cost constraints (Quinn-Davidson and Varner 2012). In addition, policy and 

management requirements also factor into how wildfires are managed. For example, Forest 

Service fire policy (Forest Service Manual 2320) states that in wilderness, fire should be allowed 

to play its natural role as nearly as possible but this presents challenges if the fire has the potential 

to burn outside of wilderness areas and threaten communities or other resource values. 

Mechanical treatments have their own set of legal, operational, and administrative constraints, 

limiting the location and extent of treatment (North et al. 2015), including exclusion in 

wilderness. Forest and wildland fire managers in the southern Sierra Nevada currently have the 

ability to more holistically manage wildfire by incorporating the management of wildfires to meet 

resource objective within the forest plans (Meyer 2015a).

Holistic wildland fire management can be thought of as an approach that simultaneously 

considers the role of fire in the landscape, the ability of humans to plan for and adapt to living 

with fire, and the need to be prepared to respond to fire when it occurs. There are multiple factors 

that make it difficult for forest managers to incorporate a more holistic approach into fire 

management. Some of these factors are risk aversion, sociopolitical pressures, and a resulting 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

113

propensity to choose the status quo fire response of suppression. These factors do not improve 

resource conditions and create a positive feedback loop; this is known as the “fire paradox,” in 

which aggressive suppression today leads to accumulation of fuels and worse fires in the future 

(Arno and Brown 1991). This in turn leads to continued excessive suppression expenditures 

(Thompson et al. 2013). Society’s expectation that fires are aggressively suppressed is well 

ingrained, regardless if the fires might meet the objectives of current policy. 

National Cohesive Wildland Fire Management Strategy

Increasingly, wildfire management is being viewed as a form of risk management, with a 

corresponding increase in analytical rigor and alignment with risk management principles (Calkin 

et al. 2005). Through planning, risk analysis, and collaboration between stakeholders, a broad 

coalition led by the Western Governors’ Association and Federal land management agencies 

(USDA Forest Service and Department of Interior agencies) developed the “National Cohesive 

Wildland Fire Management Strategy” to establish a national vision for fire management (referred 

to hereafter as the “Cohesive Strategy”). This strategy defines goals, describes wildfire 

challenges, identifies opportunities to reduce wildfire risk, and is the basis for the fire 

management strategies in the alternatives considered for revising the forest plans.

There are three primary goals to the Cohesive Strategy: (1) restore and maintain landscapes, 

(2) create fire-adapted communities, and (3) respond to wildfires safely and effectively. A riskmanagement approach serves as the foundation for all fire management activities. To restore and 

maintain resilient landscapes, risks and uncertainties relating to fire management must be 

understood, analyzed, communicated, and managed as they relate to the cost of doing or not 

doing an activity. To create fire-adapted communities, it is imperative to work with partners and 

use a risk management approach to identifying communities at risk and help protect these 

communities. A safe and effective response to wildfire requires moving beyond an emphasis on 

suppression and considering a more holistic way to meet resource objectives.

Funding is limited and there are not enough resources to reduce fuels with mechanical or 

prescribed fire treatments alone to change fire dynamics on a landscape scale. Managing wildfire 

to meet resource objectives is the most effective and efficient way to reduce fuels, effectively 

reduce the risk to communities and resources (such as water sources or habitat), and restore and 

maintain landscapes. Areas where fires were historically frequent can derive ecological benefits 

from fires; vegetation health is improved, habitat is improved, and species benefit.

Wildfire Risk Management

Wildfire risk management is the process whereby management decisions are made and actions are 

taken concerning control of risk and acceptance of remaining risk. It involves identifying, 

assessing, and prioritizing risks followed by the coordinated and economical application of 

resources to minimize, monitor, and control the probability or impact of unfortunate events 

(Thompson and Calkin 2011). Wildfire risk management is often supported by a scientific 

assessment that can be used to determine where individual wildfires are likely to have negative or 

positive outcomes. It is based upon a detailed quantitative analysis of the location of values at risk 

(such as water sources, communities, or recreation sites) and the likelihood of fire starts (often 

called “ignitions”), fire spread, and fire intensity. For the forest plan and alternatives analyzed in 

this environmental impact statement, a wildfire risk assessment was conducted to evaluate the 

alternatives and develop science-based management areas for strategic fire management zones. 

The strategic fire management zones for the alternatives are described briefly in chapter 2 and in 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

114

more detail below. In the next section, a brief description of the underlying analysis for the 

wildfire risk assessment is described. This includes what values at risk were included and the 

relative ranking of each. For more detailed information about the risk assessment, see specialist 

reports in the project record.

Fire Management Considerations

A strategy to address the need to change fire management includes recognizing constraints, 

acknowledging the ecological role of fire, aligning procedures with policy, and managing risk to 

the extent possible.

Recognize Constraints to Fire Management

Recognize that in general there are a very large number of burnable acres of National Forest 

System lands that cannot be actively managed by mechanical means, and an even larger number 

that cannot be economically treated with prescribed fire. Appropriately managing wildfire in 

places with an opportunity to obtain resource benefits and a low risk of potential damages may be 

the only way in many areas to increase the pace and scale of ecosystem restoration activities. 

Continued risk-informed management of wildfire would also need to include a method to 

maintain areas once restoration has occurred.

Acknowledge the Ecological Role of Fire

Acknowledge the ecological role of fire but also be cognizant of the fact that many fire regimes in 

the southern Sierra Nevada are currently highly altered and will stay altered because many 

sociopolitical concerns affect how wildfires are managed and how fuels are treated. The goal of 

ecological restoration is not to return the landscape to its historical fire regime (because such an

outcome is not realistic with the extent of human influence), but instead to have forests that are 

sustainable and resilient to expected changes over time.

Align with Policy

The 2009 “Guidance for Implementation of Federal Wildland Fire Management Policy” directs

Federal agencies to manage wildfires to accomplish protection and resource objectives. A wildfire 

may be concurrently managed for one or more objectives and these can change as fire spreads 

across the landscape. Objectives for wildfires are affected by changes in fuels, weather, and 

topography; varying social understanding and tolerance; and involvement of other governmental 

jurisdictions having different missions and objectives. This guidance requires land managers to 

address the location and conditions under which resource benefits and protection objectives can 

be met in forest plans. 

The “wildfire management continuum” was created to visually depict how wildfires may be 

managed for one or more objectives (Thompson et al. 2016). The basics of the wildfire 

management continuum can be described according to four dimensions (figure 11). Using risk 

management results according to these dimensions, allow for the landscape to be zoned according 

to broad categories. The strategic fire management zones highlight where the objectives can be 

met under a wide range of fire season conditions.

• The length (side to side) of the continuum shows the spatial component, or the location on 

the landscape. The location also affects the mix of objectives: on the left, it favors 

protection objectives, whereas on the right it favors resource objectives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

115

• The width (up and down) of the continuum illustrates the different social, ecological or 

environmental conditions affecting the mix of objectives. On the top, protection objectives 

prevail, whereas on the bottom resources objectives are easier to obtain.

• The colors depict the range of objectives, taking in the combination of both location and 

conditions. Red (upper left) represents how the combination of conditions and landscape 

location can experience higher risks to communities or ecological resources, which result in 

protection as the predominate objective. Blue (lower right) has the combination of low-risk 

conditions and landscape location that make managing for resources the primary objective. 

The colors also represent the net value change to natural resources and community assets; 

red indicates a negative change (damage) while blue indicates a positive change (benefit). 

The fire management response is to protect from potential damage and to obtain benefit. As 

risk is lowered on the landscape, more positive net value change opportunities exist over 

more locations and conditions, therefore increasing the ratio of blue to red.

• The teeth on each end of the continuum indicate that it wraps around to form a cylinder. A 

wildfire on the far left could be near an area with high risk and management of that portion 

of the fire would be to meet protection objections. Whereas, a fire on the right side being 

managed primarily for resource objectives may change to a fire managed for protection 

objectives due to environmental changes that caused it to grow and threaten resources and 

assets.

Figure 11. The wildfire management continuum

Manage Risk

Effective management of wildfire addresses the nature of wildfire and its contributing factors, 

recognizes the positive and negative consequences of fire, addresses uncertainty, and develops 

plans that reduce the chances of catastrophic losses (USDA and USDI 2014). Forest and fire 

managers manage risk, both in the short and long terms. If the potential positive and negative 

consequences of fire are recognized, and management actions to obtain positive outcomes are 

matched, then in the long term the risk to communities and assets will be reduced; fire will be 

restored as an ecosystem function to the landscape; and smoke impacts to communities will be 

reduced. Also, risks and uncertainties relating to fire management activities must be understood, 

analyzed and communicated.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

116

Synopsis

During any wildfire, fire managers must consider firefighter and public safety, risk to property, 

fire management resource availability, national and regional priorities, costs, and potential 

resource benefits in all wildfire management decisions. A wildfire may be concurrently managed 

for one or more objectives and these can change as the fire spreads across the landscape. 

Objectives are affected by changes in fuels, weather, topography; varying social understanding 

and tolerance; and involvement of other governmental jurisdictions having different missions and 

objectives (Guidance for Implementation of Federal Wildland Fire Management Policy, February 

2009). Forest Service policy dictates that all wildfires will have a protection objective (2015 

“Interagency Standards for Fire and Fire Aviation Operations”). Wildfires may also have resource 

objectives that are outlined in the forest plan. 

Analysis and Methods

A wildfire risk assessment for the Inyo National Forest was conducted using the methods outlined 

in the publication “A Wildfire Risk Assessment Framework for Land and Resource Management”

(Scott et al. 2015). The wildfire risk assessment identified areas of risk, which helped in the 

development of designating the strategic fire management zones. Spatial data is used in the 

assessment to analyze where resource objectives and protection objectives can be met.

For this analysis, FSim, a computer program for large-fire simulation, was used to quantify 

wildfire hazard across the landscape. FSim is a comprehensive fire occurrence, growth, behavior, 

and suppression simulation system that uses locally relevant fuel, weather, topography, and 

historical fire occurrence information to estimate the contemporary likelihood and intensity of 

wildfire across the landscape (Finney et al. 2011). A geographic information system model 

combined the FSim outputs and highly valued resources and assets (HVRAs) to identify the 

strategic fire management zones for the alternatives. Zones were evaluated and refined using local 

knowledge from fire managers, fuels specialists, and other forest managers.

A major part of a wildfire risk assessment is to have a good indication of where potential damages 

and benefits can occur. This is more than just locating the highly valued resources and assets, it is 

locating where they have the potential to be positively or negatively affected considering the 

likelihood of a wildfire occurring and the intensity at which it would likely burn. The two main 

indicators are location (where the potential damages and benefits to highly valued resources and 

assets are located) and source (where the wildfire ignitions of these potential damages and 

benefits start). The technical measure of the potential damages and benefits for location and 

source is determined by the net value change and is documented in the “Southern Sierra Nevada 

Wildfire Risk Assessment” report in the project record.

Highly valued resources and assets are a combination of natural resources and community assets 

whose value could potentially be affected either positively or negatively by fire. A requirement 

for highly valued resources and assets is that they must be spatially identified. Once highly valued

resources and assets were categorically identified and mapped, resource specialists identified

what the potential response to fire would be for each category. Next, the Forest Supervisor for the 

Inyo National Forest determined the relative importance between the highly valued resources and 

assets (table 10).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

117

Table 10. Example highly valued resources and assets (HVRAs) and their relative importance values

Highly Valued Resources and Assets (HVRAs)

Relative Importance

(max. 100)

Human habitation – (classified into 3 sub-HVRAs) High-density human 

habitation, moderate-density human habitation, and low-density human 

habitation1

97

Major infrastructure – (classified into 4 sub-HVRAs) Electrical power 

transmission lines, non-hydroelectric power plants, communication sites, 

hydroelectric power plants

83

Watershed resources – (classified into sub-HVRAs) based on number of

people served (Forest to Faucets2), vegetation, slope and erosion potential

80

Critical terrestrial habitat (classified into sub-HVRAs) based on 4 habitat 

types: modified California spotted owl,

3 northern goshawk, and greater 

sage-grouse, and different species type and size of trees

78

Timber resources – 3 groups of tree species and size (classified into 6 

sub-HVRAs) based on access (terrain steepness and access from road)

74

Inholdings – include State forests and private timber lands 67

Recreation and administrative infrastructure – (classified into 2 subHVRAs); Low and high developed sites

65

Visual resources - scenic byways 60

Vegetation condition class – (classified into 15 sub-HVRAs) based on 

biophysical settings, succession class, and relative abundance

50

1. Additional egress routes were evaluated within the high density human habitation asset

2. Forests to Faucets is a reference for how the number of people served by watershed was determined (see 

http://www.fs.fed.us/ecosystemservices/FS_Efforts/forests2faucets.shtml)

3. California spotted owl habitat was modified to only include the conifer forested portions of the Kern and San Joaquin 

drainages on the Inyo National Forest. 

Relative importance values were developed by first ranking the highly valued resources and 

assets, then assigning a relative importance value to each. The most important highly valued 

resources and assets were assigned a relative importance value of 97 (Scale ranges from 0-100). 

Each remaining highly valued resource and asset was then assigned a relative importance value 

indicating its importance relative to the most-important highly valued resource and asset.

As previously stated, the Cohesive Strategy goals formed the basis for developing the fire 

management strategies in the alternatives. Using the wildfire risk assessment as a tool, the three 

goals from the Cohesive Strategy are evaluated as indicators for each alternative:

• Restore and maintain landscapes through the use of wildfire. Landscapes are resilient to 

fire-related disturbances in accordance with management objectives and the risk of 

undesired effects to landscapes is diminished. Managing wildfire to meet resource 

objectives is vital to meeting this goal, especially in areas where active management is 

limited.

• Support fire-adapted communities. Human populations and infrastructure within and 

adjacent to the national forest can withstand a wildfire without loss of life and property. 

Risk of wildfire impacts to communities is diminished. Assess the level of risk and 

establish roles and responsibilities for mitigating both the threat and the consequences of 

wildfire.

• Improve safe and effective fire response. All jurisdictions participate in making and 

implementing safe, effective, efficient risk-based wildfire management decisions. Assessing 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

118

wildfire risk upfront is essential to safe and effective response. Risk exposure to firefighters 

is based on a balanced consideration of values protected and the probability of success. 

Injuries and loss of life to the public and firefighters are diminished.

Two measures rate how well each alternative addresses the indicators:

• Managing Uncertainty: Managing uncertainty aids in making more holistic wildland fire 

management decisions by giving decision makers needed information on potential decision 

outcomes and their associated risks in advance of the time when these decisions become 

urgent. Uncertainty is measured by how well each strategic fire management zone in each 

alternative categorizes the potential damages and benefits to highly valued resources and 

assets from simulated wildfires. A zone that captures mostly benefits would have low 

uncertainty while a zone with a high mix of both damages and benefits would have high 

uncertainty.

• Facilitating Wildland Fire Management: This measures the ability of each alternative to 

identify and enhance strategic fire management features on the landscape and provide a 

greater ability to enhance these features through fuel reduction and vegetation treatments.

Affected Environment

Historical Wildfires and Wildfires Managed to Meet Resource Objectives

Wildfires on the Inyo historically burned about 98,242 acres, averaging 4,678 acres a year from

1996 to 2016. The amounts fluctuate from year to year depending on conditions and the number 

of fire ignitions. Fire ignitions are either from lightning or human-caused sources. Over the 20 

year analysis period, 861 lightning-caused fires burned approximately 61,591 acres whereas 

1,275 human-caused fires burned approximately 36,651acres (figure 12).

Wildfires managed to meet resource objectives, on average totaled approximately 995 acres a 

year (20-year average). Per Forest Service policy, national forests are only allowed to manage 

lightning-caused wildfires to meet resource objectives (FSM 5130.3). While fire managers have 

had the option to manage wildfires to meet resource objectives, it has been rarely used.

Fuel Reduction Treatments

Mechanical treatments average approximately 2,300 acres annually (10-year average) on the Inyo 

National Forest. In shrublands, treatments are usually mowing or cutting shrubs with chainsaws. 

The treatments are often implemented in a mosaic to mimic natural patterns, retain important 

shrub species for wildlife, and to reduce the visual impacts. In forested ecosystems, most 

mechanical treatments are a combination of mechanical thinning of understory trees and 

mastication (shredding of woody vegetation) or piling and burning of small trees and activitygenerated fuels. Most treatments are designed to reduce surface fuels so that future fires will burn 

with lower flames. Treatments are intended to raise the height of tree branches so flames are less 

likely to burn into the crowns of trees and spread rapidly. Project design criteria often include 

variable spacing and requirements to retain more canopy cover and to retain patches of shrubs 

and small or more dense trees for wildlife cover and to provide more natural scenery. This results 

in heterogeneity in fuels and higher fuel levels that influence the behavior of future fires within 

treated areas, increasing fire intensity and fire spread. In the Jeffrey pine ecosystem on the Inyo 

National Forest, however, treatments accomplished to date are expected to help moderate wildfire 

behavior, thus facilitating the use of managed wildfires to achieve resource objectives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

119

Figure 12. Historic ignitions and acres burned by cause: 1996-2016, Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

120

Prescribed fire treatments on the Inyo National Forest, on average, were approximately 1,500 

acres annually (10-year average). Currently, the amount of prescribed burning is not occurring at 

a sufficient scale to reduce fuels to the extent that would influence large wildfires that burn at 

high intensity or at a pace to restore the desired fire return frequency that would restore resilience 

to the landscape. Most prescribed burning occurs within areas either previously mechanically 

treated to reduce fuels or areas that have previously been prescribed burned. Prior to a prescribed 

burn, a burn plan prescription is developed that determines the burn objectives, resource 

requirements (such as limited operating periods for wildlife and protection measures for cultural 

resources) and weather and fuel conditions under which the prescribed burn can be implemented. 

Before burning, fire managers determine if the weather and fuel conditions are within the burn 

plan prescription and fire management resources are sufficient to ensure the burn objectives can 

be safely met. Because prescribed burning is dependent upon weather and fuel conditions, 

seasonal timing, availability of resources, and acceptable conditions for managing smoke, some

areas have been mechanically treated but have not yet been burned due to suboptimal conditions.

Fire Management Coordination

The Forest Service coordinates with local fire districts and State fire agencies, interagency

partners (especially the National Park Service and Bureau of Land Management), and tribal 

liaisons during wildfire incidents and prior to fire season to develop prevention programs in high 

wildfire risk areas. Fire managers work with local communities to decide where and how to apply 

fuel reduction projects on Federal lands through a community wildfire protection plan. Under all 

alternatives, this communication and coordination would continue and propagate as fuel reduction 

treatments are planned on the Inyo National Forest.

Environmental Consequences of Fire Management

Strategic Fire Management Zones

The wildfire risk assessment includes the Inyo National Forest and surrounding areas to analyze 

fires that not only occur on the national forest, but also fires that originate on other lands and burn 

onto the national forest. Vegetation on the Inyo varies from desert shrubs in the lowest elevations 

to alpine areas on the mountain crests. In the arid portions of the national forest, sagebrush and 

pinyon-juniper can occur from the lower elevations and extend all the way up into the subalpine 

zone. Where there is more precipitation in the montane zone, Sierra type conifer forests occur. 

Subalpine forests usually dominated by five-needle pines occur in the higher elevations of all the 

mountain ranges. Alpine areas and areas characterized mostly by rock are common.

The zones used in alternative A (the current forest plan) consist of the two zones within the 

wildland-urban intermix: the defense zone and the threat zone; and the general forest, which 

consists of the area outside the urban-wildland intermix. The wildfire risk assessment was the 

basis for the creation of strategic fire management zones in alternatives B, B-modified, D and, in 

part, the zones in alternative C. The zones identified from the modeling outputs are described 

below. The consequences are described separately by alternative in the analysis that follows.

Overview of the Proposed Strategic Fire Management Zones

Strategic Fire Management Zones in Alternative A

The zones in alternative A shown in figure 13 were created for the existing forest plan during the 

2004 Sierra Nevada Forest Plan Amendment (USDA Forest Service 2004d) and were not created 

using a wildfire risk assessment.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

121

Figure 13. Map showing the location of the strategic fire management zones for alternative A
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

122

1. Wildland-urban Intermix Defense Zone: This zone identifies areas with a one-quartermile buffer from structures. Fire management direction within this zone focuses on 

hazardous fuel reduction treatment as the highest priority. Fuel reduction treatments 

(mostly mechanical) in this zone are the most intense to create defensible space to 

prevent the loss of life and property. Wildfires will continue to be managed using the 

appropriate suppression strategy.

2. Wildland-urban Intermix Threat Zone: This zone identifies areas with a buffer of 1.25 

miles beyond the one-quarter-mile buffer from the wildland-urban intermix defense zone. 

Fire management direction within this zone focuses on hazardous fuel reduction 

treatment as the highest priority. Fuel reduction treatments in this zone are strategically 

located to interrupt wildfire spread and reduce fire intensity. Wildfires will continue to be 

managed using the appropriate suppression strategy.

3. Other: This zone identifies areas in the rest of the national forest outside the wildlandurban intermix defense and threat zones. This area encompasses other land allocations, 

but home range core areas, old forest emphasis areas, general forest, and wilderness 

allocations predominate. Fuel treatments in the general forest are designed to support 

treatments in the wildland-urban intermix threat zone, to protect sensitive habitats, and 

reintroduce fire into fire-dependent ecosystems. Wilderness is managed to maintain 

predominantly natural and natural-appearing environments and mechanical vegetation 

treatments are not allowed. Prescribed fire can be used to reduce the risk and 

consequences of wildfire burning within wilderness, or prevent wildfire escaping from 

wilderness to an acceptable level. Lightning-caused wildfires may be managed to meet 

resource objectives when conditions allow and it can be done in a safe manner.

Strategic Fire Management Zones in Alternative B 

The zones for alternatives B are management areas created from modeled outputs produced by 

the wildfire risk assessment. The proportion of area in each zone is shown in figure 18 along with 

a map in figure 14.

1. Community Wildfire Protection Zone: This zone identifies the areas where

communities, community assets, and private land could be at a high risk of damage from 

wildfire. This zone assists with preparedness decisions, communication and outreach to 

high-risk communities, and prioritization of fuel treatments within and near communities. 

Although it may be limited, lightning-caused wildfires may be managed to meet resource 

objectives when conditions allow, and it can be done in a safe manner as identified within 

the current forest plans.

2. General Wildfire Protection Zone: This zone identifies areas with a moderate to high 

risk to communities and assets as well as natural resources. This zone assists in 

prioritizing fuel treatments and fire management activities where targeted ecological 

restoration and hazardous fuel reduction will be needed to contribute to the protection of 

communities. Although it may be limited, lightning-caused wildfires may be managed to 

meet resource objectives when conditions allow, and it can be done in a safe manner as 

identified within the current forest plans.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

123

Figure 14. Map showing the location of the strategic fire management zones for alternative B 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

124

3. Wildfire Restoration Zone: This zone identifies the areas with a low to moderate risk, 

mostly to natural resources and some risk to assets. This zone assists with prioritization 

of fuel reduction treatments to create more opportunities under a wider range of 

conditions to manage wildfires to meet resource objectives and achieve forest plan 

desired conditions. The management of wildfires to meet resource objective is 

encouraged when conditions allow and when it can be done in a safe manner.

4. Wildfire Maintenance Zone: This zone identifies the areas with very low risk, mostly to 

natural resources and some risk to assets. Wildfires that occur in this zone will likely 

maintain or help achieve forest plan desired conditions. The management of wildfires to 

meet resource objective and applying prescribed fire treatments is encouraged when 

conditions allow and when it can be done in a safe manner.

Strategic Fire Management Zones in Alternatives B-modified and D

The zones for alternatives B-modified and D are management areas created from modeled outputs 

produced by the wildfire risk assessment. Modifications were made to correct errors to highly 

valued resources and assets and adjust potential wildland fire operational delineation units

(PODs) when creating the zones (see chapter 2). The proportion of area in each zone is shown in 

figure 19 along with a map in figure 15.

1. Community Wildfire Protection Zone: This zone identifies the areas where 

communities, community assets, and private land could be at a high risk of damage from 

wildfire. This zone assists with preparedness decisions, communication and outreach to 

high-risk communities, and prioritization of fuel treatments within and near communities. 

Although it may be limited, lightning-caused wildfires may be managed to meet resource 

objectives when conditions allow, and it can be done in a safe manner as identified within 

the current forest plans.

2. General Wildfire Protection Zone: This zone identifies areas with a moderate to high 

risk to communities and assets as well as natural resources. This zone assists in 

prioritizing fuel treatments and fire management activities where targeted ecological 

restoration and hazardous fuel reduction will be needed to contribute to the protection of 

communities. Although it may be limited, lightning-caused wildfires may be managed to 

meet resource objectives when conditions allow, and it can be done in a safe manner as 

identified within the current forest plans.

3. Wildfire Restoration Zone: This zone identifies the areas with a low to moderate risk, 

mostly to natural resources and some risk to assets. This zone assists with prioritization 

of fuel reduction treatments to create more opportunities under a wider range of 

conditions to manage wildfires to meet resource objectives and achieve forest plan 

desired conditions. The management of wildfires to meet resource objective is 

encouraged when conditions allow and when it can be done in a safe manner.

4. Wildfire Maintenance Zone: This zone identifies the areas with very low risk, mostly to 

natural resources and some risk to assets. Wildfires that occur in this zone will likely 

maintain or help achieve forest plan desired conditions. The management of wildfires to 

meet resource objective and applying prescribed fire treatments is encouraged when 

conditions allow and when it can be done in a safe manner.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

125

Figure 15. Map showing the location of the strategic fire management zones for alternatives Bmodified and D
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

126

Strategic Fire Management Zones in Alternative C

The zones created for alternative C are management areas based on a combination of existing 

management areas and modeled outputs from the wildfire risk assessment (figure 16).

Figure 16. Map showing the location of the strategic fire management zones for alternative C
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

127

The distance-based wildland-urban intermix defense zone around communities would remain the 

same as in the existing plan. The maintenance zone is created using the same risk-based 

methodology used to create the wildfire maintenance zones as alternative B-modified and D. The 

general wildfire zone consists of the restoration zone, general wildfire protection zones, and 

portions of the community wildfire protection zone. Modifications were made to correct errors to 

highly valued resources and assets and adjust potential wildland fire operational delineation units 

(PODs) when creating the zones (see chapter 2).

1. Wildland-urban Intermix Defense Zone: This zone identifies areas created with a onequarter-mile buffer from structures. This zone is the same as the wildland-urban intermix 

defense zone in alternative A.

2. General Wildfire Zone: This zone identifies a broad area, including the wildfire 

restoration zone, general wildfire protection zone, and portions of the community wildfire 

protection zone from alternatives B, alternative B-modified, and D. An increased 

emphasis on managing wildfire to meet resource objectives and increased use of 

prescribed fire in fire adapted ecosystems would occur in this zone.

3. Wildfire Maintenance Zone: This zone identifies areas with very low risk, mostly to 

natural resources and some risk to assets. Wildfires occurring in this zone will likely 

maintain or help achieve forest plan desired conditions. This zone was created with the 

same concept as the wildfire maintenance zone in alternatives B, B-modified, and D; 

however, the proportion of the forest area that it covers is slightly higher due to the way 

the zones were divided. Management of wildfires to meet resource objectives and 

applying prescribed fire treatments is encouraged in this zone when conditions allow and 

when it can be done in a safe manner. 

Figure 17. Proportion of the Inyo National Forest within each zone in alternative A

Consequences Specific to Alternative A

Under this alternative there are two fire management oriented zones and the rest of the general 

forest area referred to as “other” (see figure 13). The proportion of the total area of the Inyo 

National Forest within each zone are 1 percent in the wildland-urban intermix defense zone, 10 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

128

percent in the wildland-urban intermix threat zone and 89 percent in “other” as shown in figure 

17.

These two wildland-urban intermix zones were created using proximity to communities as a 

proxy for fire risk, with the highest risk immediately adjacent to communities but recognizing 

fires that start more than 1.5 miles away from communities and outside of the wildland-urban 

intermix can still be a threat. These wildland-urban intermix zones are used primarily to prioritize 

fuel treatments on each national forest.

The focus of fire management in this alternative is to use mechanical treatments and prescribed 

fire to slow fire spread in the forest overall and provide defensible space in the wildland-urban 

intermix. Treating along key roads and ridges provides fire managers with opportunities to 

develop operational plans to conduct larger prescribed burns or to manage wildfires to meet 

resource objectives. 

Under alternative A, the primary response to wildfire ignitions is to continue suppressing most 

lightning fires, which will continue to move areas away from the natural range. Fuel reduction 

treatments (prescribed burning and mechanical treatment) would remain the same as under 

current direction.

Restore and Maintain Landscapes Through the Use of Wildfire

Managing Uncertainty: Alternative A was developed with an emphasis on reducing fire threats 

to communities based upon a concept of two distance-based zones in the wildland-urban intermix 

where fuel reductions are concentrated. Alternative A does not assess the potential benefits or 

damages to resources that would be expected from wildfires. The wildfire risk assessment 

validates that the existing wildland-urban intermix defense and threat zones reasonably capture

where potential damages might occur in relation to where people live as shown by the amount of 

red and orange areas in figure 13 in those zones. However, the two wildland-urban intermix zones 

do not capture potential damages to infrastructure outside these areas or to natural resources as 

shown in the amount of red and orange in the “other” portion of the forest. In addition, benefits to 

natural resources from wildfires shown in the blue areas in figure 13 are not captured, so areas 

where wildfires could contribute to ecosystem restoration and maintenance of ecosystem 

functions are not identified.

In alternative A, it is more difficult for forest and fire managers to know where the potential 

damages and benefits are located when deciding on a fire management strategy when a fire 

ignition occurs. Under this alternative, these decisions are typically supported by analysis and 

information about potential wildfire risks and benefits gathered on-the-fly after the wildfire starts. 

This can be challenging when there are multiple fires occurring in the area, across states, or 

across the nation. In these situations, fire resources are scarce and precautionary decisions to 

suppress fires are often made by default. With current fire management strategies that lack 

upfront identification of potential risks and benefits and associated plan components that identify 

resource objectives, there would be a continued emphasis on suppressing wildfires.

Facilitating Wildland Fire Management: The primary emphasis in alternative A is to reduce the 

threat of wildfire to communities in the wildland-urban intermix. The strategies and priorities 

were designed to reduce fuels near communities and employ fuel reduction treatments in other 

areas of the forest so fires would burn into them and slow down and lessen their intensity to aid in 

suppression. The most flexibility to design effective fuel reduction treatments occurs in the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

129

wildland-urban intermix defense zone, closest to communities. Outside of the wildland-urban 

intermix defense zone, additional standards and guidelines apply to minimize or mitigate 

concerns for the effects of fuel reduction treatments on wildlife habitat. Some of those standards 

and guidelines are reduced or waived in the wildland-urban intermix threat zone to recognize the 

need for more effective treatments to reduce the potential for fires to burn from the threat zone 

into the defense zone and threaten communities. However, designing implementable and effective 

fuel reduction projects that comply with the standards and guidelines has been difficult in some 

areas, resulting in small, disconnected treatment units, or treated areas with residual fuels and 

vegetation that are not very effective at slowing fires down or that make prescribed burning more 

complex.

Most fuel reduction treatments are designed as mechanical thinning or mechanical manipulation 

of fuels followed by prescribed burning of treated units or burning of piles of fuels. In many 

cases, thinning has occurred but restoring fire through prescribed burning has yet to occur 

resulting in a backlog of areas ready for prescribed burning. The opportunity to apply prescribed 

burning over large landscapes is limited given the pattern of heavy fuels and interspersed areas 

where fuel reduction treatments have occurred.

The ability to manage wildfires to meet resource objectives is allowed, but it is rarely done. 

Previous plan direction does not emphasize additional fuel reduction treatments in key locations 

such as along ridges and key roads that can serve as anchor points for larger landscape prescribed 

burning or serve as tactical locations to manage wildfires to meet resource objectives. The current 

pattern of small and disconnected fuel reduction treatments under alternative A would remain at 

the same low pace and scale of treatment due to constraints for other resources; this is reducing 

the potential to restore and maintain landscapes to a level where they are sustainable, resilient,

and can recover from disturbance.

Support Fire-adapted Communities

Managing Uncertainty: Under alternative A, the wildfire risk to communities and values are 

defined by the distance-based wildland-urban intermix defense and wildland-urban intermix

threat zones, which were not created using a risk assessment. Although management activities in 

these zones are focused on protecting life and property, without a risk assessment management 

decisions in the general forest are likely to be less effective because managers don’t fully 

understand how risks are distributed across the landscape spatially and which highly valued 

resources and assets face the greatest loss or benefit. Important factors such as the type and 

distribution of fuels, terrain, winds, historic fire ignition locations, and the combinations of these 

factors are recognized as contributing to fire risk in the wildland-urban intermix, but they were 

not modeled to evaluate potential risk to communities in the wildland-urban intermix zones. 

Continued coordination with local partners and communities for protection and prevention in high 

wildfire risk areas exists to enhance the effectiveness of initial fire response.

Facilitating Wildland Fire Management: Although fuel reduction treatments are limited in 

alternative A, fire managers would continue to work with communities to be more fire adapted 

through collaborative efforts, supporting community wildfire protection plans, and conducting 

fuel reduction treatments in the wildland-urban intermix defense and threat zones. A priority is 

placed on fuel reduction in the two wildland-urban intermix zones. Alternative A does not account 

for the likelihood of fires to spread from adjacent areas in the “other” portions of the national 

forest that contribute to the risk to communities or infrastructure. Managing wildfires to meet 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

130

resource objectives is a decision option, although it is rarely used near fire-adapted communities 

due to public concerns and the challenge of managing risks.

Improve Safe and Effective Fire Response

Managing Uncertainty: Under alternative A, risks have not been spatially identified outside the 

wildland-urban intermix defense and wildland-urban intermix threat zones. Without assessing risk 

upfront, pre-planning actions such as fuel reduction treatments and fire prevention actions would

not be focused or prioritized on high risk locations. Wildfire response would continue to favor the 

current response of actively suppressing most fires. This would continue to make it difficult for 

fire managers to make on-the-fly decisions that consider the safety of fire responders and costs of 

the fire commensurate with values at risk because these risks to values are not evaluated upfront.

Facilitating Wildland Fire Management: The two wildland-urban intermix zones in alternative 

A do not provide the support for improving wildfire response to large, unwanted wildfires that 

could threaten communities, or identify where the potential damages and benefits are located to 

enhance wildfire response. The limited fuel reduction treatments are focused on slowing fire

spread and reducing fuels in more easily treatable areas near roads and on flatter ground. The 

original intent to treat in a more geometric pattern so that wildfires would run into these areas like 

speedbumps has proven difficult to implement on the ground due to prescriptive and restrictive 

standards and guidelines that limit the type of treatment and the effectiveness of reducing fuels. 

Communities would continue to experience the risk of high-intensity fires that threaten structures 

and homes from fires that burn on national forest and move toward communities. Although the 

choice to manage wildfires to meet resource objectives exists, it is not the current management 

choice in most situations.

Figure 18. Proportion of the Inyo National Forest within each zone in alternatives B 

Consequences Specific to Alternative B 

Under this alternative there are four risk-based strategic fire management zones (figure 14).The 

proportion of the total area of the Inyo National Forest within each zone is 9 percent in the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

131

community wildfire protection zone, 19 percent in the general wildfire protection zone, 29

percent in the wildfire restoration zone and 44 percent in the wildfire maintenance zone (figure 

18).

In alternative B, fuel reduction treatments are more extensive than alternative A to improve 

vegetation desired conditions and to make more areas suitable for managing fires to meet 

resource objectives. Managing wildfires to meet resource objectives is highly encouraged in the 

maintenance and restoration zones and somewhat limited in the protection and general zones.

Restore and Maintain Landscapes Through the Use of Wildfire

Managing Uncertainty: Under alternative B, a full spectrum of fire management strategies

ranging from full suppression (where fires are extinguished) to confine and contain, and 

monitoring (where fires can be managed to meet resource objectives) are available across all the 

zones. Allowing the natural role of fire to occur under conditions that are conducive to meeting 

resource objectives when it can be done in a safe manner would provide for ecological restoration 

and improved resilience within any of the zones. Having the flexibility to manage wildfire along 

the full range of the continuum can be useful if decisionmakers have the needed information to 

decide to use that flexibility. In this alternative, the strategic fire management zones were 

designed with the risk assessment that reduces uncertainty to fire management decisionmakers.

The zones categorize the locations of where the values of highly valued resources and assets

change positively or negatively for both assets and natural resources. These zones capture where 

benefits and damages are likely to happen under a wide range of fire conditions because the zones 

were developed using a modeled risk assessment. Important strategic locations are identified in 

relation to potential damages and benefits, most of which are along zone boundaries. The 

condition a fire burns under ultimately dictates the outcome of the fire but these zones aid in 

defining the location of likely outcomes. Managing uncertainty should result in more wildfire 

being managed in a way that restores and maintains landscapes; however, it is expected that this 

would occur the most often in the wildfire restoration and wildfire maintenance zones because 

these zones identify the areas with the lowest risk to highly valued resources and assets.

Facilitating Wildland Fire Management: Wildfire management under alternative B provides an 

increased opportunity to manage larger wildfires due to the increased amounts of treatments that 

reduce fuel loading in strategic locations. In alternative B, there would be more opportunity for 

fuel reduction projects and wildfires managed to meet resource objectives. Treatments would be 

prioritized in strategic locations (roads, ridgetops, and other natural and manmade features) 

designed to treat primarily the dry forest patches to restore fuels toward the natural range of 

variation. These treatments would serve as anchor points for larger prescribed burns and they 

create areas of low fuel that can be used to manage future wildfires. All of these restoration 

activities would reduce potential smoke emissions from large, undesirable wildfires.

Support Fire-adapted Communities

Managing Uncertainty: The community and general wildfire protection zones capture a 

substantial portion of the high fire risk to communities and assets as shown by the large portion of 

red and orange in figure 18. Increased fuel reduction treatments in alternative B would assist in 

creating more fire-adapted communities with improved certainty of resource and asset locations 

in the community and general wildfire protection zones. The identification of fire risk would aid 

in coordination with State and local fire agencies.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

132

Facilitating Wildland Fire Management: More fuel reduction treatments occur in alternative B 

than in alternative A. Fire managers would continue to work with communities to help them

become more fire adapted through collaborative efforts, such as supporting community wildfire 

protection plans and prioritizing fuel reduction treatments in the community and general wildfire 

protection zones. Managers would continue to coordinate with local partners and communities for 

protection and prevention in the high wildfire risk areas to enhance the effectiveness of initial 

response to fires. Although the use of wildfire to meet resource objectives would likely be limited 

initially in the wildfire protection zones, more fuel reductions treatment would lower the risk over 

time and increase the potential to reduce fire suppression costs by managing at least portions of 

wildfires to meet resource objectives.

Improve Safe and Effective Fire Response

Managing Uncertainty: In alternative B, risks are better identified than in alternative A by the 

creation of the four strategic fire management zones based upon the wildfire risk assessment. The 

zones reduce uncertainty by categorizing risk and allow for fires to be managed on a continuum 

between meeting protection objectives and resource objectives within these zones, while using 

risk-based responses. Categorizing the potential benefits along with the residual risks to resources 

reduces uncertainty in the wildfire restoration and maintenance zone as shown by the gradation of 

red to blue in those two zones as shown in figure 18.

Facilitating Wildland Fire Management: In alternative B, treatments would be designed along 

strategic roads, ridgetops, and other natural and manmade features that would create more 

opportunities to conduct larger prescribed burns and provide tactical locations to manage future 

wildfires. This alternative allows for wildfires to be managed to meet resource objectives as areas 

on the landscape (zones) shift toward the wildfire maintenance zones. The additional 

recommended wilderness areas in the community and protection zones could limit use of 

mechanized equipment during wildfire response and limit fuel reduction treatments, but use of 

prescribed fire could occur under some circumstances when it is for restoring fire toward the 

natural range of variation and to meet wilderness desired conditions. In the community wildfire 

protection zone, community buffers are identified in close proximity to structures where fuel 

conditions, large logs, and snags are treated to allow for safer conditions for firefighters and 

public safety (Ewell et al. 2012, Agee and Skinner 2005).

Consequences Specific to Alternative B-modified

Alternative B-modified uses the same strategic fire management zones as described for 

alternatives B and D (figure 15). The proportion of the total area of the Inyo National Forest 

within each zone is 6 percent in the community wildfire protection zone, 28 percent in the general 

wildfire protection zone, 27 percent in the wildfire restoration zone and 39 percent in the wildfire 

maintenance zone (figure 19).

The proportions are slightly different than the zones in Alternative B because the zones in 

alternatives B-modified and D were created using modifications to the data used in the risk 

assessment (see chapter 2, “Revision Topic 1: Wildland Fire Management,” “Strategic Fire 

Management Zones” for specific modifications).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

133

Figure 19. Proportion of the Inyo National Forest within each zone in Alternatives B-modified and D

Consequences Specific to Alternative C

In alternative C, mechanical fuel reduction treatments are focused around structures and limited 

in other areas in alternative C. Managing wildfire to meet resource objectives is limited in the 

wildland-urban intermix defense zone (1 percent) and highly encouraged in the general wildfire 

and wildfire maintenance zones (58 percent and 41 percent, respectively; figure 20).

Figure 20. Proportion of the Inyo National Forest within each zone in alternative C

Restore and Maintain Landscapes Through the Use of Wildfire

Managing Uncertainty: Under alternative C, a full spectrum of fire management strategies

ranging from full suppression (where fires are extinguished) to confine/contain and monitoring 

(where fires can be managed to meet resource objectives) are available across all the zones.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

134

Similar to alternative A, fires would be managed to meet resource objectives when conditions 

allow and it is safe to do so; however, with much uncertainty in the general wildfire zone. The

wildfire maintenance zone was created using the risk assessment and generally occurs in the 

higher elevations and wilderness areas. The wildland-urban intermix defense zone was defined by 

proximity to communities and is primarily at the lower elevations along the national forest 

boundary, but it also surrounds smaller communities and developments within the national forest.

This leaves a large area between these two zones, which became the general wildfire zone with a 

wide range of highly valued resources and assets potentially changing value from high damage 

shown in the red and orange in the upper left, to low benefit shown in blue and green in the 

bottom right. This wide range in risk in the general wildfire zone provides decision makers little 

information to aid in choosing an appropriate management strategy for a wildfire.

Facilitating Wildland Fire Management: Mechanical fuel reduction treatments in this 

alternative would be more restricted than in alternative A, but strategically placed as in alternative 

B. The costs of removing only small material would limit the amount of area that can be 

accomplished due to the need to use appropriated funding where projects cannot offset costs with 

timber harvest and stewardship funding. This would leave more fuels to be removed by 

prescribed burning, which may require multiple prescribed burns over time to effectively reduce 

fuels. Prescribed burning would be encouraged and would likely initially focus on burning areas 

previously treated mechanically and expanding treated and burned areas to larger landscapes. 

Prescribed burns may be more complex compared to if fuels were reduced mechanically; this 

would require additional fire resources to complete the burn and more careful planning for 

weather and fuel conditions to safely meet burn objectives. When conditions allow and it is safe 

to do so, wildfires would be managed to meet resource objectives under this alternative, but this is 

mostly limited to the wildlife maintenance zone due to the more limited areas of effective fuel 

reduction treatment in the other zones.

Support Fire-adapted Communities

Managing Uncertainty: The wildland-urban intermix defense zone captures much of the risk 

closest to communities but does not account for the likelihood of fires to spread from high risk 

areas in the adjacent general wildfire zone to the wildland-urban intermix defense zone, which 

would threaten communities or infrastructure (as shown by the large area of red and orange in the 

general wildfire zone in figure 20). In this alternative, fuel reduction and preparedness in the 

communities are relied upon more to manage risk on the lands closest to the structures.

Facilitating Wildland Fire Management: In alternative C, continued coordination with local 

partners and communities for protection and prevention in high wildfire risk areas would enhance 

the effectiveness of initial response. Mechanical fuel reduction treatments would be more limited 

in alternative C than in alternatives B and D as limitations on mechanical treatments to provide 

for habitat for the California spotted owl apply even within the wildland-urban intermix defense 

zone. However, fire managers would continue to assist communities in being more fire adapted 

through collaborative efforts such as community wildfire protection plans and an increased focus 

on fuel reduction treatments where possible in the wildland-urban intermix defense zone. There is 

the least amount of mechanical treatment and it is limited to primarily small-diameter tree 

removal. This would make it more costly and take longer to conduct some prescribed burns where 

fuels are heavier and multiple prescribed burns may be needed to achieve effective fuel reduction. 

Prescribed burning is encouraged in lieu of mechanically removing medium and larger trees but 

where the costs of prescribed burning is higher due to heavier fuels and where it takes multiple 

prescribed burns to reduce fuels, there would be fewer acres with effective fuel reduction
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

135

compared to the other alternatives. There is more uncertainty in completing prescribed burning as 

the primary method to reduce fuels because of the increased complexity to plan and implement 

prescribed burns in areas with high fuels. The management opportunity to manage wildfires to 

meet resource objectives exists under this alternative in all zones but is not likely to be used in the 

wildland-urban intermix defense zone or general wildfire zone.

Improve Safe and Effective Fire Response

Managing Uncertainty: Under alternative C, risks have been identified outside of the wildlandurban intermix defense zone. Similar to alternatives B, B-modified, and D, the wildfire 

maintenance zone reduces the uncertainties of where potential resource benefits can be obtained 

by managing wildfire to meet resource objectives in the higher elevation areas. However, similar 

to alternative A, there is a large portion of the national forest with little improvement in reducing 

the uncertainty for potential risks and benefits to highly valued resources and assets as shown by 

the large area with red and orange in the general wildfire zone shown in figure 20. This large 

uncertainty in the general wildfire zone makes it difficult to make fire management decisions that 

consider safety to firefighters and the public in relation to risks to highly valued resources and 

assets.

Facilitating Wildland Fire Management: In this alternative, there would be the fewest areas 

where fuels are reduced mechanically prior to prescribed burning of all alternatives. Fuel 

reduction treatments would primarily be with mechanical removal of small-diameter trees, mostly 

in the wildland-urban intermix defense zone. Some strategic treatments along key roads and 

ridges may occur, which may facilitate some large prescribed burning but with heavier initial 

fuels. However, it may make it more difficult to conduct prescribed burns due to an increased 

complexity of the burns and more limited timing when weather and fuels conditions would allow 

prescribed burns to be safely conducted and meet burn objectives. In areas where prescribed 

burning has occurred, there would be greater opportunities to manage future wildfires. Where 

fuels are heavier (higher densities of trees, large snags, and high surface fuel loading) or fuel 

reduction treatments are less effective, the primary response to wildfire ignitions would likely 

continue to favor suppression. The opportunity to manage wildfires to meet resource objectives 

exists under this alternative in all strategic fire management zones; however, with the uncertainty 

of risks to structures and assets, the possibility of this management response may be limited 

except in the wildfire maintenance zone.

Consequences Specific to Alternative D

Alternative D uses the same strategic fire management zones as described for alternatives B and

B-modified above. Fuel reduction treatments would be applied in all strategic fire management 

zones dependent on vegetation conditions, with fewer funding and resource limitations than any 

other alternative. Mechanical treatments are slightly higher than all other alternatives. Like 

alternatives B and B-modified, managing wildfire to meet resource objectives is highly 

encouraged in the wildfire maintenance and restoration zones and somewhat limited in the 

community wildfire protection and general wildfire protection zones.

Restore and Maintain Landscapes Through the Use of Wildfire

Managing Uncertainty: In alternative D, managing uncertainty would be the same as described 

previously for alternatives B and B-modified.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

136

Facilitating Wildland Fire Management: The same amount of strategic treatments along 

ridgetops, roads, and other natural and manmade features to support large landscape prescribed 

burns or as an opportunity to manage wildfires to meet resource objectives are allowed in 

alternative D as in alternatives B and B-modified. As with alternatives B and B-modified,

important strategic locations are identified in relation to potential damages or benefits, most of 

which are along the boundaries between zones. These fuel reduction treatments would result in 

areas of reduced fuels and restoring vegetation toward its natural fire regime, which has the 

greatest benefit for restoring fire in the wildfire restoration and maintenance zones. Under 

alternative D, there would be more opportunity than alternative C for fuel reduction projects,

which increases the potential for wildfires managed to meet resource objectives in all zones. 

There would be more potential to manage wildfires to meet resource objectives if there are more 

areas with fuel reduction and more strategic areas that can be used to control or contain fires. All 

of these restoration activities would reduce fuels and potential smoke emissions compared to 

large, undesirable wildfires.

Support Fire-adapted Communities

Managing Uncertainty: In alternative D, there would be more opportunity for coordination with 

local partners and communities for fire protection and prevention in high wildfire risk areas,

which would enhance the effectiveness of initial fire response to the extent there is more 

collaborative fuel reduction projects in the community and general protection zones.

Facilitating Wildland Fire Management: There would be more fuel reduction treatment 

opportunities in alternative D than in all alternatives. Fire managers would continue to assist 

communities to become more fire adapted through continued collaborative efforts such as 

community wildfire protection plans and fuel reduction treatments. An increase in the amount of 

fuel reduction under this alternative includes more mechanical treatment and the same amount of 

prescribed burning as in alternatives B and B-modified. Fuel reduction in the wildfire restoration 

zone would further reduce the risk of large high-intensity wildfires starting further away on the 

national forest that may threaten communities.

Improve Safe and Effective Fire Response

Managing Uncertainty: In alternative D, risks are better identified than in alternatives A and C 

by the creation of the four strategic fire management zones. Fires are managed on a continuum 

between meeting protection objectives and resource objectives within these zones, while using 

risk-based responses. This alternative would reduce fuels on more of the landscape, which would

reduce risks over time and should tend to shift areas toward less risk in future risk assessments.

Facilitating Wildland Fire Management: Alternative D has the highest possibility of generating 

revenue from treatments with timber harvest that can be invested in reducing fuels on more areas. 

This would allow for strategic treatments, mostly along roads, ridgetops, and other natural and 

manmade features to support large landscape prescribed burns or as an opportunity to manage 

wildfires to meet resource objectives. These applications would allow areas on the landscape to 

shift toward the wildfire restoration and wildfire maintenance zones as more areas with 

vegetation density move toward the natural range of variation, allowing fire to burn at lower 

intensity overall and with more variable patches of low, moderate, and high severity. This would

give fire managers more options to provide for the safety of firefighters and the public while 

managing costs of fire suppression and risks and benefits to highly valued resources and assets.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

137

Cumulative Effects

There are cumulative effects from the management of wildland fire by adjacent landowners. 

These include the National Park Service, managing Sequoia, Kings Canyon and Yosemite 

National Parks, the Bureau of Land Management, and State fire agencies. There are also large 

areas of private land adjacent to and within the plan area. The Park Service emphasizes fire 

restoration and has cooperated with the Forest Service numerous times on management of 

wildfires to meet resource objectives in the southern Sierra Nevada (Meyer 2015a). Under all 

alternatives, fire management is coordinated with neighboring units as agencies work together 

across jurisdictions and boundaries to manage fires. 

The cumulative effect has been that on adjacent National Park Service and Sequoia National 

Forest lands there is a high level of restoration that has been accomplished in the last 15 years, 

greatly reducing the probability of large, high-intensity fires in this area. The Bureau of Land 

Management manages fires similarly to the Forest Service although with more of an emphasis on 

fire suppression. Consequently, there has been little wildfire managed to meet resource objectives 

on National Forest System lands near Bureau of Land Management lands.

Wildfire ignitions may increase in the Sierra Nevada with increased population growth (including 

increased human development in the wildland-urban intermix) and climate change. However, 

future projections in human-caused ignitions and lightning strike density are highly uncertain 

(especially the latter). This would have a cumulative effect of increasing the likelihood of large, 

high-intensity fires but to an unknown degree. Although some regions of the western United 

States may experience projected declines in wildfire extent and severity with climate change (due 

to reduced plant productivity in the later 21st century), total burned area and fire severity in the 

Sierra Nevada are likely to increase or remain moderately high through the coming decades 

(Lenihan et al. 2008, Westerling et al. 2011, Parks et al. 2016).

Analytical Conclusions

Alternative A does not proactively analyze risk with a spatial risk assessment, which highly limits 

the restoration and maintenance of landscapes through managing wildfire to meet resource 

objectives, and the safe and effective fire responses due to the uncertainty of the location of assets 

and resource at risk. The lack of risk-informed fuel reduction treatments also limits the restoration 

and maintenance of landscapes through the use of wildfire, both with strategically located 

prescribed burning and wildfires managed to meet resource objectives. Alternative A relies 

heavily on a risk assessment after the fire has started and local fire manager knowledge to manage 

wildfire to meet resource objectives, but is not as reliable since it is more reactionary and depends 

primarily on experienced fire managers knowledgeable of the local conditions.

The strategic management zones created by the wildfire risk analysis for alternatives B, Bmodified, and D identify areas of risk more accurately than the wildland-urban intermix defense 

and threat zones in alternative A and the wildland-urban intermix defense and general wildfire 

zones in alternative C. By using the spatial wildfire risk assessment, alternatives B, B-modified,

and D allow identifiable areas on the landscape where strategic fuels and vegetation treatment 

might be cost-effective in managing wildfire. These alternatives also identify where fire may play 

a beneficial role and can be managed to meet resource objectives rather than taking suppression 

actions.

Alternatives A and C do not account for the likelihood of fires to spread from adjacent areas,

which could potentially contribute to the risk to communities or infrastructure. Outside of the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

138

wildland-urban intermix defense and threat zones in alternative A, there is little specific direction 

that encompasses a risk management-based approach to wildfires. In alternative C, a risk 

management-based approach is applied in the wildfire maintenance zone and partially to create 

the general wildfire zone, but there are fewer fuel reduction treatments planned along strategic 

fire management features (such as along ridgetops, roads, or other natural or man-made features) 

that facilitate safely conducting more cost-effective, larger prescribed fires or that provide more 

opportunities to manage wildfires to meet resource objectives. Forest and fire managers would

continue to work with communities and stakeholders to support fire-adapted communities under 

all alternatives, having the most restrictions under alternatives A and C.

In alternatives B, B-modified, C (partially), and D, the risk assessment provides information that 

reduces uncertainties and allows forest and fire managers to have more latitude to proactively 

plan and restore the landscape by managing wildfire to meet resource objectives and using 

prescribed fire, partially due to the awareness of where the assets are located, thereby reducing 

risk. Alternative C emphasizes the use of prescribed fire and limits mechanical treatment to smalldiameter trees. Alternatives B, B-modified, and D apply risk management the most explicitly and 

have the most amount of restoration that reduces risk and provides resource benefits. The zones in 

alternatives B, B-modified, and D provide the most efficient and effective way to prioritize fuel 

reduction treatments around communities and other values at risk and prioritize ecological 

restoration to increase the potential to safely manage wildfires to reduce landscape fuels and 

benefit resources. The increase in ecological restoration projects and the enhancement of strategic 

fire management features would provide the greatest likelihood of implementing large prescribed 

fires or managing wildfires to meet resource objectives. This provides a safer work environment 

for firefighters, lowers the likelihood for fire that escapes control, and allows a larger window of 

opportunity to manage wildfire.

The following graphs compare the results for location and source from the risk assessment for all 

the alternatives (figure 21 and figure 22). The location identifies where on the landscape fire 

ignitions result in negative versus positive outcomes. The source identifies where the fire was 

ignited to identify spatial patterns on the landscape.

Figure 21 shows the amount of potential damage and benefits to assets and resources at the 

location of where these potential changes occur, based on modeled outputs. The pie charts on the 

left represent the percentage of the forest that resides in the different strategic fire management 

zones. The bar charts on the right show the percentage of benefit or damage to highly valued 

resources and assets.

A graph with higher values on the damage side leads to managing for protection objectives while 

those with higher values on the benefit side would result in managing primarily for resource value 

objectives. It is also important to know what is possibly going to be affected; zones that have a 

large proportion of either resource or assets helps in the wildfire management decisions. 

Alternatives B, B-modified, and D categorize risk location and can aid in managing uncertainty. 

For these reasons, alternatives B, B-modified, and D are more effective, because the protection 

zones have a higher damage-to-benefit ratio while the maintenance zones have a higher benefitto-damage ratio, leading to less uncertainty in management decisions.

The amount of potential damage and benefits to assets and resources at the source (where 

wildfires start) that cause these changes based on modeled outputs are shown in figure 22. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

139

Figure 21. Risk location by alternative or comparison of the magnitude of net value 

change by strategic fire management zone
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

140

Figure 22. Risk source by alternative or comparison of the magnitude of net value change

by strategic fire management zone
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

141

As before, the risk location of any strategic fire management zone with nearly equal potential for 

damage and benefits has a high level of uncertainty and adds little information for forest and fire 

managers in their wildfire management decisions. Also graphs that have a large proportion on one 

side or the other help manage uncertainty and aid in management decisions. A graph that has a 

larger proportion on the damage side leads to managing for protection objectives while those that 

have a larger proportion on the benefit side leads to primarily managing wildfire for resource 

value objectives. It is important to know what value is possibly going to be affected. Since these 

graphs capture changes from the source, most zones show both resource and assets affected 

because wildfires start in those zones and move into adjacent zones where resource and assets 

exist. However, alternatives B, B-modified, and D are more effective in categorizing risk and can 

aid in managing uncertainty because the majority of the asset damage is in the protection zones.

The five alternatives are ranked by the measures (managing uncertainty and facilitating fire 

management) for each indicator (table 11). All indicators were measured to rate how well each 

alternative addresses them. These measures were given a numerical rating based on how well 

they managed uncertainty and how well they addressed facilitating wildfire management. Note 

that the lower the number, the better the alternative in regard to meeting the fire management 

indicator. In this ranking indicators were equally weighted. Low: poorly represents actions that 

support the measures. Medium: may have some positive/negative with overall neutral outcome, 

High: greatly increases the ability to support the measures.

Table 11. Comparative ranking of alternatives by fire management indicators and measures

Alternative Indicator

Managing 

Uncertainty

Facilitating Fire 

Management Total

A Restore and maintain landscapes 4 3 7

A Fire-adapted communities 3 3 6

A Wildfire response 3 3 6

B Restore and maintain landscapes 2 2 4

B Fire-adapted communities 2 2 4

B Wildfire response 1 2 3

B-modified Restore and maintain landscapes 2 2 4

B-modified Fire-adapted communities 2 2 4

B-modified Wildfire response 1 2 3

C Restore and maintain landscapes 3 4 7

C Fire-adapted communities 4 4 8

C Wildfire response 4 4 8

D Restore and maintain landscapes 2 1 3

D Fire-adapted communities 2 1 3

D Wildfire response 1 1 2

Wildfire Risk Management

The individual indicators shown in table 12 on page 144 can be summarized as an overall 

assessment of risk management for each alternative.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

142

Consequences Specific to Alternative A

Managing Uncertainty: Fire management decisions in alternative A are not guided by risk-based 

strategic fire management zones. The two zones: wildland-urban intermix defense and wildlandurban intermix threat zones, and the general forest (which contains the areas outside of the other 

land allocations on the national forest) were generated for the forest plan (figure 13). Although 

these areas were not created using a wildfire risk assessment, due to the proximity to assets, 

potential damages to highly valued resources and assets in the wildland-urban intermix defense 

and threat zones are moderately captured. However, these two zones do not account for potential 

damages to infrastructure such as powerlines outside communities or the negative wildfire 

impacts to community ecosystem services such as water supplies and wildlife habitat. In regard to 

categorizing risk to aid management decisions, these two zones are not adequate, leaving the 

general forest with a wide range of risk ranging from a high potential for damage to a moderate 

potential for benefits. There are many uncertainties for location and source of risk under this 

alternative. Risk management is difficult when values at risk are not pre-identified.

Facilitating Wildland Fire Management: Fire management practices in alternative A would 

provide firefighter safety in all zones while providing asset protection (structures, powerlines, 

etc.). Implementing effective strategic fire management by managing wildfires to meet resource 

objectives and accomplishing fuel reduction treatments that improve safety during fire 

management practices would be limited to the current plan constraints. The level of safe and 

effective fire management to facilitate the appropriate management response to wildfire would

remain the same. This would continue to allow the accumulation of fuels that contribute to large, 

unwanted wildfires that damage forests and wildlife habitat, negatively affect stream and 

watershed quality, reduce air quality with increased smoke, and threaten homes and communities 

in the wildland-urban intermix.

Consequences Specific to Alternative B

Managing Uncertainty: Alternative B is composed of four zones: community wildfire 

protection, general wildfire protection, wildfire restoration and wildfire maintenance (figure 14).

These four zones were designed to categorize risk and reduce many of the uncertainties on the 

location and source of potential damages and benefit to highly valued resources and assets. They 

facilitate fire management decisions by reducing the uncertainty of where and under what 

conditions wildfires are more likely to have positive outcomes and be suitable to consider for 

managing to meet resource objectives.

Facilitating Wildland Fire Management: Fire management practices in alternative B would 

provide firefighter safety in all zones while providing asset protection (such as structures and

powerlines). An increase in implementing effective strategic fire management through fuel 

reduction treatments and managing wildfire to meet resource objectives would be more 

attainable. The risk-based strategic fire management zones would help prioritize fuel reduction in 

areas based upon the location and source of potential damages and benefits to highly valued 

resources and assets.

Consequences Specific to Alternative B-modified

Managing Uncertainty: Alternative B-modified is composed of the same four zones as 

alternatives B and D: community wildfire protection, general wildfire protection, wildfire 

restoration and wildfire maintenance (figure 15). Modifications were made to correct highly 

valued resources and asset errors and adjustments to potential wildland fire operational 

delineation units (PODs, chapter 2). These four zones were designed to categorize risk and reduce 

many of the uncertainties on the location and source of potential damages and benefit to highly 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

143

valued resources and assets. They facilitate fire management decisions by reducing the 

uncertainty of where and under what conditions wildfires are more likely to have positive 

outcomes and be suitable to consider for managing to meet resource objectives.

Facilitating Wildland Fire Management: Fire management practices in alternative B-modified

would provide firefighter safety in all zones while providing asset protection (structures, 

powerlines, etc.) in the community wildfire protection and general wildfire protection zones. An 

increase in implementing effective strategic fire management through fuel reduction treatments 

and managing wildfire to meet resource objectives would be more attainable. The risk-based 

strategic fire management zones would help prioritize fuel reduction in areas based upon the 

location and source of potential damages and benefits to highly valued resources and assets.

Consequences Specific to Alternative C

Managing Uncertainty: Alternative C has three zones: the wildland-urban intermix defense 

zone, general wildfire zone, and wildfire maintenance zone (figure 16). The zones consist of a 

combination of existing plan direction and new zones created from the results of the wildland fire 

risk assessment. The distance-based wildland-urban intermix defense zone around communities 

would remain the same as in alternative A and does not account for potential damages to 

infrastructure and assets. The general wildfire zone consists of the restoration zone, general 

wildfire protection zones, and portions of the community wildfire protection zone. The general 

wildfire zone does not categorize risk well because it consists of a combination of risk-based 

zones where the risk ranges from a high potential of damages and moderate potential for benefits, 

thus resource objectives assigned to this zone cannot be safely used to make fire management 

decisions due to the wide range of uncertainty of risk. The maintenance zone was created using 

the same risk-based methodology used to create the wildfire maintenance zones as alternative B, 

B-modified and D, where there are lower risks. The zones in alternative C make it more difficult 

to manage fire compared to the other alternatives, due to the higher uncertainty of where risk 

resides combined with less fuel reduction treatments that primarily rely on prescribed fire and 

much less mechanical thinning of fuels.

Facilitating Wildland Fire Management: Fire management practices in alternative C would 

provide firefighter safety in all zones while providing asset protection (structures, powerlines, 

etc.) in the community wildfire protection and general wildfire protection zones. Managing 

wildfire to meet resource objectives in alternative C would be similar to the decision to manage 

wildfire for resource benefit in the wildland-urban intermix defense zone in alternative A; 

somewhat limited in the general wildfire zone; and highly encouraged in the wildfire maintenance 

zone. Prioritizing fuel reduction treatments would be similar to alternative A, based upon project 

planning due to the uncertainty of the risk to values and resources conveyed by the general 

wildfire zone. This will continue to allow the accumulation of fuels that contribute to large, 

unwanted wildfires that damage forests and wildlife habitat, negatively affect stream and 

watershed quality, reduce air quality with increased smoke, and threaten homes and communities 

in the wildland-urban intermix.

Consequences Specific to Alternative D

Managing Uncertainty: Alternative D is composed of the same four zones as alternatives B and

B-modified: community wildfire protection, general wildfire protection, wildfire restoration and 

wildfire maintenance (figure 15). These four zones were designed to categorize risk and remove 

many of the uncertainties on the location and source of potential damages and benefit to highly 

valued resources and assets.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

144

Facilitating Wildland Fire Management: Fire management practices in alternative D would 

provide firefighter safety in all zones while providing asset protection (structures, powerlines, 

etc.) in the community wildfire protection and general wildfire protection zones.

Summary

The five alternatives are ranked by the measures (managing uncertainty and facilitating fire 

management) for how they overall address risk management (table 12). As with table 11, these 

measures were given a numerical rating based on how well they managed uncertainty and how 

well they addressed facilitating wildfire management. Note that the lower the number, the better 

the alternative in regard to addressing risk management.

Alternative D has the highest rank (lowest total) because it uses a set of strategic fire management 

zones that help inform fire management decisions across the fire continuum, while treating more 

acres (prescribed and mechanical) and managing more wildfires to meet resource objectives. 

There is more certainty about managing fire for protection objectives in the community and 

general wildfire protection zones and more certainty about managing fires to meet resource 

objectives in the wildfire maintenance zone. Alternative D includes direction to strategically treat 

areas in the wildfire restoration zone to encourage restoring fire as an ecosystem process and 

lower fire risk over time. Alternatives B and B-modified have the same fire management zones

and the same classifications of fire risk as alternative D, but it reduces fuels and restores fire on 

fewer acres so fire risk remains higher in more areas. Alternative A classifies fire risk in the 

wildland-urban intermix defense zone and threat zone but doesn’t encourage or prepare the 

landscape for greater management of wildfires to meet resource objectives so the fire risk would

remain high in many areas. Alternative C has the lowest rank (highest total) because it classifies 

fire risk in only the smaller wildland-urban intermix defense zone and in the wildfire maintenance 

zone but poorly classifies risk in the larger general wildfire zone. Combined with fewer strategic 

fuel reduction treatments due to plan components for other resource, the fire risk would remain 

high across most of the national forest in the general wildfire zone but might be reduced similar 

to alternatives B, B-modified, and D in the wildfire maintenance zone.

Table 12. Summary of approach to wildfire risk management by alternative

Alternative Indicator

Managing 

Uncertainty

Facilitating Fire 

Management Total

A Risk Management 3 3 6

B Risk Management 2 2 4

B-modified Risk Management 2 2 4

C Risk Management 4 4 8

D Risk Management 2 1 3

Air Quality

Background

Air quality is important to human health, visitor experience, vegetation health, soil quality, water 

quality, and visibility. Both external and internal sources of air pollution that can affect Inyo 

National Forest lands. Although most of these air pollutants originate outside of the national 

forest, some of them can have a negative impact on forest health. Management on national forests 

can make forests more resilient to certain pollutants (Bytnerowicz, Fenn, and Long 2014). 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

145

Management actions effect air quality within the plan area, especially through fire emissions such 

as prescribed burning or managing wildfires to meet resource objectives. 

The emphasis in this section is on smoke from prescribed burning and wildfire managed to meet 

resource objectives since these management actions contribute to air pollution on National Forest 

System lands but can also influence short- and long-term smoke emissions from unplanned 

wildfires. The source of other air pollutants is from lands adjacent to the national forest, 

especially in the San Joaquin Valley and wind-blown dust from Mono Lake and the Owens 

Valley. For more details on other air pollutants see the Science Synthesis (Bytnerowicz, Fenn, and 

Long 2014) and the assessments (USDA Forest Service 2013a, 2013b, 2013c, and 2013d).

Federal, State, and local air districts each have rules and regulations that the Forest Service must 

meet in regards to air quality. The federal Clean Air Act sets forth air quality standards. The 

standards include regulating concentrations of pollutants such as ozone, particulate matter, carbon 

monoxide, nitrogen oxides, sulfur dioxide, and lead. In addition, visibility goals set forth by the 

Regional Haze Rule for class I airsheds (wilderness areas) are applicable. Local air district rules 

and State coordination will be applicable to smoke-producing actions. The Inyo National Forest 

falls within two different air districts; for additional background information on various air 

quality designations within the plan area see the Inyo National Forest assessment (USDA Forest 

Service 2013a). The majority of the national forest is within the Great Basin Unified Air Pollution 

Control District (figure 23). 

Analysis and Methods

This analysis examines the potential air quality impacts from implementation of the proposed 

forest plan and alternatives. The proposed action is programmatic covering the broad pattern of 

potential projects and wildfires that can influence air quality. Project-level emissions analysis will 

take place prior to conducting any smoke-producing management activities. 

The assessment of air quality impacts is both quantitative and qualitative. The primary approach 

compares the tradeoffs between potential smoke emissions from the restoration treatments that 

reduce the potential wildfire emissions and the wildfire emissions that would occur without the 

restoration. For more detail on the emissions analysis, see the Fire-climate supplemental report 

and the Smoke and Air Quality supplemental report. The Carbon Stability supplemental report 

discusses forest carbon storage and effects of each alternative. This section focuses on regulated 

air pollutants.

Assumptions

There are many uncertainties about when or where wildfires occur and what potential other 

sources of smoke may be and how great the emissions. We made several assumptions for this 

analysis, mostly to address these uncertainties.

• It is unknown exactly, when, where or how much wildfire will occur but the trend of 

increasing large wildfires and associated high smoke emissions is expected to continue 

(Hurteau et al. 2014). In addition, research indicates that wildfire emissions are widely 

underestimated (Liu et al. 2017).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

146

Figure 23. Map of air pollution control districts (APCDs) and Air Quality Management District (AQMD)

in and around the Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

147

• The amount of emissions released by combustion of vegetation will vary depending on the 

amount of vegetation present and the completeness of combustion. For example, 

combustion of a stand of Douglas-fir produces more emissions than a sparsely vegetated 

acre of pinyon-juniper with identical combustion efficiency. Thus, vegetation type is an 

important factor in quantifying emissions. See the Smoke and Air Quality supplemental 

report for assumptions of vegetation types under each alternative and corresponding 

emissions factors.

• Restoration actions that follow the proposed plan and alternatives would result in reduced 

emissions from wildfires that burn across those areas (Hurteau and North 2009, Hurteau 

and North 2010, Tarnay and Lutz 2011, Vaillant, Reiner, and Noonan-Wright 2013). 

Restoration treatments would “offset” future large wildfire emissions. The amount of the 

reduction depends upon the type and intensity of treatments. See below for a summary of 

the research on the amount of emissions reductions with forest thinning, biomass removal, 

mastication, and prescribed fire.

• Smoke management would be practiced actively with all prescribed fire and wildfires 

managed to meet resource objectives. This would include smoke prediction modeling, 

smoke monitoring, and close coordination with the local air districts.

Mechanical Thinning, Biomass Removal, and Mastication

Mechanical treatments include thinning trees, removing biomass (smaller trees, shrubs, or larger 

tree branches), and mastication (where small trees and shrubs are shredded or crushed). Thinning 

can result in substantially lower emissions during large wildfires (Hurteau and North 2009) and 

local examples indicate by as much as 90 percent or more (Hurteau, Koch, and Hungate 2008). 

During large wildfires, woody biomass burns resulting in a release of carbon and smoke. 

Thinning will occur in each alternative where practical. Machinery use would generate emissions; 

however, these would be minimal at the plan area level. Project-level analysis will address 

emissions from machinery.

Smoke from Prescribed Fires and Wildfires Managed to Meet Resource Objectives

All fires produce smoke emissions. The amount of smoke emitted and the area impacted varies 

with the size of the fire, type of fire, vegetation density, and location. Smoke management is a 

key aspect of prescribed fires and wildfires managed to meet resource objectives. Prescribed fire 

activities generally occur under favorable atmospheric conditions for smoke dispersion to limit 

human health impacts. Wildfires managed to meet resource objectives offer long-term benefits by 

reducing future wildfire emissions. Research indicates that prescribed burning results in an 18 to 

25 percent reduction in smoke emissions, with examples as high as 60 percent (Wiedinmyer and 

Hurteau 2010). Long-term reductions in emissions from implementation of these activities were 

modeled (Hurteau et al. 2014). In addition, smoke emissions from wildfires managed to meet 

resource objectives can be more than five times lower per burned unit area than emissions 

resulting from large and catastrophic wildfire events, such as the 2013 Rim Fire (Long, Tarnay, 

and North 2017). The amount of restoration that occurs will affect the amount of emissions 

reduction from catastrophic wildfires in the long term.

Smoke from Wildfires

In general, large wildfires produce 100 to 1,000 tons of fine particles in smoke per day, 

moderately sized fires 10 to 100 tons, and small fires less than 10 tons (Tarnay and Lutz 2011). 

Emissions from wildfires are generally much larger than prescribed fire (Vaillant, Reiner, and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

148

Noonan-Wright 2013). Larger fires have regional impacts, whereas smaller fires have local 

impacts. Restoration treatments such as mechanical thinning, prescribed fire, and wildfires

managed to meet resource objectives can reduce long-term wildfire emissions. Research indicates 

that smoke emissions from large fires will double during the next half century due to trends in 

vegetation conditions, climate, and fire ignitions (Hurteau et al. 2014). Increasing smoke 

emissions identified by Hurteau et al. is a baseline in this analysis.

Indicators and Measures

Three indicators describe the indirect and cumulative effects of each alternative to air quality. A 

short-term (present to 10 years) or long-term (10 years to mid-century) category describes the 

timeline of effects to each indicator. The selected indicators consist of smoke effects from 

alternative implementation on air quality, recreation, and visibility.

Smoke Effects on Air Quality

The smoke effects on air quality indicator is quantitatively measured. Emissions produced by 

alternative A serve as a baseline to compare emissions produced by actions under alternatives B, 

B-modified, C, and D. The pollutants analyzed are the criteria pollutants of total organic gases 

(TOG), reactive organic gases (ROG), carbon monoxide (CO), nitrogen oxides (NOx), sulfur 

oxides (SOx), particulate matter (PM), particulate matter less than 10 micrometers (PM10), and 

particulate matter less than 2.5 micrometers (PM2.5). Long-term, indirect, and cumulative effects 

from implementation is analyzed using modeled future emissions (Hurteau et al. 2014). This 

indicator is comprised of two categories of emissions: wildfires and restoration treatments. 

Restoration treatments include mechanical treatments, prescribed fire, and managing wildfire to 

meet resource objectives.

Smoke Effects to Recreation

The smoke effects to recreation indicator is qualitatively measured. Smoke obscures visibility and 

impacts recreation through visitor avoidance of smoke impacted areas. Long-term, indirect, and 

cumulative effects from implementation are analyzed using modeling information (Hurteau et al. 

2014).

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

The Forest Service, along with other agencies, monitors class I wilderness areas through the 

Interagency Monitoring of Protected Visual Environments (IMPROVE) network. There are two

sites within the Inyo National Forest, the Kaiser Wilderness and Hoover Wilderness. This 

monitoring network measures pollutant concentration and visibility. The presence of air pollution 

can affect how clearly the human eye perceives distant objects or scenery. The smoke effects to 

visibility in class I airsheds indicator will be quantitatively assessed. Current trends are compared 

to long-term modeled impacts (Hurteau et al. 2014).

Affected Environment

The air quality on the eastern side of the Sierra Nevada, including the Inyo National Forest,

mostly meets air quality standards except when wildfire smoke is present. At this time, the 

eastern side of the Sierra is in attainment of State and Federal standards. Overall air quality within 

the region is largely outside of the control of the Forest Service except for smoke management on 

National Forest System lands of some fires. Smoke management opportunities are limited during 

large wildfires. There has been a trend in increased large wildfires and associated heavy smoke 

emissions. The level of smoke emissions from large wildfires is expected to double over the next 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

149

50 years, given current vegetation conditions and trends in climate and fire ignitions (Hurteau et 

al. 2014). There have been a limited number of prescribed fires in the last decade (see “Fire 

Management” section). Some wildfires managed to meet resource objectives have occurred in the 

southeastern portion of the Inyo National Forest in the Kern River drainage.

Environmental Consequences to Air Quality

Consequences Common to all Alternatives

Each alternative proposes differing amounts of treatments resulting in differing impacts to air 

quality. Current air district emissions server as a baseline to analyze impacts to the indicators and 

measures of air quality, recreation, and visibility. Background information collected during the 

assessment phase on air quality within the plan area was included in this analysis.

The southern Sierra Nevada fire-climate study investigated reductions in projected wildfire 

emissions under differing levels of restoration (see the “Fire Trends” section). Figure 24 shows 

the reductions in projected wildfire smoke emissions with four different restoration scenarios. 

This graph was based upon a climate projection called the GFDL (Geophysical Fluid Dynamics 

Laboratory) A2 climate scenario and it assumed that the fires burn with high severity and high 

emissions. 

Figure 24. Graph displaying modeling results of particulate matter 

emissions from wildfires under differing treatment scenarios at midcentury (Hurteau et al. 2014). The baseline and mid-century simulations 

represent a 5-10 percent restoration scenario. See table 5 for a comparison 

of restoration levels by alternative.

Figure 24 shows that with climate projections, smoke emissions are predicted to double from the 

model’s point of reference level from 1961 to 1990 labeled as “baseline.” The second bar 

represents the current trend of wildfire emissions into the future labeled “Mid-Century 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

150

simulation.” The remaining bars indicate future wildfire emission reduction comparing total 

particulate emissions measured in kilograms per hectare (kg/ha) from different treatment levels. 

The same relationships were applied to the indirect and cumulative effects of each alternative.

Based on the fire-climate simulations, wildfire emissions would continue to increase and double 

from current conditions by mid-century with some limited exceptions (Hurteau et al. 2014). All 

alternatives would have beneficial reductions in potential wildfire smoke emissions where 

restoration treatments occur; however, the degree of long-term improvement depends on the level 

of restoration (figure 24). Uncertainty of analysis exists when considering when, where, and how 

much of a large wildfire will overlap with restoration treatments. 

The “Mid-Century simulation” represents alternative A emissions in the long-term. Under 

Alternative A with restoration occurring at the current pace of treating 5 to 10 percent of the 

landscape, long-term emissions will greatly increase. Restoration ranges between the 15 and 30 

percent represent alternatives B and B-modified. Under this scenario, some long-term reduction 

in emissions will occur. Restoration scenarios between the mid-century simulation and 15 percent 

treatment represent long-term emissions reduction under alternative C. Restoration scenarios 

between the 30 and 60 percent of treatment represent long-term results in emissions reduction 

under Alternative D. There are some levels of increasing emissions long-term even under full 

treatment compared to the baseline emissions of 1961-1990.

Consequences Specific to Alternative A

Under alternative A, there would continue to be limited restoration treatments (such as prescribed 

burning and mechanical treatments) that would reduce fuels and potentially reduce emissions 

during large wildfires. This alternative represents current management and resulting emissions. 

The primary impact from alternative A would be a continuation of current trends in large 

wildfires that produce large smoke emissions.

Smoke Effects on Air Quality

In alternative A, there would be a continuation of current trends in large uncharacteristic wildfires 

that contribute to reduced sustainability of air quality as modeled by Hurteau et al. (2014).

Because emissions from wildfires are largely uncontrollable and can be large in scale, they result

in large air quality impacts. In addition, wildfires may occur during times of unfavorable 

atmospheric conditions resulting in a compounded air quality effect. Smoke from wildfires tends 

to be of higher intensity than prescribed fires and managers have little control to limit emissions.

Consequences include adverse effects on human health, particularly for residents of communities 

in that path of smoke events.

Alternative A would not contribute to changing current trends or improve the sustainability of air 

quality benefits to people. See table 13 for an estimate of annual emissions from alternative A. 

The table shows emissions in tons per year and modeled mid-century emissions with no change in 

management from today. The annualized increase in emissions is primarily due to the trend of 

increasing wildfire in this alternative at mid-century. This alternative serves as a baseline for 

comparison of each alternative. Emissions figures represent the most recent reported annual 

emissions from the Great Basin Valleys Air Basin (California Air Resources Board 2013).

There would be a moderate to substantial intensity of the associated short- and long-term effects 

to air quality across a large geographic area from alternative A. Air quality would degrade due to 

increased wildfire emissions in the long term (mid-century). In the short term, treatments would
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

151

cause a sporadic reduction (as treatments occur) of impacts to air quality from wildfires and 

prescribed burning. Mechanical pre-treatment of vegetation can reduce smoke impacts from 

prescribed fire.

Table 13. Table displaying air basin baseline annual emissions in tons per year and emissions under 

alternative A

Reference

Carbon

Monoxide

Nitrogen

Oxides

Sulfur 

Oxides

Particulate 

Matter

PM10

Particulate 

Matter

PM2.5

Annualized baseline air district 

emissions 8,359 1,898 219 17,776 2,409

Annualized alternative A emissions 10,896 68 57 1,018 863

Annualized percent increase of 

emissions 57 3 21 5 26

PM10 and PM2.5 refer to particulates that are 10 or 2.5 micrometers in size. Those are sizes used in standard 

measurements of particulate matter for compliance with air quality regulations.

Smoke Effects to Recreation

There would be no change in the current trends of forest conditions that result in smoke due to 

wildfire in the short term. In the long term, smoke from wildfire will increase, leading to reduced

recreational visitation on the national forest. There is also loss of benefits to the recreational users 

who must find other settings for their recreational activities. Substitute recreation sites may offer 

less opportunities or lower quality of the experience. In addition, substitute sites may be located 

farther away than the preferred site, thus increasing costs of recreating. Some recreational users 

may also choose not to recreate at all due to air quality conditions.

There is an economic contribution provided by recreation to both local communities through 

visitation and to recreational users through the recreational experience that contributes to quality 

of life. Rural communities located along access routes to the national forest have a strong tie to 

the economic contributions that recreational visitors provide. This includes the spending that 

supports jobs and contributions to local tax revenues through the sales tax and lodging tax 

collected. These local tax revenues support important public services that improve the quality of 

life in these communities. The connection between recreation visitation and local economies is 

especially true for the Inyo National Forest and the context of recreational-based, service-oriented 

businesses within Inyo and Mono Counties. Alternative A does not contribute to altering current 

trends or improve the sustainability of these recreational benefits to people. Increasing wildfire

emissions have potential adverse long-term effects on local community economics.

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

In general, data from the three IMPROVE sites show that visibility is currently increasing within 

the plan area (USDA Forest Service 2013a). However, modeling indicates that wildfire emissions 

will significantly increase by mid-century (Hurteau et al. 2014). Long-term increasing emissions 

will contribute to reduced visibility throughout the plan area. Visibility in class I airsheds is 

regulated under the Regional Haze Rule and the Forest Service is responsible for meeting goals 

set forth by the Environmental Protection Agency. Implementation of alternative A would make 

attaining these goals unlikely as wildfire emissions increase. Under alternative A, smoke impacts 

to visibility will be low to moderate in the short term and increase to high in the long term.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

152

Consequences Specific to Alternative B

In alternative B, there would be more prescribed fire, mechanical thinning, and in some areas,

wildfires managed to meet resource objectives than in alternative A. All of these restoration 

activities would reduce potential emissions from large, undesirable wildfires. There would be 

increased smoke emissions from prescribed fires, but levels of smoke would be substantially 

lower (45 percent less) than during wildfires and result in immediate post-fire reductions in 

potential wildfire smoke emissions (Vaillant, Reiner, and Noonan-Wright 2013).

Smoke Effects on Air Quality

Alternative B would contribute to reducing current trends in large uncharacteristic wildfires that 

adversely affect the long-term sustainability of air quality. Prescribed burning in this alternative 

would have a potential short-term adverse effect on air quality, but conducting them under 

favorable atmospheric conditions can mitigate impacts. Wildfires managed to meet resource 

objectives similarly consider the impacts of smoke, although there is less control than for 

prescribed fires. The mechanical thinning proposed in the alternative would reduce the quantity of 

smoke that would occur during prescribed fire activities and for wildfires managed to meet 

resource objectives by reducing the amount of fuels available to burn.

The Forest Service does not have direct control over pollution outside of the Inyo National Forest

but can contribute to air quality enhancement by limiting the smoke from wildfires. In the long

term, implementation of alternative B would indirectly improve air quality compared to 

alternative A by reducing the potential for large wildfires, and therefore reducing emissions. 

Reductions in emissions from mechanical pre-thinning of vegetation was not included and actual 

emissions are likely to be lower (table 14). Actual emissions and smoke impacts depend on 

additional factors such as seasonality of implementation, meteorology, and combustion efficiency.

In the short term, alternative B would increase emissions during implementation. By mid-century, 

alternative B will decrease emissions from wildfires (Hurteau et al. 2014).

Table 14. Emissions from treatments under alternative B measured in tons per year and compared to 

the air basin baseline

Reference 

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Oxides

Particulate 

Matter 

PM10

Particulate 

Matter 

PM2.5

Annualized baseline air district 

emissions 8,359 1,898 219 17,776 2,409

Annualized alternative B emissions 26,739 183 146 2,510 2,129

Annualized percent increase of 

emissions 76 9 40 12 47

PM10 and PM2.5 refer to particulates that are 10 or 2.5 micrometers in size. Those are sizes used in standard 

measurements of particulate matter for compliance with air quality regulations.

There would be a moderate intensity of the associated short- and long-term effects to air quality 

across a large geographic area under alternative B. Air quality would improve through wildfire 

emissions reduction in the long term (mid-century). In the short term, treatments would cause a 

sporadic reduction (as treatments occur) of impacts to air quality from wildfires, but would have 

pulses of impact associated with prescribed burning and wildfires managed to meet resource 

objectives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

153

Smoke Effects to Recreation

Alternative B would contribute to reducing current trends in forest conditions that result in smoke 

due to wildfire. Reductions in smoke events have potential beneficial short- and long-term effects 

on local community economics due to reductions in interruptions to visitation. There is a 

corresponding potential for short-term reductions in air quality due to increases in prescribed 

burning. Mechanical pre-thinning of vegetation prior to treatment would reduce smoke impacts to 

recreational visitation during implementation. Most prescribed burning occurs in the late fall 

through spring, outside of the peak recreation season. Long-term impacts from wildfire smoke to 

recreation would be lower in this alternative than alternatives A and C, thereby improving the 

sustainability of recreational benefits to people.

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

Effects to the visibility in class I airsheds under alternative B represent a trade-off. In the short

term, increased emissions would reduce visibility in the class I airsheds within the analysis areas. 

In the long-term, treatments under alternative B would reduce wildfire emissions and thus 

improve visibility in class I airsheds by mid-century. In general, data from three IMPROVE sites 

show that visibility is currently increasing within the plan area (see Assessment). However, 

modeling indicates that wildfire emissions would significantly increase by mid-century (Hurteau 

et al. 2014). Increasing emissions will reduce visibility throughout the plan area when wildfires 

are present. Restoration treatments can improve visibility through the reduction of emissions in 

the long term. 

In the short term, moderate to substantial intensity impacts resulting in decreased visibility could 

occur in class I airsheds during implementation. More smoke would occur in the short term under 

this alternative compared to A and C. This effect would decrease after restoration treatments are

complete. In the long term, a more resilient landscape would increase the likelihood of meeting 

visibility goals by the mid-century.

Consequences Specific to Alternative B-modified

Air quality effects both beneficial and adverse under this alternative would be similar to 

alternative B.

Smoke Effects on Air Quality

Alternative B would contribute to reducing current trends in large uncharacteristic wildfires that 

adversely affect the long-term sustainability of air quality. The prescribed burning and wildfire 

use to meet resource objectives in this alternative would have a potential short-term adverse effect 

on air quality (table 15). Conducting treatments under favorable atmospheric conditions can 

mitigate impacts. Wildfires managed to meet resource objectives similarly consider the impacts of 

smoke, although there is less control than for prescribed fires. The mechanical thinning proposed 

in the alternative would reduce the quantity of smoke that would occur during prescribed fire 

activities and for wildfires managed to meet resource objectives by reducing the amount of fuels 

available to burn.

There would be a moderate intensity of the associated short- and long-term effects to air quality 

across a large geographic area under alternative B-modified. Air quality would improve through 

wildfire emissions reduction in the long-term (Hurteau et al. 2014). In the short term, treatments 

would cause a sporadic reduction in air quality as treatments occur.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

154

Table 15. Emissions under alternative B-modified in tons per year compared to the air basin baseline

Reference

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Oxides

Particulate 

Matter PM10

Particulate 

Matter 

PM2.5

Annualized air basin baseline

emissions 19,255 1,966 276 18,793 3272

Annualized alternative Bmodified emissions 29,274 199 159 2,747 2,329

Annualized percent increase of

emissions 60 9 37 13 42

PM10 and PM2.5 refer to particulates that are 10 microns or 2.5 microns in size. Those are sizes used in standard 

measurements of particulate matter for compliance with air quality regulations.

Smoke Effects to Recreation

Alternative B-modified would contribute to reducing current trends in forest conditions that result 

in smoke due to wildfire. Reductions in smoke events have potential beneficial short- and longterm effects on local community economics due to reductions in interruptions to visitation. 

However, there is a corresponding potential for short-term reductions in air quality due to 

increases in prescribed burning. Mechanical pre-thinning of vegetation prior to treatment would

reduce smoke impacts to recreational visitation during implementation. Most prescribed burning 

occurs in the late fall through spring, outside of the peak recreation season. Long-term impacts 

from wildfire smoke to recreation would be lower in this alternative than alternatives A and C. 

Long-term changes in wildfire emissions in this alternative is expected to be similar to B. Longterm reductions to wildfire emissions would improve the sustainability of recreational benefits to 

people.

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

In general, data from the three IMPROVE sites show that visibility is currently increasing within 

the plan area (see Assessment). Meeting the class I airsheds goals will be more likely under this 

alternative than A and C. Modeling results indicate that wildfire emissions will increase 

somewhat under this alternative by mid-century (Hurteau et al. 2014). Short-term impacts to 

visibility may sporadically occur during treatment implementation. 

Consequences Specific to Alternative C

Alternative C increases the amount of treatment compared to alternative A. This would result in 

short-term smoke emissions, but potential reductions in large wildfire smoke emissions in areas 

where large prescribed burns occur. Completing prescribed fire activities under favorable 

atmospheric conditions can mitigate smoke impacts as opposed to wildfire. However, there is 

uncertainty about feasibility of implementation of this alternative because of limitations on 

mechanical treatments. These limitations would result in less treatment of strategic areas along 

roads and ridgetops. This alternative is less likely to result in a decrease of particulate matter 

emissions by mid-century than all other alternatives except A (Hurteau et al. 2014).

Smoke Effects on Air Quality

Alternative C would contribute to reducing current trends in large uncharacteristic wildfires that 

adversely affect the long-term sustainability of air quality to the extent that large landscape 

prescribed burning occurs. The prescribed burning would have a potential short-term negative 

effect on air quality, but completing these activities under favorable atmospheric conditions can 

mitigate smoke impacts. There is less mechanical thinning proposed under this alternative than B 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

155

and D leaving more fuels to burn during implementation with greater quantities of smoke

produced.

Alternative C would contribute to altering current trends and improving the sustainability of air 

quality benefits to people. The emissions estimates were conservatively modeled and no 

reduction techniques, such as pre-treatment thinning of vegetation, were included (table 16). 

Actual emissions and smoke impacts depend on additional factors such as seasonality of 

implementation, meteorology, and combustion efficiency. In the short term, alternative C would

increase emissions due to treatment implementation. By mid-century, alternative C would reduce

some wildfire emissions but not as aggressively as alternatives D, B-modified, and B.

Table 16. Emissions from treatments under alternative C measured in tons per year and compared to 

the air basin baseline

Reference

Carbon 

Monoxide

Nitrogen 

Oxide

Sulfur 

Oxide

Particulate 

Matter 

PM10

Particulate

Matter

PM2.5

Annualized air district baseline

emissions 8359 1898 219 17776 2409

Annualized alternative C emissions 25730 162 136 2405 2039

Annualized percent increase of

emissions 75 8 38 12 46

PM10 and PM2.5 refer to particulates that are 10 microns or 2.5 microns in size. Those are sizes used in standard 

measurements of particulate matter for compliance with air quality regulations.

There would be a moderate intensity of the associated long-term effects to air quality across a 

large geographic area and a moderate to substantial intensity of associated short-term effects. Air 

quality would improve through reduced wildfire emissions in the long term (mid-century) where 

treatments occurred. In the short term, treatments would cause a sporadic reduction (as treatments 

occur) of air quality impacts from wildfires. There would be pulses of impact associated with 

prescribed burning and wildfires managed to meet resource objectives that would be larger than 

alternatives B and D due to less fuel reduction with mechanical methods resulting in more fuels to 

burn.

Smoke Effects to Recreation

Alternative C contributes to reversing current trends in forest conditions that result in smoke due 

to wildfire. Reductions in smoke events have potential beneficial short- and long-term effects on 

local community economics due to reductions in interruptions to visitation. There is a 

corresponding potential for short-term reductions in air quality due to increases in prescribed 

burning and wildfires managed to meet resource objectives. The net-effect on air quality is more 

uncertain under alterative C than alternatives B and D given there is less mechanical thinning 

occurring before any prescribed burning. There would be mitigation measures considered to 

control when and where prescribed burning and managing wildfires to meet resource objectives

can occur in order to reduce smoke exposure. There would also be additional benefit to the 

recreational users who are able to enjoy recreational activities in the national forest when 

wildfires would otherwise prevent visitor use.

Like alternatives A and B, there is an economic contribution provided by recreation to both local 

communities through visitation and to recreational users through the recreational experience that 

contributes to quality of life. Alternative C would also contribute to altering current trends to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

156

improve the sustainability of recreational benefits to people. A moderate to substantial intensity of

smoke that would affect recreation across a large geographic area from the associated short- and 

long-term effects of implementing alternative C.

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

Effects to the visibility in class I airsheds under alternative C represent a trade-off. In the shortterm, if fully implemented, increased emissions from prescribed fire and wildfires managed to 

meet resource objectives would reduce visibility in the class I airsheds within the analysis areas. 

In addition, limitations to mechanical pre-thinning of vegetation will result in less mitigation of 

smoke impacts during implementation. In the long-term, treatments under alternative C would

reduce emissions from wildfires and thus improve visibility in class I airsheds by mid-century.

However, not to the same degree as alternative D, B, and B-modified.

Consequences Specific to Alternative D

Alternative D would have the greatest amount of restoration activities, including prescribed fire, 

mechanical thinning, and wildfire managed to meet resource objectives. Based on the fire-climate 

scenarios (see “Fire Trends” section) this would result in a substantial reduction in potential 

wildfire emissions. At mid-century, there would still be an increase in emissions over current 

levels but far less than the projected doubling of smoke emissions under alternative A (Hurteau et 

al. 2014).

Smoke Effects on Air Quality

Alternative D contributes to reducing current trends in large uncharacteristic wildfires that 

adversely affect the long-term sustainability of air quality. Emissions from wildfires would still 

occur; however, the trend of increasing mega fires would slow by mid-century due to treatments 

(Hurteau et al. 2014). The amount of prescribed burning and wildfire managed to meet resource 

objectives in this alternative would have adverse short-term effects on air quality greater than all 

other alternatives (table 17). However, due to the level of treatments, long-term emissions from 

wildfires would be lowest under this alternative.

Implementing treatments under favorable atmospheric conditions can mitigate smoke impacts to 

some extent as well as pre-thinning of vegetation. Reductions in emissions from mechanical prethinning of vegetation was not included in the analysis and actual implementation emissions may 

lower. Smoke impacts depend on additional factors such as seasonality of implementation, 

meteorology, and combustion efficiency.

Table 17. Emissions under alternative D in tons per year compared to the air basin baseline

Reference

Carbon 

Monoxide

Nitrogen 

Oxides

Sulfur 

Oxides

Particulate 

Matter 

PM10

Particulate 

Matter 

PM2.5

Annualized air basin baseline

emissions 8,359 1,898 219 17,776 2,409

Annualized alternative D

emissions 46,146 318 252 4,334 3,675

Annualized percent increase of

emissions 85 14 54 20 60

PM10 and PM2.5 refer to particulates that are 10 microns or 2.5 microns in size. Those are sizes used in standard 

measurements of particulate matter for compliance with air quality regulations.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

157

Smoke Effects to Recreation

Alternative D would contribute the most to reducing current trends in those forest conditions that 

result in smoke due to wildfire effects. Reductions in smoke events have potential beneficial 

short- and long-term effects on local community economics due to reductions in interruptions to 

visitation. There is a corresponding potential for short-term reductions in air quality due to 

increases in prescribed burning and wildfires managed to meet resource objectives. Mechanical 

pre-thinning prior to treatment and coordination between agencies to mitigate the effect of smoke 

on recreational visitation.

As with the other alternatives, there is an economic contribution provided by recreation to both 

local communities through visitation and to recreational users through the recreational experience 

that contributes to quality of life. Alternative D would contribute to altering current trends in air 

quality to improve the sustainability of recreational benefits to people in the long term. However, 

there would be a moderate to substantial intensity of the associated short-term effects of 

alternative D to air quality across a large geographic area.

Smoke Effects to Visibility in Class I Airsheds (Wilderness)

Like the other alternatives, increased emissions from prescribed fire and mechanical treatments in 

alternative D would reduce visibility in the class I airsheds within the analysis areas in the short 

term. In the long term, treatments under alternative D would reduce wildfire emissions and thus

improve visibility in class I airsheds by mid-century. Restoration treatments can improve 

visibility through the reduction of emissions in the long term.

With the increased amounts of restoration and reduction in smoke from future wildfire, 

implementing alternative D increases the likelihood of attainment in class I airsheds by the midcentury. In the short term, moderate to substantial intensity impacts resulting in decreases in 

visibility to class I airsheds would occur during implementation of prescribed burning. In the long

term, moderate to substantial intensity impacts resulting in improved visibility in class I airsheds 

is expected.

Cumulative Effects

The Forest Service does not have direct control over pollution generated off national forest lands

but can contribute to air quality enhancement within the plan area by completing treatments that 

limit smoke emissions from wildfires. Increasing the use of fire as a treatment for wilderness and 

remote areas is consistent with approaches of the National Park Service and Bureau of Land 

Management. 

In the short term, close coordination exists between various agencies to manage cumulative 

effects of smoke on a daily interagency coordination call. Frequent attendees include 

representatives from the Sierra, Sequoia, and Inyo National Forests, Sequoia and Kings Canyon 

National Parks, San Joaquin Valley Unified Air Pollution Control Districts, Great Basin Valleys 

Air Pollution Control District, and others. This daily call limits the amount of smoke produced 

within the airsheds of the plan area to prevent cumulative impacts to day-to-day air quality. In the 

short term, implementation of all alternatives would add cumulatively to air quality issues;

however, intensity would vary by the amount of treatment implemented. In the short term, 

alternative A would result in fewer cumulative impacts followed by alternatives C, B, B-modified, 

and D. This trend would reverse in the long term with restoration of ecosystem resilience 

(Hurteau et al. 2014). Long-term air quality impacts from the Inyo National Forest management 

actions is modeled to be lowest under alternative D followed by B-modified, B, C, and A. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

158

Analytical Conclusions

Effects to air resource indicators from each alternative are categorized by timeframes of shortterm (present to 10 years) and long-term (10 years to mid-century). Effects to air resource 

indicators are categorized by emissions source-type of either wildfire or restoration treatments 

(prescribed fire, wildfire managed for resource benefit, and mechanical thinning) as shown in 

table 18. No alternative offers both short-term and long-term improvements to air resource 

indicators. Models indicate wildfire emissions will increase through time and are considerably 

greater than restoration emissions. Restoration treatments would slow the progress of increasing 

wildfire emissions. The degree of slowing wildfire emissions growth through time depends on the 

level of treatments.

Table 18. Summary of air quality indicators and effects by alternative

Smoke 

effects 

indicator Alternative A Alternative B Alternative C Alternative D

Alternative Bmodified

Air quality Short-term, 

emissions stay 

the same.

Long-term, 

emissions 

increase

Short-term, 

emissions 

increase.

Long-term, 

emissions 

reduced

Short-term, 

emissions 

increase.

Long-term, 

emissions 

reduced

Short-term, 

emissions 

increase the 

most.

Long-term, 

emissions 

reduced the most

Short-term, 

emissions 

increase.

Long-term, 

emissions 

reduced.

Recreation Short-term 

effects stay the 

same.

Long-term, 

more smoke 

effects

Short-term, 

more smoke 

effects.

Long-term, 

slightly less 

smoke effects

Short-term 

effects stay the 

same.

Long-term, 

more smoke 

effects

Short-term, more 

smoke effects.

Long-term, 

greatest reduced

smoke effects.

Short-term, 

more smoke 

effects.

Long-term, 

slightly less 

smoke effects.

Visibility in 

class I 

airsheds

Attainment 

unlikely

Attainment 

more likely

Attainment likely Attainment most 

likely

Attainment more 

likely

Restoration activities would increase emissions and affect air quality in the short term, but the 

degree of increase is dependent on the amount of treatment. Alternative D has the highest shortterm emissions from treatments followed by alternatives B-modified, B, C, and A In the long 

term, alternative D would result in the greatest reduction in emissions from wildfires followed by 

alternatives B-modified, B, C, and lastly, A. Smoke management best practices can moderate 

short-term effects to air resource indicators from restoration activities.

There would be potential adverse short- and long-term effects on recreational visitation. In the 

short term, current trends of increasing impacts to recreation would continue in alternative A due 

to smoke from wildfires that burn during the summer recreation season. In addition, treatment 

timing can avoid smoke impacts during peak visitation periods. There would be less smoke in the 

long term in alternatives B, B-modified and D, where wildfires burn into areas where treatments 

occurred. There would be less benefit in alternative C due to the low amounts of treatment. In the 

long term, impacts to recreation are expected to increase with increasing wildfire emissions in 

alternative A, but to a lesser degree in alternatives B-modified, B, and slightly lesser degree in 

alternative C. Only alternative D would decrease the long-term smoke from wildfires in the 

summer recreation season due to the greater amount of fuels reduced.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

159

Increases in emissions and other cumulative effects would make long-term attainment of visibility 

goals unlikely under alternative A. Restoration treatments under alternatives B, B-modified, and 

D would result in a reduction in smoke emissions by mid-century. Reduction in wildfire 

emissions would make long-term attainment of visibility goals more likely under alternatives B, 

B-modified, and D than under alternative A (figure 24). The prescribed burning restoration 

treatments under alternative C would result in reduced smoke emissions by mid-century and, to 

the extent that prescribed burning and wildfires managed to meet resource objectives occur. A

reduction in wildfire smoke would make long-term attainment of visibility goals more likely than 

under alternative A but less likely than under alternatives B, B-modified, and D. Short-term 

impacts would lessen throughout time as fuels are reduced and would increase visibility in the 

long term.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

160

Revision Topic 2:

Ecological Integrity

Background

The topic of ecological integrity is very broad and spans from terrestrial to aquatic ecosystems. It 

includes the organisms that live in these ecosystems as well as the functions of the ecosystems 

themselves. To address this revision topic, the analysis is divided into three sections: terrestrial 

ecosystems; aquatic and riparian ecosystems; and wildlife, fish and plants. This topic also relies 

heavily upon the information provided in the “Agents of Change” section. The major vegetation 

types are discussed in the “Terrestrial Ecosystems” section and that discussion is referred to by 

other sections in this document.

Terrestrial Ecosystems

The terrestrial ecosystems analysis is presented in three subsections: terrestrial vegetation 

ecology, terrestrial ecosystem process and function, and climate vulnerabilities and adaptations.

Terrestrial Vegetation Ecology

Background

This section summarizes current terrestrial ecosystem conditions of dominant vegetation types on 

the Inyo National Forest, and the consequences of implementing the final forest plan or the 

alternatives. It includes an analysis of the alternatives’ effects on vegetation ecology including 

composition, structure, and resilience to fire, climate, drought, insects, and pathogens by major 

ecological zone and vegetation type. Building upon the “Agents of Change, Climate, Fire, Insects 

and Pathogens” section, there are more specifics about fire regime integrity and effects by 

vegetation type.

Much of the analysis is based upon the premise that the natural range of variation provides 

important background for evaluating ecological integrity and sustainability (Wiens et al. 2012, 

Manley et al. 1995). It was used to develop plan direction and select indicators and measures for 

the analysis. Also important in the analysis of ecological integrity and sustainability of vegetation 

was consideration of climate and associated fire trends that may be creating a combination of 

conditions that are outside of what occurred in the natural range of variation (Safford, North, and 

Meyer. 2012, Millar and Stephenson 2015).

Natural range of variation is a concept that focuses on the dynamic nature of ecosystems, 

recognizing they are not static or narrowly bound in their representative attributes (Landres, 

Morgan, and Swanson 1999b). This concept is relevant to ecosystem attributes such as vegetation 

composition, structure, and function that influence ecosystem values and services such as wildlife 

habitat. Natural range of variation is typically characterized as the ecosystem conditions and 

processes that have occurred over long time periods that are appropriate for a given management 

application (Morgan et al. 1994, Wiens et al. 2012). While natural processes such as fire are part 

of the ecosystem that contributes to the natural range of variation, it is recognized that human 

actions following Euro-American settlement have dramatically changed vegetation and fire

regimes in the analysis area. Because of these changes, the natural range of variation is typically 

analyzed for the time period prior to European settlement; generally mid- to late-1800s, 

depending on vegetation type. A basic premise is that ecosystems currently have greater integrity 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

161

and are more sustainable if their conditions fall within the natural range of variation (Safford et 

al. 2012).

Application of natural range of variation concepts also recognize that native cultures managed 

and influenced ecosystem conditions and processes (Jackson and Hobbs 2009). For example, in 

the analysis area, Native American Tribes actively used fire to manage resources of tribal

importance, such as vegetation and game (Lake and Long 2014b).

Although the concept of natural range of variation and its use in sustainable ecosystem 

management is well developed from a theoretical standpoint, its application in resource 

management is not always straightforward. For example, sometimes an important measure of 

vegetation structure used to characterize wildlife habitat, such as canopy cover, is not directly or 

easily reconstructed historically. Or, quantitative information on historic conditions, such as tree 

densities, may only be available for a short period of time just before or at the onset of European 

settlement. Despite these limitations, it is still considered a useful way to evaluate the very 

important but complex concept of ecological sustainability. It is also increasingly recognized that 

human presence and needs may result in desired ecological conditions that are different than the 

natural range of variation (Higgs et al. 2014). Vegetation desired conditions for the proposed plan 

take into account not only natural range of variation, but also current societal desires for 

supporting recovery of endangered species and reducing fire near communities. 

During the assessment phase, terrestrial ecosystems were classified into broad ecological zones, 

based upon similarities in dominant vegetation types, climate, and fire patterns at a landscape 

scale. These broad ecological zones were used to analyze and summarize conditions and impacts 

of the alternatives to vegetation ecology and terrestrial function in the following subsection. The 

ecological zones include Sierra Nevada montane zone (also referred to as “montane”), subalpine 

and alpine zone, and eastside shrublands and woodlands as shown in figure 25 (see the maps in 

volume 3 to see ecological zones by alternative). The Sierra Nevada montane zone includes forest 

and other vegetation (Jeffrey pine, dry mixed conifer, red fir, and wet and dry lodgepole pine 

forests) at mid-elevations in the Sierra Nevada and Glass Mountains. The subalpine and alpine 

zone includes high-elevation (generally above 10,000 feet) vegetation in the Sierra Nevada and 

White, Inyo, and Glass Mountains. The eastside arid shrublands and woodlands vegetation group 

includes sagebrush, pinyon-juniper woodlands, mountain mahogany, and xeric shrublands and 

blackbrush. Three other vegetation types are described but not shown on these maps due to their 

small and localized distribution: aspen, and black oak/canyon live oak. The area in acres in each 

ecological zone is shown in table 19.

Table 19. Area in acres by ecological zone or vegetation 

group, rounded to the nearest thousand acres

Ecological Zone/

Vegetation Group Acres

Montane 339,000

Subalpine/Alpine 465,000

Eastside shrublands and woodlands 1,168,000
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

162

Figure 25. Ecological/vegetation zones groups on the Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

163

Analysis and Methods

The overarching approach we used in this analysis was to evaluate the similarity of current and 

estimated future conditions under each alternative to the desired conditions for each vegetation 

type. We used a combination of qualitative and quantitative analysis. For both types of 

evaluations, we identified the specific indicators, measures, thresholds for levels of similarity 

between desired conditions and current or future conditions, and associated assumptions. These 

are described in more detail in the Vegetation Ecology and Fire Ecology supplemental reports.

The desired conditions for vegetation and other terrestrial ecosystems are all directly related to 

the natural range of variation. For each major vegetation type, we developed desired conditions 

for vegetation structure, composition and function that were specific and quantitative where 

possible. For example, there has been extensive research on how forest density has changed over 

the last 100 or more years (Stephens et al. 2015, Collins, Everett, and Stephens 2011, Collins et 

al. 2015) and other research on how forests differ between areas in national parks that have had 

little direct management except fire suppression and where over the past 40 years, fires have been 

restored (Lydersen and North 2012, Lydersen et al. 2013). This research includes information on 

dominant species, tree densities of different tree sizes, variation in tree spacing or heterogeneity, 

and evidence of high fire severity. There are some desired conditions that strive for a balance 

between habitat needs for at-risk species and the natural range of variation. That includes having 

more areas of sagebrush cover for greater sage-grouse and structurally-diverse old-forest habitat 

for California spotted owl (not uniformly high canopy cover across the landscape).

The choice of specific measures used in the desired conditions depends on a combination of what 

conditions are used to characterize suitable wildlife habitat, what is important for ecological 

integrity and sustainability, what is most departed from the natural range of variation, and what is 

most useful to apply to restoration projects. Canopy cover is an example that is important to 

wildlife habitat, is known to be outside the natural range of variation and can be used to apply to 

restoration projects. Tree density is more difficult to relate to habitat and sustainability because it 

varies so widely from site to site. Basal area is a measure of forest density that incorporates 

aspects of tree density and tree sizes, and is available from the natural range of variation research 

and is very useful in restoration project design. Because of these considerations, desired 

conditions were developed for canopy cover at the landscape scale and within patches, and basal 

area was used to measure forest density.

Indicators and Measures

There are several main aspects to vegetation ecology that were used for this analysis.

Composition. Composition includes the mix of plant species. The analysis looks at predicted 

changes to overstory and understory composition. For the overstory, we considered the primary 

tree species, such as amount of pinyon-juniper in sagebrush areas (eastside). For the understory, 

we considered the mix of native flowering plants, shrubs and grasses and presence and extent of 

nonnative, invasive plants.

Structure. Structure includes the type of plants (trees or shrubs), how big individual plants or 

trees are, how dense they occur, and how they are arranged, such as uniformly or in a clumpy or 

heterogeneous pattern. Vegetation structure at the landscape scale was characterized by the 

amount of vegetation in the California Wildlife Habitat Relationships classes (Mayer and 

Laudenslayer Jr 1988). At the patch scale, we analyzed forest density, represented by canopy 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

164

cover and basal area. We used heterogeneity (variability in tree spacing, sizes and openings) to 

analyze within-patch structure.

Vegetation types as described by California Wildlife Habitat Relationships classes are useful in 

comparing the proportion of the landscape in forested versus nonforested areas, and the amount 

of open versus close-canopied, or small- versus large-tree-dominated patches. While they are 

sometimes equated to seral stages (stages of forest development), there is not necessarily a oneto-one correspondence. For example, very open small-tree-dominated woodland at high 

elevations may be a very old subalpine forest. The stand size characteristic is based upon the 

average stand diameter. When forests consist of mixtures of tree sizes or diameters, this can make 

it difficult to distinguish younger from older forests. The California Wildlife Habitat 

Relationships classification does not reflect aspects of structure that are important to many 

wildlife species, such as large trees and snags (North 2012b). The analysis of old forest 

characteristics, including the proportion of the landscape in old forest, large tree densities, and 

restoration approaches for large and old trees in old forests, are described in greater detail in the 

Old Forest supplemental report. Despite the short-comings of the California Wildlife Habitat 

Relationships classification, it is what has been applied for multiple decades. It is still used in part 

to characterize wildlife habitat suitability for some of the species of conservation concern 

analyzed in this plan. Because of its continued use in wildlife models, it was analyzed here.

Resilience to Fire, Climate, Drought, Air Pollutants, Insects and Pathogens. Resilience is a 

measure of the elasticity of an ecosystem; that is, its ability to absorb disturbances or stressors 

such as severe droughts and insect outbreaks and to maintain or quickly recover its intrinsic 

ecological characteristics (composition, structure, and function) and ecosystem services (such as 

provide habitat or soil protection). For this analysis, the ability of terrestrial ecosystems, 

especially vegetation, to withstand drought, warmer temperatures, high-intensity fires and insect 

and pathogen outbreaks was analyzed. In the previous section on climate, the broader capacity of 

ecosystems to respond to climate change was covered. Resilience to fire was addressed in the 

context of the natural range of variation of fire regimes.

Two different measures were used to reflect ecological fire resilience. In forested ecosystems, we 

used the intensity and type of fire, such as surface or crown fire. In non-forest and woodland 

ecosystems, we used fire return interval departure and presence of nonnative annual grasses to 

analyze resilience. For both of these measures, the analysis was at a landscape scale, since fires 

and vegetation responses can vary from site to site. The aggregate of all of those effects and 

resilience to fire is most important for ecological impacts.

Analysis Methods and Data Sources

We used a combination of scientific summaries, scientific research, and existing and available 

vegetation information for the analysis. This included Forest Inventory and Analysis plot data and 

remote sensing, satellite data. Most of the information included in the “Affected Environment” 

section was based upon the bio-regional and forest assessments (USDA Forest Service 2013a, 

2013b, 2013c, and 2013d). These included information from the “Living Assessment” (USDA 

Forest Service 2013e, 2013f, 2013g, and 2013h), published scientific literature, the “Scientific 

Synthesis” (Long, Quinn-Davidson, and Skinner 2014b), and the “Natural Range of Variability 

Assessments” (Safford and Stevens 2017, Estes 2013a and 2013c, Merriam et al. 2013, Meyer 

2015b and 2015c, Sawyer 2013b, Slaton and Stone 2015a and 2015b). This information was used 

to evaluate the conditions of the indicators relative to desired conditions and analysis thresholds.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

165

For each indicator and vegetation type or ecological zone, we evaluated potential effects on 

composition, structure, and resilience at the programmatic level for each alternative. This entails 

identifying plan direction relevant to the vegetation type for each alternative and making 

projections about the potential effects of future implementation of that plan direction. The 

specific timing and location of potential restoration projects is not known but the types of effects 

associated with implementation can be discussed. The evaluation of potential effects to 

composition, structure, and resilience associated with plan implementation is based on scientific 

literature (and professional experience) that has examined the effects of treatments similar to 

those that would be implemented under alternatives B, C, and D using fire-climate modeling (see 

“Fire Trends” section, (Westerling, Milostan, and Keyser. 2015), and ecological fire resilience 

modeling (USDA Forest Service 2013a, e 2013b, 2013c, and 2013d).

Most of the earlier literature on the ecological restoration of Sierra Nevada montane forests has 

focused on fuels treatments. More recently, there has been an increase in ecological restoration 

for vegetation composition, structure, and ecological function. Much of the associated research on 

ecological restoration for mixed conifer and yellow pine (ponderosa and Jeffrey pine) forests has 

been summarized in two recent technical reports, GTR 220 and 237 (North, Stine, O’Hara, et al. 

2009, North 2012a)), and the recent “Science Synthesis for the Sierra Nevada Bioregion” (Long, 

Quinn-Davidson, and Skinner 2014a). Red fir restoration is also addressed in the Science 

Synthesis to some degree. Restoration management strategies and treatments proposed and 

described in those documents are the basis for management direction contained in alternatives B,

B-modified, C, and D.

For sagebrush and pinyon-juniper ecosystems, we examined several recent comprehensive 

scientific literature reviews and management strategies directed at restoration of greater sagegrouse habitat (Chambers et al. 2007, Wisdom and Chambers 2009, Arkle et al. 2014, Chambers 

et al. 2013, Chambers et al. 2014). This includes reducing conifer density in sagebrush areas, 

prevention and restoration of areas with nonnative, invasive annual grasses, and restoration of 

perennial grasses.

For some vegetation types there are multiple applicable research papers, and for readability only 

key ones were cited here. Additional scientific research on the effects of different restoration 

management activities specific to different vegetation types are summarized in the Vegetation 

Ecology supplemental report.

The analysis is displayed in two ways. First, there is a narrative for each indicator by major 

vegetation type that explains the potential consequences of implementing the different type, 

amount, and location of restoration activities. Second, there is an overall rating of whether the 

indicator has a low, moderate, or high similarity to desired conditions. This rating is based upon 

the degree of departure (and especially the proportion of the landscape with departure of current 

or expected future conditions) from the desired conditions and natural range of variation. The 

criteria and thresholds for the ratings were identified for each major vegetation type and indicator 

and are displayed in the Vegetation Ecology supplemental report. The tables for montane Jeffrey 

pine and dry mixed conifer (table 20) and eastside sagebrush and pinyon-juniper (table 21) are 

included below because these are the primary vegetation types that would be managed.

Thresholds for evaluating condition of vegetation indicators were based upon scientific literature 

where available and, where not available, on general ecological theory (that is, percolation theory, 

(Turner 1989), research on landscape vegetation conditions and changes in fire patterns (Parisien, 

Junor, and Kafka 2007; Parisien et al. 2010 and 2012; Westerling, Milostan, and Keyser 2015), 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

166

and logical categories. There is limited scientific literature that specifies what proportion of a 

landscape needs to be in a certain condition to have ecological integrity. Landscape ecology 

theory provided an overall basis for setting the high and low ecological condition thresholds 

(Turner 1989). Percolation theory distinguishes changes in landscape processes and functions 

when less than 40 percent of a landscape is in a different condition. This could include 

fragmentation of habitat, movement of wildlife, or movement of fire. Research on fire 

probabilities (extent, large fire size and severity) suggest that landscapes with at least 40 percent 

in a condition that is more consistent with the natural range of variation have a reduced likelihood 

of fire probability and large fire size, and areas with more than 60 to 75 percent have a 

substantially reduced likelihood (Parisien, Junor, and Kafka 2007; Parisien et al. 2010 and 2012; 

Westerling, Milostan, and Keyser 2015).

Table 20. The indicators, measures and criteria for evaluating the current condition and 

consequences for the Sierra Nevada montane zone (and dry mixed conifer) composition

Vegetation/

Ecosystem

Type Indicator Measure Criteria

Dry mixed 

conifer

Overstory 

composition

Similarity of dominant overstory 

tree composition to desired 

conditions (over 60 percent pine 

in mixed conifer) 

High: meet conditions on most (over 

60 percent of area) of the landscape 

Moderate: meet conditions on some

(40-60 percent of area) of the 

landscape 

Low: meet conditions on limited 

(less than 40 percent of the area) of 

the landscape

Jeffrey pine 

and dry

mixed conifer

Understory 

composition

Understory – native plant 

composition, abundance and 

condition (improved with 

openings and fire restoration)

High – open canopy (similar to 

desired conditions) dominant, with 

restoration of fire common: over 60

percent area

Moderate – same as above but 30-

60 percent area

Low – same as above but less than 

30 percent area

Jeffrey pine 

and dry 

mixed conifer

Overstory 

structure

Similarity of overstory stand

structure to desired conditions 

(within the natural range of 

variation with respect to tree 

densities, canopy cover, basal 

area, tree size class distribution)

High: meet conditions on most (over 

60 percent of area) of the landscape 

Moderate: meet conditions on some 

(40-60 percent of area) of the 

landscape 

Low: meet conditions on limited 

(less than 40 percent of the area) of 

the landscape
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

167

Table 21. The indicators, measures and criteria for evaluating the current condition and 

consequences for eastside ecological zones and vegetation types

Vegetation/

Ecosystem Type Indicator Measure Criteria

Sagebrush Composition Similarity of understory 

composition and condition to 

desired condition (areas of 

native perennial grasses and 

flowering plants thriving and 

increasing, native shrubs 

healthy)

High: meet conditions on many areas 

(over40 percent area);

Moderate: meet conditions on some (20-

40 percent ) of the area; 

Low: meet conditions on limited (less 

than 20 percent) of the area; 

Sagebrush Composition Presence of conifer trees 

(pinyon, juniper, Jeffrey pine) in 

historically tree free areas

High: less than 10 percent of sagebrush 

area invaded by conifers

Moderate: 10 to 30 percent of sagebrush 

areas invaded by conifers 

Low: more than 30 percent of sagebrush 

areas invaded by conifers

Sagebrush Structure Similarity of seral stage mosaic 

to desired condition (within the 

natural range of variation; areas 

of sage-grouse nesting and 

brooding/rearing habitat within 

desired conditions

High: meet conditions on most (over 60

percent of area) of the landscape 

Moderate: meet conditions on some (40-

60 percent of area) of the landscape 

Low: meet conditions on limited (less 

than 40 percent of the area) of the 

landscape

Sagebrush Structure Age structure and condition of 

shrubs (decadence)

High: shrub age structure diverse and 

within the natural range of variation on 

most of landscape (over 60 percent of 

area)

Moderate: same as above for some of 

area (40 to 60 percent area)

Low: same as above for little of the area 

(less than 40 percent area)

Pinyon-juniper Composition Similarity of species composition 

to desired condition (limited 

nonnative invasive grasses or 

plants, primarily cheatgrass)

High: few to no invasive plants 

Moderate: limited frequency of 

occurrence and slow rates of spread

Low: moderate to high frequency of 

occurrence and rates of spread

Pinyon-juniper Structure Pinyon pine regeneration, 

mature trees and pinyon nut 

production

High: most (over 60 percent) of the area 

within desired condition 

Moderate: some (40-60 percent) of the 

area within desired condition

Low: limited (less than 40 percent) area 

within desired condition

Xeric Shrub-black 

brush

Composition Native species composition; 

invasive species (occurrence, 

density and number of species); 

native soil crusts are intact

High: few to no invasive plants; native 

plants and soil crusts in good condition 

over most (over 98 percent of the area)

Moderate: limited frequency of 

occurrence and slow rates of spread of 

invasive plants and/or disruption of soil 

crusts (under 5 percent area)

Low: moderate to high frequency of 

occurrence and rates of spread; and 

disruption of soil crusts over increased 

area (over 5 percent area)

Xeric Shrub-black 

brush

Structure and 

resilience

Presence of nonnative plants, 

especially annual grasses

See above
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

168

We made reasonable assumptions that:

• the majority (greater than 60 to greater than 75 percent) of a landscape in condition within 

the natural range of variation or similar to desired conditions would have high ecological 

integrity;

• nearly half (greater than 40 to greater than 50 percent) of a landscape in condition within 

the natural range of variation or similar to desired condition would have moderate 

ecological integrity; and

• less than that would have low ecological integrity (less than 20 to less than 40 percent)

• The characterization of the natural range of variation of fire severity in Sierra Nevada forest 

ecosystems (including the characterization of high severity fire proportion and patch size) 

is based on a large volume of best available science information summarized in Safford 

(2013), Meyer (2013a, b), Long et al. (2014c), North et al. (2009, 2012a), and other sources 

cited in the “Agents of Change” section. These comprehensive best available science 

information summaries only include information sources that meet criteria for best 

available science information as defined by the 2012 Forest Planning Rule as accurate, 

reliable, and relevant to the issues being considered. In particular, valid best available 

science information is characterized by several features, including but not limited to: 

(1) quantitative analysis was performed using appropriate statistical or quantitative 

methods, (2) logical conclusions and reasonable inferences were drawn, (3) science uses 

well-developed scientific methods that are clearly described, and (4) information is placed 

in proper context including spatial and temporal scales.23 Information sources that do not 

meet these criteria or characteristics of best available science information (Baker 2014, 

Odion et al 2014, Hanson and Odion 2014, Odion and Hanson 2016), were not included or 

cited in the evaluation of fire regime natural range of variation in Sierra Nevada forest 

ecosystems used in the final environmental impact statement and revised forest plan. 

Moreover, several recent best available science publications (Levine et al. 2017, Stevens et 

al. 2016, Fulé et al. 2014, Stephens et al. 2015, Miller and Safford 2017, Safford, Miller, 

and Collins 2015, Safford et al. 2008), disprove the best available science information 

validity of the aforementioned publications due to: (1) a series of serious analytical and 

methodological issues, (2) unreasonable inferences and inappropriate conclusions drawn, 

(3) scientific methods and analyses poorly developed and described, (4) science 

information placed in inappropriate ecological context, and (5) other related issues (such as 

technical references inappropriately cited and placed out of context). For these reasons, 

these information sources were not considered valid best available science information for 

the evaluation of fire regime integrity or resilience in Sierra Nevada ecosystems.

Affected Environment

Current conditions are first summarized overall and then later described by ecological/elevation 

zone and vegetation type. The distribution and area in major vegetation types are shown in table 

22 and figure 26. Note that the vegetation map for the Inyo National Forest is based upon the 

Terrestrial Ecological Unit Inventory. Some of the smaller patches were merged with adjacent 

larger patches. The information has not been updated for recent fires occurring since 2009. 

(However, updates for vegetation changes since the large, recent fires before 2015 were made to 

the underlying fuels layers used to model ecological fire resilience). In addition, vegetation on the 

 23 FSH 1909.12 - Land management planning handbook, Chapter 42.12
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

169

ground would show more detail and smaller patches of varying vegetation types than represented 

in these figures.

Table 22. Acres of major vegetation types, Inyo National Forest1

Vegetation/Ecosystem Type

Ecological Zone/Vegetation 

Group Acres

Pinyon-juniper Eastside shrublands and 

woodlands

563,884

Subalpine conifer forest Subalpine/alpine 335,453

Sagebrush Eastside shrublands and 

woodlands

309,426

Xeric shrub and blackbrush Eastside shrublands and 

woodlands

213,971

Jeffrey pine Montane 135,106

Alpine Subalpine/alpine 129,845

Red fir Montane 118,061

Mountain mahogany Eastside shrublands and 

woodlands

81,683

Lodgepole pine2 Montane 48,004

Special type Unique vegetation type 49,490

Dry Mixed conifer Montane 45,692

Aspen Unique vegetation type 12,462

Black oak/Canyon live oak Unique vegetation type 393

1. Vegetation types based on the California Wildlife Habitat Relationships classification (for Sierran Mixed conifer) and the 

Inyo National Forest Terrestrial Ecosystem Unit Inventory classification (for all other vegetation types).

2. Includes wet and dry lodgepole pine ecosystem types.

Hardwood types are important for wildlife species and some of the species of conservation 

concern. These were broken out by dominance of the primary species such as black oak, canyon 

live oak, or aspen. Table 23 below shows the area of vegetation dominated by different hardwood 

species. 

Table 23. Area in acres in different hardwood vegetation types 

rounded to the nearest hundred acres

Regional Dominance Type* Inyo National Forest Acres

Black Oak 246

Canyon Live Oak 4,155

Quaking Aspen 16,780

* Defined by California Wildlife Habitat Relationships classifications
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

170

Figure 26. Major ecosystem types from the Terrestrial Ecological Unit Inventory, Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

171

Summary of Similarity of Current Conditions to Desired Conditions

Based on the assessments for individual major vegetation types, the current conditions show a 

high similarity with desired conditions for only a few types, particularly the alpine and subalpine 

types. For the majority of vegetation types, especially those in the montane and Great Basin 

ecological zones, the vegetation characteristics exhibit a low to moderate similarity with the 

desired conditions. A summary of the current condition compared to the desired conditions are 

shown in table 24 for eastside vegetation types and ecological zones.

Table 24. Comparison of current conditions to desired conditions vegetation types and ecological zones1

Vegetation 

Type

Vegetation 

Composition

Overstory

Vegetation 

Composition

Understory

Vegetation 

Structure

Density

Vegetation 

Structure

Heterogeneity

Drought, 

Climate 

Resilience

Fire 

Resilience

Sagebrush not applicable low moderate low moderate moderate

Pinyon-juniper high moderate moderate low-moderate moderate low-moderate

Mountain 

mahogany not applicable moderate moderate moderate moderate moderate

Jeffrey Pine Moderate to 

high

Moderate to 

high low low low low

Dry mixed 

conifer low low low low low very low

Red fir-Moist 

Lodgepole pine high moderate low low-moderate low low

Subalpine/

Alpine

high moderate-high moderate to 

high

moderate to 

high

moderate moderate to 

high

Desert Shrub/

Blackbrush not applicable moderate-high

low

not 

applicable not applicable moderate low

1. Comparison of vegetation structure, composition, or function is based on a qualitative assessment of similarity between 

current and desired conditions. Low similarity indicates that current conditions are dissimilar to desired conditions (e.g., 

tree densities and forest biomass are outside the desired variation), and high similarity indicates that current conditions 

are similar to desired conditions (e.g., overstory tree composition is within the natural range of variation).

Vegetation in the Kern River drainage is covered separately in table 25 because the current 

condition of most resident vegetation types differs substantially from the rest of the Inyo National 

Forest. This is because of the extensive restoration of wildfire managed to meet resource 

objectives in this more remote area over the last 15 years (Fites-Kaufman, Noonan, and Ramirez 

2005, Ewell, Reiner, and Williams 2012, Meyer 2015a). This area also has a substantially 

different current condition and similarity to desired conditions. It spans westside to eastside 

vegetation, but is mostly similar to the westside conditions. It is described at the end of the 

vegetation section.

Table 25. Comparison of current conditions to desired conditions, vegetation types and ecological 

zones in the Kern River drainage1

Ecological Zone

Vegetation 

Composition

Overstory

Vegetation 

Composition

Understory

Vegetation 

Structure

Density

Vegetation 

Structure

Heterogeneity

Drought, 

Climate 

Resilience

Fire 

Resilience

Montane moderate to 

high

moderate to 

high

moderate to 

high

moderate to 

high

moderate moderate to 

high

Subalpine/ Alpine high moderate-high moderate to 

high

moderate to 

high

moderate moderate to 

high

1. See table note for table 24 footnote for description of low, moderate, and high ratings.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

172

Ecological Zones and Vegetation Types

There are three broad ecological zones in the plan area: Sierra Nevada montane, subalpine and 

alpine, and eastside shrublands and woodlands. Each of these zones spans a wide elevational 

gradient that contains multiple vegetation or ecosystem types adapted to local variations in 

climate, soils, topography, and natural disturbance regimes. In the following sections, each of 

these three zones and their component ecosystem or vegetation types are described in greater 

detail.

Sierra Nevada Montane Zone

The Sierra Nevada montane zone in the plan area contains a patchy mosaic of forest, shrub, and 

herb-dominated (meadow) vegetation types that change with elevation, topography, soils, climate, 

and prior disturbance history. Dry mixed conifer, Jeffrey pine, red fir, lodgepole pine, and 

mountain mahogany are the primary upland vegetation types (mountain mahogany occurs in the 

montane, subalpine and alpine, and eastside shrubland and woodland ecological zones). Extensive 

meadows and riparian areas also occur in many areas of this zone, especially within drainages and 

lower topographic positions. Fire is an especially important ecological process in the montane 

zone, influencing composition, structure, and resilience (van Wagtendonk and Fites-Kaufman 

2006). Decades of fire exclusion, timber harvest prior to the 1990s, widespread sheep grazing 

prior to the early 20th century, and patterns of increasing high-severity fire in many of these 

landscapes have resulted in changes at the landscape scale (Meyer et al. 2014a, Safford et al. 

2013c). Most forest areas have become more dense and uniform in structure. Increased highseverity fire has also resulted in greater degrees of forest fragmentation and reduced forest 

connectivity. These patterns of increasing fragmentation resulting from stand-replacing fire were 

often linked to warming climate and, in fire-excluded forests characterized with a frequent fire 

regime (such as Jeffrey pine forests), increased fuel loading (Miller and Safford 2012). Although 

tree mortality levels in the Sierra Nevada montane zone on the Inyo National Forest are likely in 

the upper portion of the natural range of variation, future warming climate trends and hotter 

droughts in the region will result in future tree mortality that will exceed the natural range of 

variation (Allen, Breshears, and McDowell 2015; Safford 2013; Safford and Stevens 2017).

Dry Mixed Conifer Forests

Although not as prevalent in the eastern Sierra Nevada as other forest types, dry mixed conifer 

forests do occur in moderately-sized patches in isolated areas on the Inyo National Forest, mostly 

on the Kern Plateau and also on the eastern escarpment. Here, dry mixed-conifer forests contain a 

mixture of Jeffrey pine and white fir, sometimes including lodgepole pine and, at higher 

elevations, some red fir (Safford and Stevens 2017, Fites-Kaufman et al. 2007). These are the

relatively productive areas, where a combination of climate and soils provide ideal growing 

conditions for trees and other vegetation. Historically, these productive forests had the most 

frequent fire, averaging 5 to 20 years (Safford et al. 2013b, van Wagtendonk and Fites-Kaufman 

2006). Frequent fires swept through the understory, keeping understory tree densities and surface 

fuels low. There was thought to be a high level of structural variation, with varied tree sizes, 

densities, spacing, and arrangements, collectively called “heterogeneity” (North, Stine, O'Hara, et 

al. 2009).

Current vegetation composition, structure and resilience of dry mixed conifer forests are highly 

dissimilar to desired conditions, except in the Kern Plateau and Kern River drainage. Conditions 

have changed considerably since before European settlement (van Wagtendonk and FitesKaufman 2006, Fites-Kaufman et al. 2007, Van de Water and Safford 2011, Collins, Everett, and 

Stephens 2011, Lydersen and North 2012, Safford and Van de Water 2014, Collins et al. 2015, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

173

Stephens et al. 2015), and are largely outside the natural range of variation in most of the 

montane zone (Safford and Stevens 2017, Merriam et al. 2013).

Composition of the overstory and understory in this ecosystem type has changed substantially. 

Jeffrey pines have decreased in dominance and shade-tolerant species, especially white fir, have 

increased (North, Stine, O'Hara, et al. 2009). Increases in tree density, and decreases in frequent, 

low- and moderate-intensity fires have impacted understory shrubs, grasses and flowering plants 

(van Wagtendonk and Fites-Kaufman 2006, Fites-Kaufman et al. 2007, Wayman and North 2007, 

Webster and Halpern 2010). These plants have evolved with fire and some of them have 

adaptations, such as the ability to sprout from bulbs or roots, or fire-stimulated seed germination 

that enables them to thrive with fire. Other plants, such as Jeffrey pine, need bare soil to 

germinate and survive. As a result, in the absence of frequent fire, the understory flora of shrubs, 

flowering plants, and grasses, is less diverse and in poor condition.

Forest structure in dry mixed conifer has changed in several ways. Forest density is higher, 

canopy cover of trees more uniformly higher, small and medium tree density is higher, and large 

tree density is lower (Collins, Everett, and Stephens 2011; Collins et al. 2015; Stephens et al. 

2015). Within-stand variation in tree size and density has decreased substantially (Lydersen et al. 

2013). Large tree densities and distribution across the landscape is substantially lower in most 

places than historically (USDA Forest Service 2001b, Franklin and Fites-Kaufman 1996, FitesKaufman et al. 2007, Stephens et al. 2015). Until recently, the low levels of large trees were due 

to past harvest from the European settlement period to the 1980s (Mckelvey and Johnston 1992). 

More recently, water stress, climate change, and possibly air pollutants have weakened large trees 

(Panek et al. 2013; Bytnerowicz, Fenn, and Long 2014). Outside of fires, large tree mortality has 

doubled in the last two to three decades across the western United States (Van Mantgem et al. 

2009). This pattern is associated with increases in temperature and droughts. There are also high 

levels of air pollutants, primarily ozone and possibly nitrogen that are impacting forest health and 

contributing to increased tree mortality to an unknown degree (USDA Forest Service 2013a and

2013d). Ozone weakens trees, especially yellow pines including Jeffrey pine, and makes them 

more susceptible to drought and insects (see “Air Quality” section). These stresses are 

compounded by the competition for water from the dense, younger trees that surround many old 

trees (McDowell et al. 2008, Franklin and Johnson 2012).

Resilience of dry mixed conifer forests to high-intensity fire, drought, insects, pathogens, climate 

change, and air pollution is very low in most areas (Safford et al. 2013c, North 2012b, Collins 

and Skinner 2014a). Dense vegetation contributes to higher intensity fire and increased tree 

mortality from fires. Dense forests are more vulnerable to stress brought on by drought, insects, 

pathogens, and air pollution. Currently, in dry mixed conifer forests there has been and continues 

to be elevated tree mortality, especially in white fir and red fir. Mortality is extending up into the 

higher elevations in mixed conifer forests based upon aerial surveys conducted by the USDA

Forest Service State and Private Forestry program (see figure 8 and figure 9 in the “Insects and 

Pathogens” section). However, mortality levels are not as extensive on the eastside as on westside 

forests. This mortality is primarily resulting from a combination of hotter drought (driven by 

warming climate trends) and insects. There may also be a contribution from ozone weakening the 

trees. This not only reflects decreased resilience but is also resulting in decreased forest diversity

and heterogeneity.

Fires in dry mixed conifer are less frequent but evidence is strong that they are on average larger 

and more severe in large uniform areas, than before European settlement (Collins and Skinner 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

174

2014a, Safford et al. 2013c). Changes in fire have contributed to shrinking chaparral patches 

scattered within forests (Estes 2013a). Most of the montane area is likely to burn as crown fires 

during peak fire weather conditions. The mix of fire types (crown and surface fires), and resulting 

severity (high to moderate or low) is difficult to predict precisely. There are many conditions that 

influence the type and effects of fires including the time of day, condition of the vegetation, and 

dryness of the vegetation and fuels. Overall, the more continuously dense vegetation is and dry, 

the more likely large areas of crown fire will occur. Recent trends in fires have been increased 

proportions of crown fire and high-severity effects to forests, especially in dry mixed conifer and 

yellow pine forests (Miller and Safford 2012; Steel, Safford, and Viers 2015).

Jeffrey Pine Forests

Jeffrey pine forests are scattered along the escarpment of the Sierra Nevada, on the Kern Plateau, 

Glass Mountains, Mono Valley, and Upper Owens River area. This forest type generally occurs 

on shallow, less productive soils on middle to upper slope positions. Eastside Jeffrey pine forests 

typically occur in “pure” stands dominated by Jeffrey pine. In some areas it may be mixed with 

pinyon pine, white fir, red fir, lodgepole pine, western white pine, or limber pine. The understory 

usually consists of a low cover of herbaceous plants or shrubs such as sagebrush or bitterbrush.

Composition is low to moderate in its similarity to desired conditions. The overstory has had less 

fire and therefore an increasing proportion of white fir, red fir, and lodgepole pine. But in most 

areas, Jeffrey pine remains the dominant tree species. The understory has had more changes and 

has a low similarity to desired conditions. This is due to an increase in nonnative, annual grasses 

that displace native understory plants. Fire suppression and grazing have also resulted in changes 

in understory composition.

Stand structure conditions in eastside Jeffrey pine 

forests are different from desired conditions. Tree 

densities have increased, and there has been a 

considerable shift in the tree size class distribution 

to smaller diameters, a decrease in heterogeneity 

and greater uniformity of forest structure at patch 

and landscape scales, increased canopy cover, and 

a general decrease in the density of large-diameter 

Jeffrey pine trees (Safford and Stevens 2017). 

There is a deficit of open-canopy mature and old 

forests throughout the plan area. Surface fuels and 

small trees that serve as ladder fuels are greater 

than the desired condition.

Resilience of Jeffrey pine forests is low to very 

low. Increased density has made them more 

susceptible to drought, insects and pathogens, 

climate change, and high-intensity fire-related 

mortality (figure 27). Climate projections of 

eastside Jeffrey pine forests suggest this forest 

type will shift upwards to the higher elevations on 

the eastside Sierra Nevada (Finch 2012, Schwartz 

et al. 2013b, Thorne et al. 2017).

Figure 27. Recently dead and dying Jeffrey

pines in eastside pine stand on the Inyo

National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

175

Red Fir Forests

Red fir forests are common in upper montane landscapes of the southern Sierra Nevada. This 

forest type is dominated by red fir and typically occurs on deeper, more productive soils on most 

slope positions except ridgetops. Mixed red fir stands may also contain white fir at lower 

elevations and lodgepole pine, Jeffrey pine, western white pine, or mountain hemlock at higher 

elevations (Potter 1998). The understory may include several species of shrubs or herbaceous 

plants, including pinemat manzanita, greenleaf manzanita, huckleberry oak, chinquapin, 

snowberry, Utah serviceberry, mountain whitethorn, pine-woods lousewort, and Brewer’s golden 

aster.

Tree species composition is generally similar to the desired conditions, but understory species 

cover and diversity in fire-excluded stands is at the lower end of the desired conditions and the 

natural range of variation (Meyer et al. 2014a).

Current stand structure conditions in red fir forests are dissimilar to desired conditions. There has 

been a considerable shift in the tree size class distribution to smaller diameters. Forest structure at 

the stand and landscape scales is more uniform and less heterogeneous. There has been a decrease 

in the density of large-diameter red fir trees in many areas (Meyer et al. 2014a). Younger and 

intermediate-sized trees are denser than the desired condition, and there is a deficit of opencanopy mature and old forests in most of the plan area. 

Resilience of red fir forests to drought, insects, pathogens, climate change and high-intensity fire 

is moderate but declining. Tree mortality rates associated with pathogens and moisture stress in 

red fir forests is increasing at a rate that will soon exceed the desired conditions and natural range 

of variation (Mortenson, Gray, and Shaw 2015). Climate vulnerability of red fir forests is 

relatively high compared to other vegetation types (Meyer 2013a). Because red fir is associated 

with colder winters and snow, it is particularly vulnerable to climate change. Resilience to highintensity fire is moderate. Higher stand density, more uniform forests have resulted in increased 

high severity areas. Although some areas of high severity are within the natural range of variation

(van Wagtendonk and Fites-Kaufman 2006), larger patches of high severity are becoming more 

common with drought and hot and dry weather.

Lodgepole Pine Forests

This vegetation type is further divided into dry versus wet lodgepole pine. Dry lodgepole pine 

dominates in higher elevation dry sites generally above 8,500 feet elevation, often located on 

benches, upper topographic positions, and moderate slopes. Stands are typically in broken terrain 

and shallow, drier, and nutrient-poor soils. Western white pine may be present, but mesic tree 

species (such as red fir and mountain hemlock) are generally absent or infrequent. Understory 

herbaceous plant cover is generally less than 30 percent and bare ground and rock cover is 

generally more than 30 percent. Either wet or dry lodgepole may border some meadow 

ecosystems, depending upon the ecological setting.

Wet lodgepole pine dominates in higher elevation wet sites generally above 7,500 feet elevation, 

often located on gently rolling lower slopes and drainage bottoms. Stands are located on 

relatively productive, moister, and deeper soils in the montane zone. Red fir or mountain hemlock 

may be present in wet lodgepole pine stands. Understory herbaceous plant cover is generally 

more than 30 percent and bare ground and rock cover is generally less than 30 percent. Either wet 

or dry lodgepole may border some meadow ecosystems, depending upon the ecological setting.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

176

Unique Landscapes within the Sierra Nevada Montane Zone

The Kern River drainage is a unique landscape in the Sierra Nevada montane zone that includes 

the Kern Plateau, located east of the Kern River, which dominates the center of the Sequoia 

National Forest and a small area on the southwest portion of the Inyo National Forest. The 

canyon where the Kern River drains is also included in the Kern River drainage, especially in the 

north and middle sections of the watershed. Much of this area is remote and steep and as a result 

there have been multiple wildfires that have been managed to meet resource objectives in this 

area over the past 15 years (Meyer 2015a). Most of the area is within the montane zone. Some of 

the fires in the area have been very large, and mostly high intensity and severity, including the 

McNally Fire. This was in the western portion, partly outside of the Kern River drainage. Most of 

the McNally Fire was not beneficial because it had very large patches of high-severity fire, but 

the majority of the fires have been beneficial and have resulted in substantial movement toward 

desired conditions (Fites-Kaufman, Noonan, and Ramirez 2005, Ewell, Reiner, and Williams 

2012, Meyer et al. 2015).

On the Kern Plateau, extensive fires have occurred over the last 15 years in a range of weather 

conditions. Because the area is very dry, increases in forest density have been less dramatic than 

other mixed conifer areas. There has been less ingrowth of white fir. Because of these more 

moderate changes in forest density and composition, the effects of the fires in the last 15 years 

have been less severe in many areas. For many of these fires, there has been a greater proportion 

of moderate- and low-intensity fire and resulting low- and mixed-severity effects. As a result, 

large areas have had reductions in forest density toward the desired conditions. There has been an 

increase in heterogeneity at the landscape, patch and within-patch scales in forests and chaparral. 

These fires have restored understory plant composition and condition, since the majority of the 

species are adapted to and may benefit from fire. This includes the riparian areas. Examples 

include lupines, aspen, grasses and other sprouting plants. Overall, montane forests in much of 

the Kern Plateau have a moderate to high similarity to desired conditions. The area has a 

moderate to high resilience to drought, insects, pathogens, climate change, and high-intensity fire. 

This is apparent in lower levels of tree mortality and increasingly restricted sizes of large fires. 

This has happened multiple times, mostly recently on the Rough and Cabin Fires on the Sequoia 

National Forest in 2015 (Reiner et al. 2016).

Subalpine and Alpine Vegetation Zone

The subalpine and alpine zone occurs at the highest elevations of the eastern Sierra Nevada and 

White, Inyo, and Glass Mountains in the Great Basin. This zone is characterized by mostly steep 

slopes, poorly-developed granitic-based soils, and a very high percentage of precipitation that 

falls as snow (van Wagtendonk and Fites-Kaufman 2006). The primary vegetation types in this 

zone include subalpine forests and alpine communities dominated by either shrubs or herbs that 

are often patchily distributed across the landscape (Potter 1998). Warming climate trends in the 

plan area are likely to lead to increased fragmentation and reduced connectivity of subalpine and 

alpine vegetation, especially in the latter half of the 21st century (Lenihan et al. 2008, Schwartz et 

al. 2013b, Thorne et al. 2017). These broad-scale changes have important implications for a wide 

array of species dependent on subalpine and alpine environments, especially southern Sierra 

Nevada endemics such as foxtail pine (Pinus balfouriana subspecies austrina), alpine chipmunk, 

granite draba, Sierra Nevada leptosiphon, and sweet-smelling monardella (Meyer et al. 2014a, 

Rundel 2011).

Subalpine landscapes in the eastern Sierra Nevada contain a number of species that are absent or 

rare on the westside, such as limber pine. There are other species that are limited in distribution to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

177

other areas in the eastside and Great Basin, notably the Great Basin bristlecone pine (referred to 

as ‘bristlecone pine’ hereafter). The White, Inyo, and Glass Mountains contain other subalpine 

and alpine species only found on the eastside of the Sierra Nevada, such as the bristlecone 

cryptantha, July Gold, White Mountains draba, and White Mountains wild buckwheat. Eastside 

elevation gradients tend to be more dramatic than on the westside, in many subalpine landscapes, 

leading to rapid changes in species composition and structure of eastside, high-elevation 

ecosystems.

The current composition and structure of subalpine and alpine ecosystems are mostly similar to 

desired conditions, with a few exceptions noted below (Meyer 2015c). Resilience is similar as 

well. The impacts of climate change will affect connectivity of subalpine forests, especially in the 

latter half of the 21st century. The following sections give more specific details for the two 

vegetation types.

Subalpine Woodlands and Forests

Subalpine vegetation occurs near the highest elevations of the plan area. Subalpine treedominated areas form woodlands when trees are sparse or low density. Most subalpine treedominated areas are woodlands. In other areas, trees are moderate to high density, more often in 

smaller patches. These areas comprise subalpine forests. The subalpine vegetation type typically 

occurs on shallow, less productive soils on most slope positions including ridgetops and steep 

slopes.

Current overstory and understory species composition is similar to the desired conditions. Current 

subalpine woodland and forest structure is also mostly similar to desired conditions, although 

there is a recent increase in the density of small-diameter subalpine trees and a decrease in the 

density of large-diameter trees. This has been attributed to climatic warming trends, which has 

increased favorable growing conditions in this harsh environment (Meyer 2015c; Safford, North, 

and Meyer 2012).

Resilience of subalpine woodlands and forests was high until recently but is undergoing rapid 

changes due to climate warming. Climate vulnerability of subalpine forests is among the highest 

of all vegetation types in the plan area (Meyer et al. 2014a; Safford, North, and Meyer 2012). 

Tree mortality rates associated with moisture stress and insects (especially mountain pine beetle) 

in subalpine forests dominated by high-elevation white pines is increasing at a rate that may soon 

exceed the desired conditions and natural range of variation. Resilience to fire is generally high 

(Meyer et al. 2014a). White pine blister rust may also increase in incidence within high elevation 

white pine stands on the Inyo National Forest (Maloney 2011).

Alpine Vegetation

Alpine vegetation occurs at the highest elevations of the plan area (greater than 10,000 feet 

elevation). This vegetation type typically occurs on very shallow, low productivity soils on most 

slope positions including ridgetops and steep slopes. Alpine vegetation in the plan area is 

dominated by perennial herbaceous plants (like Mason’s sky pilot) or dwarf shrubs (such as white 

heather), but may also contain small, isolated subalpine tree islands and krummholz (stunted) 

whitebark pine stands. Shallow bedrock may dominate much of the cover in many alpine 

landscapes of the plan area.

Current species composition and structure of alpine vegetation is very similar to the desired 

conditions. Resilience is low to moderate. The vegetation in the alpine areas establishes and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

178

grows very slowly. Climate vulnerability of alpine vegetation is among the highest of all 

vegetation types in the plan area (Lenihan et al. 2008; Safford, North, and Meyer 2012), and some 

alpine plant and animal species have recently shifted their geographic ranges to higher elevations 

in the plan area (Kopp and Cleland 2014, Moritz and Stephens 2008, Moritz et al. 2008). With no 

other area to go to at higher elevations for cooler temperatures, these plants may decline in 

numbers or locations.

Eastside Shrublands and Woodlands

Eastside shrublands and woodlands dominate the lower elevation landscapes of the plan area. The 

primary vegetation types include sagebrush, pinyon-juniper, mountain mahogany (also occurs in 

Sierra Nevada montane and subalpine/alpine zones), and xeric shrub/blackbrush. These 

vegetation types occur in an area of convergence among three biogeographic provinces: the Sierra 

Nevada, Great Basin, and Mojave Desert. This area of convergence within the eastside shrublands 

and woodlands is characterized by high regional plant diversity, including relictual species, and 

an area of active expansion and contraction of species’ geographic distributions (Slaton 2015). 

Changes in climate, and fire and grazing regimes in the late 19th and 20th centuries have been 

particularly important factors influencing the composition, structure and distribution of the 

different vegetation types within the plan area (Slaton and Stone 2015a, Slaton and Stone 2015b). 

These changes include an expansion of trees into open shrublands, and changes in vegetation 

successional patterns associated with modern livestock grazing and fire exclusion, although these 

patterns depend on several additional factors (such as vegetation type or climate). Invasive plants 

like cheatgrass and red brome have also significantly expanded their range in many arid 

shrublands and woodlands in recent years on the eastside of the plan area, especially in areas 

recently impacted by wildfires or inappropriate livestock grazing that can facilitate cheatgrass 

dispersal (Slaton and Stone 2015a and 2015b). In some cases this has led to type conversion from 

native shrub or woodland vegetation to nonnative grasslands, which includes the loss of native 

perennial grasses, native forbs, and biological soil crusts which are important for ecosystem 

integrity (Chambers et al. 2014). This rate of invasion is expected to continue or increase in the 

future, although projected changes in climate will alter the geographic distribution of these 

invasions in the later 21st century (Bradley 2009, Finch 2012).

Sagebrush

This vegetation type occurs in the Great Basin portions of the plan area, mostly the Inyo National 

Forest but also small portions of the eastern Sequoia National Forest. The distribution of different

sagebrush species are strongly correlated to temperature and precipitation regimes. Dominant 

species include all subspecies of big sagebrush, low sagebrush, bitterbrush, and black sagebrush 

(Slaton and Stone 2015b). Big sagebrush and black sagebrush are generally restricted to moist

and frigid soils, with low sagebrush occurring on some cryic (cold) soils.

The condition of sagebrush areas depends upon the location and environment. The current 

composition and structure of sagebrush on some more productive substrates are different from the 

desired conditions for this vegetation type. The composition and structure on less productive, 

harsher (colder, drier, shallow and rocky) soils is mostly similar to desired conditions.

The extent of sagebrush has decreased substantially. On the Inyo National Forest, an estimated 

25,000 acres of sagebrush has had encroachment of several trees per acre or more (Slaton 2013). 

These areas were historically dominated by sagebrush but pinyon-juniper, and in some cases 

Jeffrey pine, have encroached into these shrublands due to a combination of fire suppression, 

livestock grazing, and climate change (Slaton and Stone 2015a). Projected changes in climate 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

179

suggest that the geographic distribution of sagebrush will largely shift northward and to higher 

elevations due to increased summer moisture stress (Finch 2012). Resilience to invasion by 

pinyon and juniper or Jeffrey pine is low to moderate.

Overall, resilience of sagebrush is low to moderate depending upon the type of sagebrush, amount 

of nonnative annual grasses and proximity to risk factors for fire and nonnative grass invasion. 

Nonnative invasive plant species are increasing in number and extent in sagebrush, especially at 

lower elevations, in recently burned areas, and sites of inappropriate livestock grazing. Most 

notably the invasive annual grasses of cheatgrass and red brome have increased in the plan area. 

The map in figure 28 depicts the pattern of invasion of cheatgrass and red brome on the Inyo 

National Forest. 

Information is combined from the Forest Inventory and Analysis plots and Terrestrial Ecological 

Unit Inventory plots and vegetation maps. This map does not represent a complete distribution of 

these invasive grasses but shows the extent of their invasion. Where these invasive grasses have 

been detected at survey plots, they are shown as red and orange dots and plots with no detections 

are shown as purple dots. Higher elevation sagebrush areas, with colder soils and moderate to 

high native perennial grass cover are more resilient. These areas are more likely to resist type 

conversion to annual grasses, including after fire (Chambers et al. 2007).

In the eastside vegetation types, there are large sagebrush and pinyon-juniper areas that have 

decreased fire resilience because of nonnative annual grasses (such as cheatgrass and red brome) 

that make them susceptible to more frequent fires that disrupt native vegetation composition and 

structure (Chambers et al. 2014). For example, post-fire vegetation recovery in sagebrush 

ecosystems invaded by cheatgrass can result in the conversion of sagebrush vegetation to 

nonnative annual grassland, especially in the presence of other stressors, such as inappropriate 

livestock grazing, climate change and overgrazing by wild horses (Chambers et al. 2007, 

Chambers et al. 2014). 

Pinyon-juniper

Pinyon-juniper is extensive in the plan area, mostly on the Inyo National Forest. This vegetation 

type dominates mid-elevations on the eastside plan area, especially on the east slope of the Sierra 

Nevada, Great Basin, Mojave Desert, and portions of the Kern Plateau. Pinyon-juniper is 

dominated by single leaf pinyon and Utah juniper, although many stands in the plan area are 

dominated exclusively by single leaf pinyon (Slaton and Stone 2013a). Pinyon-juniper types may 

also be mixed with or located in close proximity to sagebrush, mountain mahogany, and xeric 

shrublands. 

The condition of structure in pinyon-juniper compared to desired conditions varies with location 

and environment. Where pinyon-juniper grows on harsher sites (steep rocky slopes and ridges or 

sites with shallow and rocky soils), structure is generally similar to desired conditions (Slaton and 

Stone 2015a). On more productive sites, structure of pinyon-juniper is moderately dissimilar to 

desired conditions. Tree density is higher.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

180

Figure 28. Occurrences of cheatgrass in vegetation plots, Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

181

Resilience also varies with location and environment. On the harsher sites, the vegetation is 

generally resilient because the structure has remained more open and there is low understory 

vegetation cover. On the more productive sites, resilience is low to moderate. Higher tree density, 

accumulated fuels around the base of the trees, and higher and more decadent shrub, grass, and 

herb cover result in higher intensity fire and less resilience to drought, insects, and pathogens. 

There have been elevated levels of tree mortality in pinyon-juniper (see “Insects and Pathogen”

section). Pinyon-juniper ecosystems invaded by cheatgrass have reduced ecological integrity and 

are prone to type conversion to nonnative grasslands, particularly in areas of inappropriate 

livestock grazing, uncharacteristic wildfires (fires burning too frequently), and other stressors 

(such as high vulnerability to climate change) (Miller, Chambers, and Pellant 2014; Miller et al. 

2014).

Mountain Mahogany

Mountain mahogany occurs in the eastside shrublands and woodlands but can also occur at higher 

elevations in the Sierra Nevada montane zone or subalpine and alpine zone (Slaton 2013). This 

vegetation type generally occurs on steep, rocky, and variable terrain and is frequently mixed with 

other types, such as Jeffrey pine forest, pinyon-juniper, and sagebrush. The current composition, 

structure, and resilience of mountain mahogany vegetation is broadly similar to the desired 

conditions and natural range of variation in the plan area. However, mineral development, roads, 

and dispersed recreation may be negatively impacting this vegetation type at localized scales. 

Here there have been changes to composition, structure and spatial pattern. In these localized 

areas, there has been a decrease in native plants and an increase in nonnative annual grasses. The 

primary change has been increased fragmentation in small areas.

Xeric Shrub-Blackbrush

Xeric shrub and blackbrush occupies the lowest elevations of the plan area. This type is 

dominated by one or more desert shrub species, including but not limited to blackbrush, saltbush, 

goldenbush, and horsebrush.

The current composition, structure, and function of most xeric shrub and blackbrush ecosystems 

are consistent with the desired conditions for this vegetation type. However, portions of these arid 

shrublands have been negatively impacted by too-frequent fire (post-fire recovery of blackbrush 

is typically more than 50 to 75 years; (Brooks and Minnich 2006), mining, off-highway vehicle

activity, livestock grazing, and invasive plants. In particular, nonnative annual grasses, red brome 

and cheatgrass, are increasing in frequency in many xeric shrub and blackbrush communities. 

There is a corresponding decrease in native plants, away from the desired conditions. The 

increase in nonnative annual grasses decreases resilience to fire dramatically. Nonnative grasses 

increase the likelihood of fire, which is naturally rare in these sparsely vegetated areas. Projected 

changes in climate suggest that some xeric shrub ecosystems will expand in the plan area in the 

coming decades, and Mojave Desert associated species (such as creosote bush and Joshua tree) 

will shift northward into the lower elevations of the Great Basin (Finch 2012).

Environmental Consequences to Vegetation Composition, Structure, and Resilience

This analysis focuses on vegetation types most departed from the natural range of variation and 

vegetation desired conditions as described in the revised forest plan. These vegetation types are

also the focus of restoration actions (mechanical and prescribed fire treatments and managing 

wildfire to meet resource objectives) and where the greatest potential consequences will occur. 

This includes mixed conifer, eastside Jeffrey pine, pinyon-juniper, and sagebrush vegetation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

182

types. There will be some increased emphasis on restoration actions in red fir and lodgepole pine 

forests in some alternatives and on the eastside around developed areas. There will be some 

management of chaparral near developed areas. For other vegetation types, there will likely be 

little management activity and as a result, little to no expected consequences. This includes 

subalpine, alpine, desert (xeric shrub/blackbrush) and mountain mahogany vegetation types.

Consequences Common to all Alternatives

Alternatives B, C, and D share most of the same vegetation desired condition plan components 

(table 26). The differences are in some of the overlapping desired conditions for some wideranging wildlife species. Below is a discussion of the general nature and environmental 

consequences of the large number of shared vegetation desired conditions.

Table 26. Revised forest plan desired conditions for vegetation across all vegetation types

Vegetation Function Desired Conditions1

Mosaic providing ecosystem integrity and diversity. Provides habitat for 

native and desirable nonnative plant and animal species.

TERR-FW-DC-01, 06; 

SPEC-FW-DC-01

Resilience to climate change, drought, insects and pathogens TERR-FW-DC-02, 03. 04

Conditions contribute to recovery and persistence of threatened and 

endangered species and species of conservation concern

TERR-FW-DC-05; 

SPEC-FW-DC-02, 03

Provides landscape connectivity for wide-ranging habitat generalist (deer) 

and habitat specialist (old forest and sagebrush) species

TERR-FW-DC-06;

TERR-OLD-DC-02

SPEC-SG-DC-04;

Carbon carrying capacity is stable or improving TERR-FW-DC-07

Fire occurs within ecologically appropriate regime and enhances 

ecosystem heterogeneity, habitat and species diversity. Vegetation 

conditions help reduce the threat of undesirable wildfires to local 

communities, ecosystems and scenic character.

TERR-FW-DC-08,09

Landscape sustainability provides a variety of benefits to people TERR-FW-DC-10

Vegetation supports continued use by tribes TERR-FW-DC-11

1. Specific desired conditions are referenced in the Land Management Plan for the Inyo National Forest

The vegetation desired conditions for these alternatives are specific to each major vegetation type 

and include desired ranges and often median levels of seral stages and canopy cover, basal area, 

snags, and large tree densities (table 27). 

Table 27. Revised forest plan desired conditions by ecological zone and major vegetation types

Ecological Zone Vegetation Types Desired Conditions

Sierra Nevada Montane Dry Mixed Conifer, Jeffrey Pine, Red 

Fir, Lodgepole Pine (wet and dry 

types)

TERR-MONT-DC 01-03; 

TERR-DMC-DC 01-06;

TERR-RFIR-DC 01-07;

TERR-JEFF-DC 01-07;

TERR-LDGP-DC 01-10; 

Subalpine and Alpine Subalpine conifer, Alpine vegetation TERR-ALPN-DC 01-05

Eastside Shrublands and 

Woodlands

Sagebrush, Pinyon Juniper, Mountain 

Mahogany, Xeric Shrub/Blackbrush

TERR-SAGE-DC 01-05;

TERR-PINY-DC 01-05;

SPEC-SG-DC-02, 05, 08;

TERR-XER-DC-01-04
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

183

These are based on a combination of best available scientific information that reflects the natural 

range of variation (Safford et al. 2013c, Meyer et al. 2014b, Slaton and Stone 2015b) and habitat 

requirements for wide-ranging federally listed species or species of conservation concern (greater 

sage-grouse; see Vegetation Desired Condition supplementary report). There are more general 

desired conditions that are important, but there is no specific best scientific information to base 

them on. This includes forest heterogeneity (North, Stine, O'Hara et al. 2009; North 2012b).

For purposes of this analysis, it is assumed that when vegetation treatments move vegetation 

toward the vegetation desired conditions, the vegetation moves toward the natural range of 

variation and has associated benefits of moving toward ecological integrity and sustainability. The 

landscape amount and intensity of the treatments affect how much the vegetation moves toward 

desired conditions. Low-intensity treatments, where little area is treated or slight changes are 

made, would have a slight improvement in vegetation conditions (Schmidt, Hille, and Stephens 

2006; Stephens et al. 2015). When more area is treated, particularly at the landscape scale, there 

is a greater positive impact on ecological integrity and sustainability. For example, in the “Fire 

Trends” section, the effect of restoring between 40 and 60 percent of the landscape was sufficient 

to result in reduced trends in large fires and associated large, high-severity patches that are 

considered outside the natural range of variation (van Wagtendonk and Fites-Kaufman 2006, 

Collins and Skinner 2014a, Stephens et al. 2015).

The same treatment means are available across each of the alternatives but will be used to varying 

degrees. Treatments would include mechanical thinning (various prescriptions, understory, varied 

diameter), salvage, mastication, prescribed fire (small and landscape, by itself or with mechanical 

treatment) and wildfire managed for resource objectives. The environmental consequences 

depend upon the extent and intensity of the treatment, and the vegetation type it is applied in. 

Below is a brief description of the array of restoration treatments that will be used and a summary 

of the overall consequences for the major vegetation types they will be applied to. This includes 

the more recent and relevant best available scientific information. A more detailed discussion of 

the best available science is found in the Vegetation Ecology supplemental report.

Sierra Nevada Montane Zone

Mechanical Treatments: Mechanical restoration treatments in the montane zone can be highly 

effective at restoring forest structural features (canopy cover, tree density, heterogeneity) and 

overstory tree species composition in montane forests (Larson, Stover, and Keyes 2012; North 

2012b and 2014; North, Innes, and Zald 2007; North, Stine, O'Hara, et al. 2009). However, the 

type and intensity of treatment can result in varying levels of change in forest structure.

Additionally, mechanical treatments may be effective at achieving some restoration objectives 

(such as restoration of tree species composition), but these treatments are often less effective than 

fire treatments (prescribed fire or wildfires managed for resource objectives) for the restoration of 

structural heterogeneity and key ecological processes (such as nutrient cycling, plant-pollinator 

interactions, or soil respiration). 

In long-term monitoring plots on Forest Service study sites in California, both overstory and polesized tree densities were effectively reduced following mechanical treatment but fuel levels 

increased 8 years following treatment due to vegetation re-growth and dead fuel accumulation 

(Vaillant et al. 2015). Similarly, research fuel treatment plots also resulted in decreases in tree 

density (Stephens and Moghaddas 2005). There are two types of thinning that would occur in 

alternatives B, C, and D. One is thinning from below where smaller diameter trees are removed. 

The second is variable diameter thinning where smaller diameter understory trees and some larger 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

184

diameter midstory or overstory trees are removed. There is no specific research to compare the 

effects of these two approaches on moving vegetation toward the desired conditions. However, in 

many stands that have densities exceeding the desired conditions, thinning from below will 

remove fewer trees and have a limited effect of moving stands toward desired conditions for 

canopy cover, basal area, or heterogeneity. 

Prescribed Fire and Wildfire Managed for Resource Objectives: Prescribed fire can restore 

understory species composition (Wayman and North 2007, Webster and Halpern 2010), and 

reduce tree density (Stephens and Moghaddas 2005, Vaillant et al. 2015). The amount of 

reduction in overstory tree density depends on the intensity and size of the fire. Low-intensity 

fires have little to no effect on overstory tree density and composition, but moderate-intensity fire 

has been found to reduce forest density by up to 70 percent and basal area by 20 percent 

(Schmidt, Hille, and Stephens 2006). There is little research on the effects of prescribed fire on 

heterogeneity, but the prevailing view is that prescribed fire can increase heterogeneity if it is 

incorporated into the burn prescription (Collins and Skinner 2014a), especially if it is moderate 

intensity (Schmidt, Hille, and Stephens 2006). Larger landscape prescribed fire or wildfire

managed for resource objectives are likely to restore heterogeneity at multiple spatial scales 

(Collins, Everett, and Stephens 2011, Kane et al. 2013, Kane et al. 2014, Meyer 2015a). This may 

be due in part to more varying fire intensity with larger burn areas, across a wider range of 

conditions (burning day and night, on different days). Wilderness areas are especially conducive 

towards the management of wildfires for resource objectives, which supports ecological benefits 

in wilderness areas of the southern Sierra Nevada (Meyer 2015a) and elsewhere in the western 

United States (Miller and Aplet 2016). Additionally, wilderness areas with restored natural fire 

regimes can provide important reference sites that inform wildland fire science and the natural 

range of variation in montane forest ecosystems (Miller and Aplet 2016).

Mechanical and Prescribed Fire Treatments: Many studies show that the combination of 

mechanical thinning and prescribed or wildfire managed to meet resource objectives are the most 

effective in reducing vegetation density, restoring understory and overstory composition, and 

increasing heterogeneity (North, Innes, and Zald 2007, Collins, Moghaddas, and Stephens 2007, 

Collins and Skinner 2014a). This is especially the case for understory composition. Many plants 

in the analysis area in areas that had frequent fire historically, are fire adapted (Fites-Kaufman, 

Bradley, and Merrill 2006, van Wagtendonk and Fites-Kaufman 2006).

The longevity of restoration treatments depends largely on the growth rates of the plants that have 

been affected by the treatments. For understory trees and shrubs, reduced density only lasts 8 to 

15 years because they grow back rapidly (Stephens, Collins, and Roller 2012, Chiono et al. 2012), 

and (Vaillant et al. 2015). On the other hand, fire-induced reductions in tree density took up to 8 

years to be realized in one prescribed fire study (Van Mantgem et al. 2011).

The best information pertaining to the effectiveness of mechanical treatments at restoring

structural heterogeneity in Sierra Nevada mixed conifer stands comes from research conducted at 

the Teakettle Experimental Forest and Stanislaus-Tuolumne Experimental Forest. Understory and 

variable-density thinning in mixed conifer stands at these experimental forests resulted in reduced 

stem density and a residual spatial tree pattern that was closest to historic conditions (that is, 

reduced tree clustering at smaller spatial scales); although surface fuel loading was not reduced 

relative to stands not thinned (North, Innes, and Zald 2007, Knapp et al. 2017). Consequently, 

understory thinning (and especially variable density thinning) increased structural heterogeneity 

at smaller spatial scales. At the Teakettle and Stanislaus-Tuolumne Experimental Forests, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

185

prescribed burning decreased mixed conifer stand densities, reduced surface fuel loading, and 

increased stand heterogeneity but had marginal effect on canopy cover. In contrast, mixed conifer 

stands treated with a combination of mechanical thinning followed by prescribed burning had 

substantially lower densities and canopy cover (closer to the historic conditions or the natural 

range of variation), reduced fuel loading, and greater stand heterogeneity than untreated stands or 

those treated with prescribed burning or mechanical thinning alone (North, Innes, and Zald 2007, 

Knapp et al. 2017). Consequently, post-treatment stand structure in the combined understory-thin 

and burn treatment was closer to the historic conditions and resulted in generally greater stand 

structural heterogeneity than found in stands treated with a single restoration treatment 

(mechanical thinning or prescribed burning alone). The combination of mechanical and 

prescribed fire treatments were most effective at restoring stand structure, but only in cases where 

the mechanical treatments retained the largest-diameter trees in the stand (North, Innes, and Zald 

2007, North, Stine, O'Hara, et al. 2009) and where thinning prescriptions emphasized variable 

density thinning to enhance structural heterogeneity (Knapp et al. 2017).

In red fir forests, low severity fire is especially conducive to increasing forest structural 

heterogeneity at multiple spatial scales (Kane et al. 2013). In addition, surface fuel loading tended 

to be two times higher in unburned than twice-burned red fir stands of Yosemite National Park, 

with high variation in fuel loading among burned and unburned sites. Both prescribed fire and 

wildlife managed for resource objectives (especially low to moderate severity fire) are highly 

effective at restoring stand structure (e.g., tree densities, basal area, canopy cover, heterogeneity) 

and understory diversity in red fir forests (Meyer et al. 2010).

Eastside Shrublands and Woodlands

Mechanical and Prescribed Fire Treatments: There are two general purposes for treatments 

that will occur in eastside shrublands and woodlands, especially sagebrush and pinyon-juniper 

woodlands. First, treatments can focus on reducing fire hazard around communities and 

infrastructure using treatments such as mechanical mowing or crushing. Second, treatments may 

focus on sagebrush restoration by reducing the density of encroaching conifers in sagebrush 

habitat (i.e., mechanical thinning), which often includes the treatment of slash (can vary from 

removal, to piling or scattering). Restoration treatments in sagebrush may also focus on 

enhancing structural heterogeneity, age and size diversity, and understory diversity in sagebrush 

areas by reducing the density of large and dense shrub patches.

Woody vegetation reduction by any means, either prescribed fire or burning can result in higher 

herbaceous cover (McIver et al. 2014). Where slash is removed there can be benefits to plant 

species richness and diversity (Brockway et al. 2002). Prescribed fire can be effective at 

removing woody vegetation but may result in a greater risk of invasion by nonnative annual 

plants (Chambers et al. 2014, Miller et al. 2014) (Pyke et al. 2014). Mechanical treatments can 

more directly target individual trees that are desired to be removed but also can lead to increased 

nonnative plant invasion, especially in areas of inappropriate livestock grazing or Off-Highway 

Vehicle (OHV) use (Chambers et al. 2014, Miller et al. 2014, Pyke et al. 2014). However, the use 

of targeted nonnative plant treatments (e.g., control or eradication of invasive annual grasses such 

as cheatgrass) or seeding with native perennial bunchgrasses and forbs in combination with 

mechanical thinning and prescribed fire treatments may reduce the long-term abundance or 

occurrence of some nonnative plants, especially in cooler and moister sites (Chambers et al. 2014;

Miller, Chambers, and Pellant 2014; Pyke et al. 2014). 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

186

Treatment of shrub vegetation with mowing and prescribed fire have varying effects on the 

understory but different effects on the shrub layer. Some researchers found increases in native 

herbaceous and perennial grass species with prescribed fire or mowing (Bourne and Bunting 

2011, Chambers et al. 2014, Miller et al. 2014, McIver et al. 2014), whereas others found 

decreases (Pyke et al. 2014). Shrub cover responses varied with decreases reported after 

prescribed fire (Roundy et al. 2014) or mowing (Bourne and Bunting 2011). In some cases, shrub 

cover decreased for the first year (Bourne and Bunting 2011) but then cover and seedling density 

rebounded or increased by year three (Miller et al. 2014) summarized the shrub changes in terms 

of greater sage-grouse habitat and reported an increase of three times in shrub cover for 

prescribed fire and two times pre-treatment levels for mechanical treatments.

Mechanical treatments in eastside pinyon-juniper and sagebrush ecosystems may include the 

cutting and falling of encroaching conifers, followed by the piling or scattering of slash or 

removal of slash offsite. Mastication treatments can be applied to mow and mulch shrubs and 

small trees. Slash may be chipped to alter and redistribute surface fuels. Conifer removal and 

mastication treatments are generally effective at restoring ecosystem structure and are considered 

low to moderate intensity methods with less impact on biological soil crusts and invasive species 

spread than high-intensity mechanical methods (such as chaining, bulldozing, or plowing; 

Chambers et al. 2014, Miller et al. 2014). Mechanical treatments of encroached conifers in 

sagebrush ecosystems generally result in increased native herbaceous plant cover and diversity 

(including native forbs and perennial grasses), increased native shrub abundance, reduced canopy 

and ladder fuel loading, and increased fine surface fuel loading (Roundy et al. 2014). Mechanical 

treatments are most effective in promoting native herbaceous plant and sagebrush cover and 

inhibiting cheatgrass cover with the application of post-treatment management approaches, such 

as delayed grazing coupled with post-treatment monitoring (Chambers et al. 2014, Miller et al. 

2014). Cheatgrass abundance may actually increase following mechanical treatments in the 

absence of these post-treatment measures (Chambers et al. 2007; Miller, Chambers, and Pellant 

2014).

Prescribed fire is often applied in pinyon-juniper and sagebrush ecosystems to restore ecosystem 

structure and composition (Chambers et al. 2014; Miller et al. 2014; Miller, Chambers, and 

Pellant 2014). Applied alone or in combination with mechanical treatments, prescribed fire can be 

effective at reducing the densities of encroaching conifers, increasing sagebrush seedling density, 

increasing native forb and grass cover, reducing ladder and surface fuel loading, and decreasing 

overall biomass (Miller et al. 2012, Rau et al. 2010). Prescribed fire is particularly effective at 

restoring ecosystem composition and mitigating cheatgrass invisibility within sagebrush 

ecosystems with relatively high ecological integrity (in the early to mid-phase of pinyon or 

juniper expansion (Chambers et al. 2014). In contrast, the application of prescribed fire can 

exacerbate cheatgrass invisibility in sagebrush ecosystems lacking sufficient pre-fire cover or 

seed banks of residual native grasses and forbs (as in the late-phase of pinyon or juniper invasion; 

(Jones et al. 2015, Miller, Chambers, and Pellant 2014). Additionally, prescribed fire (especially 

at higher burn intensities) can reduce the abundance of biological soil crusts (Miller, Chambers, 

and Pellant 2014), which reduces the resistance of sagebrush ecosystems to cheatgrass invasion 

(Chambers et al. 2007). However, proper pre-fire fuel mitigation such as mechanical treatments 

and post-fire management (like grazing management) may help reduce some of the impacts of 

prescribed fire to biological soil crusts (Miller et al. 2014).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

187

Invasive Plant Treatments All Areas

Alternatives B, B-modified, C, and D include similar measures to mitigate the invasion and 

spread of nonnative species such as risk assessment and rapid identification and control where 

possible.

Ecological Fire Resilience

Ecological fire resilience is most important at the landscape scale. Individual small patches of 

high fire severity are within the natural range of variation (van Wagtendonk and Fites-Kaufman 

2006). The consequences of large areas of high severity and proportions exceeding the natural 

range of variation are important. To analyze these consequences, ecological fire resilience was 

analyzed using “benchmark” or generalized landscape restoration levels of 15, 30, 60 and 100 

percent of the landscape (see “Fire Trends” section, scenario modeling discussion). The specific 

locations of restoration treatments are not identified in the draft programmatic plans or 

alternatives. These results were used to make inferences on the consequences of the different 

levels and spatial patterns of restoration among the alternatives. See discussion in the “Fire 

Trends” section for more detail on the effects of landscape changes in vegetation and effects on 

fire and potential for large, high-intensity fires.

The changes in ecological fire resilience for the scenarios are shown in figure 29. For the primary 

forest types where restoration would occur (mixed conifer, red fir, and Jeffrey pine) high 

resilience is where less than 25 percent of the area would burn as crown fire. Low resilience is 

where more than 75 percent of these areas would burn as crown fire. While the scenarios were not 

developed specifically for the alternatives, alternative A would be most similar to the current 

condition or 15 percent restoration scenarios, alternatives B and alternative B-modified would be 

most similar to the 15 percent or 30 percent scenarios, alternative C would be similar to the 15 

percent scenario, and alternative D would be most similar to the 30 percent to 60 percent 

scenarios.

Comparison of Composition and Structure by Alternative

Table 28 through table 31 show how similar vegetation composition and structure would be to 

desired conditions by ecological zone and vegetation type for each alternative. Table 28 and table 

29 show the Sierra Nevada montane zone, table 30 shows eastside shrublands and woodlands, and 

table 31 shows the Kern River drainage. This area is intermediate between westside and eastside 

vegetation. A discussion of the consequences by alternative follows. For table 28 through table 

31, see Table 24 for a description of low, moderate, and high ratings.

Table 28. Similarity to vegetation composition and structure desired conditions for Sierra Nevada 

montane zone by alternative

Characteristic Alternative A

Alternatives B and 

B-modified Alternative C Alternative D

Composition Low (limited 

restoration)

Low-moderate ; 

moderate in areas of 

increased restoration and 

managed fire

Low (limited 

restoration); sight 

increase over A

Somewhat 

greater than B 

(more restoration)

Composition

(Invasive plants)

Moderate Moderate, slightly greater 

than A

Moderate Slightly less than 

B

Structure Low (limited 

restoration)

Low to moderate; 

Somewhat greater than 

A

Low (limited 

restoration); 

slight increase 

over A

Somewhat 

greater than B 

(more restoration) 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

188

Figure 29. Landscape ecological fire resilience by restoration scenarios

Note: Areas in dark red are very low resilience, orange are low resilience,

yellow is moderate resilience, and green is high resilience. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

189

Table 29. Similarity to vegetation composition and structure desired conditions for Sierra Nevada 

montane zone by alternative and location relative to the fire protection zones 

Characteristic

Inside fire protection 

zones, 

Inside fire 

protection zones 

Outside fire 

protection zones

Outside fire 

protection zones 

Composition Low-moderate (limited 

restoration, slightly 

greater than A)

Moderate Low to moderate Low, similar to A

Composition

(Invasive Plants)

Low (limited 

restoration, slightly 

greater than A)

Low to moderate Low to moderate Low, similar to A

Structure Low (limited 

restoration, slightly 

greater than A)

Moderate Low to moderate Low, similar to A

Table 30. Similarity to vegetation composition and structure desired conditions for eastside 

shrublands and woodlands zone by alternative 

Characteristic Alternative A

Alternative B

and Alternative 

B-modified Alternative C Alternative D

Composition Low (limited 

restoration)

Low to moderate 

(restoration areas)

Same as B (same 

as D in sagebrush)

More than B (more 

restoration)

Composition

(Invasive plants)

Low to moderate 

(low in low 

elevations) 

Slight increase 

from A

(restoration areas)

Slight increase in 

similarity to desired 

conditions from A 

(restoration areas)

Less similarity to 

desired condition 

as compared to B 

(and similar to A)

Structure Low (limited 

restoration)

Low to moderate 

(restoration areas)

Moderate

(more similar to 

desired conditions 

because more 

treatments in 

sagebrush)

More than B (more 

restoration)

Table 31. Similarity to vegetation composition and structure desired conditions for the Kern River 

Drainage by alternative

Characteristic Alternative A

Alternative B

and Alternative 

B-modified Alternative C Alternative D

Composition Low (limited 

restoration)

Low to moderate 

(restoration areas)

Same as B More than B (more 

restoration)

Composition

(Invasive plants)

Low to moderate 

(low in low 

elevations) 

Slight increase 

from A

(restoration areas)

Slight increase in 

similarity to desired 

conditions from A 

(restoration areas)

Less similarity to 

desired conditions 

as compared to B 

(and similar to A)

Structure Low (limited 

restoration)

Low-moderate 

(restoration areas)

Less than B More than B (more 

restoration)

Consequences Specific to Alternative A

Although the current plan aspires to treat 20 to 30 percent of the forest to reduce fuels, this has 

not been achieved. It is estimated that 5 to 10 percent of the Sierra Nevada montane zone and 

eastside sagebrush and pinyon-juniper areas have been treated since 2001. Most of the treatment

would occur in the sagebrush, pinyon-juniper and wildland-urban intermix area on the east side.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

190

Sierra Nevada Montane Zone

Overall treatment rates are limited in alternative A. Generally, less than 5 to 10 percent of the 

landscape has been restored over the last 10 years. The treatments in these forest types are usually 

low intensity due to restrictions on the amount of canopy cover that can be reduced and, more 

importantly, the lack of mill infrastructure within a reasonable distance to the Inyo National 

Forest. As a result, composition, structure, and resilience would remain dissimilar to vegetation 

desired conditions.

Composition. There would continue to be a high proportion of shade-tolerant and fire-intolerant 

trees in the overstory and understory. Within dry mixed conifer and some Jeffrey pine stands, 

there would be limited opportunities to restore dominance or codominance of Jeffrey pine due 

primarily to the proximity to mills but, even if the infrastructure existed within a reasonable 

distance, diameter limits would restrict removal of competing shade-tolerant species that have 

grown quickly during a century of fire suppression. For the same reasons, there would be little 

opportunity to create sunny openings of sufficient size for Jeffrey pine regeneration. Treatments 

or managed fire would retain desired overstory composition for red fir and lodgepole pine stands. 

However, limited amounts of prescribed fire would result in little restoration of understory plants 

that are adapted to fire.

Structure. There could be restoration to increase heterogeneity, but restrictions on changing 

canopy cover and proximity to mills limit how much change would occur. While treatments 

primarily reduce understory trees, there would continue to be a high dissimilarity to vegetation 

desired conditions in most of the landscape.

Resilience to Fire, Drought, Air Pollutants, Climate Change, Insects, and Pathogens. The 

low proportion of the landscape that would be restored and the low intensity of treatments make it 

highly likely most of the area would continue to have a low resilience to drought, climate change, 

insects, pathogens, and large, high-intensity fire.

Montane Forests (Kern River Drainage)

There would continue to be limited mechanical treatment and prescribed fire restoration in 

montane forests of the Kern River Drainage in alternative A. There would be some wildfire 

managed to meet resource objectives, especially in the Kern River drainage and some wilderness 

areas. These managed fires would generally move montane forests toward vegetation desired 

conditions. Composition, structure and resilience of montane chaparral and Jeffrey pine forests 

would benefit from fire.

Composition. Restoration treatments would move understory tree composition toward desired 

conditions in Jeffrey pine forests. Shade- and fire-intolerant white fir would be removed up to the 

diameter limit. Mechanical treatments and fire would have a similar beneficial effect. There 

would be little change in composition of red fir forests and lodgepole pine forests because they 

tend to be the dominant species, with or without restoration. Understory composition would 

continue to improve with restoration, especially where it includes fire (Wayman and North 2007). 

Where wildfire is managed to meet resource objectives, it would improve montane chaparral 

composition. Many of these species in montane chaparral are adapted to fire.

Structure. Restoration treatments would move some areas slightly toward desired conditions and 

others substantially. There would be limited ability to reduce forest density and most importantly 

in the montane forests, increase heterogeneity. Where large areas have wildfire managed to meet 

resource objectives there would be increased heterogeneity and a decreased vegetation density. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

191

Chaparral would have more of a mosaic of age structure. Jeffrey pine and red fir forests would

have increased heterogeneity, reduced and patchier surface fuels and increased resilience.

Resilience to Fire, Drought, Air Pollutants, Climate Change, Insects, and Pathogens.

Restoration treatments would continue to be at a very low level, except for more remote areas 

(like the Kern River drainage and wilderness areas) that have had and will likely continue to have

wildfire managed to meet resource objectives. The more remote areas have a moderate level of 

resilience and the Kern River drainage would likely increase to a high level of resilience over the 

period of the plan. The other areas would likely remain at a low level of resilience.

Subalpine and Alpine Zone

There is little direct management vegetation in the subalpine and alpine zone in alternative A. 

Most of this vegetation is in wilderness areas, where natural processes are the dominant 

management approach. Exceptions are in limited locations where recreation use is concentrated.

Composition. Alternative A would continue to minimize the spread of invasive plants in 

subalpine and alpine environments where restoration treatment activities are supported (like ski 

areas).

Structure and Resilience. Subalpine and alpine vegetation are among the most vulnerable to 

climate change (Meyer et al. 2014b, Sydoriak et al. 2013b). Management in the remote areas, 

mostly wilderness where these vegetation types occur, would continue to be very limited. With 

changing climate, in the absence of restoration, mortality of some subalpine trees (like whitebark 

pine) would continue to increase.

Eastside Shrublands and Woodlands (excluding Sagebrush)

Treatments in pinyon-juniper and arid shrublands are limited in alternative A. Most of it would 

continue to occur in the wildland-urban intermix defense and threat zones.

Composition. There would be limited opportunities to reduce or eradicate nonnative invasive 

plants. These areas would continue to remain dissimilar to desired conditions for understory 

species composition. Targeted treatments to reduce or eradicate nonnative invasive plants would 

continue to occur. However, there would likely continue to be an increase in the area occupied by 

nonnative invasive plants.

Structure. Limited restoration would leave many areas with higher pinyon and juniper density 

where they exceed desired conditions. This is only a portion of the pinyon and juniper vegetation. 

Areas on very harsh sites would remain similar to desired conditions.

Resilience to Fire, Drought, Air Pollutants, Climate Change, Insects, and Pathogens. There 

would continue to be large areas that are dissimilar to desired conditions and have high levels of 

insect-related mortality. Current trends of elevated insect and drought-related mortality are likely 

to increase. There would continue to be areas with low resilience to drought, climate change, 

insects and pathogens, and large, high-intensity fire.

Eastside Shrublands and Woodlands: Sagebrush

Restoration of sagebrush habitats would continue to implement the “Sage-Grouse Interim 

Management Policy” for greater sage-grouse; however, there is the least amount of restoration in 

sagebrush vegetation in alternative A. Restoration of composition and structure would be limited 

to small areas and a very small proportion of the extent that this vegetation type occurs.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

192

Composition. There would be limited areas that will move vegetation toward desired conditions. 

There would be fewer opportunities to remove conifers encroaching in sagebrush vegetation. 

Alternative A would continue to minimize the spread of invasive plants in arid shrublands and 

woodlands because there would be fewer restoration treatments.

Structure. There would continue to be many areas that are dissimilar to desired conditions for a 

mosaic of ages of sagebrush. There would continue to be large areas where many of the shrubs 

are older and decadent (lack new growth).

Resilience to Fire, Drought, Air Pollutants, Climate Change, Insects, and Pathogens. There 

would continue to be a low resilience to large, high-intensity fire and climate change. Low

structural diversity and limited reduction of invasive plants would make it likely that resilience 

will decline further. There would continue to be a high dissimilarity to desired conditions.

Cumulative Effects of Alternative A

There would continue to be effects of warming and drier climate into the foreseeable future. The 

effects of climate change would be more prominent than the restoration benefits because of the 

low amount, small scale, and limited intensity of restoration in alternative A (see “Climate” 

section). There would continue to be restoration on adjacent Federal, State and local agency lands 

(such as Los Angeles Department of Water and Power) that are similar to those on National 

Forest System lands. Restoration on these other lands would also be limited. There would 

continue to be urbanized development adjacent to national forest lands and increased recreational 

visitor use. There would likely be related increases in human-ignited fires and spread of invasive 

plants as a result of the combination of increased human presence and climate change. The size 

and area of large, high-intensity fires would continue to increase (see “Fire Trends” section). 

Overall, vegetation composition, structure, and resilience would become more dissimilar to 

desired conditions.

Consequences Specific to Alternative B

In these alternatives, plan direction for vegetation management would change desired conditions, 

objectives, standards and guides, management approaches, and goals that would affect vegetation 

composition, structure and resilience. The degree of change varies by vegetation type and 

location. The most overarching changes are described here and the remainder in specific 

vegetation types and locations as relevant.

All Areas

Throughout all of the analysis area, there are two fire-related management areas that have 

different vegetation-related plan direction and each would have different impacts. They are the 

strategic fire management zones and the community buffers.

Community buffers are linear areas surrounding communities and, on the Inyo National Forest, 

they surround developed recreation sites at high fire risk. The widths are based on expected fire 

behavior. The desired conditions for vegetation may be different in the community protection 

zone, with lower canopy cover, snag densities, log densities, and surface fuels (MA-CWPZ-GDL01). Otherwise, management direction for fire-oriented treatments is consistent with desired 

conditions for terrestrial vegetation (MA-CWPZ-GDL-02).

There are several differences in plan components in the two wildfire protection zones compared 

to the other strategic fire management zones that would affect the mix and intensity of vegetation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

193

treatments and thus vegetation consequences. The direction on large-diameter trees differs as 

shown in table 32.

Table 32. Application of large tree plan components across strategic fire management zones, 

alternatives B and B-modified

Plan Direction

Inside Wildfire 

Protection Zones

Outside Wildfire 

Protection Zones

TERR-FW-STD-01 

(30-inch diameter limit)

Does not apply Applies, same as 

alternative A

TERR-OLD-DC-04

(desired densities of large trees by forest type) 

Applies Applies

Although there are desired conditions for old forest, in the two wildfire protection zones there are 

no diameter limits on large trees that can be removed mechanically. This may result in more 

intensive thinning in some areas, but how much is unknown. Outside of the two wildfire 

protection zones, the standard restricting removal of 30-inch diameter trees is retained (TERRFW-STD-01). This may have consequences for old forests and is discussed in the following 

subsection on “Terrestrial Ecosystem Processes and Function.” There would also be more use of 

wildfire managed to meet resource objectives, primarily outside of the wildfire protection zones. 

This would result in more restoration of vegetation using this treatment. This would most likely 

occur in Sierra Nevada montane zone and subalpine vegetation type.

Treatments would primarily be variable density mechanical thinning and burning to restore 

heterogeneity, decrease overall forest density, decrease surface fuel continuity, and increase 

understory cover, density, and vigor, particularly of sun-loving plants. The approach would be as 

described in GTR 220 and 237 (North, Stine, O'Hara et al. 2009; North 2012b), emphasizing 

restoration of heterogeneity. There would be variable spacing in thinning and burning. Some areas 

would be thinned more and some areas less or not at all. Thinning could occur across a range of 

diameters, between small- to medium-diameter trees. Some small openings would be created 

while clumps of trees would be retained in some areas. There would be retention and creation of 

heterogeneity in the understory as well, as described in the desired conditions. Some patches of 

high surface fuel would occur, and other areas would have little to none.

Sierra Nevada Montane Zone

Alternative B would increase the amount of vegetation restoration in the Sierra Nevada montane 

zone. Although wildfires managed to meet resource objectives has occurred extensively in the 

Kern Drainage, the new plan direction that provides for managing wildfires to meet resource 

objectives would make this more likely to continue to occur or increase (MA-WRZ-GOAL-01, 

MA-WRZ-STD-01, MA-WMZ-DC-02, and MA-WMZ-STD-01 to 02).

The amount of prescribed fire and wildfire managed to meet resource objectives could increase in 

alternative B (TERR-FW-OBJ-02; TERR-FW-DC-08; TERR-MONT-DC-02), although there are 

some uncertainties about the amount of increase. The amount could double that in alternative A. 

Larger prescribed fires would be more feasible because the prioritized restoration along ridges 

and roads would provide “anchors” for burn operations (MA-CWPZ-GDL-02; MA-GWPZ-GDL01). Wildfires managed to meet resource objectives would still be very limited in most montane 

areas due to concerns that wildfires could become uncontrollable in the dense forests if they burn 

into these areas (except for in the Kern Drainage).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

194

In alternative B, there is a moderate level of uncertainty in how much prescribed fire could occur 

in montane areas. There is uncertainty that there would be sufficient time periods or “windows” 

to conduct prescribed burning because of recent drought, longer fire seasons, mitigations for 

wildlife, and air quality regulations. Alternative B emphasize designing larger landscape 

prescribed burns where feasible. The fire management strategy emphasizes restoration along 

ridges and roads to increase capacity to conduct large prescribed burns:

During ecological restoration treatments, reduce fuels along ridges, roads, or other natural 

or man-made features to aid in the use of large prescribed fires and in managing wildfire, 

including wildfires managed to meet resource objectives.

Restoring prescribed fire in mechanically treated areas is needed to best achieve some of the 

vegetation desired conditions because mechanical treatments cannot fully mimic the ecological 

function of fire (TERR-MONT-DC-02), including beneficial effects to fire-adapted plants (see 

next section on “Terrestrial Ecosystem Processes and Function”). Prescribed fire can reduce and 

maintain desired conditions by reducing understory vegetation density (like tree seedlings and

saplings), reducing and creating shrub decadence (dead branches), and reducing surface fuels and 

creating patchy distributions of fuels that would result in improved fire resilience. 

Composition. Restoration treatments would move vegetation toward desired conditions 

substantially in treated areas (TERR-MONT-DC-01; TERR-JEFF-DC-01; TERR-DMC-DC-01; 

TERR-LDGP-DC-01). Treatments would increase the dominance and codominance of Jeffrey 

pine, especially on dry sites within the two wildfire protection zones. Desired conditions and 

direction to increase open mature forest patches (TERR-MONT-DC-01; TERR-JEFF-DC-01, -03; 

TERR-DMC-DC-03, -05; TERR-RFIR-DC-03, 06; TERR-LDGP-DC-01, 03, 06), reduce tree 

density (cover and basal area), and increase heterogeneity (TERR-FW-GDL-01) would favor the 

shade-intolerant but drought-tolerant Jeffrey pine. The health and resilience of large pines would

be improved by reducing stand density around them, although clumps and groups of large and old 

trees would be retained. This would increase the likelihood that the current pine trees survive 

stresses from drought, air pollutants, and climate change (temperature increases). Restoration of 

heterogeneity through mechanical thinning, and especially prescribed fire would move the 

composition, condition, and diversity of native understory plants toward desired conditions. 

Shrubs, flowering plants, and grasses that are adapted to fire would have more vigorous and 

dense foliage, increased flowering and fruiting, and increased density in a patchy pattern (FitesKaufman, Bradley, and Merrill 2006; Wayman and North 2007; Webster and Halpern 2010).

Structure. In alternative B, tree density would be lower and heterogeneity higher in treated 

patches and across large areas of the landscape. Landscape forest structure would be most 

changed in the areas with large prescribed fires. This would move some of the landscape toward 

desired conditions, including heterogeneity at the landscape, patch, and within-patch scales. 

Ecological Resilience to Fire, Drought, Air Pollutants, Climate Change, Insects, and 

Pathogens. In the montane zone, alternative B would promote the resilience to fire, climate 

change, drought, air pollutants, insects, and pathogens in treated patches (TERR-FW-DC-02;

TERR-MONT-DC-01, -03). The elevated restoration treatment rates would build greater 

adaptive capacity in montane landscapes. Decreased tree density and increased heterogeneity at 

the landscape and site scales would improve resilience to the multiple stressors (North 2012a). 

Restoration of more vegetation species resilient to drought, climate and fire (especially Jeffrey

pine) would improve overall forest resilience. Increased fire resilience will be most effective Kern 

Drainage where managed fires have been prevalent (Meyer 2015a) because a sufficient 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

195

proportion of the landscape would be restored to result in changed fire intensity at the landscape 

scale (the scale of fires; see the “Fire Trends” section).

Subalpine and Alpine Zone

There would be slight increases in the amount of restoration in subalpine and alpine vegetation. 

This would be from increased opportunities for wildfire managed to meet resource objectives and 

potentially from restoration of whitebark pine to reduce damage from white pine blister rust

(TERR-ALPN-DC-03). In general, most subalpine and alpine vegetation occurs within wilderness 

areas where natural processes are the primary emphasis of maintenance and restoration. Little 

restoration would occur and where it does, it would primarily be limited to small areas in need of 

rehabilitation from concentrated recreation impacts (e.g., ski areas, campgrounds) or invasive 

species (DA-WILD-SUIT-01; DA-WILD-GDL-01).

Composition and Structure. Alternative B would improve composition in subalpine and alpine 

areas through targeted restoration in highly impacted areas (e.g., DA-WILD-GDL-01) and 

wildfire managed to meet resource objectives. There might be some limited restoration treatments 

involving control or eradication of nonnative invasive species (like cheatgrass) that would benefit 

native vegetation, but most of this would occur in foothill or montane areas where they are more 

impacted. Although fire is naturally infrequent in subalpine and alpine areas, it is an important 

natural process. More opportunities to manage wildfire to meet resource objectives would restore 

the effects of this natural process on subalpine and alpine composition and structure.

Ecological Resilience to Drought, Air Pollutants, Climate Change, Insects, and Pathogens.

In most subalpine forests, alternatives B would promote increased resilience to fire, climate 

change, drought, insects, and diseases because of higher restoration treatment rates (specifically 

the restoration of fire). Wildfire would increase resilience primarily through the reduction of stand 

densities, increased heterogeneity, and promotion of seral class diversity and tree regeneration. In 

addition, whitebark pine forests located in recreation areas (like ski areas) would be more 

ecologically resilient under alternative B. Alternative B would likely have greater treatment rates 

in recreation areas based on a regional whitebark pine restoration strategy. Despite differences 

among alternatives, many whitebark pine and other subalpine forests would be heavily impacted 

by insects and diseases associated with increased moisture stress and warming climate conditions 

under all alternatives (Meyer et al. 2014b, Schwartz et al. 2013b).

Eastside Shrublands and Woodlands (excluding Sagebrush)

Alternative B would have increased vegetation restoration over current levels (TERR-FW-OBJ01 to 02). There would be more mechanical restoration, primarily thinning or removal of juniper 

that has invaded historic sagebrush areas. There would also be some restoration of pinyon-juniper 

to meet desired conditions in areas of tribal importance and in community buffers (TERR-FWDC-10, 11; TRIB-FW-DC-03 to 05; TERR-FW-OBJ-03). There would be restoration of some 

areas to reduce and eradicate nonnative annual grasses.

Composition. Alternative B restoration would include actions to control or eradicate invasive 

plant species in arid landscapes, as described above for sagebrush areas. This would move 

composition more toward desired conditions. However, as described in the “Sagebrush” section, 

control and eradication efforts are unlikely to keep up with the proposed increase in treatment 

rates. There would also be additional restoration in areas of tribal interest that would benefit 

understory composition, in part through restoring fire with prescribed fire. This would be a result 

of the relatively greater restoration treatment rates under this alternative compared to alternative 

A. Where prescribed fire is applied, it would be aimed at primarily positive changes in species 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

196

composition. This is because fire would be applied in areas with little to no existing cheatgrass

and fire prescriptions would be designed to benefit native perennial grasses and other native 

species. Fire would be applied in a mosaic pattern that would be beneficial to fire-tolerant species 

and have limited impacts on fire-intolerant species (Brooks and Minnich 2006).

Structure. Alternative B would improve structure in restoration areas. Removal of juniper from 

sagebrush areas would be the primary means. In other areas, trees would be thinned and 

heterogeneity increased. There might be some pruning of lower branches where prescribed fire or 

hand treatments are applied. In restoration areas, vegetation would move toward desired 

conditions.

Ecological Resilience to Fire, Drought, Climate Change, Insects, and Pathogens. Alternative

B would improve resilience to fire, drought, insects, and pathogens to some degree, because of 

the elevated restoration treatment rates. Restoration would build greater adaptive capacity to 

climate change than alternative A. Thinning and control and minimization of nonnative invasive 

grasses would be the primary changes that would increase resilience. There would continue to be 

elevated levels of insect-related tree mortality in large areas because trees would remain at higher 

densities in untreated areas. This would especially be the situation on lower elevation sites and 

more productive sites that have high tree density due to the fire suppression effect.

Eastside Shrublands and Woodlands: Sagebrush

There would be substantially more restoration of sagebrush in alternative B compared to 

alternative A (TERR-FW-OBJ-01 to 02). This would be to maintain and restore habitat for the 

greater sage-grouse (SPEC-SG-OBJ-01), reduce fire risk to communities and developed 

recreation sites, and restore resilience to forests, woodlands and riparian areas (MA-RCA-OBJ01; FIRE-FW-GOAL-01,-03, and 05). Most of the restoration would be to treat areas with conifer 

invasion (SPEC-SG-DC-05). There would be more mechanical restoration, primarily thinning or 

removal of juniper that has invaded historic sagebrush areas. There would be some increases in 

prescribed fire (TERR-FW-OBJ-02), but it would be limited to smaller areas and carefully 

applied to avoid invasion and expansion of nonnative annual grasses (like cheatgrass and red 

brome). There would be restoration of some areas to reduce and eradicate nonnative annual 

grasses (SPEC-SG-DC-06; INV-FW-OBJ-01) and measures to minimize the spread of noxious 

weeds (SPEC-SG-GDL-03; SPEC-SG-STD-01) and nonnative invasive plants (INV-FW-GDL-01

to 05). Vegetation treatments and post-soil or other disturbance activities in sage-grouse habitat 

would be followed by seeding or replanting of sagebrush where appropriate (SPEC-SG-GDL-04). 

The restoration would occur around communities, in greater sage-grouse habitat that is in poor 

condition, and in areas of tribal importance (TERR-FW-OBJ-03).

In sagebrush, pinyon-juniper and Jeffrey pine areas, management approaches would be applied 

that minimize the invasion and spread of nonnative plant species and restore vegetation 

composition, structure, and resilience. These include:

Projects in sagebrush should prioritize restoration treatment to remove trees from 

shrublands, which include recent expansion areas of pinyon and juniper into sagebrush 

ecosystems and other adjacent shrublands.

Unwanted fire (i.e., more frequent, severe or larger than the natural range of variation) in 

sage-grouse priority habitat is limited or prevented.

Use an adaptive management strategy shall be used when conducting vegetation 

treatments within sage-grouse habitat. Treatment methods and intensities will be 

determined based on the results of past treatments as information from those past 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

197

treatments becomes available. If the results of past treatments show that those treatments 

have caused an increase in nonnative annual grasses and poor sagebrush recruitment, 

further treatments within sage-grouse habitat will not adhere to the same prescription.

Where sage-grouse habitat is being degraded due to wild horse and burro use, determine 

site-specific measures to improve or restore sage-grouse habitat.

Work with tribes to determine priority areas for weed prevention and control, especially 

focused on traditional gathering areas that are threatened by weed infestations. Consult 

with tribes before using pesticides or herbicides that may affect traditional gathering. 

Coordinate with research and other organizations to evaluate the potential effects of 

climate change on the spread of invasive, nonnative species.

Integrate terrestrial ecosystem desired conditions into spatial patterns for fuel reduction 

treatments. Incorporate heterogeneity by increasing variation in tree spacing, enhancing 

tree clumps, creating canopy gaps, promoting fire resilient tree species, increasing the 

ratio of large to small trees, and using topographic variation (e.g. slope, aspect, and 

position) to guide treatment prescriptions.

Develop landscape scale projects to increase the pace and scale of ecological restoration, 

ecosystem resilience and fire resilience, and to protect the carbon carrying capacity of the 

forest.

Plan vegetation, fuels, and other restoration projects across large landscape areas (e.g., 

greater than 5,000 to 10,000 acres), when it can increase efficiency in planning and 

support partnership-based approaches, such as stewardship contracts.

Composition. Alternative B would promote or sustain the dominance of sagebrush and perennial 

herbaceous plants in these arid landscapes through ecological restoration treatments. There are 

specific desired conditions and direction for implementing treatments that would reduce conifer 

encroachment into sagebrush areas and restore native perennial grasses. Management direction 

for sage-grouse habitat restoration emphasizes maintenance and enhancement of native plant 

communities and movement toward vegetation desired conditions (SPEC-SG-DC-05 to 06; 

SPEC-SG-STD-01, -02, -03, -09). Composition would move toward desired conditions in these 

areas. However, control and eradication efforts are unlikely to keep up with the proposed increase 

in treatment rates. Increases in invasive plants are one of the negative effects that the management 

direction tries to minimize, knowing that the benefits of restoration treatment outweigh this 

negative effect. Restoration treatment does not eliminate the effect. Where prescribed fire is 

applied, there would be primarily positive changes in species composition. This is because fire 

would be applied in areas with little to no existing cheatgrass, and projects would be designed to 

benefit native perennial grasses and other native species. Fire would be applied in a mosaic 

pattern that would be beneficial to fire-tolerant species and have limited impacts on fire-intolerant 

species (Brooks and Minnich 2006).

Structure. Alternative B would improve structure in sagebrush vegetation. Removal of juniper, 

pinyon pine or Jeffrey pine from sagebrush areas would be the primary means (SPEC-SG-DC05). Where prescribed fire is restored in sagebrush areas there would be an improvement in 

structural and age diversity toward the desired conditions.

Ecological Resilience to Fire, Drought, Climate Change, Insects, and Pathogens. Alternative

B would improve resilience to fire, and climate change in sagebrush, because the elevated 

restoration treatment rates under these alternatives build greater adaptive capacity in arid 

ecosystems than alternative A. Reduced numbers of pinyon and juniper trees, reduced or 

minimized nonnative annual grass introduction and spread, promotion of native perennial grasses, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

198

and increased age and structural diversity of sagebrush would improve resilience to climate and 

reduce the likelihood of large, high-intensity fires, high-severity fire effects, and poor recovery 

from fire.

Cumulative Effects of Alternative B

There would continue to be effects of warming and drier climate into the foreseeable future. In 

some areas, where there is less restoration, the effects of climate change would be more 

prominent than the restoration benefits because of the low amount, small scale, and limited 

intensity of restoration (see “Climate” subsection). Areas where there are substantial treatments 

that would result in improved climate resilience and adaptation are Kern River drainage and 

restored eastside Jeffrey pine, sagebrush and pinyon-juniper.

There would continue to be restoration on adjacent Federal, State and local agency lands (like Los 

Angeles Department of Water and Power) that are similar to those on National Forest System

lands. Restoration on these other lands would also be limited. There would continue to be 

urbanized developed adjacent to national forest lands and increased recreational visitor use. There 

would likely be related increases in human-ignited fires and spread of invasive plants as a result 

of the combination of increased human presence and climate change. The size and area of large, 

high-intensity fires would continue to increase (see “Fire Trends” section). Overall, vegetation 

composition, structure, and resilience would become more dissimilar to desired conditions 

outside of areas with concentrated restoration. Higher elevation areas would mostly remain 

moderately similar to desired conditions. Vegetation in the Kern River drainage would potentially 

increase to high similarity to desired conditions with increased fire because the landscape is 

moderately resilient to fire and more fire would increase overall resilience.

Consequences Specific to Alternative B-modified

The consequences of alternative B-modified would be similar to alternative B, but there would be 

a slightly higher restoration treatment rate under alternative B-modified from wildfires managed 

to meet resource objectives (6,000 acres per decade). This increase in restoration treatment acres 

would result in about a 2 percent increase in restoration treatment rates for montane forest 

ecosystems on the Inyo National Forest (Jeffrey pine, dry mixed conifer, and red fir). This slight 

increase in restoration rates in alternative B-modified will marginally increase the acreage of 

forest vegetation that is restored to proper structure, composition, and function. In contrast, 

restoration rates in sagebrush and other arid shrubland and woodland ecosystems will be highly 

similar between alternatives B and B-modified, because these vegetation types will be restored 

using approaches other than wildfires managed for resource objectives (prescribed fire and

mechanical thinning of encroaching conifers; treatment rates using these approaches are identical 

under alternatives B and B-modified).

In comparison to alternative B, 133,490 acres (or 7 percent of the total acres on the Inyo National 

Forest) would be reclassified from the Maintenance or Restoration Fire Management Zone to the 

General Wildfire Protection Zone in alternative B-modified. Nearly all of these acres are located 

in lower elevations of the sagebrush vegetation type, where the primary restoration approaches 

will rely on methods other than wildfires managed to achieve resource objectives (prescribed 

burning and mechanical thinning of encroaching conifers). Although, this fire management zone 

reclassification will not result in changes to sagebrush treatment rates, it will result in fewer 

wildfires burning in this vegetation type in areas with potential for fire-facilitated cheatgrass 

invasion (see figure 28). Therefore, the reclassification of more acres of sagebrush vegetation to

the General Wildlife Protection Zone, and added protection from wildfires and cheatgrass 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

199

invasion in alternative B-modified will result in more ecologically intact sagebrush ecosystems in 

alternative B-modified compared to alternative B. 

Cumulative Effects of Alternative B-modified

There would continue to be effects of warming and drier climate into the foreseeable future. The 

effects of climate change would be reduced similar to alternative B, because increased restoration 

treatments in alternative B-modified would confer greater adaptive capacity and resilience to 

forest ecosystems (see “Climate Change” section). Restoration and development on adjacent 

agency and private lands, as well as urbanization and increased human use would be the same as 

described for the other alternatives, with increased fire ignitions and nonnative plant invasions 

(cheatgrass). Overall, vegetation structure, composition, and function would be more similar to 

desired conditions under alternative B-modified.

Consequences Specific to Alternative C

There is a goal of increased prescribed fire and wildfire managed to meet resource objectives in 

alternative C. There is a moderate to high uncertainty that increased prescribed and wildfire 

managed to meet resource objectives would occur in alternative C. One reason is that there would 

be less mechanical treatment and less opportunity to restore vegetation along ridges and roads 

that would be used to “anchor” prescribed fire and wildfire managed to meet resource objectives. 

This is especially a limitation in the Sierra Nevada montane zone, and eastside shrublands and 

woodlands (especially pinyon-juniper and sagebrush areas) where there are fewer natural features 

(like rock outcrops) that could be used to burn from or contain fires. Another uncertainty comes 

from less intense reduction of vegetation density, particularly in mixed conifer forests. This 

makes prescribing or managing wildfires more difficult because fuel conditions are greater and 

the risks of managing fires safely and within adequate management control become higher.

Vegetation

Overall, there is substantially less vegetation restoration in alternative C. The consequences of the 

reduced restoration is that most areas would remain at the same level of dissimilarity to desired 

conditions as they are now, or decline because of continued effects of fire, spread of nonnative

invasive plants, recreation use, and warming climate. Invasive plant treatments would be 

conducted similarly to other alternatives.

Sierra Nevada Montane Zone

Alternative C would provide some restoration in the Sierra Nevada montane zone but less than in 

alternatives B and D, at a level similar to alternative A, assuming the rate of prescribed burning 

compensates for the reduction in mechanical thinning. Most of the mechanical thinning would 

occur in the wildland-urban intermix defense zone which is managed similar to alternative A. 

There would be some restoration along ridges and roads. There would be little reduction in forest 

density and little to moderate increases in heterogeneity in areas treated mechanically. This is 

because of management direction that limits canopy reductions at the landscape scale and limits 

the size of trees removed. There is an increased emphasis on prescribed fire but there is a 

moderate to high uncertainty that much prescribed fire or wildfire managed to meet resource 

objectives would occur due to most areas continuing to have high fuel levels and conditions that 

favor high-intensity fire. But there is a higher likelihood of very large, high-intensity fires in 

alternative C, according to the fire-climate scenario predictions (see “Fire Trends” section).

Composition. The effects of alternative C on composition would be similar to alternative A. Most 

areas would continue to have a high dissimilarity with desired conditions. There is a potential for 

more prescribed fire that would improve the condition of understory plants that benefit from fire, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

200

but there is a high to moderate uncertainty that this would occur. There would continue to be large 

areas with more canopy cover at levels outside the natural range of variation and would result in 

large areas where shade-intolerant pines are in poor condition. There would be less restoration of 

overstory composition toward desired conditions and less reduction in tree density that shades out 

a large portion of the understory plants. Where prescribed fire is used in place of mechanical 

thinning, it could result in less reduction of high density understory seedlings and saplings, 

especially of shade- and fire-intolerant species such as white fir because the fires may have to be 

designed to burn with lower intensity to balance damaging larger trees that are desired to be 

protected. By burning at lower intensity, it may require several re-burn entries over time to 

achieve the same desired change in composition as achieved in alternatives B and D.

Structure. The effects of alternative C on structure would be similar to alternative A because of 

the restrictions on canopy cover reductions. There would continue to be large areas that are highly 

dissimilar to desired conditions. There is the potential for restoration of forest structure toward

desired conditions with fire but there is a high uncertainty that prescribed fire and wildfires 

managed to meet resource objectives would occur to a great extent.

Ecological Resilience to Drought, Air Pollutants, Climate Change, Insects, and Pathogens.

The effects of alternative C on ecological resilience would be similar to alternative A. Resilience 

would continue to be very low to low across most of the landscape because vegetation density 

would remain high and heterogeneity low. Denser vegetation is more susceptible to any additional 

stress because plants compete more for water, nutrients and light. Wildfire could potentially 

restore resilience but there is a moderate to high uncertainty that it would occur.

Subalpine and Alpine Zone

Alternative C would have similar effects in subalpine and alpine vegetation as alternatives B and 

alternative B-modified because management direction in higher elevation and wilderness areas 

are similar. 

Eastside Shrublands and Woodlands (excluding Sagebrush)

Similar to sagebrush, there would be an increase in restoration of pinyon-juniper areas in 

alternative C compared to alternative A. There would be movement toward desired conditions of 

composition, structure, and resilience similar to alternatives B and B-modified in the restored 

areas. Similar to sagebrush, the amount of restored area would be slightly lower than in 

alternatives B and D. The result is that overall, there would continue to be large areas that have a 

low to moderate dissimilarity with desired conditions.

There would be very limited restoration of xeric shrub/blackbrush and mountain mahogany, 

associated primarily with treatment in community buffers. The net effect would be that there 

would be a limited and negligible movement toward desired conditions of composition, structure, 

and resilience in these vegetation types.

Eastside Shrublands and Woodlands: Sagebrush

Areas with restoration treatments would move toward desired conditions for composition, 

structure, and resilience similar to alternative D in areas of sage-grouse habitat restoration and 

maintenance and similar to alternatives B and B-modified in other areas of sagebrush vegetation. 

Most of the restoration would involve removal of invading conifers from sagebrush that provides 

habitat for the greater sage-grouse. Many untreated areas would continue to have a low similarity 

to desired conditions. In a few areas where montane forest vegetation intersects with sagebrush, 

there is slightly less restoration treatments in alternative C than in alternatives B and D due to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

201

some stewardship opportunity from mechanical thinning in montane vegetation but more than 

alternative A.

Cumulative Effects of Alternative C

There would continue to be effects of warming and drier climate into the foreseeable future. The 

effects of climate change would be more prominent than the restoration benefits because of the 

low amount, small scale, and limited intensity of restoration in alternative C (see “Climate” 

subsection). Like other alternatives, there would continue to be restoration on adjacent Federal, 

State and local agency lands that are similar to those on national forest lands. Restoration on these 

other lands would also be limited. There would continue to be urbanized developed adjacent to 

national forest lands and increased recreational visitor use. There would likely be related 

increases in human fire ignitions and spread of invasive plants as a result of the combination of 

increased human presence and climate change. The size and area of large, high-intensity fires 

would continue to increase (see “Fire Trends” section). Overall, vegetation composition, 

structure, and resilience would become more dissimilar to desired conditions.

Consequences Specific to Alternative D

The greatest amount of restoration would occur in alternative D (table 4, page 83). The increased 

restoration would include mechanical treatment, prescribed fire, and wildfire managed to meet 

resource objectives. The combined area of restoration increases from an estimated 48,000 acres in 

alternative A, to between 90,000 and 100,000 acres in alternatives B and B-modified, to 140,000 

acres in alternative D. Some of these acres may include areas with overlapping treatments, 

meaning some of the areas may be treated with both mechanical treatment and prescribed fire or 

mechanical treatment and managed fire.

Most of the increased restoration would occur in the Jeffrey pine, pinyon-juniper, and sagebrush 

ecosystem types. Overall, alternative D emphasizes more rapidly restoring vegetation resilience 

recognizing there may be short-term consequences. There are fewer wildlife-related restrictions 

on vegetation restoration in alternative D, especially more flexibility in limited operating periods 

and an increase in the amount of habitat that can be restored in the short term to achieve greater 

long-term benefits.

Restoration in alternative D would include the same management direction as alternatives B and 

B-modified described above to limit the introduction and spread of nonnative invasive plants. 

Any associated improvements to native plant composition may be offset to an unknown degree by 

nonnative invasive plant expansions in restoration areas, despite best management practices since 

climate change can favor the growth and spread of invasive species.

Restoration in alternative D would be similar to alternatives B and B-modified in location but the 

area restored would increase substantially. This includes areas around communities and 

developed recreation sites, sagebrush areas with encroaching conifers, Jeffrey pine departed from 

the desired conditions, dense pinyon-juniper woodlands, and some other areas with nonnative 

plant invasions.

Vegetation

The dominant eastside vegetation types (sagebrush, Jeffrey pine, and pinyon-juniper) would 

move toward desired conditions with restoration treatments, similar to alternatives B and Bmodified. There would be more area restored in the middle elevations in alternative D that would 

result in movement toward desired conditions for composition, structure, and especially resilience 

at the landscape scale. There would be more removal of invading conifers in sagebrush areas, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

202

along with control and eradication of nonnative invasive plants. There would be larger areas of 

Jeffrey pine where tree density is reduced, heterogeneity is increased, surface fuels are reduced, 

and understory composition is restored. There would be substantially more area of pinyon-juniper 

with reduced density and nonnative invasive plants eradicated or controlled.

Sierra Nevada Montane Zone

Alternative D would have the greatest amount of restoration in the Sierra Nevada montane zone. 

Restoration would focus on the Jeffrey pine vegetation type but also include treatments within dry 

mixed conifer, red fir, and some lodgepole pine, especially within the Mammoth Lakes and June 

Lake area. The concentration of restoration in landscape areas would result in a higher likelihood 

that these areas would burn at lower intensities during wildfires and retain mature forest. 

The amount of prescribed fire and wildfire managed to meet resource objectives would be 

greatest in alternative D. The total amount of prescribed fire would be about 10 to 30 percent

higher than alternative A, and the total amount of wildfire managed for resource objectives would 

be a substantially higher than alternatives A, B, B-modified, and C. The increase would be due to 

the greater amount of mechanical restoration and emphasis on increasing the use of fire as a 

restoration tool and to restore it as an ecosystem process to these frequent fire-adapted and firedeficit ecosystems. The mechanical restoration would focus first on strategically placed areas on 

ridges, along major roads, and other strategic locations that can serve as future fuel treatment 

“anchors” for the safe and effective reintroduction of fire (North, Collins, and Stephens 2012;

North et al. 2015). The purpose of these strategic areas is to improve the ability to safely and 

effectively conduct large prescribed fires, suppress fires, and to manage wildfires in a manner that 

results in beneficial fire effects that enhances protection of communities and restores ecosystems. 

There would also be more prescribed fire in and between areas restored mechanically. Larger 

prescribed fires would be more feasible because vegetation would be less dense, making desired 

fire effects and fire control more achievable. There would be a lower likelihood of sustained 

crown fire. There is a moderate level of uncertainty that the planned amount of prescribed fire 

would not occur because of air quality constraints.

Composition. Restoration treatments would substantially increase the dominance and 

codominance of Jeffrey pine, especially on dry sites. Desired conditions and direction to achieve 

them include decreased tree density (cover and basal area) and increased heterogeneity. These 

would favor the shade-intolerant pine. The health and resilience of large pines would be improved 

by reducing stand density around them, although clumps and groups of large and old trees would 

be retained. This would increase the likelihood that the current pine trees survive stresses from 

drought, air pollutants, and temperature increases related to climate change.

Restoration of heterogeneity through mechanical thinning, and especially prescribed fire and fire 

managed to meet resource objectives would improve the composition, condition and diversity of 

native understory plants. Shrubs, flowering plants, and grasses that are adapted to fire would have 

more vigorous and dense foliage, increased flowering and fruiting, and increased density in a 

patchy pattern.

Structure. In alternative D, tree densities would be lower and heterogeneity considerably higher 

across large areas of the landscape. The landscapes would be most changed in the protection 

zones, but also in the restoration zones accessible by road and equipment and feasible for large 

landscape prescribed fire. This would move substantial portions of the landscape toward desired 

conditions.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

203

Ecological Resilience to Drought, Air Pollutants, Climate Change, Insects, and Pathogens. In 

montane forests, this alternative builds greater adaptive capacity than other alternatives. 

Decreased tree density and increased heterogeneity at the landscape and site scales would 

improve resilience to these multiple stressors. Higher levels of prescribed fire associated with 

increased mechanical treatments and large prescribed fires in other areas would decrease surface 

fuels and increase resilience to large, high-intensity fire more than other alternatives.

Subalpine and Alpine Zone

Overall, alternative D would have similar consequences to alternatives B, B-modified, and C in 

subalpine and alpine vegetation. Wildfire managed to meet resource objectives would increase 

resilience fire, drought, climate change, and to insects and diseases primarily through the 

reduction of stand densities and promotion of diversity of species, and structures, and tree 

regeneration. Whitebark pine forests located in recreation areas (like ski areas) would potentially

be more resilient to insects and diseases under alternative D. Alternative D would have greater 

treatment rates in recreation areas based on a regional whitebark pine restoration strategy.

Despite differences among alternatives, many whitebark pine and other subalpine forests would 

be heavily impacted by insects and diseases associated with increased moisture stress and 

warming climate conditions under all alternatives.

Eastside Shrublands and Woodlands (including Sagebrush)

Alternative D would promote the greatest resilience to climate change in the eastside shrublands 

and woodlands, because the elevated restoration treatment rates under these alternatives build 

greater adaptive capacity in these arid ecosystems (especially in the sagebrush and pinyon and 

juniper vegetation types) than alternative A. A substantial portion of the landscape would have 

increased resilience to large, high-intensity fire and lower risk of nonnative invasive plants 

spreading in burned areas, especially cheatgrass and other highly flammable grasses. Decreased 

nonnative plant spread would have an additional positive effect of further reducing the likelihood 

of large, high-intensity fires. These long-term improvements may be offset to an unknown degree 

by nonnative invasive plant expansions in restoration areas, despite best management practices 

since climate change and treatment activities themselves can favor the growth and spread of 

invasive species.

Cumulative Effects of Alternative D

There would continue to be effects of warming and drier climate into the foreseeable future. The 

effects of climate change would be somewhat reduced because of the increased climate resilience 

that results from the substantial amounts, scale, and intensity of restoration treatments in 

alternative D (see “Climate Change” section). Restoration and development on adjacent agency 

and private lands, as well as urbanization and increased human use would be the same as 

described for the other alternatives, with increased fire ignitions and invasive plant spread 

occurring. Overall, vegetation composition, structure, and resilience would become more similar 

to desired conditions.

Analytical Conclusions

Sierra Nevada Montane Zone

Alternative D followed by alternatives B and B-modified would move the most area toward and 

closest to the desired conditions for vegetation ecology. The higher rates of treatment and 

emphasis on treating across larger areas would be more likely to result in entire landscapes that 

are restored within the next 10 to 15 years. This increases the likelihood that large landscape areas 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

204

are not only restored but that they can withstand fires of all intensities and still maintain much of 

their forest structure and composition with moderate or mixed severity and limited large patches 

of high-severity fires. While small, distributed pockets of high-severity fire can provide 

heterogeneity and old forest and complex early seral forest (see “Complex Early Seral Forests” in 

the following section), very large fires are outside of the desired condition. 

The beneficial effects of alternative D are greater than in alternatives B and B-modified. This 

would result in a higher level of resilience across larger landscape areas that would improve the 

resilience of adjacent areas.

Alternatives A and C are both likely to result in low levels of restoration treatments. Vegetation is 

likely to remain highly dissimilar to desired condition for structure, composition and resilience 

across most of the landscape. The increased emphasis in alternative C on prescribed fire and 

wildfire managed to meet resource objectives may result in some increases in areas restored by 

fire. But these may be more limited than intended because of the low levels of accompanying 

mechanical treatment in strategic locations that would aid in conducting more large prescribed 

burns or benefiting from wildfires.

There is a relative difference among the alternatives in the cumulative environmental 

consequences. This is especially the case with the overlaid consequences of climate warming and 

increased probability of large, high-intensity fires on top of the restoration treatments. The trend 

for increasing large, high-intensity fire is highly likely to continue in all alternatives, but there 

will be a lower probability in alternative D and a slightly lower probability in alternatives B and 

B-modified based on the fire-climate restoration scenario research (Westerling, Milostan, and 

Keyser. 2015).

Subalpine and Alpine Zone

Alternatives B, B-modified, C, and D would move the greatest amount of subalpine and alpine

vegetation toward the desired conditions. The higher restoration treatment rates under these 

alternatives build greater adaptive capacity in many subalpine landscapes than alternative A. 

Alternative A will likely support the slowest rate of return to desired conditions and promote the 

least long-term resilience to stressors. This is a consequence of the lower treatment rates under 

alternative A, especially the use of wildfires managed to meet resource objectives. Alternative A 

is also the only alternative that does not involve the creation of an interagency whitebark pine 

conservation and restoration strategy. Under alternatives B, B-modified, C, and D, this strategy 

would enhance the success of whitebark pine and other subalpine forest restoration efforts in the 

southern Sierra Nevada. This would be particularly evident in recreation areas where increased 

treatment rates would build greater adaptive capacity.

Under all alternatives, alpine vegetation would have low resilience to climate change, because 

these high-elevation vegetation types have high exposure to the effects of climate change and low 

adaptive capacity to changing climate under all climate scenarios (Safford, North, and Meyer. 

2012; Lenihan et al. 2003 and 2008). Active management is also similarly limited in alpine 

environments in all alternatives, which further limits the adaptive capacity of alpine ecosystems 

under any one alternative. Consequently, there are no differences among alternatives with respect 

to the maintenance of desired conditions in alpine ecosystems.

Eastside Shrublands and Woodlands (excluding Sagebrush)

Alternative D, followed by alternatives B and B-modified, would move the greatest amount of 

pinyon-juniper vegetation toward desired conditions. Increased treatment rates and intensity 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

205

would restore less dense and more heterogeneous structure, and reduce nonnative invasive plants. 

These changes would increase the resilience to drought, insects and pathogens, climate change, 

and fire. Alternative A would have the least restoration of all alternatives, but alternative C would 

have only slightly more restoration treatments. Under both alternatives A and C, most pinyonjuniper vegetation would remain dissimilar to vegetation desired conditions.

Under all alternatives, there would be a similar, low amount of restoration in xeric 

shrub/blackbrush and mountain mahogany vegetation types. These vegetation types would remain 

moderately dissimilar to desired conditions. There would be beneficial effects of all alternatives 

on these arid shrublands, through eradication or control of nonnative invasive plants on adjacent 

sagebrush, pinyon-juniper and Jeffrey pine vegetation. This would reduce the likelihood of spread 

of nonnative invasive plants into the arid shrublands.

Eastside Shrublands and Woodlands: Sagebrush

Similar to other eastside shrublands and woodlands, Alternative D followed by alternatives B and 

B-modified would move the greatest amount of sagebrush toward the desired conditions. The 

higher treatment rates in these alternatives would more likely result in landscape-scale restoration 

in the next 10 to 15 years. The greater restoration treatment rates in sagebrush landscapes

increases the capacity of component ecosystems to resist nonnative plant invasions and maintain 

much of their desired structure and composition despite climate change. Alternative A would 

likely result in lower restoration treatment rates than other alternatives. Consequently under 

alternative A, vegetation would likely remain dissimilar to the desired condition in structure, 

composition and resilience across many arid landscapes. Alternative C would have only slightly

greater restoration treatment levels than alternative A; resulting in continued dissimilarity of 

sagebrush vegetation to desired conditions in most areas.

Terrestrial Ecosystem Processes and Functions

Background

Functions of terrestrial ecosystems can refer to many things. Here, the primary functions 

considered include how vegetation and terrestrial ecosystems provide for carbon cycling and 

regulation, fire regimes as an ecological process, terrestrial biodiversity that includes old forest 

and complex early seral forest habitats and habitat for pollinators and tree cavity excavators (like

woodpeckers), and connectivity for species across landscapes.

This section also contains an integrated analysis of varied aspects of biodiversity and ecological 

sustainability from other sections and multiple supplemental reports. This includes an integrated 

analysis of ecosystem condition in relation to tribal uses, fire regime and fire effects information,

and important seral stages. Tribes have lived with and relied upon terrestrial (and aquatic and 

riparian) ecosystems in the analysis area for thousands of years. In this section, the condition of 

plants, animals, and overall terrestrial ecosystems in relation to tribal uses is analyzed. Overall 

sustainability will draw upon broad measures of ecological integrity identified in the National 

Ecological Sustainability Frameworks (USDA Forest Service 2004a, 2011a) including vegetation 

condition, air pollutant exposure, insect and pathogen levels, and fire regimes. All of these aspects 

of terrestrial ecosystem function are described below.

In addition to the broad ecosystem approach of vegetation analysis that emphasizes dominant 

vegetation types, we also recognize that some plant communities or habitats are less common and 

provide important ecological conditions for at-risk species. Some special habitats are important 

for ecological integrity because they are limited to small areas with uncommon rock types and/or 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

206

soils types, called “edaphic habitats” or they provide essential microclimate conditions 

surrounding habitats for at-risk species with a restricted distribution. Other special habitats 

include cliffs and caves essential for at-risk species. The analysis of special habitats is discussed 

in the “Wildlife, Fish, and Plants” section, especially under the subsection “At-risk Plant 

Species.”

Analysis Methods and Data Sources

The overall approach in this analysis was to evaluate the similarity of current and estimated future 

conditions to the desired conditions where possible. The desired conditions for most of these 

indicators are broadly defined because there is less specific best available scientific information 

and other sources on which to base them, or there is more uncertainty as to what desired 

conditions should be. Therefore, the evaluation is mostly a qualitative evaluation of relative 

differences in trends toward the desired conditions. In some cases there was quantitative 

information available to make the evaluation, such as aspects of old forest and complex early 

seral forests. For both types of evaluations, the specific indicators, measures, thresholds for levels 

of similarity between desired conditions and current or future conditions, and associated 

assumptions were identified.

Indicators and Measures

Fire Regimes and Fire as an Ecological Process

Fire is a “keystone” ecosystem process in most of the analysis area (McKelvey 1996, van 

Wagtendonk and Fites-Kaufman 2006, Brooks and Minnich 2006); (Wills 2006). This means that 

it has important and often dominant influences on ecosystem composition, structure, and 

function. Fire shaped most of the ecosystems. Deserts and alpine ecosystems are two exceptions.

Fire Regimes. The fire regime is the pattern of frequency, intensity, severity, seasonal timing, and 

spatial pattern of fires (Sugihara et al. 2006). Three measures of fire regimes were used here: 

(1) the frequency of fire, (2) the fire regime condition class, and (3) a qualitative analysis of fire 

regime integrity. Fire regime integrity refers to the similarity of all aspects of fire regimes 

compared to the historic patterns (prior to European settlement). Additional analysis and 

discussion of fire regimes by individual major vegetation types is addressed in the “Terrestrial 

Vegetation Ecology” section. This includes fire severity and spatial patterns.

Fire Effects. Ecological fire effects refer to how vegetation is affected by fire (for example, 

whether it is invigorated and sprouts, or killed). Many plants in the analysis area are adapted to 

fire and can respond positively to it, depending upon the intensity and duration of the fire and the 

extent (Fites-Kaufman, Bradley, and Merrill 2006). Here a broad analysis was conducted. 

Specific effects to different vegetation types are described in the “Terrestrial Vegetation Ecology”

and “Aquatic and Riparian Ecosystems” sections.

Carbon Stocks, Sequestration, and Stability

The primary criteria used to analyze carbon stocks, sequestration, and stability were the resilience 

to fire, climate, and insects and pathogens. In dry forest systems, there can be dramatic changes in 

carbon stocks and sequestration capacity with one large, high-intensity fire (North 2014). Carbon 

stability was a focus of analysis because managing for long-term carbon stability, within a carbon 

carrying capacity, is a forest-wide desired condition. Carbon stocks and sequestration are both 

dependent on the carbon carrying capacity, and, consequently, highly related to the carbon 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

207

stability of an ecosystem. In arid, eastside shrublands and woodlands, soil carbon was 

emphasized.

Connectivity

The ability for species to move throughout a landscape is important for ecological integrity 

(Rudnick et al. 2012). Species that are wide ranging are able to maintain genetic diversity and 

sustainability in the face of changes to their population or environment (Gilbert-Norton et al. 

2010). Connected landscapes allow other species to migrate in the face of climate change or other 

pressures (Heller and Zavaleta 2009). Despite its ecological importance, in practice connectivity 

is a very difficult concept to apply because it depends on the species and its associated life history 

and dispersal characteristics (Cushman, Landguth, and Flather 2012). Connectivity for wideranging habitat specialists (like the greater sage-grouse or marten) are different than for 

generalists (like bears) or short-dispersal specialists (like plants growing on certain rock types). 

For this analysis, the emphasis was on broad patterns of vegetation structure or landscape 

arrangement of vegetation and some aspects of connectivity function. Functional aspects included 

existing and predicted habitat fragmentation for vegetation types and important seral stages (like

old forest) and landscape patterns of broad management intensities including less managed areas 

(such as wilderness), varying road densities (Cushman and Landguth 2012), and different large 

fire probabilities.

Terrestrial ecosystem connectivity was analyzed at multiple spatial scales. These are all related 

but focus on different aspects of terrestrial ecosystem connectivity. Most of the analysis was 

qualitative, based upon key sources of connectivity presented in the assessments (such as the

State of California Essential Habitat Connectivity project, Sierra Nevada Ecosystem Project Areas 

of Late Successional Emphasis) and maps of broad management regimes (like wilderness) by 

alternative. Connectivity of old forest and complex early seral habitats, which are described in 

more depth in the supplemental reports on that topic.

Thresholds were based upon general connectivity theory, especially for wide-ranging wildlife. 

There are many different ways to measure connectivity but for a general view, percolation theory 

is useful. Percolation theory suggests that when the majority of a landscape has conditions 

suitable for movement, then movement is more likely to occur (Turner 1989, Metzger and 

Décamps 1997, Kindlmann and Burel 2008). It matters less how habitat is arranged when there is 

more of it. The thresholds vary by species habitat requirements and mobility. For this analysis, we

assumed that landscapes with greater than 60 percent habitat suitable for movement provided 

high connectivity. Some research suggests that the threshold is greater than 40 percent. For this 

analysis we assumed that 40 to 60 percent provided moderate levels of habitat connectivity. In 

addition to the amount and distribution of habitat, areas that block or constrict movement, such as 

large reservoirs or major highways can influence connectivity. Since this is a general landscape 

view of connectivity, we assumed that relative differences in the number of major barriers 

provided relative differences in the ability of wide-ranging species to move through the 

landscape.

Criteria and thresholds for environmental analysis of landscape connectivity across vegetation 

types within the Sierra Nevada montane ecological zone and eastside shrublands and woodlands

are shown below.

Indicator: Connectivity for wide-ranging montane forest species (bear, deer, marten; see also 

“Old Forest” below).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

208

Criteria:

• Major barriers and connecting habitat with hiding cover (overhead shrub and/or tree cover).

• Location of and amount of barriers (such as large reservoirs, developed areas, major roads, 

high road density)

Thresholds and Evaluation Approach:

• High: No major barriers preventing dispersal of sensitive species; greater than 60 percent of 

the landscape with hiding cover.

• Medium: Pinch points or barriers exist in limited places; 30-60 percent of the landscape 

with hiding cover.

• Low: Multiple pinch points or barriers; less than 30 percent of the landscape with hiding 

cover

Criteria and thresholds for environmental analysis of landscape connectivity across vegetation 

types across eastside landscapes (sagebrush and pinyon-juniper) are shown below:

Indicator: Connectivity for sage-grouse and other sagebrush-dependent species.

Criteria:

• Major barriers and, amount and distribution of connecting sagebrush habitat

• Location and amount of barriers (such as large reservoirs, developed areas, major roads, 

high road density). 

• Extent of area with moderate sagebrush cover without encroaching conifers (like juniper)

Thresholds and Evaluation Approach:

• High: No major barriers preventing dispersal of sagebrush species, greater than 60 percent 

of landscape with sagebrush cover.

• Moderate: Pinch points or barriers exist in limited places, 30-60 percent of the landscape 

with sagebrush cover.

• Low: Multiple pinch points or barriers exist. Less than 30 percent of the landscape with 

sagebrush cover.

Terrestrial Biodiversity

The analysis of important aspects of terrestrial biodiversity, including old forest and complex 

early seral forest habitat (important seral stages), and keystone groups (pollinators and cavity 

excavators) adds to the course filter vegetation analysis above. These are important aspects of 

biodiversity and support the fine-filter analysis of biodiversity by individual species in the 

sections for at-risk terrestrial wildlife and plant species. It provides an evaluation of the extent to 

which plan components that provide ecosystem diversity will also provide the ecological 

conditions necessary to support species of conservation concern.

Old Forest and Complex Early Seral Forest

There are two specific seral stages that provide important habitat for terrestrial biodiversity in 

Sierra Nevada montane forests: old forest (table 33) and complex early seral forests (table 34).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

209

Old forest was analyzed by comparing conditions and trends with similarity to desired conditions 

for large tree densities and landscape proportions of old forest (table 32). 

Table 33. Indicators, criteria and thresholds used to analyze environmental consequences for the old 

forests (Sierra Nevada montane zone only)

Old Forest 

Characteristic Criteria

Thresholds for Qualitative Evaluation 

of Trends

Large trees Densities compared to desired 

conditions

Relative trends (increase, decrease, stay 

the same)

Amount of old forest Proportion of landscape with 

large trees (size varies by 

species, see desired conditions) 

high = more than 60 percent of landscape

moderate = 40-60 percent of landscape

low = less than 40 percent of landscape

Large snags (larger than 

20 inches diameter at 

breast height)

Density (per 10 acres) and 

variability (range in densities) 

compared to desired condition

high = 20-40 per 10 acres 

moderate = 5-20 per 10 acres; 

low = less than 5 per 10 acres

Table 34. Indicators, criteria and thresholds used to analyze environmental consequences for 

complex early seral forest (Sierra Nevada montane zone only)

Complex Early Seral 

Characteristic Criteria

Qualitative Evaluation of 

Consequences

Amount/Proportion of 

montane forest 

landscape

Proportion of landscape (across the 

Sierra Nevada montane forest zone) that 

is classified as complex early seral and 

its comparison to the natural range of 

variation

Relative evaluation of the trends in 

amount and levels of departure from 

the natural range of variation

Spatial pattern Evenness in distribution across 

landscape, and grain (size of patches) 

relative to natural range of variation

Relative evaluation of pattern 

compared to desired conditions

These desired conditions recognize a “gradient” approach to defining old forest (Franklin and 

Fites-Kaufman 1996; Spies 2004). That means that there are different degrees of what is 

considered old growth. Areas that have high densities of large trees relative to the natural range of 

variation (the median and high range of desired conditions) are at one end of the old forest 

spectrum, and areas with low densities of large trees (the low range) are at the other end of the 

spectrum. Because of the long history of selective removal of large, old trees in the analysis area 

(Mckelvey and Johnston 1992), areas that have low densities are more common (Franklin and 

Fites-Kaufman 1996). While even single large, old trees can be ecologically important given this 

history and current patterns, old forest is still focused on large, old trees within an area. The 

analysis reflects this gradient approach and wide range in current conditions in large tree 

densities.

Complex early seral was analyzed by examining: (1) anticipated temporal trends, (2) proportional 

abundance relative to the natural range of variation, and (3) spatial patterns such as the patch size 

and evenness in distribution.

Keystone Groups (Pollinators and Cavity Excavators)

Some plants, animals, insects, and fungi stand out in their role in ecosystem function. Pollinators 

are one such group. They include mostly insects, including butterflies and bees, but also other 

animals, like hummingbirds. Without these pollinators, many flowering plants would fail to
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

210

persist or be rare on the landscape. This would then have repercussions on other insects and 

animals that use these plants for food and shelter. 

Another standout group is woodpeckers and other primary cavity excavators (such as nuthatches 

and sapsuckers) because they make cavities that are used by many other birds and mammals. For 

this analysis, these two keystone groups were selected as important, but it is not meant to imply 

that there might not be other ones. These are two groups that might be impacted by treatments. 

The analysis of consequences to pollinators and cavity excavators was qualitative. Findings on 

climate, fire, insects, pathogens, vegetation, less common habitats, and at-risk species were 

synthesized.

For pollinators, three recent management strategies were used to identify measures and practices 

to analyze. These all incorporate summaries of research key elements of pollinator habitat and 

management approaches. These include the “Pollinator Research Action Plan” by USDA and EPA 

(2015), “Region 5 Draft Pollinator Best Management Practices” (Van Zuuk 2014), and “Pollinator 

Friendly Best Management Practices for Federal Lands” (United States Departments of 

Agriculture and Interior 2015). The key element of pollinator habitat is the abundance, condition, 

and spacing of flowering plants in the landscape. Openings in forests and sunny areas are 

identified as important and dense forests as a concern. Also important are nearby water sources, 

and nesting habitat that is widely varied and can include holes in the ground, logs, hollow or pithy 

shrub stems, and snags. Continuously burned areas can be detrimental but fire can also improve 

understory plant flowering. Any activity or management action that removes or reduces flowering 

can have impacts including intensive grazing, recreation use, mowing, or herbicides. For this 

analysis, changes to forest heterogeneity that create openings, and restoration of low and 

moderate-intensity fire were used to evaluate environmental consequences as described below.

Indicator: Understory plant composition, condition and distribution

Criteria:

• Amount of sunny openings or overstory heterogeneity in forests.

• Amount and type of fire relative to the natural fire regime (enhances native flowering 

plants).

Thresholds:

• High: Dominant vegetation is mostly (greater than 60 percent) within the desired conditions 

for structure and fire regimes. Fire is restored to many areas in historically frequent fire 

ecosystems. Nonnative plants are limited in extent.

• Moderate: Dominant vegetation is somewhat (30 to 60 percent) within the desired 

conditions for structure and fire regimes. Fire is restored to some areas in historically 

frequent fire ecosystems. Nonnative plants are present in some areas.

• Low: Dominant vegetation is mostly (less than 30 percent) outside of the desired conditions 

for structure and fire regimes. Fire is restored to limited areas in historically frequent fire 

ecosystems. Nonnative plants are present in numerous areas, dominant in some larger areas.

For primary cavity excavators, primarily woodpeckers, snags are a primary habitat. Many species 

of woodpeckers use a variety of snag sizes in a variety of forest conditions. This includes small to 

large snags in young to old forests (used by white headed and pileated woodpeckers (Bull and 

Holthausen 1993, Morrison et al. 1987, Raphael and White 1984), or unburned to burned forests 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

211

(used by black-backed woodpeckers; Saracco, Siegel, and Wilkerson 2011; Fogg, Roberts, and 

Burnett 2014; Siegel et al. 2014). The amount and distribution of snags in varied forest conditions 

was used to evaluate environmental consequences as described below.

Indicator: Amount and distribution of snags in both burned and unburned forests. Diversity of 

snag habitats.

Criteria:

• Density and variation in size and decay class of snags compared to desired conditions. 

Spatial pattern (evenness across larger areas but clumpy patterns at smaller scales). 

Presence in multiple forest conditions and settings (young forests, old forests, burned 

forests, and unburned forests).

Thresholds:

• High: Snag densities and distribution are within the desired conditions across most the 

landscape. These occur in a variety of forest ages and burned and unburned conditions.

• Moderate: Snag densities and distribution are somewhat within the desired conditions 

across the landscape. These occur in a variety of forest ages and burned and unburned 

conditions but may be missing in some areas.

• Low: Snag densities and distribution are within the desired conditions across limited areas 

the landscape. These occur in some forest age classes and burned and unburned conditions 

but are missing across significant areas.

Tribal Uses and Biocultural Diversity

Native Americans have lived throughout the analysis area for thousands of years (Lake and Long 

2014b). The people of various Tribes have historically and are currently tied to different 

ecosystems across the area that provide for basic life needs of food, shelter, and culture. Plants, 

animals, springs, and seeps across all elevational zones and vegetation types are often important 

to Tribes. There are strong ties between Tribes and all components of ecosystems. The condition 

of biodiversity thus can impact cultural diversity, or the ability of Tribes to maintain their culture. 

The condition and distribution of these culturally important aspects of ecosystems is the focus of 

this section.

A qualitative analysis was conducted for tribal uses and biocultural diversity. This included a 

synthesis of the findings in the Vegetation Ecology, Fire Ecology, and Vegetation Resilience

supplemental reports, and discussions in numerous tribal forums over the last several years. 

Terrestrial Ecosystem Sustainability

The National Forest Sustainability Framework (USDA Forest Service 2004a, 2011a) was used to 

evaluate terrestrial ecosystem sustainability considering aspects of biodiversity and ecosystem 

processes (table 35). This includes ecosystem resilience, connectivity, vegetation condition, insect 

and pathogen processes, fire regimes, species diversity and at-risk species. This section draws 

upon findings in the sections discussing “Agents of Change,” “Terrestrial Vegetation Ecology,”

“Fire Ecology,” and “At-risk Species.”
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

212

Table 35. Characteristics from the National Forest Sustainability Framework used in the analysis

Characteristic Analysis

Area affected by insects and 

pathogens beyond natural range 

Summary from the “Insects and Pathogens” section in the “Agents 

of Change” section

Area affected by air pollutants that 

may cause negative effects 

Summary from the “Air Quality” section

Area affected by invasive species Summary from the “Terrestrial Vegetation Ecology” section

Area with fire condition class 

outside of natural range 

Summary from the “Fire Regimes and Fire as an Ecological 

Process” section

Area with vegetation condition 

outside of natural range 

Summary from the “Terrestrial Vegetation Ecology” section

Affected Environment

A summary of the current conditions of carbon, connectivity, old forest, complex early seral 

habitat, limited habitat types, and tribal uses are shown in table 36. The conditions are described 

in broad terms in relation to the desired conditions by ecosystem types (see “Terrestrial

Vegetation Ecology” section for descriptions).

Table 36. Summary of the similarity of current conditions to desired conditions for major indicators 

of terrestrial function by ecosystem type

Ecosystem Type

Fire Regimes 

and Fire as an 

Ecological 

Process

Carbon 

Stability

Landscape 

Connectivity

Old Forest 

Condition 

and 

Amount

Complex 

Early Seral 

Forest

Tribal Uses, 

Biocultural 

Diversity 

(Conditions)

Jeffrey Pine and 

Dry Mixed 

Conifer

Low Low Moderate Low Moderate 

to High Low

Red Fir and 

Lodgepole Pine

Low to 

moderate

Low to 

moderate High Moderate High Moderate

Subalpine High Moderate High High NA Moderate

Alpine High Moderate High NA NA High

Sagebrush Moderate Moderate Low To 

Moderate NA NA Low

Pinyon-Juniper Moderate Moderate Moderate Moderate NA Moderate

Xeric 

Shrub/Blackbrush 

and Mountain 

Mahogany

Moderate Moderate High NA NA Moderate

NA = not applicable

Fire Regimes and Fire as an Ecological Process

Fire Return Interval Departure

Historically (before 1850), the area that burned in the analysis area and California overall was 

estimated to be vastly greater than current patterns (Stephens, Martin, and Clinton 2007). These 

changes have not been uniform. The frequency of fire has decreased the most in eastside Jeffrey 

pine, and dry mixed conifer forest types. These forests used to burn on average every 10 to 15 

years (Van de Water and Safford 2011). Higher elevation red fir forests have longer fire return 

intervals and have changed less, only missing one or two burn cycles on average (Safford and Van 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

213

de Water 2014). Subalpine and alpine areas have changed little if at all. Although lightning strikes 

often hit the crest where they occur, the sparse vegetation carries little fire. In sagebrush, pinyonjuniper and other eastside shrubland and woodland vegetation types, the level of fire regime 

interval departure is low but variable (Safford and Van de Water 2014). Where there have been 

invasions of nonnative, annual cheatgrass, fire is becoming more frequent than historically

(Chambers et al. 2014). Other areas have had some declines in fire frequency, such as sagebrush 

ecosystems in the absence of cheatgrass invasion.

The fire return interval departure index is one way of showing changes in fire frequency (Van de 

Water and Safford 2011). The maps below show fire return interval departure for the Inyo 

National Forest (figure 30). This map is based on van de Water and Safford (Van de Water and 

Safford 2011, Safford and Van de Water 2014). The departure is based upon the difference 

between the current fire frequency (average years between fires) and historic fire frequency. High 

departure can represent a lack of fire (shown in red, minus 66 percent) or too frequent fire (shown 

in dark blue, plus 66 percent). A moderate departure, can represent a lack of fire (orange, minus 

33 percent) or too frequent return of fire (light blue, plus 33 percent). A low departure, shown in 

green and yellow, represent less than a 33 percent change in fire frequency. Recent fires are 

shown as transparent shaded areas. The fire return interval departure values are based on the most 

recent departure data that includes fires since 2016.

Vegetation types where fires burned most frequently in the past, such as Jeffrey pine or dry 

mixed-conifer, have “missed” the most historic fire return intervals and have undergone the 

sharpest decline in ecological condition. Jeffrey pine and dry mixed conifer have generally 

experienced a two-thirds decrease in mean percent fire return interval departure, which is 

categorized as high departure. This pattern of high fire return interval departure in Jeffrey pine 

and dry mixed conifer forests of the plan area is similar to other regions of the Sierra Nevada and 

California (Safford and Van de Water 2014). As an exception, the Kern Plateau across the 

southern Inyo is characterized by relatively low levels of departure (fire return intervals are closer 

to the natural range). This is because there have been extensive areas of wildfires managed to 

meet resource objectives in this area (Meyer 2015a).

Subalpine forests, where fires were historically less frequent due to the patchier and sparse 

vegetation and shorter fire season, have undergone fewer changes. Red fir and lodgepole pine 

forests have had moderate departure in fire frequency because fires in these forest types were 

historically less frequent (Meyer 2013a, 2013b). Currently the departure is low in higher 

elevations of red fir and subalpine forests, but projected increases in fire frequency with climate 

change may reduce this departure over time.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

214

Figure 30. Map of fire return interval departure, Inyo National Forest
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

215

The departure in eastside sagebrush and pinyon-juniper ecosystems is varied from low to 

moderate. Sagebrush ecosystems show moderate levels of fire return interval departure, but 

pinyon-juniper, mountain mahogany, and xeric shrub/blackbrush vegetation generally have low to 

moderate levels of departure. Where cheatgrass or other invasive annual grasses has invaded

eastside shrubland ecosystems, fires are more burning more frequently than historically resulting 

in moderate to high fire return interval departure (bluish or aqua greenish colors in figure 30.

Fire Regime Integrity

In addition to the occurrence and frequency of fire, the type of fire (surface, passive crown, or

active crown fire) and severity of fire are important aspects of fire regimes. Many factors 

influence how severe a fire affects vegetation. This includes the density, size, species, and 

condition of vegetation as well as the intensity (heat level), speed (spread rate), and duration 

(length of time heat is emitted) of a fire. In much of the analysis area, decreased fire frequency as 

a result of aggressive fire suppression in combination with past forest management has led to 

denser, more uniform vegetation. This densification, especially in forests that historically burned 

frequently (Jeffrey pine and dry mixed conifer) promotes more severe fire effects, including 

higher proportions and patch sizes of high-severity fire under contemporary conditions than under 

the natural range of variation (Safford et al. 2013a). Table 37 shows the current condition of fire 

regime integrity for the Inyo National Forest ecological zones and vegetation types. Dense, 

uniform vegetation conditions resulting from long-term fire exclusion are especially the case of

Jeffrey pine and dry mixed conifer forests (Steel, Safford, and Viers 2015). In red fir forests, there 

has been only a marginal change in fire severity patterns over the last few decades (Meyer 

2013a). In sagebrush and pinyon-juniper there has been a more complex change dependent on 

ecosystem type and rates on nonnative grass invasion (Slaton and Stone 2015a, 2015b). For 

example, cheatgrass invasion has led to more frequent and larger fires than historically. 

Conversely, fire suppression has resulted in an ingrowth of conifers (pinyon pine and Jeffrey 

pine) into sagebrush areas. Now, when sagebrush areas burn, they burn hotter because of the 

conifers.

Table 37. Summary of current condition of fire regime integrity by vegetation type 

in the Inyo National Forest

Vegetation Type Current Condition Fire Regime Integrity

Sagebrush and Pinyon-juniper moderate

Jeffrey pine and dry mixed conifer low

Mountain mahogany moderate

Xeric shrub/blackbrush) moderate

Red fir and lodgepole pine moderate

Subalpine and Alpine high

Carbon Stocks, Sequestration, and Stability

The mixed conifer and eastside pine areas have low carbon stability because vegetation is dense 

and it is at a high risk of high-intensity fire (see “Fire Trends” and “Fire Management” sections

and the Carbon Supplemental Report). Subalpine, alpine, sagebrush, and pinyon-juniper

landscapes have moderate carbon stability. They have less standing carbon and have a moderate 

to low risk of high-intensity fire. Red fir and lodgepole pine forests have low to moderate carbon 

stability. At the lower elevations in this zone, forest density and fire risk conditions are similar to 

forests in the Sierra Nevada montane zone and carbon stability is low. At higher elevations, near 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

216

subalpine areas and on rockier sites within the upper montane zone, the carbon stability is 

moderate because fire risk is moderate.

Most of the landscape area on the eastside is dominated by non-forest vegetation, primarily 

sagebrush. In these areas, soil and belowground carbon are important (the stability of this carbon 

is described in the Assessment reports; (USDA Forest Service 2013a, 2013b, 2013c). Restoration

of degraded arid shrublands and woodlands can also enhance carbon stocks and sequestration, 

including areas invaded by invasive grasses (Finch 2012). These restoration approaches may 

increase belowground carbon storage, especially in deep-rooted shrub and perennial grass 

species, and increase the resilience of arid ecosystems to future stressors. This increase in

resilience supports a greater long-term carbon carrying capacity and provides for improved 

carbon stability in arid landscapes.

Landscape Connectivity

Landscape connectivity is moderate to high in all areas except at lower elevations in sagebrush.

Connectivity is low to moderate in sagebrush landscapes because of the invasion of conifers and 

areas of large high-intensity fire where cheatgrass has invaded.

Important Seral Stages

Old Forests

Old forests in the analysis area include legacy forest ecosystems in the Sierra Nevada montane 

zone, which includes the eastern escarpment of the Sierra Nevada and associated montane 

ecosystems in the Glass Mountains. Old forests in the area include mature stands that share the 

presence of large, old trees, for their species and site productivity (Franklin and Fites-Kaufman 

1996, North et al. 2004). The density of large old trees, size, arrangement, and density of the 

forests they are embedded in varies by ecosystem type. For example, old Jeffrey pine forests 

often have trees that are several hundred years old that are variable in density and open and 

scattered in distribution. Old forests may also contain large snags and logs in various stages of 

decay, but densities of these structures can vary greatly with some stands lacking these elements. 

Historic stand inventories also indicate that many current old forest stands have experienced 

increases in snag and log densities associated with increased tree densities (Safford and Stevens 

2017) and increased tree mortality rates, especially in larger diameter trees located in denser 

stands (Ritchie, Wing, and Hamilton 2008; Allen, Breshears, and McDowell 2015).

The condition and amount of old forest is low to moderate in the Sierra Nevada montane zone. 

These areas were most impacted by preferential logging of large and old trees during European 

settlement and more recent forestry practices up until the early 1990s (See “Forest Products” 

section and Vegetation Ecology supplemental report). Large trees have been killed by large, highintensity fires (such as the 2002 McNally Fire on the Inyo and Sequoia National Forests), and 

stress-related factors (Van Mantgem et al. 2009). More recently, many trees are dying throughout

montane forests on the Inyo National Forest due to ongoing drought, increasing temperatures 

associated with climate change, and related insect outbreaks (see the “Insects and Pathogens”

section). 

Complex Early Seral Forests

Complex early seral forests apply to actively managed forests in the Sierra Nevada montane zone, 

including dry mixed conifer, Jeffery pine, lodgepole pine, and red fir ecosystem types. However, 

Sierra Nevada dry mixed conifer and yellow pine (Jeffrey pine) forests are generally the forest 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

217

types that experience most post-fire management activities and associated research studies in the 

plan area and bioregion (Knapp and Ritchie 2016, Long, Quinn-Davidson, and Skinner 2014c).

Early successional forests following stand-replacing events (such as high-severity fire) within the 

natural range of variation represent an important ecological stage that supports diverse ecological 

processes, ecological communities, and structures (Swanson et al. 2010). The concept of complex 

early seral forests is based on ecological function and not just the age of the vegetation. This 

habitat type is created by stand-replacing disturbance events, including fires, insects, and wind 

throw. These disturbance events create clumps, patches, or larger areas of early successional 

(young) forest where overstory trees are temporarily absent or rare. Consequently, this forest 

successional stage represents a transitory period immediately following a stand-replacement event 

and prior to the ensuing period of forest development and canopy reestablishment.

Complex early seral forest is a type of early successional forest that contains structural, 

compositional, or functional elements of ecological complexity or integrity. This complexity and 

integrity in early seral forests often comes from the presence of elements created by the 

disturbance, such as snags, logs, isolated live trees (or tree clumps), young shrubs, herbaceous 

plants, regenerating trees, and sprouting hardwoods. Spatial heterogeneity (variation) in 

vegetation composition and structure during recovery after a disturbance is another important 

element of complexity in early seral forest (Swanson et al. 2010). Legacy structures following a 

disturbance like fire (such as large snags and logs, resprouting plants, and understory plant 

diversity) can provide habitat for early-successional-associated wildlife species and firedependent plants.

Complex early seral forests (such as those derived from high severity fire) provide a number of 

benefits when these stand-replacing patches fall within the natural range of variation. This 

includes habitat for early successional plant and animal species (Betts et al. 2010, Swanson et al. 

2010, Fontaine and Kennedy 2012, Tingley et al. 2014), increased plant-pollinator interactions

(Ponisio et al. 2016), and structural heterogeneity (Kane et al. 2013). In burned forest landscapes, 

a mosaic of low, moderate, and high severity patches interspersed with unburned refugia are 

characterized by high pyrodiversity (high diversity of fire effects across the landscape based on 

fire frequency, severity, and extent) that increases the diversity of plants and animals (Ponisio et 

al. 2016, Tingley et al. 2016). Patches of early successional forests within this mosaic may 

increase forest landscapes resilience by promoting tree regeneration and colonizing species, such 

as early successional mycorrhizae, nitrogen-fixing plant species, and keystone species associated 

with early successional habitats (such as pollinators, cavity excavators; Swanson et al. 2010;

White et al. 2016; Saracco, Siegel, and Wilkerson 2011; Siegel et al. 2015). Early successional 

patches may also increase tree regeneration and recruitment for disturbance-dependent species 

such as aspen or giant sequoia (Krasnow and Stephens 2015, Meyer and Safford 2011, Piirto and 

Rogers 2002).

Post-fire management activities may reduce or increase structural complexity in early seral 

vegetation, depending on a variety of factors, including the specific management activity, forest 

type, ecosystem characteristics (such as fuels, habitat features, plant diversity, and composition), 

disturbance history, and extent and severity of fire (Long, Quinn-Davidson, and Skinner 2014c). 

Salvage and reforestation removes some structural elements such as snags and logs, or creates 

conditions that may not provide the same level of complexity or habitat quality for associated 

species (Swanson et al. 2010, Noss et al. 2006). Some habitat elements like pine snags often have 

limited longevity regardless of the level of management after a fire, such as salvage logging 

(Ritchie, Knapp, and Skinner 2013). In addition, the effects of post-fire management (salvage and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

218

reforestation) on early seral forest is dependent on the intensity and type of activities, such as 

snag and surface fuel retention levels (Ritchie, Knapp, and Skinner 2013). The effects of post-fire 

salvage and other management treatments on understory diversity, tree regeneration, and plant 

community composition are variable, with most studies indicating little to no differences in 

understory diversity and composition between treated and untreated stands (Knapp and Ritchie 

2016, McGinnis et al. 2010) or increases in understory diversity following shrub removal 

associated with reforestation (Bohlman, North, and Safford 2016). The effects of post-fire salvage 

on woody fuels is also variable, with some studies indicating no differences between salvaged 

and unsalvaged areas (McGinnis et al. 2010), and other studies documenting a reduction in 

woody surface fuels several decades post-fire (Peterson, Dodson, and Harrod 2015).

Post-fire management activities, such as salvage logging combined with planting, can 

significantly increase post-fire tree regeneration in moderate to large high-severity patches that 

are lacking natural regeneration, which can enhance long-term structural complexity and forest 

integrity in these managed areas (Collins and Roller 2013; Welch, Safford, and Young 2016).

Additionally, areas lacking post-fire management may convert to a shrub-dominated ecosystem 

following a reburn event due to elevated fuel levels associated with dense snags and shrubs 

(Coppoletta, Merriam, and Collins 2016; Harris and Taylor 2017) and the interactive effects of 

climate change and fire (Tepley et al. 2017). Similarly, selective post-fire management actions 

that target high valued areas of high fuel loading following high severity fire may effectively 

mitigate the impacts of future uncharacteristic fires and enhance the resilience to future wildfire 

events (Coppoletta, Merriam, and Collins 2016).

There is clear evidence of more high-severity fire now compared to historic conditions, 

specifically within yellow pine forests, including Jeffrey pine forests (Mallek et al. 2013, Safford 

and Stevens 2017). This is partially a consequence of increased fuel loading associated with longterm fire exclusion in these forests (Steel, Safford, and Viers 2015). Even more evident is the lack 

of low- to moderate-severity fire in nearly all forest ecosystems of the Sierra Nevada compared to 

the pre-European settlement period (Mallek et al. 2013). Importantly, the amount and proportion 

of complex early seral forest on the Inyo National Forest is very likely much higher than occurred 

historically, because there is a surplus of high-severity fire in yellow pine forests in the Sierra 

Nevada (Mallek et al. 2013), resulting in a surplus of early seral forests in Jeffrey pine forests of 

the Inyo National Forest (see Southern Sierra Nevada Wildfire Risk Assessment: Vegetation 

Condition Assessment Report), and a very low degree (about 0 to 1 percent between 1984-2014) 

of post-fire salvage and reforestation treatments in burned forests on the Inyo National Forest (see 

Complex Early Seral Forest Supplemental Report). Moreover, while there are larger patches of 

high-severity fire in current yellow pine and mixed conifer forests than under the natural range of 

variation (Safford and Stevens 2017), high-severity fire patch size remains relatively unchanged 

in most upper elevation forests with some exceptions (Meyer 2015b, Meyer 2015c). 

Where fire regimes have been partially or wholly restored with prescribed fire or wildfires 

managed to meet resource objectives, it tends to result in more desirable fire effects dominated by 

patches of low- to moderate-severity fire (the exception are patches previously burned at high 

severity). While there is some uncertainty as to exactly how much high-severity fire occurred 

historically in montane forests, most evidence indicates this to be a smaller proportion of the 

burned area in these forest types (Safford and Stevens 2017). Moreover, it is also likely that highseverity fire patch sizes have increased considerably within these forests over the past few 

decades (Miller and Safford 2012, Westerling and Keyser 2016b). Historically, these highseverity patches were smaller in size and patchily distributed (not interconnected), resulting from 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

219

mortality of individual, clumped, or small groups of trees. However, in recent years, Sierra 

Nevada dry mixed conifer and Jeffrey pine forest types have had large patches of high-severity

fire resulting in substantially larger and more interconnected patches of complex early seral 

forest. 

Keystone Species Groups

The current condition of pollinators and cavity excavators (such as woodpeckers) is uncertain, 

and there is little direct information available. For pollinators, forests with dense vegetation 

conditions lacking characteristic fire have lower levels of flowering understory plants, especially 

those dependent on higher light environments (Webster and Halpern 2010, Wayman and North 

2007). These conditions are common for the majority of the montane forest areas (see “Terrestrial 

Vegetation Ecology” section). Restoration treatments, especially prescribed fire, increase the 

diversity of native pollinators, such as butterflies (Huntzinger 2003). Canopy arthropods also 

benefit from ecological restoration treatments, if the treatments also enhance tree, shrub, and 

herbaceous plant diversity within forest stands (Rambo, Schowalter, and North 2014). Invasive, 

nonnative plants can reduce pollinator habitat, especially if the nonnative plants are wind 

pollinated grasses such as cheatgrass. Large areas in the foothill zone and eastside lower elevation 

areas have had cheatgrass and other nonnative annual grass invasions. Pollinator habitat is greatly 

reduced in these areas.

Habitat for cavity excavators (especially snags) is highly varied. In conifer forests, the average 

number of snags in an area are within the lower end of the desired conditions but are highly

variable spatially and often within or above the natural range of variation (Safford et al. 2013c, 

Meyer et al. 2014a). This high spatial variability means that there are many areas that have no 

snags and other areas that have more than the average number. Overall, large snag levels, 

especially very large snags (greater than 30 inches in diameter) may be limited in the forest 

landscape, especially within plantations (plantations cover only about 1 percent of montane forest 

vegetation or 0.2 percent of all vegetation on the Inyo National Forest), the wildland-urban 

intermix, and areas impacted by windstorms.

Tribal Uses and Biocultural Diversity

As mentioned previously, people of various Tribes in the area are and have been tied to different 

ecosystems across the bio-region that provide basic life needs of food, shelter, and culture (see 

“Tribal Relations and Uses” section). This includes gathering and tending trees such as black oaks 

and pinyon pines for primary food sources, medicinal plants, basketry and shelter from plants, 

fish and game harvest (Anderson and Moratto 1996, Anderson 2006), and culturally important 

activities including cross-Sierra travel and trade trips, and sacred ceremonies.

There was (and to a lesser degree currently is) an interaction between Native American land uses 

and management and ecosystem condition and function. Native Americans often used fire or 

other means to improve basketry or food materials, to improve habitat conditions for game 

species such as deer, and to maintain meadow ecosystems. This use of fire included riparian 

areas, because a high proportion of plants that are important for basket weaving occur there.

On the east side of the Sierra Nevada, seed, root, and bulb gathering occurred, and in some cases, 

irrigation was used to encourage desirable species (Slaton and Stone 2015a and 2015b). Activity 

in sagebrush was concentrated near meadows. Fire was conducted in the spring and fall. The 

Paiute, Shoshone and Washoe used pinyon pine extensively and still collect products from the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

220

trees, including pine nuts, pitch, and wood products. Native Americans pruned the trees, raked 

away the litter, weeded around them, and burned to increase productivity and protect them from 

wildfire. Elder interviews attest to the fact that fire was used to foster growth of particular food 

groups such as wild onions, elderberries, and caterpillars. Fire was used to eliminate excess fuels 

that threatened favorite pinyon pine stands.

The condition of plants, animals, and insects that Tribes use, as well as the ecosystems they occur 

in, is low for low- and mid-elevation areas (montane, eastside pine, and sagebrush vegetation 

types) and moderate for higher elevation areas (red fir forest, lodgepole pine forest, subalpine

forest, and alpine vegetation types). This is related to the condition of vegetation and fire regimes 

relative to the natural range of variation. Dense vegetation, and limited low- and moderateintensity fire are primary factors. Current vegetation conditions are denser and less diverse in the 

understory, and many important plants such as black oak, shrubs used for basketry, and other 

plants used for traditional foods or medicines are in poor condition. Traditional travel routes are 

covered in dense vegetation, impeding ease of travel, particularly for elders and young tribal 

members. Management for biodiversity, particularly through the use of beneficial fire, would help 

to maintain viable populations of the diverse plants and animals that are necessary for Native 

American traditionalists to continue their cultural practices.

Integrated Terrestrial Ecosystem Sustainability

The integrated terrestrial sustainability condition varies by the ecological and elevational zone. 

For details by each zone and major vegetation type, see the “Fire Trends,” “Terrestrial Vegetation 

Ecology,” and “Insects and Pathogens” sections. Here a synthesis of the overall findings from 

each of these sections is presented.

In most lower and mid-elevation areas, indicators of terrestrial ecosystem sustainability point to a 

low and moderate condition as shown in table 38 (USDA Forest Service 2004a, 2011f). The 

greatest contributors are vegetation and fire conditions that are outside of the natural range. At

lower elevations of the Inyo National Forest, invasive plants are widespread, although still 

scattered in many locations. The ecosystems are still functioning but may be at a tipping point for 

large change. This would include a higher susceptibility to widespread drought and insect- and 

pathogen-related plant and tree mortality. It includes a susceptibility to widespread changes in 

connectivity, forest cover, and mature forest area from increasingly large, high-intensity fires.

Environmental Consequences to Terrestrial Ecosystem Processes and Functions

Consequences Common to All Alternatives

Fire Regimes and Fire as an Ecological Process

Fire regimes would continue to be departed from the natural range of variation for much of the 

mid- and lower elevation areas in the analysis area, except where moderate to high levels of 

restoration occur across broader areas. Because fire operates at large scales, landscapes (areas 

greater than 10,000 acres) with at least 40 to 60 percent restoration are necessary to effect 

changes in large fire patterns (the amount of high-intensity or crown fire; see the “Fire Trends” 

section). The alternatives vary in the amount of the landscape that would have restoration of 

varied types (such as mechanical treatments, prescribed fire, or wildfire managed to meet 

resource objectives). The alternatives also vary in the intensity of the treatments, or degree of 

change in vegetation that affects fire type. Finally, the alternatives vary in the amount of fire that 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

221

would be applied or managed on the landscape at intensities within the desired condition that 

would have beneficial effects to the vegetation, and would reduce fire regime interval departure.

Table 38. Overall ecosystem sustainability conditions by characteristic from National Forest 

Sustainability Report* by major vegetation types for the Inyo National Forest

Characteristic

Sagebrush/

pinyon-juniper

Jeffrey pine

and dry mixed 

conifer

Red fir and 

lodgepole 

pine

Xeric shrub/

blackbrush 

and mountain 

mahogany

Subalpine/

alpine

Area affected by 

insects and 

pathogens 

beyond 

background 

levels

Current, low to

moderate

susceptibility 

moderate

Current 

moderate, 

susceptibility 

high

Current 

moderate, 

susceptibility 

moderate low Low

Area affected by 

air pollutants that 

may cause 

negative effects 

Low, but some 

transport of ozone 

east of the San 

Joaquin River 

drainage

Low, but some 

transport of 

ozone east of the 

San Joaquin 

River drainage

Low, but some 

transport of 

ozone east of 

the San 

Joaquin River 

drainage

low Moderate 

to low

Area affected by 

invasive species 

Moderate, 

extensive areas of 

nonnative grasses

moderate low moderate Low

Area with fire 

condition class 

outside of 

natural range 

moderate high moderate moderate Low

Area with 

vegetation 

condition outside 

of natural range 

moderate high moderate Low Low

* USDA FS 2004, USDA FS 2011

In this section, the broader characterizations of the alternatives are described by the vegetation 

type actions would most likely occur in. The majority of the mechanical and prescribed fire 

restoration treatments are most likely to occur in the pinyon-juniper and Jeffrey pine woodlands 

on the east side. Wildfire managed to meet resource objectives is most likely to occur in the the 

Kern River drainage and some other montane forest areas. Large areas of montane, mixed conifer 

forests and chaparral are highly likely to have fire managed to meet resource objectives. The 

greater amounts of mechanical treatments in alternatives B and D in strategic locations would

increase the likelihood of larger prescribed fires and managed fires to meet resource objectives in

montane areas. These characterizations by vegetation type are used to analyze the expected 

consequences of the alternatives below.

Table 39 summarizes the expected consequences of the alternatives by major vegetation type. In 

all alternatives, there is little difference among the alternatives in consequences to the subalpine 

and alpine areas. Limited vegetation and harsh growing conditions result in slow changes in 

vegetation there. The majority of these areas are in wilderness or inaccessible locations.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

222

Table 39. Fire regime integrity for vegetation types by alternative

Vegetation Type Alternative A

Alternatives B

and B-modified Alternative C Alternative D

Sagebrush Moderate Moderate to high Moderate to high Moderate to high

Pinyon-juniper Moderate Moderate to high Moderate to high Moderate to high

Jeffrey pine Very low Low to moderate Low Moderate

Dry mixed conifer Low Low to moderate Low Moderate

Mountain 

mahogany Moderate Moderate to high Moderate to high Moderate to high

Xeric shrub/black 

brush Moderate Moderate to high Moderate to high Moderate to high

Red fir and 

Lodgepole Pine Moderate Moderate to high Moderate Moderate to high

Subalpine and 

Alpine High High High High

Sierra Nevada Montane Zone

In all alternatives, red fir and lodgepole pine forests have at least moderate integrity owing to the 

relatively longer fire return intervals in these forest types (median fire return interval of 

approximately 30 to 50 years). However, most red fir and lodgepole pine forests have missed one 

or two fire return intervals, resulting in a variety of ecological impacts associated with fire 

exclusion (such as increased fuel loading and tree densities). Red fir is among the most vulnerable 

to climate change (North 2014, Meyer et al. 2014a). This is because they are experiencing and 

will continue to experience the greatest relative change in type of precipitation and temperatures. 

Fires may become more frequent in red fir forests and disrupt the current moderate levels of fire 

regime integrity and resilience.

Current Jeffrey pine and dry mixed conifer forests in the Sierra Nevada are moderately to highly 

departed from their historic fire regimes, because of decades of fire exclusion in these frequent 

fire-regime forests. Under all alternatives, fire regimes in Jeffrey pine forests would be relatively 

intact on the Kern Plateau, owing to the many wildfires that are managed to meet resource 

objectives in this portion of the Inyo Forest.

Subalpine and Alpine Zone

Alpine vegetation and many subalpine forests at higher elevations would have high fire regime 

integrity under all alternatives, because of the very long historic fire return intervals in these 

vegetation types that often exceed 150 to 200 years. This is greater than the current fire exclusion 

period of the 20th and early 21st centuries. As a result, they are within the natural range of 

variation with respect to fuel loading and fire regimes. All alternatives support at least moderately 

high resilience to fire.

Eastside Shrublands and Woodlands

Although highly variable, the historic fire return intervals were relatively long in sagebrush (40 to 

450 years), pinyon-juniper woodlands (90 to 150 years), curl-leaf mountain mahogany (60 to 70 

years), and xeric shrub and blackbrush (more than 600 years). Under all alternatives, arid 

shrublands and woodlands would have at least moderate fire regime integrity, owing to the 

relatively long fire return intervals in these arid vegetation types. However, increasing and 

excessive wildfire activity in these vegetation types that exceed the natural range of variation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

223

(that is, too frequent fire compared to the historic fire regime) would result in reduced fire regime 

integrity. This reduced integrity is often associated with vegetation type conversion favoring 

nonnative annual grasses such as cheatgrass and red brome.

Ecological restoration treatments in some eastside shrublands and woodlands (like sagebrush 

invaded by pinyon pine), could increase the resilience of these ecosystems to wildfires and reduce 

the probability of excessively frequent fire that exceeds the natural range of variation. However, 

all alternatives would support at least moderate fire regime integrity in many arid shrublands and 

woodlands (such as xeric shrub and blackbrush), because of the long historic fire return intervals 

in these vegetation types that often exceed 100 to 200 years. This is greater than the current fire 

exclusion period of the 20th and early 21st centuries.

Carbon Stocks, Sequestration, and Stability

Under all alternatives, there would be several conditions and trends that greatly influence current 

carbon stocks, sequestration, and especially stability. First, dense forests would continue to occur 

across much of the area, because there are no alternatives that restore more than 50 percent of 

most landscapes. This means that carbon storage and sequestration will continue in those areas. 

There may be increases in carbon sequestration in thinned forests, since individual trees would be 

less stressed and may have faster growth. At the same time, under all alternatives, there would 

continue to be large, high-intensity fires, especially within dense forests lacking restoration. 

When these fires occur, there will be large conversions of carbon stored in forests and soil litter, 

into carbon dioxide in the air. Climate change will also limit carbon sequestration and carbon 

stocks following these fires through increased evaporative demand that limits tree growth rates 

and regeneration.

Tribal Uses and Biocultural Diversity

There would be continued use of forest lands, vegetation, insect, and animal materials by Tribes 

in all alternatives, similar to what occur now. More information on how these are determined and 

negotiated is covered in the later section on “Tribal Relations and Uses.” The condition of 

ecosystems, plants, insects, and animals used by Tribes varies by alternatives. In addition, all but 

alternative A contains specific direction that would improve the condition and use by tribal 

members. The rate and type of ecological restoration that would result in improvements varies by 

alternative.

Consequences Specific to Alternative A

Fire Regimes and Fire as an Ecological Process

Sierra Nevada Montane Zone

Fire regime integrity would continue to be low in montane forests in alternative A. This analysis 

assumes that a low amount of any type of treatment would occur in alternative A. It also assumes

that most of the restoration treatments would result in limited to moderate changes in vegetation 

structure and composition that would influence fire type, fire severity, and effects. Most of the 

treatments would occur in montane mixed conifer vegetation. Fire regime integrity would

continue to be low across most areas, with high proportions of crown fire and fire severity 

expected during peak fire season fires. The trend of increased fire severity would continue or 

worsen due to increased burned area and fire size (see the “Climate Change” and “Fire Trends”

section).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

224

There is expected to be some restoration of wildfires used primarily to meet resource objectives 

but little to none of this would occur in montane forests except for in the Kern Plateau on the Inyo 

National Forest. Large areas in the Kern Plateau have already had managed fire (greater than 30 

percent) and would continue to in alternative A. Fire regime integrity would continue as moderate 

or shift to high in some of this area.

Beneficial effects of fire to understory flora would be limited because prescribed fires would be 

limited. Some plants and birds would benefit from large, higher severity fires, but overall, a 

deficit of low- and moderate-severity, frequent fire would have the most beneficial effects. This 

latter type of fire would be limited in alternative A.

Subalpine and Alpine Zone

Alternative A would support continued moderate to high fire regime integrity in subalpine forests 

as described under all alternatives. There would be limited restoration treatments in these areas. 

Similar to montane forests, there would continue to be some ecologically beneficial fires, 

especially in wilderness and in the Kern River drainage.

Eastside Shrublands and Woodlands

The least amount of restoration treatment would occur in alternative A in eastside shrubs and 

woodlands. There would be less restoration of sagebrush areas with conifer invasion, and in 

pinyon-juniper and Jeffrey pine forests. There would be less restoration of fire as an ecosystem 

process using prescribed fire. Invasive plant treatments would continue to minimize introductions 

of invasive species when possible, but invasive species would continue to expand and potentially 

alter fire regimes.

Carbon Stocks, Sequestration, and Stability

Low levels of vegetation restoration would continue in alternative A, while the likelihood of 

large, high-intensity fires would increase (see “Fire Trends” section; Westerling, Milostan, and 

Keyser. 2015). This would result in increased emissions of carbon to the atmosphere and 

decreases in carbon stocks and sequestration. Most of the carbon stocks and fires both occur in 

the montane zone. Therefore, an individual very large fire can have large impacts on carbon 

stocks and emissions. There would be a negative impact of alternative A on carbon stability, 

carbon stocks, and sequestration rates.

Landscape Connectivity

Alternative A would result in few indirect effects to landscape connectivity because treatment 

levels would be low. The primary consequence would be the effect of treatments in reducing the 

likelihood of large high-intensity fires that can disrupt connectivity for many species, except 

those using early seral habitat. The extent of restoration treatments is very low (less than 10 to 15 

percent of the low and mid-elevation landscape area) and thus the likelihood of large, highintensity fires would increase in alternative A (see “Fire Trends” section; Westerling, Milostan, 

and Keyser. 2015) and cause fragmentation of forested areas and areas of sagebrush habitat for 

species such as sage-grouse.

Important Seral Stages

Old Forest

The treatments in alternative A would have little to no impact on large trees and the proportion of 

area in old forest. There are diameter limits restricting the harvest of any trees greater than 30 

inches in diameter under almost all conditions. Treatment area is limited in alternative A and there 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

225

are also limitations on the forest canopy cover changes that can occur in montane forests or other 

areas where California spotted owl, Pacific fisher, or Sierra marten occur. This would result in a 

continuation of large areas of high forest density that are susceptible to high-intensity fires (see 

“Fire Trends” section and Fire Ecology supplemental report). There is an increased likelihood of

large, high-intensity fires under current treatment levels (see “Fire Trends” section; Westerling, 

Milostan, and Keyser. 2015). Therefore, this analysis assumes there would be an increased 

likelihood of large, high-intensity fires in areas with old forests.

It is unknown what proportion of areas burned in future fires would be high severity and result in 

large tree mortality. Recent fires have ranged widely in large tree mortality levels and extent. 

Given the limited levels of current old forest and the long time it takes to redevelop (several 

hundred years), the impact of single, large, high-intensity fires may have negative impacts on old 

forests. The likelihood of very large “mega fires” (greater than 50,000 acres like the King Fire 

that had extensive areas burned in old forest in Rubicon River Canyon at extremely high 

intensity) is thought to be increasing because of climate warming, longer fire seasons, and drier 

fuel conditions (Millar and Stephenson 2015). It is unknown when or where these types of fires 

may occur, but the likelihood exists in the analysis area and the likelihood is increasing.

Complex Early Seral Forest

The impacts of alternative A on complex early seral forest are related to the consequences 

described above for old forest as well as likely salvage, reforestation, and other post-fire 

restoration treatments. The amount and distribution of complex early seral habitat would likely 

increase under alternative A because the amount of high-intensity fire is likely to increase and 

anticipated rates of post-fire salvage on the Inyo National Forest will remain near zero. The 

spatial pattern of the complex early seral forest would likely continue to be mostly in large 

patches from large high-intensity fires. The exception would be portions of the Kern River 

drainage, where extensive fire restoration in the last decade has resulted in a wide variety of small 

and medium size high-severity fire patches (Meyer 2015a). Fires are starting to burn into 

previously burned areas, limiting the potential in this area especially on the Kern Plateau to 

develop large high-severity fire patches (Vaillant 2009; Ewell, Reiner, and Williams 2012).

There is no specific management direction under alternative A directed at desired conditions, 

guidelines, or standards for complex early seral forest. There is direction to leave at least 10 

percent of burned areas unsalvaged. However, the amount of salvaged or reforested burned area 

on the Inyo National Forest has been negligible to nonexistent due to the lack of local timber 

processing infrastructure, limited demand for timber products, and other reasons (such as

accessibility). In the past three decades, approximately 0 percent and 1 percent of burned areas 

have been salvaged and reforested, respectively, on the Inyo National Forest (see Complex Early 

Seral Forest Supplemental Report). Therefore, currently the vast majority of burned areas on the 

Inyo National Forest are not treated and are left to provide these habitats. In addition, early seral 

forest is currently within or slightly exceeding the natural range of variation for montane forest 

vegetation types on the Inyo National Forest (see Vegetation Condition Assessment Supplemental 

Report). Future projected increases in wildfire severity and frequency, lower rates of forest 

restoration treatments, and the near absence of post-fire management activities on the Inyo 

National Forest in alternative A will likely result in an increase in complex early seral forest that 

exceeds the natural range of variation. This will especially be evident in montane forest 

landscapes exposed to repeated uncharacteristic wildfires.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

226

Keystone Species Groups

Pollinators – Pollinators are positively impacted by restoration treatments that result in sunny 

openings and improve conditions on the forest floor. Many flowering plants benefit from fire, 

although in large fires where nonnative, invasive plants expand, they have an opposing impact. In 

alternative A, treatments would be very limited that benefit pollinators. There would be limited 

amounts of treatments that generally retain moderate and high canopy cover, and limited amounts 

of prescribed fire. Overall, alternative A would continue to maintain dense forest conditions, with 

limited fire restoration, that retains poor flowering plant conditions that pollinators depend on.

Primary Cavity Excavators – There would be increases in primary cavity exactor habitat 

because limited restoration would perpetuate dense forest conditions, which would continue to 

have trees dying and increasing snag levels. However, there is the potential that they can be 

harvested outside of wildland-urban intermix areas for fuel or hazard.

Tribal Uses and Biocultural Diversity

Alternative A has the least change in conditions of ecosystems, plants, insects and animals of 

interest to and used by Tribes than any of the other alternatives. Conditions would continue to be 

poor in most areas, with only limited areas where restoration improves them. There would be 

limited projects that specifically address tribal member concerns and incorporate some traditional 

ecological practices, but in a limited way.

Integrated Terrestrial Ecosystem Sustainability

With limited restoration levels, vegetation would continue to remain dense overall and outside the 

natural range of variation in most low and mid-elevation areas (see “Terrestrial Vegetation 

Ecology” section). There would continue to be a high susceptibility to insects, pathogens, and air 

pollution stress (on the west side especially).

Consequences Specific to Alternative B

Fire Regimes and Fire as an Ecosystem Process

Three types of restoration treatments would occur in alternative B that would move the landscape 

toward desired conditions for fire regimes and restoration of fire as an ecosystem process (TERRFW-DC-06). The first are the vegetation restoration treatments (TERR-FW-OBJ-01 to 02), 

especially in large landscape areas as described in the management approaches below.

During ecological restoration treatments, reduce fuels along ridges, roads, or other natural 

or man-made features to aid in the use of large prescribed fires and in managing wildfire, 

including wildfires managed primarily for resource objectives.

Develop landscape scale projects to increase the pace and scale of ecological restoration, 

ecosystem resilience and fire resilience, and to protect the carbon carrying capacity of the 

forest.

Plan vegetation, fuels, and other restoration projects across large landscape areas (e.g., 

greater than 5,000 to 10,000 acres), when it can increase efficiency in planning and 

support partnership-based approaches, such as stewardship contracts.

Mechanical treatments and prescribed fire would result in restoration of fire as a process in these 

areas and increase the likelihood that when large wildfires move through these areas, fire severity 

would be mixed or lower than adjacent unrestored areas (TERR-FW-OBJ-02, FIRE-FW-DC-01, 

FIRE-FW-GOAL-03). Vegetation restoration along ridges and some roads (MA-GWPZ-GDL-01)

would increase the likelihood that large prescribed fires could be used to restore fire to landscape 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

227

areas, especially where there is steep and inaccessible terrain. In alternative B, restoration along 

ridges and roads would occur mostly in the Sierra Nevada montane zone. 

At higher elevations in the montane and subalpine areas or in the Kern River drainage, there 

would be additional restoration emphasizing wildfire managed to meet resource objectives (MAWRZ-GOAL-01; MA-WRZ-DC-01 to 03; MA-WMZ-STD-01 to 02). There would be less 

restoration along ridges and roads because there are more natural features (like rock outcrops 

along ridges) and recent fires to use as fire management boundaries (MA-WRZ-STD-01). There 

would also be localized restoration of fire as part of restoring areas of tribal importance (TERRFW-DC-11).

Additional specific management direction to restore fire as an ecological process is specific to 

individual vegetation types with associated consequences as described below.

Sierra Nevada Montane Zone

There would be an increase in fire regime integrity in alternative B, because more treatments are 

focused in the Jeffrey pine and dry mixed conifer forests of the montane zone. This is because 

there is an emphasis on restoration objectives of montane and other ecosystems that historically 

had frequent fire and on management approaches prioritizing restoration in these areas (see 

below).

Areas that historically supported more frequent fire, like Jeffrey pine-dominated forests, 

and areas with high existing levels of understory fuels are prioritized for treatment.

There would be a moderate movement toward the desired fire regime in alternative B, primarily 

in the Kern drainage.

In the plan area, restoration to a lower forest density and fuel condition would decrease the 

likelihood that fires would be more severe (see “Terrestrial Vegetation Ecology” section). There 

would be fewer large areas of high-intensity fire, and instead fire effects would be more mixed 

severity (see “Fire Trends” section). There is a moderate level of uncertainty that these beneficial 

effects would occur because of restrictions on spring burning from air quality and other 

limitations. Where there is prescribed burning, there would be considerable beneficial effects on 

the plants and animals that benefit from fire. This would especially occur when there is 

restoration of sunny openings and heterogeneity coinciding with the burned areas. Many of the 

plants that are adapted to fire are also adapted to sunlight. In alternative B, there would be 

additional beneficial fire effects to plants and animals through increased emphasis on projects

related to tribal interest.

Subalpine and Alpine Zone

The greater use of wildfire to meet resource objectives in alternative B, would increase the 

integrity of fire regimes in some subalpine forests. This is especially true in subalpine landscapes 

with relatively short fire return intervals (such as forests with spatially contiguous fuel loading, 

south-facing aspects, and at lower elevations).

Eastside Shrublands and Woodlands

Alternative B would have increased levels of restoration in sagebrush and pinyon-juniper areas 

(TERR-FW-OBJ-01 to 03; SPEC-SG-OBJ-01). The restoration would include removal of 

conifers in sagebrush areas and treatment aimed at reducing nonnative annual grasses (INV-FW-
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

228

OBJ-01). There would be some increases in prescribed fire. These restoration treatments would

increase fire regime integrity and would improve habitat for greater sage-grouse. The fire-climate 

scenarios showed that restoration of 30 percent of the sagebrush and pinyon-juniper landscape 

was sufficient to decrease the likelihood of large fires and burned areas (Westerling, Milostan,

and Keyser 2015). The combined effect of the ecological restoration and increased likelihood of 

large fires will be increased fire regime integrity.

There would be an increased emphasis on cooperation with Tribes and restoration of areas of 

tribal interest in alternative B. This would include some use of prescribed fire and also some 

restoration of areas of tribal interest that are at risk of high-intensity fire. These types of 

restoration would benefit plants, insects, and animals that are associated with natural fire regimes.

Carbon Stocks, Sequestration, and Stability

Under alternative B, there would be restoration treatments across substantial landscape areas (up 

to 30 percent or more). These treatments would move vegetation toward the desired conditions, 

increasing heterogeneity and reducing forest density. This would increase fire resilience and as a 

result of carbon stability (TERR-FW-DC-02, -07). There may be short-term decreases in carbon 

storage where trees are removed by thinning, but a long-term increase through increased carbon 

stability. There would be short-term increases in carbon emissions where there are prescribed 

fires or wildfires managed to meet resource objectives but these would be offset by reductions in 

potential high-intensity wildfire emissions (see “Air Quality” section). The impact of restoration 

on carbon sequestration is more uncertain. There may be increases because vegetation in the 

thinned areas may have more optimal growing conditions. There may be decreases because trees 

are removed.

Landscape Connectivity

The impacts of alternative B on connectivity would be similar to alternative A, but with a lower 

likelihood of fragmentation of forested areas from large high-intensity fires. There is management 

direction specifically directed at connectivity for wide-ranging species and climate-related 

migrations (TERR-FW-DC-06; TERR-OLD-DC-02; TERR-SAGE-DC-04; TERR-SAGEGOAL-01b, TERR-CES-GOAL-01c; SPEC-CSO-DC-01). This includes management approaches 

to prioritize ecological restoration in areas providing connectivity in areas where it is limited for 

forest and sagebrush dependent species. This would provide connectivity for other species 

needing overhead cover. For example, TERR-SAGE-DC-04 (open sagebrush habitat with no 

overstory trees provides habitat connectivity for sagebrush-dependent species), SPEC-SG-DC-04 

(sage-grouse habitat allows for population movement, seasonal movements, and genetic flow),

and TERR-FW-DC-06 (the landscape contains a mosaic of vegetation types and structures that 

provide habitat, movement and connectivity for a variety of species) would provide short- and 

long-term habitat connectivity for sage-grouse in arid shrubland landscapes that may be impacted 

by conifer encroachment, altered fire regimes, and other stressors.

There would be lower likelihood of large high-intensity fires because of the increased area with 

restoration, especially at the mid-elevation areas (see “Fire Trends” section). The likelihood of 

large high-intensity fires would still increase because of climate warming, and these fires could 

result in fragmentation of forested areas. These fires could also increase connectivity of complex 

early seral habitat (see section in the following pages) but these habitats tend to be more dynamic 

in space and time limiting the need for true connectedness. There would be an increased emphasis 

in alternative B in restoration treatments in key habitat linkage areas for various species (such as 

sage-grouse or marten) that would decrease the likelihood of fragmentation of key north-south 

forest connecting areas. There would be an increase in connectivity of open forest habitat because 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

229

the restoration treatments would be directed toward desired conditions for forest heterogeneity 

and reduced overall forest density.

Important Seral Stages

Old Forest

Eastside Old Forests: The consequences for eastside old forests would be based on management 

toward the desired conditions for large tree densities and landscape proportions of old forests. It is 

assumed that there would be very limited if any removal of large trees during restoration to 

achieve specific objectives (e.g., to protect and promote the health of even larger and older trees 

but not to mitigate wildfire risk). The same restrictions on removing trees greater than 30 inches 

in diameter in westside forests applies to eastside forests (TERR-FW-STD-01; table 40). Because 

of the drier conditions, it is more likely that old, medium-diameter trees (greater than 20 inches 

diameter) could be removed, but it is unlikely except under certain circumstances. Most thinning 

that does occur during restoration is used as fuelwood or for community protection. Restoration 

would result in increased resilience of old forests where it decreases forest density and increases 

heterogeneity. There would be limited amounts of restoration in alternative B but an increase over 

current levels (alternative A). There would be a slight increase in resilience. There would 

continue to be losses of large and old trees from drought, insects, pathogens, and climate change 

in unrestored areas.

Table 40. Plan direction on large tree densities by location in alternative B

Plan Direction

Inside Fire Protection 

Zones

Outside Fire Protection 

Zones

Large tree direction and 

consequences

Manage for desired 

densities

30-inch tree diameter limit, 

operational exception

Wildlife-related large tree 

direction

Retain and recruit den and 

nest trees, especially old 

and with decadence

same

Potential harvest of large 

trees, (safety issues, 

excess of desired 

conditions)

Limited, amount uncertain 

(similar to D)

Little to none (similar to A)

Potential loss of large trees 

to drought, insects, 

pathogens and fire

Low resilience (limited by 

canopy retention 

restrictions)

Low resilience, similar to A

Complex Early Seral Forests

There is specific management direction for complex early seral forests in alternative B including: 

desired conditions (TERR-CES-DC-01 to 03), goals (TERR-CES-GOAL-01-0), and guidelines 

(TERR-CES-GDL-01 to -05). This includes retaining at least 10 percent of large contiguous 

blocks (1,000 acres or more) of areas burned at moderate and high severity with high snag 

densities for complex early seral habitat that is unsalvaged (TERR-CES-GDL-05). Management 

approaches include:

During post-fire restoration projects, consider the availability of complex early-seral 

forests across the Inyo and region to provide for ecological conditions needed by 

complex early seral wildlife species. This includes retaining areas of: dense, variable, and 

connected patches of snags across a range of snag sizes; naturally regenerating 

vegetation; adjacent or intermixed burned and unburned areas; or areas with moderate to 

high tree survival.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

230

Promote native vegetation (e.g., conifers, aspen, shrubs) in complex early-seral habitat 

that supports long term ecosystem integrity considering climate change, drought, insects, 

disease and fire.

Alternative B would result in some changes in the spatial pattern and amount of complex early 

seral forest. There would be some shift toward a fine-grained, mosaic of complex early seral 

forest, especially in forests that have burned in the last 15 years. Restoration aimed at increased 

forest heterogeneity would increase the likelihood of increased heterogeneity during fires of all 

kinds. Prescribed fires and wildfires managed to meet resource objectives, and desired conditions 

for fire severity mosaics (TERR-MONT-DC-02) would result in increased area with very small 

(less than 1 acre), small (1 to 10 acres) and medium to large (10 to 200 acre) patches of mixedand moderate-severity fires that would contribute to complex early seral habitat. Wildfires 

managed for resource objectives typically have high spatial complexity (Vaillant 2009); (Meyer 

2015a). The guideline to retain at least 10 percent of areas burned at moderate and high severity 

unsalvaged would provide for complex early seral habitats. 

In the past 30 years, salvage of dead trees has been virtually absent in burned areas on the Inyo 

National Forest. Artificial reforestation would occur in some very limited areas (about 1 percent

of the burned area on the Inyo National Forest), and it is often limited in scope and area to 

locations where it is safe and relatively accessible for workers and feasible to prepare mineral soil 

seedbeds for planting trees. There would be increased consideration of natural regeneration in 

some areas burned in extensive large patches of high-severity fire, where there are insufficient 

living seed trees to ensure enough seedlings will regenerate a forest. These changes, compared to 

current management, would result in an increased proportion of large, high-intensity fires that 

would provide large areas of complex early seral forest. In addition, early seral forest is currently 

within or slightly exceeding the natural range of variation for montane forest vegetation types on 

the Inyo National Forest (see Vegetation Condition Assessment Supplemental Report). Although 

projected future increases in uncharacteristic wildfire will increase proportions of complex early 

seral forest in the Sierra Nevada montane zone, increased restoration treatments rates in this zone 

for alternative B would likely mitigate this trend of increasing wildfire severity. This will bring 

the proportion of complex early seral forest closer to the natural range of variation despite future 

increases in wildfire severity and frequency.

Keystone Species Groups

Pollinators – In alternative B, there would be increased levels of restoration toward vegetation 

desired conditions, including increased heterogeneity that would benefit pollinator plants (TERRMONT-DC-01). There would be an emphasis on restoration toward desired conditions of 

vegetation that are based primarily on the natural range of variation. Restoration of native plants 

would support restoration of dependent pollinators. This would provide more openings and 

sunlight to the forest floor that would improve pollinator habitat. There would be more prescribed 

fire and wildfire managed to meet resource objectives that would improve conditions for fireassociated flowering plants (see “Fire Management” section).

In eastside shrublands and woodlands, restoration activities under alternative B would also 

improve pollinator habitat. Increased levels of restoration in sagebrush and pinyon-juniper are 

expected to generally favor annual flowering plants over perennials. This would potentially 

benefit some pollinators during spring blooms, but provide less benefit to pollinators dependent 

on greater canopy cover or on late-seral, summer perennials such as species of penstemon or mule 

ears. Benefits to pollinators would be highly dependent upon effective control of invasive species. 

Invasive, nonnative annual grasses and other nonnative plants displace native plants and their 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

231

associated pollinators. Restoration treatments in these vegetation types would be especially 

effective at enhancing pollinator habitat when treatments also minimize invasive plant spread.

Cavity Excavators – There may be an increase in the amount of snags because snag retention 

levels would be higher than currently (alternative A) in most areas (TERR-DMC-DC-06; TERRRFIR-DC-07; TERR-LDGP-DC-06, 10) except in the community buffer areas (MA-CWPZGDL-01b) in the community fire protection zone. There would be an increase in the diversity of 

plant communities or habitats that snags occur in because of increased restoration of vegetation 

into more heterogeneous conditions and retention of large trees with deformities and cavities for 

wildlife habitat (TERR-FW-GDL-01; TERR-OLD-GDL-01). This would result in an increase in 

the diversity of cavity excavator habitat (TERR-FW-GDL-02). There would be an increase in the 

amount of open and moderately open forests in the pine and mixed conifer forests. There would

be an increase in the amount of snags in small patches of burned forest because of the increase in 

prescribed fire and wildfire managed to meet resource objectives. This would increase habitat for 

cavity excavators and other species that rely upon intermixed or adjacent burned and green 

habitat. There would be increased snag retention levels and direction for complex early seral 

habitat that would provide more snag habitat in forests burned at high severity, including in areas 

of large stand-replacing bark beetle mortality events (TERR-CES-GOAL-01d; TERR-CES-GDL02; see “Complex Early Seral Forests” section above).

Tribal Uses and Biocultural Diversity

In alternative B there is specific direction to improve conditions for plants and vegetation of tribal 

interest (TERR-FW-DC-11; TERR-OAK-DC-01) and restore areas of tribal importance (TERRFW-OBJ-03). There also would be a moderate level of restoration of ecosystem, plant, insect, and 

animal conditions (see “Terrestrial Vegetation Ecology” section). Areas restored with mechanical 

thinning and prescribed fire together would result in improved conditions for plants and animals 

of tribal interest (Lake and Long 2014a). This includes overcrowded black oaks, insect resources 

associated with eastside Jeffrey pine forests (Pandora moth), and shaded understory shrubs and 

plants currently growing in dense conifer forests (Merriam et al. 2013, Safford and Stevens 

2017).

Areas with prescribed fire and fire managed to meet resource objectives would improve 

conditions for all understory plants (TERR-MONT-DC-02; TERR-DMC-DC-02; TERR-JEFFDC-02; TERR-RFIR-DC-02; TERR-LDGP-DC-02) including those used for food, basketry, and 

medicine (Anderson and Moratto 1996, Anderson 2006). Large landscape areas treated would 

improve conditions for bear, deer, and other important wide-ranging species (TERR-FW-DC-06). 

Alternative B would have an increase in fire managed to meet resource objectives, particularly at 

middle and higher elevations that would have benefits to large ecosystem areas. The ecological 

restoration projects specifically planned and coordinated with Tribes would incorporate 

traditional ecological knowledge and practices and be focused on sites selected by tribal members 

(TERR-FW-GOA L-01; TRIB-FW-DC-01).

Integrated Terrestrial Ecosystem Sustainability

Alternative B would result in increased integrated sustainability. The greater amount of the 

landscape area that would be restored under this alternative would increase the resilience of 

terrestrial ecosystems to uncharacteristic fire, insects, diseases, air pollution, or climate change. 

Sustainability would be most improved in terrestrial ecosystems targeted by restoration efforts, 

including in montane forest ecosystems and sagebrush ecosystems.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

232

Consequences Specific to Alternative B-modified

The consequences of alternative B-modified would be similar to alternative B, but there would be 

a slightly higher forest restoration treatment rate under alternative B-modified from mechanical 

thinning and wildfires managed to meet resource objectives. This slight increase in forest 

restoration rates (specifically the increase in wildfires managed to meet resource objectives) in 

alternative B-modified would marginally increase the level of fire regime restoration, carbon 

sequestration and stocks, landscape connectivity, ecological representation of important seral 

stages (such as old forest and complex early seral), habitat for keystone species (pollinators, 

cavity excavators), biocultural diversity and tribal interests, and integrated terrestrial ecosystem 

sustainability. This would be particularly evident for those terrestrial ecosystem processes and 

functions associated with forest ecosystems (carbon stocks, cavity excavators, and forest 

connectivity) that will experience marginal increases in restoration treatment rates in alternative 

B-modified. Increased rates of mechanical thinning in alternative B-modified compared to 

alternative B would increase some elements of ecosystem integrity, such as carbon sequestration 

and stocks. 

Compared to alternative B, about 133,490 acres in alternative B-modified would be reclassified 

from the Maintenance or Restoration Fire Management Zone to the General Wildfire Protection 

Zone. Nearly all of these acres are located in lower elevations of the sagebrush vegetation type, 

where the primary restoration approaches would rely on methods other than wildfires managed to 

achieve resource objectives (such as prescribed burning or mechanical thinning of encroaching 

conifers). Although, this fire management zone reclassification will not result in changes to 

sagebrush treatment rates, it will result in fewer wildfires burning in this vegetation type in areas 

with potential for fire-facilitated cheatgrass invasion. This additional protection from wildfirefacilitated cheatgrass invasion in alternative B-modified would result in slightly higher levels of 

fire regime restoration, carbon sequestration and stocks, landscape connectivity, habitat for 

pollinators, biocultural diversity and tribal interests, and integrated terrestrial ecosystem 

sustainability in alternative B-modified compared to alternative B.

Consequences Specific to Alternative C

Fire Regimes and Fire as an Ecosystem Process

Overall, there is an emphasis on fire as a restoration tool in Alternative C that would increase the 

use of fire as an ecosystem process. However, there is a higher level of uncertainty about how 

much prescribed fire would occur because there would be fewer associated mechanical treatments 

along ridges and roads that would prepare areas for conducting large prescribed fires. Similarly, 

although there is the intent to manage more wildfires to meet resource objectives, there may be 

fewer opportunities because there would be fewer areas treated mechanically and with prescribed 

fire that could assist with better management of those fires.

Sierra Nevada Montane Zone

Overall, lower levels of treatments are proposed for alternative C in montane forests. Alternative 

C would have lower levels of fire restoration (prescribed fire combined with wildfire managed for 

resource objectives) on the Inyo National Forest than in alternatives B and D. However, 

alternative C would have higher levels of fire restoration than alternative A. There would be low 

to moderate levels of wildfires used primarily to meet resource objectives and these would occur 

mostly at higher elevations. Overall, there would be a slight increase in fire regime integrity 

compared to alternative A. The higher levels of prescribed fire and emphasis on cooperation with 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

233

Tribes and restoration of areas of tribal interest would result in increased beneficial fire effects to 

plants and animals in treated areas.

Subalpine and Alpine Zone

The consequences to subalpine and alpine vegetation in alternative C would be the same as

described for alternative A.

Eastside Shrublands and Woodlands

In eastside sagebrush and pinyon-juniper there would be slightly increased fire regime integrity 

and beneficial fire effects from restoration proposed in alternative C compared to alternative A.

Fire regime integrity in mountain mahogany and xeric shrub/blackbrush would be similar 

between alternatives C and A. 

Carbon Stocks, Sequestration, and Stability

Impacts of alternative C on carbon would be similar to alternative A, except that there may be 

more prescribed fire and wildfire managed to meet resource objectives. There is a high level of 

uncertainty on how much more fire may occur, because with fewer thinning projects, prescribed 

fires and wildfires managed to meet resource objectives may be more difficult to implement and 

could be less likely to occur. Therefore, there is a high level of uncertainty on the impacts of 

alternative C on carbon. If more beneficial prescribed and managed fires occurred, then there 

would be short-term increases in carbon emissions but a long-term increase in carbon stability. 

Burned areas would have lower surface fuels, lower vegetation densities, and higher fire 

resilience, making the likelihood of large, high-intensity fires lower.

Landscape Connectivity

Alternative C would result in similar impacts to connectivity as alternative B but with more 

recommended wilderness and an increased likelihood of large, high-intensity wildfires. There 

would be a similar emphasis on restoration of fire resilience of key forest wildlife linkage areas. 

Restoration in the remaining area would be uncertain. There would be lower amounts of thinning, 

similar to alternative A, and the thinning would be at a lower intensity. The plan objectives for 

prescribed fire and fire managed primarily to meet resource objectives is greater than the 

proposed action, but there is moderate to high uncertainty how much would occur over the plan 

period, because there would be less associated thinning in strategic areas. This could make it 

more difficult to implement prescribed burning because burns would be more risky to manage 

with higher fuel levels and would be more costly to implement.

There are more recommended wilderness areas in alternative C than the other alternatives. This 

may provide for increased landscape connectivity of species that are impacted by more intensive 

management (like mechanical treatment) or uses (such as developed recreation). See the “At-risk 

Terrestrial Wildlife Species” section for more information.

Important Seral Stages

Old Forest

Management under alternative C in old forests would be similar to alternative A. There would be 

diameter limits restricting large tree harvest in all areas. Overall, there would be the least amount 

of area proposed for restoration treatment in old forest under alternatives C and A. There would 

be an increased emphasis on prescribed fire and the use of wildfires managed to meet resource 

objectives, but it is uncertain how much of this would occur because dense forest conditions

would continue that make burning difficult.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

234

Alternative C would retain all large-diameter trees, with limited exceptions. There would be 

retention of old forest with denser trees and canopy cover. There would be an increased likelihood 

that large, old trees would die from drought, insects, pathogens, and warming climate (Van 

Mantgem et al. 2009). There would continue to be an increasing and high likelihood of large, 

high-intensity fires, similar to alternative A. This would have a negative impact on old forests in 

some areas, although there is uncertainty about the resulting fire severities and how they overlap 

with old forests. Although there would be an increased emphasis on restoration of fire, it is 

unlikely that this would occur across large areas because it is more difficult to accomplish in 

dense forest conditions.

Overall, there would be little to no change in large tree density from the restoration treatments, 

because there would be restrictions on harvest of large trees. There could be a positive impact on 

old forest structure, increased heterogeneity, and increased resilience from restoration treatments, 

including thinning, prescribed burning, and wildfires managed to meet resource objectives. There 

may be some low levels of large tree mortality from fire treatments. The area that is proposed for 

restoration is lower than other alternatives and because of this there would continue to be an 

increased likelihood of large high-intensity wildfires. It is uncertain when and where large, highintensity fires might occur, but if they did there could be negative impacts if they burn large areas 

of old forest at high intensity and result in killing a lot of large trees.

Complex Early Seral Forest

In alternative C there would be marginally more complex early seral forest than under all other 

alternatives. There would be very limited salvage, only associated with safety hazards and limited 

strategic fuel treatment areas. There would be little to no reforestation or herbicide use; instead 

natural regeneration would be emphasized to minimize disruption of natural processes. There 

would be the greatest increased likelihood of large, high-intensity wildfires, and overall burned 

area (see Fire-Climate supplemental report; Westerling, Milostan, and Keyser. 2015). The spatial 

pattern of complex early seral forest is difficult to predict but there is a higher likelihood of large 

(100 to 1,000 acres), and very large (greater than 1,000 acre) patches of mixed- and especially 

high-severity (greater than 75 percent basal area mortality) fires. There would also be an 

increased likelihood of very large (greater than 10,000 acre), very high-severity (greater than 90 

percent basal area mortality) fire patches, based upon increases in fire-atmospheric interactions 

(from fire created weather, see the “Fire Trends” section).

Early seral forest is currently within or slightly exceeding the natural range of variation for 

montane forest vegetation types on the Inyo National Forest (see Vegetation Condition 

Assessment Supplemental Report). Although projected future increases in uncharacteristic 

wildfire will increase proportions of complex early seral forest in the Sierra Nevada montane 

zone, increased fire restoration treatments rates in this zone for alternative C would partially

mitigate this trend of increasing wildfire severity. This would bring the proportion of complex 

early seral forest closer to the natural range of variation despite future increases in wildfire 

severity and frequency. However, increased levels of fire restoration without mechanical pretreatment in alternative C would lead to additional production of complex early seral habitat. This 

would supplement the proportion of complex early seral forest to a level clearly exceeding the 

natural range of variation in some montane forest landscapes of the Inyo National Forest.

Keystone Species Groups

Pollinators – There would be similar impacts to pollinators in alternative C as in alternative A. 

There would be some increased emphasis on restoration of vegetation heterogeneity and fire 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

235

restoration that could create sunny openings and improve pollinator habitat. However, canopy 

cover retention in montane forests would limit these areas. In shrublands, there would be similar 

impacts to pollinators in alternative C as in alternative B, with some benefits to pollinators 

resulting from increased annual cover in restoration areas, and some benefits to diversity 

maintained by the structural diversity of tree cover.

Cavity Excavators – There would be an increase in the amount of habitat for primary cavity 

excavators because there would be an emphasis on snag retention. This would occur mostly in 

denser canopied forests and complex early seral forest because there is less restoration proposed. 

Denser stands would have greater live tree mortality, creating more snags. There may be more 

habitat in areas burned at mixed severity since there would be more prescribed fire and fire 

managed to meet resource objectives. However, there is uncertainty how much fire restoration 

would occur because there would be fewer areas treated mechanically and with prescribed fire

that could assist with better management of those fires.

Tribal Uses and Biocultural Diversity

Similar to alternatives B and D, there would be an increased consideration of tribal interests in 

ecological restoration and coordination of some of the projects. Overall, there would be less 

ecological restoration across the landscape, providing fewer benefits to ecosystems, plants, 

insects, and animals of tribal interest.

Integrated Terrestrial Ecosystem Sustainability

There would be limited increases in integrated terrestrial ecosystem sustainability in alternative 

C, similar to alternative A. This is because there would be limited areas of restoration.

Consequences Specific to Alternative D

Fire Regimes and Fire as an Ecosystem Process

Consequences for alternative D would be similar to alternative B in type but would differ in pace 

and scale. Therefore, the analysis is focused at larger landscape-scale differences and not by 

specific vegetation types.

There would be a generally higher amount of restoration treatments in alternative D that would 

have a substantial impact on fire regimes and fire as an ecosystem process in the landscapes 

where these treatments occur. This would occur most in large areas in the eastside Jeffrey pine 

and sagebrush, the latter of which has been invaded by pinyon-juniper and Jeffrey pine. A greater 

amount of these treated landscape areas would have reduced fire intensity and severity. There 

would be increased beneficial effects of restoring fire as an ecological process because there 

would be more opportunities to manage wildfires to meet resource objectives. Alternatives D and 

C would have the greatest levels of restoration that specifically target sagebrush habitat for the 

greater sage-grouse.

The consequences for subalpine and desert vegetation types would be similar to alternative B. 

There would be some additional restoration in red fir and lodgepole pine forests that would 

reduce fire intensity and severity.

Carbon Stocks, Sequestration, and Stability

The impacts of alternative D on carbon would be similar to alternative B but with beneficial 

impacts over a larger area. Under alternative D, the area proposed for thinning is the greatest. 

There would also be the greatest amount of wildfire managed to meet resource objectives. The 

combined effect of these restoration treatments would be between 30 and 60 percent of the low 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

236

and mid-elevation areas with lower forest and vegetation densities and fuel loadings. This would 

substantially decrease the likelihood of large, high-intensity fires. This means that carbon stability 

would be substantially higher and large carbon emissions the lowest (see the “Air Quality” 

section).

Landscape Connectivity

Alternative D would result in similar impacts to landscape connectivity as alternative B but with 

less likelihood of large, high-intensity wildfires that could potentially interrupt habitat 

connectivity for forest-associated species. This is due to the increased restoration treatment rates 

under alternative D compared to other alternatives. There would be more fire managed to meet 

resource objectives under alternative D, which could enhance overall long-term ecosystem 

resilience of forest linkage areas and other habitat connections. However, there would be higher

levels of mechanical thinning in alternative D than alternative B, including within forest linkage 

areas. Consequently, alternative D would likely result in greater long-term connectivity but 

significantly lower near-future (next 10 to 20 years) habitat connectivity for forest-associated 

species than other alternatives.

Important Seral Stages

Old Forest

Alternative D would have similar environmental consequences to alternative B, but with more 

area restored there would be greater positive impacts of increased heterogeneity, decreased forest 

density, and increased old forest resilience. Instead of restrictions on harvesting large trees of a 

certain diameter, alternative D emphasizes managing toward the desired conditions for large trees. 

This is the only alternative that could result in a reversal of the trend in large, high-intensity fires.

Increased mechanical restoration treatments would result in lower levels of large and old tree 

mortality from both water stress and large, high-intensity fires. The higher levels of mechanical 

restoration would increase the likelihood that more prescribed fire and wildfire managed to meet 

resource objectives would occur and these would have a positive impact on old forests. The 

impact to large trees in alternative D across the entire analysis area (outside of wilderness or other 

areas with no or highly restricted mechanical treatment) would be the same as described for 

alternative B within the fire protection zones.

The direction in alternative D for large trees focuses on desired conditions for large tree densities 

and guidelines to meet those desired conditions in vegetation management activities (such as 

restoration thinning or timber harvest) instead of the current diameter limits in alternative A. This 

may result in some removal of individual large trees, but it is expected to be very limited because

large tree densities are lower than desired conditions in most landscape areas. The exception to 

this situation would be the same as that described under alternative C primarily to thin dense, 

uniform, young but large white fir to make them more resilient. The harvests of some large trees, 

even though limited, may result in a small reduction in large tree densities, greater than in 

alternatives A, B, or C. These reductions may be offset and lower than losses of large trees in 

alternatives A, B or C from mortality due to water stress and large, high-intensity fires. It is 

unknown how much of an offset would occur.

The proposed levels of restoration in alternative D would result in numerous large landscape 

(greater than 10,000 acres) areas exceeding 40 percent and up to 60 percent or more of the area 

restored. The fire-climate scenarios show a substantially decreased likelihood of large, highintensity fires with this level of restoration (see the “Fire Trends” section). Therefore, the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

237

likelihood of large, high-intensity fire that could result in killing a lot of large trees and 

converting large areas to early seral vegetation would be decreased compared to current trends. 

This is the only alternative to result in a reversal of the trend in large, high-intensity fires. This 

would not likely be achieved until the middle and later parts of the planning analysis period (10 to 

15 years) because of the time it takes to plan and implement projects. There may be large, highintensity fires that occur in the early part of the analysis period. If large stewardship projects 

occur across very large landscapes (greater than 100,000 acres), then it is possible that the 

projects may occur more rapidly because there would be fewer limitations on the internal capacity 

to plan and implement the projects.

Complex Early Seral Forest

There would be some limited impacts of alternative D on complex early seral forest. There would 

be more restoration treatments that would increase the likelihood that fires that would occur 

would have low or mixed fire-severity effects. This would include more prescribed fires and 

wildfires managed to meet resource objectives, which would increase the amount of distributed, 

fine and medium grained, or patches of complex early seral forest. There would be a reduction in 

the likelihood of large, high-intensity fires that would also reduce the potential for very large 

patches of complex early seral forest. There would be a marginally greater amount of 

reforestation. Compared to alternative B, this alternative would marginally decrease the 

proportion of large, high-intensity fires that have high levels of complex early seral forest. In 

addition, early seral forest would currently be within or slightly exceeding the natural range of 

variation for montane forest vegetation types on the Inyo National Forest (see Vegetation 

Condition Assessment Supplemental Report). Although projected future increases in 

uncharacteristic wildfire and fire severity would increase proportions of complex early seral 

forest in the Sierra Nevada montane zone, increased restoration treatment rates in this zone for 

alternative D would likely mitigate this trend of increasing wildfire severity. This would bring the 

proportion of complex early seral forest closer to the natural range of variation despite future 

increases in wildfire severity and frequency.

Keystone Species Groups

Pollinators – Alternative D would have similar environmental consequences as alternative B but 

across more area.

Primary Cavity Excavators – Alternative D would have similar environmental consequences as 

alternative B for cavity excavators.

Tribal Uses and Biocultural Diversity

Alternative D would have similar environmental consequences as alternative B for tribal uses and 

biocultural diversity, but across more area.

Integrated Terrestrial Ecosystem Sustainability

Alternative D would have similar environmental consequences as alternative B for integrated 

terrestrial ecosystem sustainability but for considerably more area. The amount of landscape area 

that would be restored would provide for a higher level of overall integrated sustainability since 

many of the benefits increase with larger areas treated. For example, the “Fire Trends” section 

notes how the difference between restoring 60 percent of a landscape area results in a reduction in 

the increase in large fire size and area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

238

Cumulative Effects

Fire Regimes and Fire as an Ecosystem Process

Overall, climate change may accentuate the differences among alternatives. This is because fire 

frequency and intensity are projected to increase in many landscapes with rising temperatures, 

increasing fuel loading, and decreasing fuel moistures. In general, the cumulative effects 

described in the “Fire Trends” and “Climate Change” sections apply to fire ecology as well.

Carbon Stocks, Sequestration, and Stability

Cumulative effects for carbon are a complex topic, because of the interactions involved between 

vegetation in the forest and carbon dioxide in the atmosphere that comes from many diverse 

sources outside of the national forest. Here the cumulative effects emphasize those aspects of 

carbon that are vegetation related, namely carbon stability, storage, and sequestration. There is 

some reference to carbon release from vegetation but more detail can be found in the “Air 

Quality” section.

Restoration treatments and wildfires on adjacent lands that can burn onto the national forest are 

the two primary influences on the cumulative effects on carbon and vegetation. Restoration 

treatments on adjacent national parks (Yosemite and Sequoia and Kings Canyon), and Bureau of 

Land Management-managed lands can result in areas of increased fire resilience and carbon 

stability. These areas of increased fire resilience would make it less likely for large, high-intensity 

fires to move from these lands onto national forest lands. 

Landscape Connectivity

The cumulative effects of the alternatives combined with climate change, uncharacteristic fire, 

insects, and other stressors on landscape connectivity are complex and difficult to disentangle. 

However, it is anticipated that these stressors, irrespective of the alternatives, will likely have 

synergistic interactions that amplify their impact on habitat connectivity in the southern Sierra 

Nevada. Based on fire and climate model projections, it is anticipated that these synergistic 

interactions would have the greatest negative impact on habitat connectivity under alternative A, 

which promotes the fewest measures that protect or build adaptive capacity in habitat corridors or 

linkage areas. Alternatives B, B-modified, C, and D would result in similar levels of cumulative 

impacts to connectivity, with greater reliance on minimizing short-term impacts in alternative C 

followed by alternatives B and B-modified (similar).

Important Seral Stages

Old Forest

The cumulative effects of the alternatives on old forest are influenced by management on adjacent 

lands, factors that influence fire and status, and conservation plans for old forest-associated 

species (such as California spotted owl, fisher, and marten).

The combined effects of increased restoration of old forests and restoration on adjacent national 

forest and park lands combine to move more total area in old forest toward desired conditions and 

the natural range of variation. There are extensive areas of old forest in the two national forests 

and two national parks that share borders and are intermixed with the Inyo National Forest. Sierra 

National Forest and Yosemite National Park are to the northwest of the Inyo National Forest. 

Sequoia National Forest, the Giant Sequoia National Monument, and Sequoia-Kings Canyon 

National Parks lie to the east of the Inyo National Forest. The very old giant sequoia forests in the 

national park and adjacent national forests were analyzed in the Giant Sequoia National 

Monument Plan Environmental Impact Statement and Sequoia and Kings Canyon National Parks 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

239

Natural Resource Condition Assessment (Sydoriak et al. 2013a) and that information is not 

repeated here. Old forests of the Sierra and Sequoia National Forests will be addressed in the 

Sequoia and Sierra Forest Planning Environmental Impact Statement.

At higher elevations, there are extensive areas of mature and old forests in Sequoia-Kings Canyon 

and Yosemite National Parks and Sierra and Sequoia National Forests. The National Park Service 

and Forest Service have coordinated multiple times on wildfires managed to meet resource 

objectives in these areas and would continue to do so under all alternatives. Fires cross 

boundaries often. The cumulative effect is that there are large areas in Sequoia-Kings Canyon 

National Parks that have been restored adjacent to the large areas that have been restored in the 

Kern River drainage. This restoration has improved the resilience of old forests to large, highintensity fires and increased heterogeneity and restored species composition. All of the 

alternatives would continue this cooperative, beneficial management of fire across the 

boundaries.

Complex Early Seral Forest

Management of large fires and post-fire restoration in adjacent national parks, monuments and 

national forests to the west are the primary contributors to cumulative effects on complex early 

seral forest. Yosemite and Sequoia and Kings Canyon National Parks do little post-fire restoration 

that is likely to reduce the amount of complex early seral forest. There is no post-fire salvage in 

national parks, except along major roads. Future projected trends in large, high-intensity fires 

from climate warming in national parks are similar to likely trends in national forests (Westerling, 

Milostan, and Keyser. 2015). With increased likelihood of large, high-intensity fires and limited 

post-fire restoration, the cumulative effect would be to have an overall increased amount of 

complex early seral forest across the analysis area. The Sequoia and Sierra National Forests and

southern portion of the Stanislaus National Forest to the north have had repeated, large, highintensity fires, most recently including the very large Rim Fire. This resulted in several very large 

patches of complex early seral forest habitat and many moderate and small patches. There has 

been extensive roadside hazard salvage and planned salvage across large areas, but because of the 

very large burn perimeter, there still was a large cumulative increase in complex early seral forest 

habitat. Overall, with increased fire trends throughout and varying levels of salvage, the 

cumulative effect of all alternatives would have an increase in the amount of complex early seral 

forest.

Keystone Species Groups

The cumulative effects of the alternatives and various stressors on keystone species groups are 

varied. In the near future (next 10 to 15 years), the synergistic effects of climate change, 

uncharacteristic fire, air pollution, invasive species, and insect and pathogen activity would likely 

benefit cavity excavators and pollinators under all alternatives, because these stressors would 

increase the amount and proportion of early successional habitat and tree mortality that benefits

cavity excavators and pollinators (by providing increased foraging habitat). However, greater loss 

of “green forest” may have unknown impacts to other cavity excavators and pollinators that also 

depend on this habitat for nesting or foraging during some stage in their life cycle (like pileated 

woodpeckers, hairy woodpeckers, or Williamson’s sapsuckers). In the long-term (decades) the 

loss of forests due to increasing stressors (especially climate change) would reduce the habitat 

extent for these keystone species regardless of episodic increases in early seral habitats following 

fire and other ecological processes.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

240

Tribal Uses and Biocultural Diversity

Cumulative effects for tribal uses are a combination of what is described in the sections 

discussing tribal interests, vegetation ecology, fire ecology, economic and social conditions, and 

fire and climate trends. Overall, the trends in ecosystem conditions that support tribal uses would 

be improved from the restoration treatments and greater tribal cooperation and involvement. But 

the economic and social conditions for Tribes outside of the national forest where they live can 

influence their ability to access and use the ecosystems. Better economic and social opportunities 

would provide a greater ability to use these ecosystems.

Integrated Terrestrial Ecosystem Sustainability

The varied aspects of integrated terrestrial ecosystem sustainability are complex when considered 

individually, as well as when considered together. However, the cumulative effects for each are 

similar. The effects of climate are the dominant overarching outside influence that affects all 

aspects, especially fire and nonnative invasive plants.

Analytical Conclusions

Fire Regimes and Fire as an Ecological Process

Sierra Nevada Montane and Subalpine and Alpine Zones

The alternatives vary in restoration of fire regime integrity and fire as an ecological process by 

ecological zone and location. Alternatives B, B-modified, C, and D would increase fire regime 

integrity and fire as an ecological process in the Sierra Nevada montane zone, subalpine and 

alpine zone, and Kern River drainage because of an increased potential to have wildfire managed

to meet resource objectives. Large, high-intensity fires are likely to have moderate behavior in 

these restored landscapes and would result in reduced fire severity and effects. Alternative D 

would have the greatest positive benefit to fire regime integrity across the Inyo National Forest

because at least half of the entire forest area would be restored. Alternative B would only have

less of this area restored compared to alternative D. Alternatives A and C would have the lowest 

levels of restoration, primarily due to fewer opportunities to manage wildfires for resource 

objectives under these alternatives. 

The alternatives differ in proposed restoration of fire as an ecosystem process, especially in the 

montane zone. Alternatives B and B-modified have prescribed fire objectives that would 

substantially increase the prescribed burning levels over alternative A, but there is a moderate 

uncertainty that this amount of prescribed fire would occur because of air quality concerns. With 

warming climate, drought, and longer and drier fire seasons, spring burning is increasingly 

important to achieving prescribed fire objectives. There are fewer limited operating periods in 

alternative D and a higher likelihood that prescribed fire would occur, although there is 

uncertainty whether air quality conflicts would prevent burning at any time of the year.

Eastside Shrublands and Woodlands

Restoration treatment rates in eastside shrublands and woodlands are greatest under alternatives 

D, B, and B-modified, and lowest under alternatives C and A. However, all alternatives would 

support at least moderate fire regime integrity in many eastside shrublands and woodlands (such 

as xeric shrub/blackbrush), because of the long historic fire return intervals in these vegetation 

types that often exceed 100 to 200 years (greater than the current fire exclusion period of the 20th

and early 21st centuries). These vegetation types are less departed from the desired conditions 

than other more productive vegetation types in the analysis area. Alternatives B, B-modified, and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

241

D would have the greatest levels of restoration in sagebrush habitat for the greater sage-grouse 

and the least amount of undesirable fire in landscapes where these treatments exceed 30 percent 

of the area.

Carbon Stocks, Sequestration, and Stability

Alternative D, followed by alternatives B and B-modified (latter are similar), would have the 

greatest positive impact on carbon stability, and as a result, on carbon storage and sequestration. 

They have the greatest proportions of vegetation restoration that would decrease the likelihood of 

large, high-intensity fires and increase the resilience of vegetation to fires. This would result in 

less tree mortality maintenance of carbon storage. Carbon sequestration would be more stable and 

would likely increase because of less competition between trees for water, light, and openings 

that would improve understory shrub and plant vigor. Alternative D would have the greatest 

positive impact, because there is enough of the low and mid-elevation areas restored that could 

reduce the amount of large, high-intensity fires (see the “Fire Trends” section).

Alternatives A and C would likely result in a continued condition of high instability of carbon. 

There would be a continued increase in the likelihood of large, high-intensity fires and low 

climate adaptive capacity. There would continue to be large areas of the landscape with low 

ecological fire resilience and resilience to insects and pathogens (see “Insects and Pathogens”

section). This means that there would likely be large areas burned as crown fires in large, highintensity fires, or areas with widespread tree mortality due to moisture stress and insect and 

pathogen activity. While dead trees can store much of their carbon in the stems and branches, this 

is short-term carbon storage, because decay and other ecological processes (like fire) release

carbon to the atmosphere (North and Hurteau 2011). Carbon sequestration could increase because 

of more young vegetation actively growing after large fires. This increase in sequestration would 

likely be short term in both alternatives. In alternative C, there would be little to no reforestation 

and therefore, lower levels of sequestration in post-fire landscapes characterized by large highseverity fire patches with increased tree regeneration failure (Ritchie and Knapp 2014, Collins 

and Roller 2013). In alternative A, while there might be marginally more reforestation, if it is 

extensive and densely planted, there is a moderate to high likelihood that the plantations (which 

are uncommon on the Inyo National Forest) would not survive additional large, high-intensity 

fires and climate change. There is often, but not always, a pattern of repeated fires in the same 

vicinity, that burn intensely through plantations. The most notable examples are on the Stanislaus 

National Forest, near and in the Rim Fire area, which were often established following earlier 

uncharacteristically severe wildfire events (like the 1987 Stanislaus Complex).

Landscape Connectivity

Alternatives B and B-modified potentially provide for short- and long-term habitat connectivity, 

especially for forest-associated species such as marten. Alternative C provides the greatest shortterm connectivity but at the cost of elevated exposure or sensitivity to uncharacteristically severe 

fire, climate change, and other stressors that reduce long-term habitat connectivity. Alternative D 

may support the greatest long-term habitat connectivity, but at the cost of significantly reduced 

short-term habitat connectivity resulting from elevated mechanical and prescribed fire treatment 

rates in the next 10 to 20 years. Alternative A provides the lowest connectivity for forestassociated and other wildlife species under both short- and long-term horizons. Alternative A 

provides the lowest restoration treatment rates and lacks management approaches that are 

specifically focused on habitat linkage and dispersal corridor areas otherwise promoted under 

alternatives B, B-modified, C, and D for wildlife species such as marten. Consequently, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

242

alternative D would result in the greatest habitat connectivity for forest-associated and other 

species.

Important Seral Stages

Old Forest

Alternative D, followed by alternatives B and B-modified (latter are similar), would result in the 

greatest restoration of old forests. There would be more old forests that have restoration of 

desired tree density, heterogeneity, tree canopy cover, fire regime integrity, and fire as an 

ecosystem process in these alternatives. This would restore old forests toward conditions 

reflecting the natural range of variation. There would be substantially increased resilience of 

large, old trees to moisture stress, drought, insects and pathogens, ozone, and large, high-intensity 

fires. There is potential for harvest of some large trees in alternative D and within the fire 

protection zones in alternatives B and B-modified, because the direction to limit the size of trees 

removed is provided by desired conditions for old forests compared to fixed harvest diameter 

limits. It is unknown how much harvest of large trees would occur, but it is assumed that it would

be low because many areas are below desired conditions levels for large trees.

The greatest impact to old forests, aside from direct harvest of large trees, is trees dying from 

large, high-intensity fires and the combined effects of drought, insects and pathogens. Large, 

high-intensity fires can kill many large trees, across large areas at one time. The fire-climate 

research by UC Merced (Westerling, Milostan, and Keyser 2015) supports that there has been and 

will continue to be an increase in the size, number and area burned in large fires due in part to 

warming climate. In restoration scenarios, the trend did not change or reverse until 60 percent of 

the montane landscape was restored. Restoration levels of 15 and 30 percent showed less increase

of large fires compared to no treatment but there would still be increases in large, high-intensity 

fires compared to today.

In all alternatives, the Kern River drainage would reach the 60 percent restoration level rapidly, 

because it is already near or exceeding 30 percent in many areas. For all other areas, alternative D 

is the only alternative that comes close to the 60 percent restoration level. This alternative is most 

likely to have the least loss of old forest from large, high-intensity fire. Alternative B would have 

a similar impact in some areas but not all. In all alternatives, there is uncertainty as to what 

proportion of large fires would be dominated by high severity, mixed severity or low severity

effects, even though relative qualitative comparisons could be made among alternatives. Larger 

proportions of high-severity fire is likely under alternatives A and C and higher proportions of 

low and moderate severity fire are more likely under alternatives B, B-modified, and D. Even 

with the very large Rim and King Fires, there were significant portions of the fires that burned at 

moderate, mixed or low severity, especially within higher elevation forests (such as red fir and 

lodgepole pine). Similar patterns occurred with the Aspen and French Fires on the Sierra National 

Forest. These areas of low and moderate fire severity may result in some large trees dying, but 

overall would provide benefits of increased heterogeneity, desirable habitat features (such as

snags), and resilience on some parts of fires but would have very severe effects for old forest in 

other parts of the fires that burn at high severity.

Old forests can also be greatly impacted by drought, insects, and pathogen-related mortality. 

Where forest density is high, all trees are vulnerable to mortality, including the large trees. 

Current levels of mortality in some mixed conifer and Jeffrey pine forests are elevated. Mortality 

of younger and medium-sized trees from surrounding younger forests increases the likelihood that 

large trees will die because the elevated insect levels increase the extent and rate of infection. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

243

Alternative D, followed by alternatives B and B-modified (latter alternatives are similar), would 

have the greatest reduction in vulnerability to future drought, insect, and pathogen-related large 

tree mortality because the greatest intensity of forest thinning across large areas would occur and 

greater levels of fire restoration. The net result is that only a small portion of remnant large old 

trees would benefit from restoration treatments of intensity needed to increase resilience. This 

may be less than 10 percent of the areas with large, old trees. Alternatives A and C would have 

even lower levels of benefit from restoration because treatments would be less intense and less 

extensive, especially with regards to fire restoration.

Complex Early Seral Forest

The increase in complex early seral forest would be highest in alternative C, followed by 

alternatives B, B-modified (similar), and D, and the least in alternative A. There is a high level of 

uncertainty about the amount and spatial scale of the complex early seral forest patches that 

would occur because of the high uncertainties associated with fire. However, there is a high 

likelihood of increased fires under all four climate scenarios used to project large fires 

(Westerling, Milostan, and Keyser. 2015). Additionally, the difference in complex early seral 

habitat among alternatives is rather slight, owing to the very low rates of reforestation and 

virtually non-existent levels of post-fire salvage on the Inyo National Forest.

Current proportions of complex early seral forest in the Sierra Nevada montane zone of the Inyo 

National Forest are either within or slightly exceeding the natural range of variation. The 

proportion of complex early seral forest will likely remain within the natural range of variation in 

most alternatives because: (1) the application of forest restoration treatments will reduce levels of 

uncharacteristic wildfire that will likely produce an excessive level of early seral forest, and (2) a 

near absence of post-fire management activities on the Inyo National Forest will have negligible 

impacts on complex early seral forest habitat. However, alternatives A and C would likely result 

in some landscapes with an excessive level of complex early seral forest (exceeds the natural 

range of variation) due to reduced restoration treatment rates and increased levels of 

uncharacteristic wildfire.

Keystone Species Groups

Pollinators – Alternatives B, B-modified, and D would provide the greatest restoration of habitat 

to support improved pollinator habitat in forested ecosystems. There would be the greatest 

amount of restoration, when considering the combination of prescribed fire, mechanical thinning, 

and wildfire managed to meet resource objectives, at an intensity and spatial pattern to create 

openings, more open canopy, and sunlight on the forest floor. Alternative C proposes increased 

prescribed fire compared to alternative A, but overall restoration treatment rates that promote 

pollinator habitat are greater in alternative B, B-modified, and D. Alternative A would provide the 

least restoration of habitat conditions supporting pollinators. In arid woodlands and shrublands, 

alternatives B, B-modified, and D would provide greater benefit to pollinators dependent on 

annual plants, in areas where invasive species are not dominant. All alternatives would have very 

similar impacts for pollinators dependent on perennial flowers.

Primary Cavity Excavators – Alternative C would provide the most snag habitat because of the 

lower levels of mechanical restoration, increased potential levels of prescribed fire, and higher 

snag retention levels. Alternatives B and B-modified would provide slightly higher levels than 

alternatives A and D. Alternative D would provide the lowest levels of snags. It is uncertain for all 

alternatives what the distribution of snags would be on the landscape among different habitat 

types (for example young versus old, burned versus unburned forests). As described above in the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

244

complex early seral forest discussion, alternatives C followed by alternatives B and B-modified

would have the most snag habitat in burned forests but only by marginally greater amounts.

Tribal Uses and Biocultural Diversity

Alternative D, followed by alternatives B and B-modified would provide the greatest increase in 

ecosystem condition for tribal uses. More restoration would occur in these alternatives that would 

improve plant, animal, and insect habitat. Alternatives B, B-modified, C, and D, all provide for 

increased tribal coordination and restoration of areas of tribal interest. These would all increase 

the amount and quality of restoration benefitting Tribes.

Integrated Terrestrial Ecosystem Sustainability

Table 41 provides an overall summary of conditions for characteristics of integrated sustainability

by alternative. 

Table 41. Summary of conditions for characteristics of integrated sustainability by alternative

Characteristic Alternative A Alternative B

Alternative 

B-modified Alternative C Alternative D

Terrestrial Ecosystem 

Condition

Low Low to 

moderate 

(restored 

areas)

Slightly 

higher than B

Low Moderate

Area outside of the 

natural range of 

variation (low and 

mid-elevations)

Very high Moderate

(restored 

areas) to high

Moderate

(restored 

areas) to high

High Moderate 

Area and percent of 

forest affected by 

processes or agents 

beyond the range of 

historic variation (by 

insects, disease)

High 

vulnerability

Moderate to 

high 

vulnerability

Moderate to 

high 

vulnerability

High 

vulnerability

Moderate 

vulnerability

Area and percent of 

forest land subjected 

to levels of specific 

air pollutants 

(sulfates, nitrate, 

ozone) or ultraviolet 

that may cause 

negative impacts on 

the forest ecosystem

Moderate, 

Jeffrey pine 

and dry 

mixed conifer 

vulnerable

Moderate, 

Jeffrey pine 

and dry 

mixed conifer 

less 

vulnerable 

than A

Moderate, 

Jeffrey pine 

and dry 

mixed conifer 

less 

vulnerable 

than A

Moderate, 

Jeffrey pine 

and dry 

mixed conifer 

vulnerable

Moderate, 

Jeffrey pine 

and dry 

mixed conifer 

less 

vulnerable 

than A, B, or 

C

Old Forest Condition 

and Vulnerability to 

Stressors

Very low, 

high 

vulnerability

Moderate, 

moderate to 

high 

vulnerability

Moderate, 

moderate to 

high 

vulnerability

Low, high 

vulnerability

(higher 

vulnerability 

than B and Bmodified)

Low to 

moderate, 

moderate 

vulnerability

Complex Early Seral 

Habitat Amount and 

Extent

Moderate to 

high, more 

large patches

High, more 

small patches

High, more 

small patches

Marginally

higher than B

Similar to B 

but less 

extensive

Limited Plant 

Community Condition

Mixed, low to 

high

Moderate to 

high

Moderate to 

high

Moderate to 

high

Moderate to

high
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

245

Out of all of the alternatives, alternative A provides the least likelihood of sustainability. 

Alternative D, followed by alternatives B and B-modified, is the most likely to improve the 

likelihood of sustainability. Alternative C could improve sustainability but there is greater 

uncertainty because there is more reliance on fire restoration treatments with less ability to treat 

the areas prior to burning.

Sustainability of old forest condition and extent is most influenced by the amount of restoration 

of the entire landscape it occurs within as well as the old forests themselves. Alternative D, 

followed by alternatives B and B-modified, would have the greatest overall levels of restoration 

and would increase resilience to large fires. Alternative D would have the greatest amount of 

restoration in old forests outside of the forest protection zones. This would increase the resilience 

of old forests to drought, insects, pathogens, air pollution and high-intensity fire. However, some 

large trees might be harvested. Alternatives A and C would have the most restrictions on 

restoration of old forest and vegetation overall. This might provide short-term protection for old 

forests but also increase the susceptibility of mortality from drought, air pollution, insects and 

pathogens and high-intensity fire. Alternatives B and B-modified provide the greatest balance of 

short- and long-term protection and integrity of old forests by maintaining higher restoration rates 

(higher than alternatives A and C) that reduce impacts of stressors, while providing for greater 

retention of large and old trees than alternative D, particularly outside the wildfire protection 

zones. Accordingly, alternatives B and B-modified would contribute most to the ecological 

sustainability of old forest condition.

Climate, Ecological Vulnerability and Adaptation

Background

This section summarizes ecological vulnerabilities to climate changes and effects of adaptation 

strategies and plan direction addressing ecological impacts of climate change. This section 

examines the overarching and critical effects of climate change on terrestrial and aquatic 

ecosystems. It adds detail to the general discussions in the “Terrestrial Vegetation Ecology”

section on individual vegetation types.

Analysis and Methods

This section summarizes the detailed analysis of climate vulnerability and adaptation found in the 

bio-regional and forest assessments (USDA Forest Service 2013a, 2013b, 2013c, and 2013d), the 

snapshots of the “Living Assessment” used to develop the final assessments (USDA Forest 

Service 2013e, 2013f, 2013g, and 2013h), and the Pacific Southwest Science Synthesis (Long et 

al. 2014). Additional information from several recent climate change vulnerability and adaptation 

assessments Kershner 2014, Finch 2012, Schwartz et al. 2013a, Lenihan et al. 2003 and 2008, 

and Thorne et al. 2017) and natural range of variation assessments (Safford et al. 2013a) are also 

incorporated.

Indicators and Measures

Ecological vulnerability indicators include tree mortality, distribution of species (elevational 

distribution of plants and animals), presence of nonnative invasive species, and changes in fire 

regime (changes to frequency, size, and severity).

Adaptation strategies can increase the resilience of ecosystems and resources to climate change 

impacts (Intergovernmental Panel on Climate Change 2014). Short-term adaptations build 

resistance and resilience, so that ecosystems are better able to withstand undesirable effects of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

246

climate changes such as diminished ecosystem integrity and function. In table 44, the alternatives 

are compared by their relative capacity to support various climate adaptation approaches that are 

recommended by climate vulnerability assessments and other best available science information 

sources. These approaches include: (1) increase adaptive capacity of ecosystems through 

ecological restoration and climate adaptation, (2) develop and use collaborative partnerships, 

(3) apply climate vulnerability assessments in planning and prioritization, and (4) use monitoring 

and adaptation. Collaborative partnerships are addressed in the “Benefits to People” section.

The primary adaptation strategies are listed below. These are based upon several recent climate

adaptation workshops (Southern Sierra Partnership 2010, Nydick and Sydoriak 2011c, Kershner 

2014) as well as scientific literature on climate change (North, Stine, O'Hara et al. 2009; Finch 

2012; Lawler, Safford, and Girvetz 2012; Safford et al. 2012; Safford, North, and Meyer 2012;

Millar, Stephenson, and Stephens 2007; Hanberry et al. 2015).

• Manage for vegetation heterogeneity and diversity;

• Restore or maintain key ecological processes, including fire in fire-adapted forest 

ecosystems;

• Reduce the density of smaller diameter, shade-tolerant trees in fire-adapted forests to levels 

more consistent with the natural range of variation;

• Reduce the chance of uncharacteristically large and severe wildfire and other climaterelated stressors using ecologically appropriate treatments, including prescribed fire, 

mechanical thinning, and wildfires managed for resource objectives within the natural 

range of variation;

• Implement rapid detection of and response to invasive species;

• Restore ecosystem function to degraded meadows, aquatic and riparian ecosystems;

• Identify and protect future climate refugia for other areas of native species persistence;

• Maintain and restore habitat connectivity across the ecoregion to facilitate species 

movements under rapidly changing conditions; and

• Enhance recruitment and expansion in species that are ecologically underrepresented 

(aspen), functionally important (whitebark pine), or climate resilient (pines). This includes

consideration of plant species and genotypes that may be adapted to warmer or drier

climate conditions in reforestation efforts.

Assumptions

• Ecological response models assess the response of ecosystems (vegetation, wildlife habitat) 

to climate change. These models include additional assumptions that increase the level of 

uncertainty (Glick, Stein, and Edelson 2011).

• The outcomes of management actions with climate change are also highly uncertain. 

However, best strategies for adapting to future change will be based on adaptive land 

management strategies that consider historic, current, and future projected changes in 

climate and climate-related processes (Wiens et al. 2012). This provides a more 

comprehensive evaluation of the effects of climate change in the absence of robust 

projections of future climate and climate-related processes (Safford, North, and Meyer

2012).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

247

• Plan components that specifically address climate change, including desired conditions and 

management approaches, will result in improved climate adaptation.

• Climate change is a primary stressor that has wide-ranging impacts and a strong interaction 

with other ecological stressors in the plan area, including wildfire, drought, insects, 

pathogens, air pollution, and invasive species.

• Plan components that result in increased pace and scale of restoring vegetation to a more 

resilient condition (desired conditions that reflect the natural range of variation) will 

substantially improve the capacity for climate response of major vegetation types. Thus, the 

increased pace and scale of restoration treatments will provide greater support of climate 

adaptation strategies focused on enhancing ecosystem resilience.

• Increased pace and scale of restoring vegetation will include proportionate measures to 

prevent or control nonnative invasive plant species to the extent possible.

It is assumed that the different adaptation strategies are equally important. However, depending 

upon the vegetation type, species or ecosystem process, that some strategies may be more 

important than others in a particular situation. Differences in the importance of adaptation 

strategies by vegetation type, species or ecosystem processes are analyzed in the “terrestrial 

Ecosystems,” “Aquatic and Riparian Ecosystems,” and “Species of Conservation Concern”

sections.

Affected Environment

Studies of terrestrial mammals, birds, and butterflies show that ranges of many species have been 

shifting to higher elevations and shrinking in high elevation zones, probably in response to 

warming temperatures and changing precipitation patterns (Safford et al. 2012). Similar

sensitivities are suggested for aquatic and riparian species (Hauptfeld and Kershner 2014a).

As described in the “Agents of Change,” “Terrestrial Vegetation Ecology,” and “Terrestrial 

Ecosystem Processes and Function” sections, there have been changes in wildfires, tree mortality,

and insect populations related in part to climate changes that affect species habitat and 

distribution. Wildfire frequency, size, total area burned, and fire severity have all been increasing 

in the Sierra Nevada over the last two to three decades. Larger trees are also dying from factors 

other than fire throughout many parts of the Sierra Nevada (Dolanc et al. 2014, Van Mantgem et 

al. 2009). This pattern is frequently associated with increasing moisture stress and bark beetle

activity related to increasing temperatures across western North America (Logan et al. 2003

(Logan, Regniere, and Powell 2003, Van Mantgem et al. 2009). More recently, especially in the 

last several years on the western slope of the southern Sierra Nevada, extensive tree mortality has 

occurred. In some areas, forests have experienced high levels of tree mortality (see “Insects and 

Pathogens” section). These elevated levels of tree mortality are likely due to the interacting 

effects of drought, bark beetles, forest densification, and warming temperatures. Higher winter 

temperatures allow more insect survival and buildup over winter. There may be a combination of 

increased drought stress as well as increased respiration of trees (absorb water and release water 

vapor) in warmer weather (Van Mantgem et al. 2009).

Projected Future Trends in Ecological Indicators

Climate vulnerability assessments for the plan area anticipate broad-scale changes in ecosystem 

conditions, such as fire regimes, vegetation, insect activity, and species distribution patterns. 

Table 42 shows the climate vulnerability of different major vegetation types based on the degree 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

248

of climate exposure (exposure to high rates of temperature change), sensitivity to climate change

(sensitivity to changes in moisture availability), and capacity to adapt to changing conditions

(ability to disperse or relocate to more favorable environment), which is ranked on a relative scale 

from high to low based on relative vulnerability among types (low vulnerability indicates a 

vegetation type that has lower climate exposure, reduced sensitivity to climate change, and higher

capacity to adapt to changing conditions). Information sources for climate vulnerability are 

covered in the analysis and methods section above. Models suggest the area of conifer-dominated 

forest in the southern Sierra Nevada will decrease substantially, especially for high-elevation 

forests (like subalpine areas). In contrast, many hardwoods and shrubs are expected to respond 

more positively than conifers to warmer nighttime temperatures and shifting disturbance regimes 

(such as increased fire intensity and bark beetle activity). This will result in the transition of some 

coniferous forest types to arid shrublands and woodlands on the Inyo National Forest. Many 

scenarios also show an increase in grassland area at lower and middle elevations, as woody 

vegetation retracts in the face of increased fire frequency and invasion by nonnative annual 

grasses. This is expected to occur especially at the lower elevations, where sagebrush and pinyon 

woodlands may shrink in distribution or move upwards in the coming decades.

Table 42. Climate vulnerability of major vegetation types in the plan area

Vegetation type Climate vulnerability1

Subalpine forest and alpine High

Red fir forest High

Wet meadow High

Riparian Moderate‒High

Dry mixed conifer and Jeffrey pine forest Moderate‒High

Xeric shrubland and blackbrush Moderate

Sagebrush Moderate

Pinyon-juniper woodland Low‒Moderate

Mountain mahogany Low‒Moderate

Annual grassland Low

1. Climate vulnerability indicates the degree to which a vegetation type is vulnerable to the 

effects of climate change, with the most vulnerable types (i.e., high climate vulnerability) 

indicative of high climate exposure, high sensitivity to climate change, and low capacity to 

adapt to future changes. Vulnerability is based on a relative scale of low to high.

Current trends of increasing fire activity (such as longer fire seasons, and changes to fire 

frequency) and larger burned areas are expected to continue in most vegetation types under 

almost all future climate scenarios (see “Fire Trends” section). Moisture stress and the frequency 

and severity of bark beetle outbreaks are projected to increase dramatically with increasing 

temperatures in the Sierra Nevada, resulting in widespread tree mortality (Bentz et al. 2010, 

Hicke et al. 2006). This is currently happening on parts of the Inyo National Forest, where tree 

mortality rates have been substantially increasing and may be approaching the upper limit of the 

natural range of variation (discussed in the “Insects and Pathogens” section). 

Regional climate trend assessments (Safford, North, and Meyer 2012), climate vulnerability 

assessments (Kershner 2014), and natural range of variation assessments suggest that climate 

change will have impacts to species that vary by individual plant and animal species. Table 43

shows the climate vulnerability of selected species or species groups in the plan area. This is not 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

249

an exhaustive list but instead rather representative species that are vulnerable in the different 

ecosystems in the Inyo National Forest.

Table 43. Climate vulnerability of select species or species groups in the plan area

Species or Species Group Climate Vulnerability1

High-elevation white pines2 High

Alpine chipmunk High

Greater sage-grouse High

Marten High

Mountain and Sierra yellow-legged frogs High

Aspen Moderate

Clark’s nutcracker Moderate

Swainson’s thrush Moderate

Stellar’s Jay Low

1. See table 42 for a description of climate vulnerability

2. Includes whitebark pine, foxtail pine, bristlecone pine, and limber pine

There will likely be increasing vulnerability of species resulting from direct and indirect effects of 

climate change. Direct effects will include increasing evaporative demand for plants with 

warming temperatures and resultant increased water stress. Indirect effects will include habitat 

loss from vegetation changes. For example, Clark’s nutcracker is dependent on whitebark pine in 

subalpine and alpine areas for food. If whitebark pine and these forests are heavily impacted by 

climate change, then Clark’s nutcracker will be heavily impacted.

Many models project significant range contractions in some species distributions, those with high 

climate sensitivity and low adaptive capacity. For example, alpine plants and animals that live at 

the highest elevations will have few if any other places to go to stay in the colder environments 

they are adapted to. Species with low adaptive capacity include those that have small and isolated 

populations, low genetic variation, and limited ability to move widely and low reproductive rates. 

Vulnerable species also include those with habitat tied to vulnerable vegetation types. For 

example, it is predicted that the conditions that support marten presence in California are likely to 

change greatly over the next century, potentially causing a pronounced loss of suitable habitat 

(Lawler, Safford, and Girvetz 2012). Marten are closely associated with red fir forests, which are 

dependent upon snowpack. Lawler, Safford, and Girvetz (2012) suggest that marten will be 

highly sensitive to climate change, with the largest impacts in the southern Sierra Nevada.

Environmental Consequences to Climate, Ecological Vulnerability and Adaptation

The alternatives were contrasted qualitatively in the opportunity, likelihood and rate of 

application of adaptation strategies focused on building adaptive capacity of ecosystems from 

restoration actions (table 44). A rating of high means that there were likely to be numerous 

opportunities and a high likelihood of applying adaptation strategies in multiple locations. A 

rating of low meant that there were few opportunities and a low likelihood of applying adaptation 

strategies on few to no locations. Moderate would be in between, either with a lower likelihood 

and/or fewer locations where adaptation strategies would be applied.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

250

Table 44. Rating of the amount of application climate adaptation strategies by alternatives (e.g., low 

indicates a low degree of application)

Climate Adaptation Strategy Alternative A

Alternative B and 

Alternative Bmodified Alternative C Alternative D

Manage for vegetation 

heterogeneity and diversity Low Moderate (in 15 to 

25 percent of area) Low

Moderate to high 

(in 30 to 60 percent

of area)

Restore or maintain key 

ecological processes (like fire) Low

Low to moderate

(moderate to high in 

Kern Drainage)

Low Moderate

Reduce density of smalldiameter trees, reduce tree 

density in sagebrush

Low Moderate (in 15 to 

25 percent of area) Low

Moderate to high 

(in 30 to 60 percent

of area)

Reduce impacts of climaterelated stressors Low Moderate Low Moderate

Rapid detection and rapid 

response to invasive species Low to moderate Low to moderate Low to moderate Low to moderate

Restore and maintain 

watershed function Low Moderate

(some low) Low Moderate

Restore function of nonmeadow riparian vegetation 

Low Low to moderate Low Low to Moderate

Restore function of meadow 

ecosystems Low Low to moderate Moderate Low to moderate

Improve resilience of aquatic 

ecosystems Low Low to moderate Low Low to Moderate

Protect future climate refugia Low Low Low Low

Post-disturbance climate 

adaptation response strategies Low Moderate Low Moderate

Enhance ecologically 

important species Low Moderate Low to moderate Moderate

Maintain and restore dynamic 

habitat connectivity Low Moderate to high Low to Moderate Low to high

Overall Low Moderate 

(few high, some low)

Low 

(some moderate)

Moderate 

(few high, some low)

The climate adaptation strategies were assumed to be equally weighted. There may be different 

ways to weight them, emphasizing the importance of some (such as reducing vegetation density 

or protecting future climate refugia) over others. Because this analysis is general and not specific 

to individual species, it would be difficult to provide ecological justification for a specific 

weighting scheme, since it would likely vary by individual species. For analysis specific to 

individual vegetation types or specific species of conservation concern see the “Vegetation 

Ecology, Wildlife and Plants” sections.

Consequences Common to All Alternatives

Decades of fire exclusion coupled with intensive logging in forest ecosystems of the southern 

Sierra Nevada have resulted in uncharacteristically high fuel loads and homogenous forest 

structure (Kilgore and Sando 1975, Mckelvey and Johnston 1992). These conditions increase the 

susceptibility of fire-adapted forest ecosystems to climate change and related influences on 

ecosystems including uncharacteristically severe wildfire, insect or disease outbreaks, and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

251

drought-triggered mortality (North, Stine, O'Hara, et al. 2009; Stephens, Millar, and Collins 

2010). All alternatives include the reduction of small-diameter, shade-tolerant trees to increase 

forest resilience, although the amount varies considerably by alternative. The desired conditions 

for vegetation are shared across alternatives B, B-modified, C, and D and they include reduced 

forest densities and a shift from dominance of smaller to larger trees (DMC-DC-03 to 04; TERRJEFF-DC-03; TERR-RFIR-DC-03, 05; TERR-LDGP-DC-04, 07, 08).

All alternatives would continue to have opportunities to maintain and restore vegetation in the 

Kern Drainage using wildfire managed for resource objectives. These areas currently have greater 

resilience to climate change and related trends in increased fire because extensive areas have had 

restoration of wildfire managed for resource objectives over the least 15 years (Fites-Kaufman, 

Noonan, and Ramirez 2005; Vaillant 2009; Meyer et al. 2015). This area has large landscapes that 

have reduced forest density and fuel conditions. Fires are limited in size when they reach 

numerous recent fires in the area (Ewell, Reiner, and Williams 2012; Reiner et al. 2016).

Aggressive eradication and containment of established invasive species will be an important 

component of ecosystem management under a changing climate. This is especially true 

considering that while fire plays an essential role in vegetation restoration, these same activities 

can result in invasive plant species introductions and spread (Keeley 2006). Projections are for an 

increase in burned area with climate change (see “Fire Trends” section). All alternatives include 

taking an approach to controlling invasive species and preventing their introduction. Similar plan 

direction from the existing plans has been incorporated into the proposed new plans and would be 

similar under alternatives B, B-modified, C, and D. This includes desired conditions limiting 

invasive plant invasion and spread (INV-FW-DC-01 to 02; MA-RCA-DC-01), and management 

approaches, standards, and guidelines to reduce invasion and spread during management 

activities using an early detection and rapid response strategy (INV-FW-STD-01; INV-FW-GDL01 to 06).

No alternatives have identified future climate refugia for native species persistence, except for a 

desired condition for special habitats that would apply to alternatives B, B modified, C, and D 

(SPEC-FW-DC-03). However, vulnerability assessments for the southern Sierra Nevada have the 

potential to identify future climate refugia that can be prioritized for restoration or monitoring. 

Alternatives B, C, and D would share desired conditions that address connectivity and the ability 

of species to move and persist across larger areas (MA-RCA-DC-01; RCA-RIV-DC-02; TERRFW-DC-06; TERR-SAGE-DC-04; TERR-SAGE-GOAL-01b; TERR-OLD-DC-02SPEC-CSODC-01; SPEC-SG-DC-04).

No alternatives have addressed prioritization of restoration to address vulnerabilities to climate 

change. However, alternatives B, B modified, C, and D provide climate adaptation response 

strategies by emphasizing vegetation restoration to reduce climate-related stressors including 

large and severe wildfires, insect outbreaks, invasive species, and drought (table 4, page 83).

Monitoring and adaptive management approaches are fundamental to understanding how to 

respond to the impacts of climate change. All alternatives include monitoring and adaptive 

management as a component of their plan management strategies, approaches, and tools. 

Alternatives B, B modified, C, and D apply the 2012 Planning Rule that was developed in part to 

use a more flexible and adaptive planning process that allows for more frequent and streamlined 

plan amendments and revisions. This adaptive process, provides greater potential for alternatives

B, B modified, C, and D to monitor, learn, and adapt to rapidly changing climate.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

252

Consequences Specific to Alternative A

Alternative A has no management direction specific to climate adaptation or resilience. There is 

some ecological restoration aimed at reducing forest density but it is limited in intensity and 

extent. Alternative A has the lowest potential to reduce the risk of undesirable wildfires because 

of the reduced fuel treatment rates under this alternative that have resulted in a significant fuel 

treatment “backlog” and fuel buildup in Sierra Nevada forest ecosystems Alternative A would not 

emphasize forest heterogeneity approaches to promote resilience to the same degree as the other 

alternatives. Compared to the other alternatives, alternative A has the lowest rate of watershed 

restoration (less focus on priority watersheds) and has an increased potential for wildfires burning 

at increased severity outside the historic range of variation that may impair watershed function 

(such as increased soil erosion and sedimentation). Fewer fuel reduction treatments, less 

watershed restoration, and less emphasis on heterogeneity restoration would likely result in less 

prescribed burning and fewer wildfires managed primarily for resource objectives than other 

alternatives. Although alternative A has the least potential to reduce the risk of large wildfires 

which would be vulnerable to weed invasion, it also has the fewest restoration activities such as 

prescribed fire and mechanical treatments that would be vulnerable to being invaded by nonnative

plants.

Alternative A provides the least benefit to certain ecologically important species, such as aspen 

and whitebark pine, because it has the lowest treatment rates in special habitats, unique vegetation 

types, and whitebark pine stands, and the lowest potential use of wildfire managed primarily to 

meet resource objectives. Alternative A may incorporate some of these recommendations, but 

they are not part of the plan direction and there is uncertainty that the recommendations would be 

implemented. Consequently, alternative A would do the least to integrate climate vulnerability 

assessments in planning and prioritizing of all the alternatives. Alternative A does not address 

vulnerabilities to climate change for riparian and aquatic ecosystems. Alternative A does not have 

plan monitoring components focused specifically on climate change and there are no direct and 

indirect indicators of changing climate conditions.

Consequences Specific to Alternative B

Alternative B emphasizes plan direction that would increase the resilience of vegetation directly 

to climate change and indirectly through increased vegetation and watershed resilience to fire, 

drought, insects, and pathogens. This includes desired conditions on resilience to climate change 

and sustainability in the face of climate change for watershed and terrestrial ecosystems (WTRFW-DC-01, -03 to 04; TERR-FW-DC-02, -04, -07, -08) and riparian and aquatic ecosystems 

(MA-RCA-DC-09; RCA-MEAD-DC-02; RCA-RIV-DC-01; RCA-SPR-DC-02-03). There is a 

goal to integrate landscape or watershed approaches to restoration that integrates recreation, fuels, 

partnerships, and vegetation management to effectively address climate change (WTR-FWGOAL-01).

Alternative B would manage for forest and shrubland vegetation heterogeneity and diversity and 

restore or maintain key ecological processes (such as fire in frequent fire systems), and key 

approaches for resilience to climate change through guidelines and desired conditions (TERRFW-GDL-01; TERR-FW-DC-01; TERR-MONT-DC-01 to 03; TERR-DMC-DC-01 to 03; TERRJEFF-DC-01 to 03; TERR-RFIR-DC-01 to 03; TERR-LDGP-DC-01 to 03; TERR-ALPN-DC-01, 

02; TERR-SAGE-DC-01 to 02; TERR-PINY-DC-01 to 02; TERR-XER-DC-01 to 03). This 

includes restoration of vegetation density and composition to vegetation types and specific 

desired conditions that are based primarily on the natural range of variation for those types (see 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

253

“Terrestrial Vegetation Ecosystem” section for more detail). In alternative B the assumption is 

that fire, and low resilience to drought, insects, and pathogens are the greatest risk to all 

ecosystems. Therefore, the emphasis is on restoring the resilience of terrestrial ecosystems. 

Alternative B would likely increase structural heterogeneity based on the emphasis of mechanical 

thinning and prescribed fire treatments to implement concepts of ecological restoration in 

westside forests (North, Stine, O'Hara, et al. 2009; North 2012b) and vegetation diversity in 

eastside sagebrush and pinyon-juniper woodlands. This would occur on 15 to 25 percent of the 

landscape, primarily in the montane, Jeffrey pine, pinyon-juniper and sagebrush vegetation types

(TERR-FW-OBJ-01 to 03).

Alternative B would have a moderate likelihood of reducing the chance of uncharacteristically 

large and severe wildfire and other climate-related stressors in portions of the plan area based on 

the combined rates of mechanical and prescribed fire treatments and use of wildfire managed to 

meet resource objectives (see the “Fire Trends” section). Alternative B has greater treatment rates 

of mechanical treatments, prescribed fire, and wildfires managed for resource objectives (TERRFW-OBJ-01 to 03) than alternatives A and C. The greater use of mechanical treatment and 

prescribed fire in the montane, Jeffrey pine, pinyon-juniper, and sagebrush vegetation types 

would provide greater resilience to climate change, since these vegetation types are most departed 

from the natural range of variation. The greater use of wildfires managed for resource objectives 

(MA-WRZ-DC-02 and 03; MA-WMZ-STD-01; MA-WMZ-GOAL-01) would be critical to 

reduce fuel loading and the vulnerability of forest ecosystems across large spatial scales in the 

southern Sierra Nevada (Meyer 2015a), especially considering the high level of mechanical 

constraints in the steep and inaccessible areas that occur in many parts of the analysis area (North 

et al. 2015). Use of wildfires managed for resource objectives would occur primarily at higher 

elevations and in the Kern River Drainage where landscape fuel conditions are moderate to low 

overall. Since red fir, subalpine and alpine ecosystems have a high vulnerability to climate 

change, continued restoration of fire in these areas would provide increased resilience to climate 

change.

Alternative B would restore watershed function at a slightly higher rate by increasing the 

emphasis on priority watersheds for management actions (WTR-FW-OBJ-01) and objectives for 

water quality improvement projects (RCA-RIV-OBJ-01 to 02). Vegetation treatment rates in 

riparian ecosystems and meadows would also likely be higher in alternative B (MA-RCA-OBJ01; RCA-MEAD-OBJ-01) compared to alternative A, resulting in greater resilience to climate 

change and in some locations resilience to fire under alternative B. There is less emphasis on 

direct restoration of aquatic ecosystems. There would be limited improvements to aquatic 

ecosystem resilience as a result. There would continue to be vulnerability of many aquatic 

ecosystems to changing hydrographs and temperature thus increasing their vulnerabilities to 

climate change. There would be improvements to resilience of meadows to climate change that 

are restored as a result of meadow restoration objectives.

In the long term, greater resilience of forest and shrubland vegetation would improve climate 

resilience in areas where restoration is emphasized and may maintain relatively greater levels of 

habitat connectivity for forest-dependent species by facilitating species movements into suitable 

future habitat (higher elevation forests or climate refugia).

Desired conditions are provided to ensure habitat connectivity for wide-ranging species (MARCA-DC-01 and 04; RCA-RIV-DC-01; TERR-FW-DC-06; TERR-SAGE-DC-04; TERR-SAGEGOAL-01b; SPEC-CSO-DC-01; SPEC-SG-DC-04; TERR-OLD-DC-02).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

254

There would continue to be large, high-intensity fires, especially in unrestored areas in the 

montane and eastside pine, pinyon-juniper and sagebrush landscapes that would disrupt 

connectivity for some species. Only a portion of the landscape would be restored and fire trends 

would continue in many areas (see “Fire Trends” section). Species associated with mature forest 

or shrublands, including marten and greater sage-grouse, would continue to have disruptions in 

connected habitat in many areas. For more detail, see the “Old Forest” and “At-risk Terrestrial 

Wildlife Species” sections. There would be consideration of climate change in post-fire 

restoration. This is from numerous desired conditions that emphasize resilience to climate change 

(see above). There would also be a specific plan components to consider climate change 

adaptation in restoration related to reforestation (TIMB-FW-GDL-02), post-disturbance forest 

ecosystems (TERR-CES-GOAL-01i), arid shrublands and woodlands (TERR-PINY-DC-01; 

TERR-PINY-GOAL-01f; TERR-SAGE-GOAL-01f), and a management approach that addresses 

native vegetation:

Promote native vegetation (e.g., conifers, aspen, shrubs) in complex early-seral habitat 

that supports long term ecosystem integrity considering climate change, drought, insects, 

disease and fire.

Restoration in alternative B would have some benefits to ecologically important species that have 

a high vulnerability to climate change, such as aspen and whitebark pine. The restoration of 

special habitats, unique vegetation types (like aspen), and whitebark pine stands would increase

and there would be specific direction to improve management of these unique ecological 

communities. The greater use of wildfire managed to meet resource objectives would likely 

improve conditions for aspen and whitebark pine because they respond positively to mixedseverity fires.

Climate vulnerability assessments provide useful insights in the regional impacts of climate 

change. In the southern Sierra Nevada, several recent vulnerability assessments are available for 

assessing climate change effects to terrestrial and aquatic ecosystems in the plan area (Nydick and 

Sydoriak 2011a, c). Alternative B incorporates at least some recommendations of these climate 

vulnerability assessments in planning and prioritization efforts for terrestrial ecosystems (like for 

whitebark pine restoration). There is a guideline that addresses consideration of refugia for 

aquatic and riparian species associated with small-scale special habitats that are less likely to have 

connected habitat (SPEC-FW-DC-04). Fewer recommendations from the Climate Vulnerability 

and Adaptation Strategy (Kershner 2014) to use strategies and standards to address climate 

change vulnerabilities for aquatic systems were incorporated. Increased meadow restoration is 

one area where the recommendations were incorporated. Vulnerabilities to climate change for 

aquatic ecosystems are already being manifested in terms of decreased water flows and increased 

temperature.

Alternative B would have moderate potential to reduce the risk of large wildfires, which would 

make areas vulnerable to weed invasion, but it also has more restoration activities such as 

prescribed fire and mechanical that could also make areas more vulnerable to being invaded by 

nonnative plants. There is specific management direction (desired conditions, guidelines, and 

standards) to limit the invasion and spread of nonnative invasive plants that are common to all 

alternatives (described above). Alternative B also incorporates objectives to restore infested areas 

(INV-FW-OBJ-01) that would lessen the effects of climate change on increasing invasive plant 

spread. However, this would not be enough to keep up with the pace of increased invasions. 

There is a specific management approach directed at improved understanding of effectiveness of 

different methods to reduce climate related invasive species spread:
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

255

Coordinate with research and other organizations to evaluate the potential effects of 

climate change on the spread of invasive, nonnative species.

Alternative B uses more flexible plan direction and an adaptive planning process that allows for 

more streamlined plan amendments and revisions than alternative A, which requires more 

prescriptive and restrictive plan direction developed under the 1982 Planning Rule. In alternative 

B, the emphasis is on specific desired conditions at multiple spatial scales (from patches to 

landscapes) that allow for a wide range of site-specific actions to implement. This adaptive 

process that is inherent in the new planning rule provides greater potential for alternative B to 

monitor, learn, and adapt to rapidly changing climate.

Consequences Specific to Alternative B-modified

The consequences of alternative B-modified would be similar to alternative B, but there would be 

a slightly higher restoration treatment rate (specifically mechanical thinning and wildfires 

managed to meet resource objectives) under alternative B-modified. As a consequence, the 

overall adaptive capacity of montane forest stands to climate change and climate-related stressors 

would be marginally higher in alternative B-modified compared to alternative B. Slightly 

increased restoration treatment rates (about 3 percent per decade in montane forest ecosystems) 

would result in marginally more forest stands with increased structural heterogeneity and 

diversity, reduced stand densities, restoration of fire as an ecological process, enhanced watershed 

and ecosystem function, and other ecological benefits. As in alternative B, restored vegetation 

conditions in alternative B-modified would increase the adaptive capacity of terrestrial and 

aquatic ecosystems to respond to climate change and interacting stressors such as uncharacteristic 

wildfires and hotter droughts.

About 133,490 acres would be reclassified from the Maintenance or Restoration Fire 

Management Zone to the General Wildfire Protection Zone in alternative B-modified. Nearly all 

of these acres are located in lower elevations of the sagebrush vegetation type, where the primary 

restoration approaches will rely on methods other than wildfires managed to achieve resource 

objectives (prescribed burning or mechanical thinning of encroaching conifers). Although this fire 

management zone reclassification would not result in changes to sagebrush treatment rates, it 

would result in slightly fewer wildfires burning in this vegetation type in areas with potential for 

fire-facilitated cheatgrass invasion. The additional protection from fire-facilitated cheatgrass 

invasion in alternative B-modified would result in slightly more acres with proper watershed and 

ecosystem function, reduced vulnerability to climate-related stressors, and dynamic habitat 

connectivity in sagebrush ecosystems compared to alternative B.

Consequences Specific to Alternative C

Alternative C shares many of the desired conditions for forest structural heterogeneity and 

diversity and restoration and maintenance of key ecological processes (like fire) as alternative B.

However, restrictions on reducing canopy cover and using mechanical restoration in mixed 

conifer and eastside Jeffrey pine forests would limit the amount of restoration of vegetation to the 

desired conditions. This would result in lower levels of heterogeneity. Much of the landscape 

would remain in the current condition of high forest density. There would be an increased 

emphasis on restoration using prescribed fire and wildfires managed primarily for resource 

benefit but the opportunities for this type of restoration would be low in most areas (except Kern 

Drainage as mentioned previously) because vegetation would be denser and fires harder to 

control. Overall there would be lower resilience of mixed conifer and Jeffery pine forests to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

256

climate change and associated stressors of drought, insects and pathogens, and high-intensity 

wildfire.

Because of the denser forest conditions, there would be fewer opportunities to reduce the chance 

of uncharacteristically large and severe wildfire and other climate-related stressors in the plan 

area based on the combined rates of mechanical and prescribed fire treatments and use of wildfire 

managed to meet resource objectives. The greater use of wildfires managed for resource 

objectives would be critical to reduce fuel loading and the vulnerability of forest ecosystems 

across large spatial scales in the southern Sierra Nevada (Meyer 2015a), especially considering 

the high level of mechanical constraints in the steep and inaccessible areas that occur in many 

parts of the analysis area (North et al. 2015). The outcome of such fires in alternative C would be 

larger patches of high-severity fire because vegetation would remain denser throughout much of 

the montane landscape.

Alternative C would restore watershed function by increasing the emphasis on priority watersheds 

for management actions. There would be an increased emphasis on restoration using prescribed 

fire and wildfires managed primarily for resource benefit; however, whether this is sufficient to 

reduce risk of large, high-intensity fire and improve resilience to climate change in riparian 

ecosystems and meadows is unknown. It is unlikely that alternative C would result in improved 

watershed resilience compared to alternatives B and B modified.

Alternative C would have varied benefits to ecologically important species (such as keystone 

species). Although there is an emphasis on species conservation in alternative C, the benefits to 

some special habitats and unique vegetation types that are especially at risk (like aspen and 

whitebark pine) may be fewer than alternatives B and B modified due to less overall restoration 

that could include these areas. For those aquatic species without conservation strategies or 

standards and guidelines, alternative C would not improve habitat conditions or decrease 

vulnerabilities to climate change.

Like alternatives B and B modified, alternative C incorporates some of the recommendations of 

recent climate vulnerability assessments (especially for terrestrial ecosystems) that would 

increase climate adaptation. Alternative C would similarly apply only limited recommendations 

for aquatic ecosystems. The objectives for meadow restoration are increased and would provide 

for increased climate resilience in restored meadows and for associated aquatic ecosystems, 

especially downstream.

For nonnative invasive plant species, alternative C would have a more limited use of mechanical 

treatment and would reduce risk of invasion. However, this may be outweighed by a likely 

increase in the amount of burned area predicted from climate change (see “Fire Trends” section).

Consequences Specific to Alternative D

Alternative D would have similar consequences to alternative B but there would be a greater 

amount of terrestrial, riparian and aquatic ecosystem restoration. The amount of restoration would

be greater than that in alternatives B and B modified and more than double what currently occurs 

under alternative A (including wildfires managed for resource objectives). This would decrease 

the likelihood of large, high-intensity fires (see “Fire Trends” section) and increase vegetation 

resilience to climate change and related stressors. There may be increases in the spread of 

nonnative plants because of increased mechanical restoration; however, there would also be plan 

direction similar to alternatives B and B modified designed to reduce and limit invasive plant 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

257

establishment and spread. Nonetheless, nonnative plants are likely to increase to a greater degree 

under alternative D than alternatives A, B, B-modified, or C.

Alternative D has the greatest potential to reduce the risk of large wildfires which would be 

vulnerable to weed invasion, but it also has the most restoration activities such as prescribed fire 

and mechanical restoration that would be vulnerable to being invaded by nonnative plants.

Alternative D has the greatest potential for short-term impacts to habitat connectivity due to the 

increased amount of restoration occurring in a relatively short period of time, but it provides the 

most reduction of risk of large, high-intensity wildfires that have long-term impacts on 

connectivity of forest cover. The plan components from alternatives B and B modified would 

reduce some of the short-term impacts by incorporating the consideration of maintaining or 

restoring connectivity in project design.

Cumulative Effects

There are three aspects to cumulative effects from climate change. First, there are the cumulative 

effects of multiple climate change adaptation strategies. Second, there are cumulative effects of 

management across different adjacent ownerships. These interact with cumulative effects of 

climate change over time.

The cumulative effects of climate change and climate-related stressors (such as

uncharacteristically large and severe wildfire, insect outbreaks, and nonnative invasive species) 

can be substantial to ecosystems in the plan area. The incorporation of multiple or many climate 

adaptation strategies may synergistically build greater adaptive capacity than the application of a 

few approaches. Adaptation strategies that increase climate resilience across larger areas in more 

vulnerable ecosystems are likely to have the greatest positive effect. This includes restoration of 

vegetation that reduces the likelihood of large, high-intensity fire.

Reasonably foreseeable management activities on private, State, tribal, or other Federal land 

would vary in the application of climate adaptation strategies. Some management activities on 

adjacent tribal lands, national parks, and Bureau of Land Management-managed lands would be 

similar, including vegetation restoration, aquatic and riparian restoration, and measures to 

enhance habitat resilience of species and vegetation types vulnerable to climate change. Private 

land owners may implement some similar actions in conjunction with Natural Resources 

Conservation Service programs to restore watershed health and function or improve grazing 

lands. These actions would increase the positive benefits of climate adaptation actions on the 

national forest. Conversely, a lack of restoration actions on these adjacent lands could increase the 

vulnerability of terrestrial, riparian and aquatic ecosystems on national forest lands because the 

likelihood of large, high-intensity fires and limited resilience of widespread vegetation types 

would persist. Coordinated efforts across all ownerships would provide the greatest cumulative 

positive impact on climate adaptation.

Lastly, in the foreseeable future, climate will continue the trend of increasing temperature, earlier 

snowmelt, and increased level of fluctuating precipitation. It is unknown whether the current 

drought will continue or other more severe ones will occur. The climate record suggests that this 

is possible although when or how long is uncertain.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

258

Analytical Conclusions

Based on the climate adaptation indicators and measures, alternative D, followed closely by 

alternatives B and B-modified, are best for achieving overarching forest management goals and 

objectives under climate change. Alternatives B, B-modified, C, and D share most of the same 

desired conditions that incorporate resilience and adaptation to climate change. They all 

emphasize an all lands approach to management, encouraging partnerships with a wide variety of 

public groups, communities, and government agencies. These will increase the likelihood of a 

successful outcome of the application of climate adaptation strategies.

Alternative D has the greatest flexibility in the amount of vegetation restoration that would reduce 

the impacts of high-intensity fire, drought, and warmer temperatures on vegetation. Alternatives

B and B-modified have increased flexibility to conduct vegetation restoration landscape areas and 

has the potential to double current levels of restoration largely due to greater opportunities to 

manage wildfires for resource objectives. However, alternative D proposes the highest amount of 

restoration compared to alternatives A, B, B-modified, and C. Although alternative D results in 

greater potential to increase current non-climate stressors on ecosystems related to management 

activities (such as reducing habitat connectivity in the short term compared to the current 

condition), it moves the most area toward the vegetation natural range of variation over time and 

provides for the most dynamic habitat connectivity in the long term by increasing the resilience of 

vegetation to disturbance. In contrast, alternatives B, B-modified, and C contribute less to nonclimate stressors on ecosystems in the short term and maintain current habitat connectivity.

However, these two alternatives would have more areas at risk to dynamic habitat connectivity 

because of continuing high risks of large, high-intensity wildfires.

Alternatives A and C have the least flexibility in vegetation management and the least area 

planned for restoration. Both alternatives emphasize conservation of moderate to high density 

canopy cover in late seral forest habitat and would result in retention of dense vegetation 

conditions that have low resilience to large, high-intensity fires, drought and temperature 

increases. Desired results in terrestrial ecosystems and watersheds would be achieved more 

rapidly in alternatives B, B-modified, and D, but potentially at greater short-term impacts to

habitat for at-risk species than alternative C and possibly alternative A.

Aquatic and Riparian Ecosystems

Water Quality, Water Quantity, and Watershed Condition

Background

This section summarizes the current hydrological environment and soil conditions on the Inyo 

National Forest and the consequences of implementing the revised plan or its alternatives. Water 

originating on the national forest supplies municipal water and produces electric power to Los 

Angeles flowing through the Los Angeles Aqueduct (Water and Power Associates). Stream flows 

within the national forest provide recreational opportunities for locals and visitors. Water is 

integral for ecological sustainability. Streams, lakes, springs, and their associated riparian areas 

are relatively rare and important habitats on the Inyo. The Owens, South Fork of the Kern, and 

Middle Fork of the San Joaquin Rivers originate on the Inyo National Forest. The watersheds of 

these rivers contain meadows and corridors of riparian vegetation that provide wildlife habitat, 

recreational opportunities, and function to store and release water year round. The quality and 

quantity of water is of critical importance because these watersheds provide water for use by 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

259

millions of agricultural, residential, and industrial users downstream. The waters from the 

southern Sierra Nevada are essential for population centers ranging from small communities like 

Lee Vining, east of Yosemite National Park, to metropolitan areas like Bakersfield and Los 

Angeles.

For the purposes of analysis, overall watershed conditions are described in terms of 10,000 to 

40,000-acre watersheds called HUC-12 watersheds.24 The Inyo National Forest contains all or 

part of 132 HUC-12 watersheds within the Kern River, Owens River, San Joaquin River, Mono 

Lake basin and several terminus lake beds in Nevada. 

Streams and rivers are used for water supply, irrigation, transportation, hydropower, waste 

disposal, mining, flood control, timber harvest, and recreation. Many of these uses have a long 

history on the national forest and have made aquatic and riparian systems the most altered and 

impaired habitats of the Sierra Nevada. As the population of California has grown, so has the 

demand for water, leading to a potential for greater diversion and de-watering within Sierra 

Nevada hydrologic systems.

The Sierra Nevada ecosystem produces approximately $2.2 billion in commodities and services 

annually and water accounts for more than 60 percent of that total value (Hunsaker, Long, and 

Herbst 2014a). For more detailed information on water conditions see the assessments for the 

Inyo National Forest (USDS FS 2013a).

Analysis and Methods

The analysis evaluates and compares estimated future conditions for each alternative to the 

desired conditions. The indicators, measures, and assumptions described below are used to 

evaluate how the alternatives move toward desired conditions, and identify potential 

consequences from management actions across the Inyo National Forest. The indicators are used 

to predict future conditions related to water resources and overall watershed condition under the 

five alternatives.

The qualitative analysis is based primarily on the best available scientific information derived 

from the forest assessments (USDA Forest Service 2013a), the Bio-Regional Assessment (USDA 

Forest Service 2013d), the Science Synthesis (Long et al. 2014c) and recent reports and 

publications that assess current conditions and trends in conditions. In particular, soil and water 

best management practices monitoring data were reviewed to evaluate the effectiveness of current 

constraints on management actions. In addition, watershed condition assessments using the Forest 

Service Watershed Condition Framework were examined for the Inyo National Forest to assess 

the existing watershed condition ratings and identify restoration opportunities. Since the 

Watershed Condition Framework is composed of various indicators, each alternative was 

evaluated on how it would likely effect three key indicators (water quality, water quantity, and 

watershed condition). Stream condition inventory monitoring and assessment data and State 

303(d) listing information were also examined where available to evaluate restoration 

opportunities across the national forest.

 24 HUC-12 refers to “hydrologic unit code” 12, which indicates a very large-scale watershed. As watersheds decrease in 

size and are nested as subwatersheds, the hydrologic unit code number decreases. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

260

Indicators and Measures

This analysis uses three indicators: Water quality, water quantity, and the overall watershed 

condition. These indicators are evaluated over two general time periods to compare and contrast 

how the different alternatives would affect the aquatic resources.

• Short-term impacts generally run for 1 to 5 years after an event 

• Long-term impacts generally run from 5 years through the life of the plan

Water Quality

Water quality may impact the health of aquatic habitat, as well as other beneficial uses of water as 

defined by the State Water Resources Control Board (SWRCB 2015). The two most critical 

parameters with the potential to influence water quality at the landscape scale or be influenced by 

climate change are sediment loading and water temperature (Hunsaker and Neary 2012, Neary et 

al. 2005, Young et al. 2009). Other water quality parameters such as nutrient inputs (like nitrogen 

and phosphorus), metals, and bacteria (such as E. coli) are also a concern to water quality but are 

best addressed at the project level considering requirements of the Clean Water Act.

Water Quantity

Water quantity refers to the timing, overall distribution, and volume of water produced from 

forest watersheds, and includes both surface and groundwater resources. Water quantity is largely 

dependent on the amount, type, and timing of precipitation. Soil conditions and impervious 

surfaces affect how precipitation is distributed, whether through runoff or ground infiltration. 

Shallow groundwater recharge and storage redistributes the water not captured by plant roots as 

streamflow, and as springs and seeps.

Watershed Condition

In March 2011, the Forest Service assessed the condition of National Forest System lands for all 

HUC-12 watersheds, including 132 on the Inyo National Forest,25 using standardized protocols 

(Potyondy and Geier 2011). In 2015, the Forest reassessed 12 HUC-12 watersheds based on 

changed conditions in these watersheds. This watershed condition classification system, known as 

the Watershed Condition Framework, uses 12 indicators consisting of attributes related to 

watershed processes. The indicators and their attributes are surrogate variables representing the 

underlying ecological functions and processes that affect soil and hydrologic function. The 

indicators include water quality, water quantity, aquatic habitat, aquatic biota, riparian and 

wetland vegetation, roads and trails, soils, fire regime or wildfire, forest cover, rangeland 

vegetation, terrestrial invasive species, and forest health. Each indicator consists of one or more 

attributes and is assigned a weighted score. The overall watershed rating is based on amalgamated 

values of these attributes and indicators.

For the majority of the indicators, the Forest Service can take direct action that can contribute to 

maintaining or improving watershed condition, integrity and functionality. This provides a direct 

linkage between the classification system and management or improvement activities the Forest 

Service conducts on the ground (USDA Forest Service 2011d). The watershed condition 

framework and the Forest Service Manual (FSM 2521.1) use three classes to describe watershed 

condition and the condition is related to geomorphic, hydrologic, and biotic integrity and their 

functioning relative to their natural potential. Following are three watershed condition class 

ratings:

 25 http://www.fs.fed.us/biology/watershed/condition_framework.html
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

261

• Class 1 watersheds are considered to be functioning properly

• Class 2 watersheds are considering to be functioning at risk

• Class 3 watersheds have impaired function

Assumptions

There are several assumptions about ecological restoration and how different management tools 

may affect water quality, water quantity, and overall watershed condition that are described in the 

assumptions section in the “Aquatic and Riparian Ecosystem Integrity” section. There are some 

additional assumptions that inform this analysis as well.

Water Quality

• Projects developed under all alternatives would implement established best management 

practices to protect soil and water quality (USDA Forest Service 2011d, 2012b). Based on 

results of past monitoring, best management practices are expected to reduce both shortand long-term adverse impacts to less than significant levels. The Forest Service would 

continue to follow agency direction to implement an annual best management practices 

evaluation and adaptive management program. These results would then be reported to the 

jurisdictional Regional Water Quality Control Boards.

• The Forest Service would continue to work with the jurisdictional Regional Water Quality 

Control Boards to identify management strategies to address current 303(d) watersheds, 

and sources of non-point source pollution and develop total maximum daily load (TMDL) 

listings. Projects would comply with requirements of the Clean Water Act.

• The Forest Service would continue the transportation analysis planning process to 

systematically identify and address segments of roads that are causing impairment to 

hydrologic function or causing accelerated erosion.

• The Forest Service would continue to pursue opportunities to retrofit, relocate, or 

decommission roads and trails to reduce potential sediment transport to rivers and streams, 

especially within priority watersheds as outlined in watershed restoration action plans. 

System trails are currently undergoing a similar assessment and retrofit program, but are 

not considered to present the same degree of water quality threat as the road network 

because of their relatively small footprint.

• While uncertainty surrounds the degree of climate changes, observed warming air 

temperatures combined with fire suppression and insect outbreaks have changed fire 

behavior, creating the potential for increased size, intensity and frequency of wildfires, and 

observed increases in water temperatures during late summer and this is expected to 

continue (Null et al. 2013, Knowles and Cayan 2002).

• Some management activities and national forest infrastructure such as mechanical 

vegetation management treatments, roads, campgrounds, and grazing management have the 

potential to cause both short- and long-term adverse impacts to water quality that are 

evaluated and mitigated at the site-specific project level when projects are proposed and 

designed. A discussion of possible effects to water quality from the different alternatives is 

found in the “Environmental Consequences” section on page 267. 

• Forest Service restoration activities, such as landslide stabilization, road decommissioning, 

stream channel, floodplain, and meadow restoration reduce sedimentation, and restore 

resiliency to watershed processes that affect water quality.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

262

• Shallow groundwater serves as a filtering system for surface water and helps maintain 

beneficial temperatures for native fish.

Water Quantity

• The quantity of shallow groundwater is reduced under drought conditions and where 

infiltration is limited by development or hydrophobic soils, which occur in areas of high 

burn intensity after wildfire.

• The Inyo contains portions of the following recognized groundwater basins: Mono Valley, 

Adobe Valley, Long Valley, Owens Valley, Saline Valley and Rose Valley. The alternatives 

considered in detail would not affect use of groundwater in these basins.

• The Forest Service would work with the states of California and Nevada regarding 

regulated water rights, particularly during periods of drought.

• Meadow restoration activities would help regulate and extend the season of water flows, 

and may help mitigate climate change effects as flows become more erratic and the season 

for ephemeral flows changes.

• Climate predictions include increased warming, less snowpack, and earlier spring 

snowmelt. These changes would influence the amount of water supply that can originate 

from national forest lands and from precipitation.

• Climate changes, especially where rain precipitation replaces snowfall, tend to increase 

runoff and reduce infiltration and shallow groundwater recharge.

• The amount of impervious surface throughout a watershed affects the timing and flow 

characteristics because a greater area of impervious surface reduces infiltration into the soil 

of rain and snowmelt.

Watershed Condition

• Management direction would provide opportunities to improve watershed conditions to 

protect and restore the high value ecological functions of aquatic and riparian ecosystems. 

Restoration of terrestrial ecosystems would also improve or maintain watershed condition 

by increasing fire resilience, and reducing risk of large high-intensity wildfire. Under all 

alternatives, projects listed in the watershed restoration action plans would continue to be 

planned and completed within the priority watersheds.

• There would continue to be a risk of adverse resource effects associated with wildfire under 

each of the alternatives, which could result in degradation of overall watershed condition. 

The relative difference in wildfire risk between alternatives is described in the “Fire 

Trends” and “Fire Management” sections. It is assumed that the level of risk of adverse 

effects on soil and water resources can be estimated by the level of risk of catastrophic 

wildfire.

• Stream channel and floodplain restoration efforts planned and implemented, under all the 

alternatives would improve resilience to and mitigate some effects of climate change. 

Geomorphically stable stream channels and floodplains that exist in a state of dynamic 

equilibrium are better able to adjust to climate change impacts to hydrology, without 

resulting in adverse impacts to aquatic habitat, water quality, or water quantity.

The following table outlines the objectives for the number of acres of riparian vegetation 

improved; number of meadows enhanced or improved; and miles of streams restored for each of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

263

the plan revision alternatives. These numbers are the basis for the water quality, water quantity, 

and watershed effects analysis described below. 

Table 45 Water, aquatic, and riparian restoration activities by alternative per decade

Type of Restoration

Alternative 

A

Alternative 

B

Alternative 

B-modified

Alternative 

C

Alternative 

D

Acres of riparian vegetation 

improved 

(MA-RCA-OBJ-01)

300-400 400-500 At least 400 400-500 500-600

Number of meadows 

enhanced or improved 

(RCA-MEAD-OBJ-01)

3-5 5-10 At least 5 20-25 5-10

Miles of streams restored 

(RCA-RIV-OBJ-01) 10-20 10-20 At least 10 20 - 30 10 - 20

Affected Environment

Current Conditions and Trends Common to the Inyo National Forest 

Current Range Conditions: Water Quality, Quantity and Watershed Condition 

As reported in the Final Inyo National Forest Assessment (USDA Forest Service 2013a), within 

the last 10 years, condition data has been collected from key areas on 32 allotments on the Inyo 

National Forest. Data include watershed condition and stream channel assessments. Stream 

channel assessments use the proper functioning condition (PFC) protocols (Null et al. 2013, 

Knowles and Cayan 2002, United States Department of Interior 2015a). Because of the various 

differences in rangeland types, the allotments have been grouped into similar ecosystem types to 

facilitate management. These groups are: Kern Plateau, Desert Allotments, Crowley Lake, Mono 

Lake, White Mountain, Bishop, and Inyo Mountain. 

Watershed condition ratings show that 71 key areas (50 percent) rate as fully functional, 47 key 

areas (33 percent) rate as functioning at risk, 29 key areas (20 percent) rate as degraded and 6 key 

areas (4 percent) rate as non-functional. For stream reaches within grazed allotments, 67 reaches 

(59 percent) are properly functioning, 42 reaches (37 percent) are functioning at risk (with 

different trend ratings), and 5 reaches (5 percent) are non-functioning (USDA Forest Service 

2017e).

While generally good, rangeland conditions vary throughout the Inyo, based on data collected to 

assess vegetation conditions, watershed function, and hydrologic function. The Inyo National 

Forest conducts annual monitoring of range best management practices to evaluate impacts to 

water quality and aquatic habitat. Of the total 24 range allotment evaluations conducted, 16 were 

rated as both implemented and effective. Another four rated as implemented at risk, meaning that 

although the best management practices were correctly implemented, minor departures from 

effectiveness were noted. The remaining four evaluations were rated implemented but not 

effective, meaning that although the best management practices were implemented as planned, 

they were not effective in preventing adverse effects on water quality (see “Production Livestock 

Grazing” section for additional information).

Water Quality

Overall, water quality within the Inyo National Forest is good, having benefited from restoration 

projects to treat legacy impacts; low population and levels of development; and because of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

264

protective standards and guidelines in the current forest plans. Water quality is directly influenced 

by erosion of soils, pollutants, dams, roads, and management activities associated with the 

national forest. Soils are influenced by erosion, compaction, pollution, and land-disturbing 

activities and events. Water quality on the Inyo National Forest is generally good, due to high 

elevation sources (USDA Forest Service 2013a, 2013d). The Los Angeles Department of Water 

and Power uses water from the Mono and Owens River watersheds for municipal use. Their 

annual water quality reports show that water quality meets all drinking water standards. 

Relatively few areas on the Inyo National Forest have widespread accelerated erosion beyond the 

natural range of variation. Erosion rates far outside of the natural range of variation have been 

observed mainly along roads in steep areas, in developed areas such as ski areas, and after highintensity wildfires. While rilling and gullying are evident at Mammoth and June Mountain Ski 

Areas, erosion is generally limited to within the ski area boundary. Both ski areas have extensive 

ski run drainage systems and revegetation programs to reduce erosion (USDA Forest Service

2013a).

There are an estimated 1,985 miles of National Forest System roads on the Inyo National Forest. 

The estimated sediment yield from these roads is between 0.01 and 0.09 tons per acre per year. 

This compares to an estimated 0.0004 to 0.004 tons per acre per year from vegetation 

management activities (USDA Forest Service 2013d).

In the southern Sierra Nevada, fires are often observed to cause increased erosion, both from 

water and wind, and to a lesser extent, from dry ravel (Berg and Azuma 2007). Erosion rates as 

high as 30 to 44 tons per acre per year have been measured following high-severity wildfire. 

These high erosion rates seen after a fire typically decline within 3 to 5 years as vegetation 

recovers. Wildfires and soil erosion are natural processes that help shape forest ecosystems. 

Prescribed fire has not been shown to increase erosion in most studies, due to low fire severity 

that often leaves soil structure and organic matter intact. Prescribed fire has been largely 

successful in reducing fuels without significantly impairing soil productivity, soil stability, or the 

riparian vegetation which stabilizes soils (DeBano 2000; Bêche, Stephens, and Resh 2005; Pettit 

and Naiman 2007; Arkle and Pilliod 2010)

The effects of fire can be both negative and positive for water quality and quantity, depending 

upon the extent and severity of the fire. Reducing large, high-intensity wildfire is extremely 

important to lower total sediment yields from national forests in the Sierra Nevada drainage 

basins. The primary effect of large, high-severity fires on water quality is increased sediment as a 

result of loss of soil cover and soil organic matter, soil hydrophobicity (lack of ability for soil to 

absorb water), and the destabilizing of existing roads, trails, and skid trails (Neary et al. 2005, 

Hunsaker et al. 2013b). Large, high-intensity fires may also cause erosion and changes to the 

streambed that can eliminate vulnerable aquatic populations, degrade water quality, reduce 

capacity of downstream reservoirs, and increase the risk of flood (Long, Quinn-Davidson, and 

Skinner 2014b). Two recent debris flows on the Inyo National Forest occurred in watersheds that 

had recently burned at high severity: Oak Creek and Haiwee Canyon. 

There are also beneficial effects of fire to stream and river ecosystems (such as large wood 

recruitment into streams) that are described more in the “Terrestrial Ecosystems” and “Aquatic 

and Riparian Ecosystems” sections. More information on fire and its effect on hydrologic 

function may be found in the “Fire Trends” section.

The Inyo National Forest has limited direct measurements of water temperature and sediment 

from monitoring. The State and Regional Water Quality Control Boards have established lists of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

265

impaired waters on or immediately downstream of the national forest using the limited data 

available. The 303(d) list of impaired waters reports on streams and lakes identified as impaired 

for one or more pollutants; the term “impaired” means these waterbodies do not meet one or more 

water quality standards (U.S. Environmental Protection Agency 2015). Sometimes these listings 

result in the establishment of a total maximum daily load (TMDL) water quality threshold and 

management strategy for bringing these waterbodies back into an unimpaired condition. Total 

maximum daily load values have not been established yet, but some have been identified as 

needed for these waterbodies. Impaired waters are identified through assessment and monitoring 

programs conducted by volunteer networks and other local, State and Federal agencies. Table 46

shows the 303(d)-listed waterbodies within or adjacent to the Inyo and the cause of the 

impairment.

Based on an analysis of best management practice effectiveness data collected over the past 4 

years (2011 to 2014), Inyo National Forest rated 76 percent of best management practices as 

implemented and effective, respectively (Kelley 2015). Data collection and analysis were 

performed following the Pacific Southwest Region’s protocols and procedures established for 

best management practices evaluation program (USDA Forest Service 2001a).

Table 46. Impaired (303(d)-listed) waterbodies within or adjacent to the Inyo National Forest

Hilton Creek Mammoth Creek Mono Lake Rock Creek

Reason(s) for 

Listing (Pollutant)

Dissolved Oxygen 

(low levels) 

Metals (Mn, Hg, Ar) 

Total Dissolved 

Solids (TDS)

Chlorine (Cl) 

(Hypersalinity)

Total Dissolved 

Solids (TDS)

Impairment 

For What Use or 

Benefit?)

Fish Habitat Sport Fishing N/A Fish Habitat

Possible Causes / 

Notes

Unknown / 

Upstream from 

Crowley Lake

Natural sources 

(metals), mining / 

Flows through 

urbanized Mammoth 

Lakes

Evaporation / 

Downstream from 

Inyo / Not 303(d) 

listed due to special 

circumstances

Surface mining 

Year to be Rectified 2021 unknown

Settlement w/Los 

Angeles Department 

of Water and Power

2021

Total Maximum 

Daily Load (TMDL) 

Limited

Yes Yes Yes Yes

Water Quantity

The effects of climate change in the Sierra Nevada range are apparent in rising minimum 

temperatures, earlier snowpack melting, changing stream hydrology, and increased frequency of 

large, high-severity wildfires (Safford, North, and Meyer. 2012). Climate changes are also 

expected to change the pattern, frequency, and intensity of disturbances (Safford, North, and 

Meyer. 2012). The result will be increased wildfires, doubling the area burned annually by the 

middle of the 21st century.

There are limited results on the effects of watershed restoration on water quantity in the Sierra 

Nevada. Podolak et al. (2015) identified that meadow restoration had the potential to change 

timing of flows by quantifying the timing of flows from one meadow restoration. However, 

because of the lack of research on the subject they did not infer their findings to meadows across 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

266

the northern Sierra Nevada. In addition, pond-and-plug meadow restoration projects completed in 

the Northern Sierra indicate no differences were found between pre- and post-project late season 

flows (Hoffman, Roby, and Bohm 2013). At best, it may be assumed that water quantity increases 

resulting from restoration efforts may be localized. Given the variability of seasonal and yearly 

fluctuations of precipitation and flow it would difficult to determine actual effects to water 

quantity from restoration efforts in the Sierra Nevada.

Based on patterns of large flood described previously, the frequency of large floods may be 

increasing. Climate predictions indicate that changes in flow patterns will stress meadows, 

streams, and rivers in several ways. In areas where snow is replaced by rain, the opportunity to 

infiltrate and recharge shallow groundwater is reduced as more precipitation immediately runs off 

the land. Peak flows will be earlier and more intense, possibly increasing erosion and leaving less 

water later in the summer (Hunsaker, Long, and Herbst 2014a). Pulses of soil erosion and 

flooding caused by higher rainfall intensity will increase, but the pattern will be highly variable.

Because severe wildfire often leads to high erosion rates from hill slopes and stream channels, as 

climate change leads to more intense and larger wildfires, the plan area as a whole will have 

greater erosion rates. If streams tend to dry out earlier in the summer, or formerly perennial 

streams become intermittent, it is likely that there will be less riparian vegetation over time. This 

could lead to increased streambank erosion. Potential climate change effects to nutrient cycling 

and organic matter in soils has not been well studied outside of agricultural systems.

Community water supply falls within the Wildland-urban Intermix Defense Zone in alternatives A 

and C and within the Community Wildfire Protection Zone in alternatives B, B-modified and D. 

The communities within and adjacent to the Inyo receive their water from a combination of 

groundwater and surface water sources. 

Watershed Condition

The Watershed Condition Framework, completed in 2011 with an additional 12 watersheds reassessed in 2015, provides a means to evaluate, prioritize, and measure progress of restoration 

across the Inyo National Forest and to evaluate alternatives (USDA Forest Service 2011d). The 

Inyo National Forest uses the Watershed Condition Framework to assess and classify the 

condition of 132 HUC-12 watersheds (typically 10,000 to 40,000 acres) in the plan area. Most 

drain to the San Joaquin Valley, Owens River or terminal Great Basin lakes and desert valleys. 

These waters have been diverted in large quantities for agricultural, municipal, commercial, and 

industrial uses. For example, the majority of flows into the Owens River Basin are diverted to Los 

Angeles via the Los Angeles Aqueduct, greatly affecting downstream flows below the Inyo 

National Forest boundary.

Properly functioning watershed conditions create and sustain functional terrestrial, riparian, 

aquatic, and wetland habitats capable of supporting diverse populations of species. As noted 

above, assessment of watershed condition is conducted at the HUC-12 watershed level. 

Watershed condition integrates the entire ecological function of a land area contained within a 

given hydrologic boundary. For the forest, existing assessments describe watershed condition 

within their administrative boundaries that are subject to management by the Forest Service and 

not lower watersheds and intervening areas that may be impacted by agricultural or urban 

development.

Management activities that affect watershed condition class ratings are not limited to soil and 

water improvement activities, but include a broad array of resource program areas from 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

267

hazardous fuel treatments, invasive species eradication, abandoned mine restoration, riparian area 

treatments, aquatic organism passage improvement, road maintenance and obliteration, and 

others. To achieve a change in watershed condition class will in most cases require changes 

within a watershed that are significant in scope and include treatments from multiple resource 

areas.

The discussion and analysis of watershed conditions and consequences of selecting forest plan 

alternatives is focused on individual or aggregated effects on HUC-12 watersheds. Some adjacent 

HUC-12 watersheds are hydrologically connected to each other and others are not. Therefore it is 

possible to have one or more HUC-12 watersheds that exhibit poor ecological integrity, adjacent 

to highly functioning watersheds.

The condition of the HUC-12 watersheds on the Inyo National Forest is summarized in table 47. 

The condition class area is based on National Forest System lands contained within the HUC-12 

watersheds. Private lands cover approximately 37 percent of the area within the HUC-12 

watersheds shown in the table. Class 1 represents watersheds that are considered to be 

functioning properly. Class 2 represents watersheds considered to be functioning at risk. Class 3 

represents watersheds that are considered to have impaired function.

Table 47. Number of and percentage of HUC 12 watersheds by 

condition class on the Inyo National Forest

Condition Class Inyo (number) Inyo (percentage)

Condition Class 1 118 89%

Condition Class 2 14 11%

Condition Class 3 0 0%

Total 132 100%

High fuel loads, road density, road proximity to water, invasive species, and aquatic habitat 

fragmentation due to dams were the most common stressors affecting watersheds that were not 

properly functioning, or functioning at risk.

The Inyo National Forest is focusing restoration activities within its priority watersheds to 

minimize past impacts of high road density, high fire risk due to bark beetle infestation, and 

channel destabilization caused by runoff and debris flows from high-severity wildfires. About 7 

percent, or 117 miles of the 1,640 miles of perennial streams on the national forest are 

downstream of a dam, where flows are determined by both natural precipitation and runoff, and 

the operations of these dams. As noted in table 47, the Inyo National Forest does not have any 

watersheds assessed as impaired but 14 are considered at-risk watersheds.

Environmental Consequences to Water Quality and Quantity, and Watershed Condition

This section evaluates how the five alternatives considered in detail affect water quality, water 

quantity, and watershed condition based on the pace and scale of ecological restoration and plan 

components. Consequences common to all the alternatives are described first, followed by 

consequences specific to each alternative. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

268

Consequences Common to All Alternatives

Water Quality

The key water quality indicators are temperature and sediment loading since these factors are 

critically important to aquatic species and the overall health of the aquatic system (see “Aquatic 

and Riparian Ecosystem Integrity” section). Climate change will alter the overall hydrologic 

regime in the Sierra Nevada. The higher ambient air temperatures will cause earlier peak flows 

and lower base flows in the summer and fall throughout the southern Sierra Nevada. All 

alternatives seek to mitigate these effects through restoration to maintain or reduce water 

temperatures and prevent erosion for the benefit of native fish and other species.

The Inyo National Forest and its partners are actively implementing restoration actions to reduce 

erosion on roads, trails, dispersed camping areas, grazed areas, and other developed and dispersed 

recreation sites. These efforts are expected to continue, further reducing erosion on the forest. 

Water quality would be improved where the Forest Service and partners actively restore 

watersheds.

Water quality in 303(d)-listed streams, shown in table 46 on page 265, is likely to be unchanged 

except where restoration has occurred and the contaminant is within control of Forest Service 

management. Sources of contaminants, such as mercury, manganese and arsenic and that have 

caused 303(d) impairment to streams are from geologic or legacy sources that are not a result of 

Forest Service management.

All alternatives maintain the same level of livestock grazing as the 1988 Land and Resource 

Management Plan (alternative A), as amended (USDA Forest Service 1995b, 2001, 2004). There 

would be no change to existing management direction for livestock grazing. Current management 

direction for term grazing permits and allotment management plans remain in place. New permits 

and management plans would follow direction identified in the Inyo Forest Plan, chapter 2 

Rangeland Livestock Grazing. Forest plan direction includes grazing management in meadows 

(MA -RCA-STD-10-14 and 17; MA-RCA-GDL-03, 05 and 07). These standards and guidelines 

and others (RANG-FW-STD-01-07) while not new, are anticipated to improve grazing 

management, and result in positive meadow and water quality trends over time, especially as the

forest continues to implement riparian and range improvement projects.

Water Quantity

Climate change will alter timing and distribution of runoff and infiltration to recharge shallow 

groundwater, which affects stream flow and downstream agricultural, municipal, and industrial 

users of both surface water and groundwater. Warming air temperatures will bring about less 

snowfall, more intermittent snowpack at all but the highest elevations, more rain-on-snow events, 

reduced spring snowmelt, earlier and likely lower peak spring runoff, and higher 

evapotranspiration rates for vegetation (Podolak et al. 2015). These impacts reduce snow melt 

timing and quantity which reduce the effectiveness of precipitation to refresh shallow 

groundwater, and in turn stream flow. As less snow is stored on the landscape, higher 

evapotranspiration returns more water to the atmosphere, and as the period in which snowmelt is 

available is reduced and shifts to earlier in spring rather than distributed over many months, 

overall water quantity is reduced resulting in reduced percolation into shallow groundwater 

storage, and reduced baseflow in streams that are groundwater dependent (Bales et al. 2011).

Climate change will tend to reduce the overall quantity of water produced by the Sierra Nevada 

affecting both on-forest and downstream beneficial uses. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

269

All alternatives would work toward ecological restoration and attempt to mitigate effects of 

climate change at varying scales across the national forest. All alternatives include both removal 

of vegetation through hand thinning, mechanical treatments, prescribed fire, and wildfire 

managed to meet resource objectives. The use of fire to restore landscapes in the Sierra Nevada is 

a key part of all alternatives and has been used for centuries by Sierran Tribes to maintain flow 

from springs and streams among other benefits (Parrotta and Trosper 2011, Anderson 2006).

Taking action to improve or maintain watershed condition will make the Inyo more resilient to 

climate change (reducing fuel loading in high fire risk areas, restoring meadows and stream 

channel function). As the Inyo National Forest, within the bio-region increases the pace and scale 

of restoration, including mechanical tree thinning and managed fire, the national forest should 

become more resilient to climate change.

No change is expected to water quantity given implementation of forestwide watershed and 

grazing plan components which are unchanged from current direction and common among all 

alternatives. 

Watershed Conditions

The Inyo National Forest has identified priority watersheds to focus work in such a way that 

produces overall benefits to a watershed, rather than restoring disparate locations throughout the 

national forest. For all priority watersheds, the forest has developed water restoration action 

plans, which identify essential projects to restore sites with legacy erosion and degraded aquatic 

and riparian habitats, such as streams and meadows. The watershed restoration action plans

provide managers with a list and schedule of projects to be completed and are designed to 

improve the condition class rating of priority watersheds. As Inyo staff completes these essential 

projects, they evaluates the watersheds to determine whether the projects achieved their goals and 

track and report projects through national agency databases such as the Watershed Improvement 

Tracking (WIT) and Watershed Condition and Assessment Tracking Tool. The staff develops

funding strategies, focuses resources, and develops appropriate partnerships to complete the 

identified projects to maintain or enhance the watershed.

The forest plans do not determine the development of new priority watersheds. Instead, watershed 

managers use the watershed condition framework process to recommend new priority watersheds 

to appropriate-level responsible officials after assessing need to restore degraded aquatic and 

riparian habitats. Recommendations are based on national forest inventory and monitoring data 

and factors such as interest and availability of partners, the presence of a listed or species of 

conservation concern, and the risk of large, high-intensity wildfire. Managers will also consider 

watersheds already identified for fuel reduction and other ecological restoration. As new priority 

watersheds are selected, essential projects are identified in watershed restoration action plans.

Although Forest Service budgets are expected to stay relatively static, with limited funding 

available to meet all the restoration needs currently identified on the national forest, there are 

increasing opportunities for projects to restore watersheds through State water bond grants and 

other funding. There are a variety of partners interested in applying for grants to accomplish work 

on National Forest System lands. The Inyo has a substantial list of potential projects that are 

ready to begin or are being planned for implementation once funding is available. These projects 

are currently listed in the Watershed Improvement Tracking database, and can easily be 

incorporated into watershed restoration action plans as new priority watersheds are selected. The 

Forest Service anticipates that such partnerships would compete well for these and other State 

funding for potential projects that benefit watershed condition on the national forest. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

270

The monitoring data shows that conditions in grazing allotments are generally improving based 

on historical ratings. We expect no change to slight improvement to watershed condition 

indicators for riparian/wetland condition (5) and rangeland vegetation (10) because we are not 

changing existing management direction for livestock grazing. 

Consequences Specific to Alternative A

Alternative A continues the current objectives for reducing fuel loading covering approximately 

10 to 15 percent of the lands needing this treatment to substantially reduce the risk of large highintensity wildfires. The priority for treatment is within the Wildland-urban Intermix Defense and 

Threat Zones and upland areas with road access and on low to moderate slopes where mechanical 

equipment can operate safely with minimal ground disturbance. The amount of fuel reduction 

work completed under the existing forest plans is not sufficient to reduce the threat of large highintensity wildfire, so the potential to maintain or enhance watershed condition remains low (see 

“Terrestrial Ecosystems” section). Alternative A does not change the pace and scale of terrestrial 

restoration and retains the restrictive and prescriptive standards and guidelines in the current 

forest plan. While these standards and guidelines serve to protect water quality and watershed 

function in areas where projects occur over the short term, the pace and scale is not sufficient to 

reduce the long-term negative effects from high-intensity wildfire across the landscape. Since 

climate change is likely to increase the risk of high-intensity wildfire, the overall impact on water 

quality and watershed function would decline under alternative A. The development of fixed 

width riparian conservation areas and associated standards and guidelines in the current forest 

plans has provided an effective level of protection to water quality throughout the Southern Sierra 

Nevada. The riparian conservation areas have resulted in reduced soil disturbance and erosion in 

areas of highest risk of sediment entering a stream.

The current plans also have the critical aquatic refuges as described in the “Aquatic and Riparian 

Ecosystems” section. Critical aquatic refuges can be areas of focused restoration when needed for 

species conservation and water quality improvement. The Inyo completed restoration work in 

several critical aquatic refuges over the past 10 years. Where roads are used for management 

actions, managers would look for opportunities to maintain, repair, reroute, or improve aquatic 

organism passages across them through stewardship or partnership opportunities. 

Water Quality

Alternative A maintains current riparian conservation areas and standards and guidelines from the 

current forest plans. Short-term sediment impacts from continuing at the current pace and scale of 

restoration would remain nearly the same. However, long-term indirect impacts would be greater 

from trends of increasing wildfire frequency and fires that burn with higher intensity (see 

“Terrestrial Ecosystems” section). Ecological restoration reduces fuel loading and tends to have a 

dampening effect on wildfire intensity. Wildfire behavior would be less constrained by fewer 

treated acres, be expected to grow larger and burn at higher intensity, and may affect multiple 

watersheds. Within the burned areas, these types of fires destabilize hillslopes and stream 

channels, consume surface litter that protects the soil, and create hydrophobic soils that can 

significantly limit infiltration and increase runoff. These effects can cause accelerated soil 

erosion, impaired water quality, and reduced watershed function (Neary et al 2005).

Water Quantity

Alternative A would continue to contribute to reduced flows due to higher evapotranspiration 

rates of dense forests over broad landscapes, exacerbated by lower precipitation and higher 

temperatures from climate change. The decrease of winter snowpack and increased proportion of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

271

rain verses snow reduces the infiltration and increases runoff compared to the past. This would 

potentially cause earlier peak flows, lower late spring and early summer runoff, and lower 

baseflows during the dry season. After high-intensity wildfires greatly reduce vegetation, ground 

cover, and evapotranspiration, runoff spikes are further amplified by the reduction of infiltration 

by hydrophobic soils, for the short term. This runoff carries a high potential for downstream 

flooding, soil erosion, and sediment loading of streams. The overall annual yield of surface water 

is likely to be lower and more difficult to manage and store for beneficial downstream uses (Bales 

et al. 2011).

Shallow groundwater would also potentially be reduced due to maintaining the current pace and 

scale of terrestrial and meadow restoration combined with climate change effects. Deep 

percolation through the soils would be reduced by evapotranspiration in unburned and untreated 

areas and infiltration would be reduced where high-intensity wildfire causes hydrophobic soils.

Water quantity reductions may be mitigated where forest managers actively restore the 

watersheds. Since the current forest plan does not limit watershed restoration, the pace and scale 

may increase as new opportunities and funding sources evolve and partnerships are enhanced to 

complete watershed restoration projects. Shallow groundwater recharge would increase only 

where meadows have been restored, but generally would decline overall due to the relatively low 

pace of restoration.

Watershed Conditions

Alternative A emphasizes restoration activities within priority watersheds to maintain or improve 

watershed conditions. Under the current forest plan, additional watershed restoration occurs in 

areas where mechanical thinning occurs and stewardship opportunities exist. Additional sources 

of funding and assistance through partnerships could be used to improve watershed conditions 

throughout the Inyo National Forest. Riparian and aquatic habitat restoration help offset effects of 

climate change on stream temperatures, better maintain base flows, and can enhance riparian 

condition. However, overall watershed conditions would continue to be at risk from highintensity wildfire and legacy impacts.

The existing forest plan contains specific standards and guidelines and implements best 

management practices to protect soils on steep slopes, especially within the riparian conservation 

area. The critical factors to maintain and enhance soils productivity are to minimize soil 

disturbance and compaction. Alternative A maintains the current pace and scale of ecological 

restoration and all riparian conservation area protections in the current plans.

The existing critical aquatic refuges were created to protect and enhance habitat for aquatic 

species. Alternative A would not add new critical aquatic refuges and would continue to minimize 

ground-disturbing activities within them.

Alternative A is not likely to adequately address watershed condition indicators such as water 

quantity, fire regime, forest cover, and forest health issues such as tree mortality and insect 

infestation over the long term, because these require an increase in pace and scale of terrestrial 

restoration to moderate the risk of large high-intensity fire at a landscape scale. Riparian area 

conditions may also decline over time due to increased risk of high-intensity wildfire within the 

riparian conservation areas.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

272

Consequences Specific to Alternative B

Alternative B proposes to double ecological restoration across the Inyo National Forest compared 

to alternative A and would treat 15 to 30 percent of areas identified as needing this treatment to 

substantially reduce the risk of high-intensity fire. These treatments are expected to reduce the 

likelihood of large high-intensity fire compared to current conditions under alternative A but there 

would still be an increasing trend in large high-intensity wildfires due to climate change (see 

“Fire Trends” section).

The development of fixed width riparian conservation areas and associated standards and 

guidelines in the current forest plans has provided an effective level of protection to water quality 

throughout the Southern Sierra Nevada. The riparian conservation areas have resulted in reduced 

soil disturbance and erosion in areas of highest risk of sediment entering a stream. These would 

be carried forward, with flexibility to adjust the widths based on project analysis.

This alternative contains critical aquatic refuges as described in the “Aquatic and Riparian 

Ecosystems” section. Critical aquatic refuges can be areas of focused restoration when needed for 

species conservation and water quality improvement. The Inyo completed restoration work in 

several critical aquatic refuges over the past 10 years. Where roads are used for management 

actions, managers would look for opportunities to maintain, repair, reroute, or improve aquatic 

organism passages across them through stewardship or partnership opportunities. 

Water Quality

Alternative B requires the use of best management practices in project design and implementation 

that are effective in reducing soil erosion and sediment delivery to streams in order to protect 

watersheds. The southern Sierra Nevada has large areas where steep slopes and unconsolidated 

granitic and pumice soils are common. However, alternative B maintains the riparian 

conservation areas of generally fixed widths, which can be adjusted on a project-by-project basis. 

These riparian conservation areas have proven effective at reducing soil disturbance and erosion 

in critical areas near special aquatic features such as streams, lakes, wetlands, fens and springs.

The proposed use of best management practices, standards, and guidelines in project design and 

implementation would be effective in reducing soil compaction, erosion, and sediment delivery to 

streams to protect watersheds. Short-term sediment impacts from increasing the pace and scale of

restoration would likely be slightly higher than alternative A but project implementation of best 

management practices, standards, and guidelines should minimize impacts to water quality.

Although alternative B emphasizes fire’s role in restoring ecological integrity to the landscape 

and would moderate the upward trend of wildfire frequency and intensity, the effects of climate 

change and insect and disease outbreaks over the long term would increase the risk of highintensity wildfire over current conditions. The emphasis on restoring low- and medium-intensity 

fires across the landscape (including within riparian areas) would limit the accumulation of fuels, 

restore understory plants of cultural importance to Sierra Tribes, and encourage vigorous riparian 

habitats. The long-term potential for indirect impacts of sediment delivery to streams is lower 

than alternative A. High-intensity fires are trending larger and may affect entire or multiple 

watersheds. Within the affected areas, these fires destabilize hillslopes and stream channels, 

consume surface litter that protects the soil, and create hydrophobic soils that can significantly 

limit infiltration and increase runoff. It is these effects that contribute to accelerated soil erosion, 

impaired water quality, and reduced watershed function (Neary et al 2005).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

273

Temperature may be improved due to slightly higher base flows caused by lower 

evapotranspiration on the restored uplands adjacent and upstream from affected stream reaches. 

Restoring meadows would help regulate downstream flows and store water under the surface 

where it maintains cooler temperatures. Riparian plants shade streams and would be restored or 

protected to cool streams. Fuel reduction treatments would reduce the potential for high-intensity 

wildfires. Reducing the risk that high-intensity wildfires would kill vegetation, particularly within 

riparian areas, would maintain cooler water temperatures by providing more stream shade 

(Westerling et al. 2006). This is more important considering the expected higher air temperatures 

(see “Fire Trends” section). Restoration of riparian areas and meadows, combined with upland 

reintegration of fire into the landscape, would likely enhance greater infiltration and recharge 

shallow groundwater. Greater groundwater recharge and storage increases baseflow of surface 

water across the landscape and tends to lower water temperatures during the dry season, which 

provides habitat for aquatic species and water sources for terrestrial species (see “Aquatic and 

Riparian Ecosystems” section).

Water Quantity

Climate change is likely to reduce effective precipitation. Deep percolation through the soils is 

reduced by evapotranspiration in unburned and untreated areas and infiltration is reduced where 

high-intensity wildfire has caused hydrophobic soils. Overall, shallow groundwater recharge and 

storage is likely to be slightly reduced compared to current conditions due to climate change. 

Alternative B would help somewhat to maintain shallow groundwater recharge and storage under 

warming climate conditions.

Mechanical thinning of trees and low-intensity underburning of vegetation would reduce 

evapotranspiration and maintain, slightly increase, or extend the timing of stream flows 

(Hunsaker et al. 2014). Alternative B would treat more area than alternative A, and combined 

with more meadow restoration could increase infiltration on a landscape scale, thereby providing 

more groundwater recharge and storage. Increased shallow groundwater storage potentially 

mitigates some of the impacts from climate change and increases aquatic system resilience, 

stabilizes stream flows, and benefits wildlife dependent on springs.

Watershed Conditions

Alternative B would address watershed condition factors such as water quantity, fire regime, 

forest cover, and some forest health issues because of the increased pace and scale of terrestrial 

restoration at a landscape scale. Riparian conditions may improve due to less risk of highintensity wildfire within riparian conservation areas, but not as much as alternative D.

Alternative B proposes a new critical aquatic refuge for the benefit of the black toad on the Inyo 

National Forest. The opportunity to focus restoration within existing critical aquatic refuges to 

benefit species would be the same as alternative A. The additional critical aquatic refuge in 

alternative B is outside of areas to be actively managed so impacts would be similar to alternative 

A.

Riparian areas are likely to be maintained as restoration activities proceed within riparian 

conservation areas in the short term and improve over the long term compared to alternative A. 

This is because ecological restoration of adjacent uplands could benefit riparian structure where 

native species occur. The potential for short-term effects from the increased pace and scale of 

restoration would be balanced against the long-term benefits to riparian areas for alternative B.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

274

Soils may be impacted more in the short term due to ground disturbance during restoration 

activities when compared to alternative A, but would improve over the long term where 

restoration has reduced the risk of high-intensity wildfire. The critical factors that maintain and 

enhance soil productivity are to reduce soil disturbance and compaction. The increased pace and 

scale of ecological restoration, especially using ground-based mechanical equipment, causes soil 

disturbance and compaction. Infiltration is reduced on compacted soils and tends to run off and 

increase erosion. The riparian conservation areas and equipment exclusion zones are designed to 

limit soil disturbance adjacent to streams and to provide filter strips to capture erosion from 

adjacent uplands. These filter strips have proven effective in preventing sediment delivery to 

streams and protecting aquatic species such as salamanders (Olson 2015). Alternative B would 

maintain similar riparian conservation area protections and requires the use of best management 

practices to reduce soil compaction and erosion. The potential for short-term effects from the 

increased pace and scale of restoration would be balanced against the long-term benefits to soil 

sustainability for alternative B.

The likelihood of large high-intensity fires would continue to increase but at a lower rate than in 

alternative A. As a result, alternative B fuel reduction work would provide benefits to maintaining 

water and soil quality, and watershed condition over the long term. As the pace and scale of 

restoration is increased, including mechanical tree thinning and managed fire, the forests should 

become more resilient to climate change than alternative A.

Consequences Specific to Alternative B-modified

Overall, alternative B-modified has a similar set of consequences as described in alternative B for 

water quality, quantity and watershed conditions. The primary difference between alternatives B 

and B-modified is that critical aquatic refuges are not brought forward and, instead, are replaced 

by conservation watersheds.

Alternative B-modified proposes approximately the same amount of acres of wildfire managed to 

meet resource objectives reducing the risk of high-intensity fire, treatment of nonnative invasive 

plants (INV-FW-OBJ-01) and the amount of acres of sage-grouse habitat maintained, improved 

or restored as alternative B. As in alternative B, these treatments are expected to reduce the 

likelihood of large high-intensity fire compared to current conditions under alternative A;

however, there would still be a trend increase in large high-intensity wildfires due to climate 

change (see “Fire Trends” section).

Under alternative B-modified, riparian conservation areas remain the same as in alternative B. 

However, critical aquatic refuges are not brought forward in this alternative. Under this 

alternative, areas that are no longer critical aquatic refuges and those areas that are outside of 

riparian conservation areas would be managed following forestwide terrestrial ecosystem and 

vegetation, watershed, and other applicable forestwide direction, as well as applicable 

management area or designated area direction. 

Conservation watersheds are management areas that represent long-term prioritization for 

maintenance and restoration so as to provide for the persistence for at-risk species and maintain 

functioning conditions of the watershed, which provide for high quality water for beneficial uses.

In principles outlined in the Watershed Condition Framework, the Forest Service has provided 

national direction to protect high quality watersheds already in good condition first, then maintain 

the condition of watersheds to keep them from becoming threatened. After actions to maintain 

class 1 watersheds, the forest focuses on restoring watersheds identified as functioning at-risk. 

Desired conditions for conservation watersheds are for high-quality habitat and functionally intact 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

275

ecosystems, which in turn improves the quantity and quality of water available to improve aquatic 

systems and to be available for other beneficial uses.

Conservation watersheds are intended to be a network of watersheds which have been determined 

to have a functioning or functioning at-risk rating based on the Watershed Condition Framework. 

As presented on the Watershed Condition Framework map, the majority of all at risk watersheds 

are located outside of the conservation watersheds. An at-risk watershed (Soda Creek-South Fork 

Kern River), located on the South Fork Kern River Headwaters conservation watershed, is rated 

as such, due to poor riparian wetland vegetation conditions, poor aquatic habitat and poor forest 

health conditions (see Development of Conservation Watersheds for the Inyo National Forest 

2017, project record).

The four proposed conservation watersheds are located almost entirely within wilderness areas. 

Total acres proposed for the four conservation watersheds is approximately 387,000 acres. 

Approximately 77 percent, or about 298,000 acres, are located within wilderness or inventoried 

roadless areas (see conservation watershed map appendix A, Land Management Plan Inyo 

National Forest, 2018). Names and acreages of these conservation watersheds are shown in table 

51. The Forest Service manages wilderness areas for natural process to occur with minimal 

development. Generally, wilderness areas provide for high quality habitat and water quality given 

the nature of the land designation and lack of development. 

Alternative B-modified proposes a zone concept and incorporates recreation opportunity 

spectrum (ROS) in place of recreation places (alternatives B, C and D) to manage for sustainable 

recreation. The recreation zones include Destination Recreation Area, General Recreation Area 

and Challenging, Backcountry Recreation Area. Conservation watersheds do not restrict 

development of additional recreation infrastructure contained mostly within the General 

Recreation Area. There are approximately 47,734 acres (12 percent) of General Recreation Area 

outside of riparian conservation areas (most likely areas of additional development) within the 4 

conservation watersheds. The South Fork Kern River 12,494 acres (7 percent) and the Mono Lake 

Headwaters 11,067 (12 percent) contain the most acres of General Recreation Area. Forestwide 

watershed plan components in addition to specific conservation watershed components will 

ensure protection of water quality and water quantity and specific Watershed Condition 

Framework indicators. 

When implementing watershed improvements, motorized equipment may not be used in 

wilderness areas to accomplish improvement objectives unless a Minimum Requirements 

Decision Guide analysis is completed to demonstrate the need. The Inyo has aggressively 

implemented meadow and stream restoration in degraded areas within wilderness areas, though 

mostly within the Golden Trout Wilderness. 

Water Quality

Development of conservation watersheds for the Inyo National Forest (located in project files in 

the Inyo National Forest Supervisors Office) displays Watershed Condition Framework indicator 

ratings for the four proposed conservation watersheds. This information indicates that under the 

current plan, alternative A, water quality in the proposed conservation watersheds is rated “good.”

All alternatives require the use of best management practices in project design and 

implementation. Best management practices have proven to be effective in reducing soil erosion 

and sediment delivery to streams. The continued use of best management practices, standards, 

and guidelines in project design and implementation would be effective in reducing soil 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

276

compaction, erosion, and sediment delivery to streams to protect watersheds. Short-term sediment 

impacts from increasing the pace and scale of restoration and increasing the amount of acres of 

wildfires managed to meet resource objectives would likely be similar to alternative B in the short 

term but provide for a decrease in the potential for a stand-replacing wildfire and associated 

impacts to water quality in the long term. Project implementation of best management practices, 

other plan components, and the use of resource advisors and applying Minimum Suppression 

Impact Techniques (MIST for wildfires) should minimize impacts to water quality.

Although alternative B-modified emphasizes fire’s role in restoring ecological integrity to the 

landscape and would moderate the upward trend of wildfire frequency and intensity, the effects of 

climate change and insect and disease outbreaks over the long term increase the risk of highintensity wildfire over current conditions. The emphasis on restoring low- and medium-intensity 

fires across the landscape (including within riparian areas) would limit the accumulation of fuels, 

restore understory plants of cultural importance to Tribes, and encourage vigorous riparian 

habitats. The long-term potential for indirect impacts of sediment flows to streams is lower than 

alternative A and similar to alternatives B and D. Within the affected areas, these fires destabilize 

hillslopes and stream channels, consume surface litter that protects the soil, and create 

hydrophobic soils that can significantly limit infiltration and increase runoff. It is these effects 

that contribute to accelerated soil erosion, impaired water quality, and reduced watershed function 

(Neary et al 2005).

Alternative B-modified maintains best management practices, riparian conservation areas, and 

forestwide watershed, fire, terrestrial ecosystem and vegetation direction similar to alternative B. 

Management direction for conservation watersheds provides further emphasis and support for 

maintaining water quality within the four established conservation watersheds. Although this 

direction differs from critical aquatic refuges, water quality direction under critical aquatic 

refuges was limited to smaller acreages, or watersheds, unlike the larger, landscape-scale of 

conservation watersheds. Conservation watersheds allow for the use of fuels treatments and use 

of wildland fire to meet resource objectives, which allows for the continuance of long-term

positive impacts to water quality. 

Water Quantity

Development of conservation watersheds for the Inyo National Forest (on file at the Supervisors 

Office) displays Watershed Condition Framework indicator ratings for the four proposed 

conservation watersheds. This information indicates that under the current plan, alternative A, 

water quantity is rated good in three of the four conservation watersheds. In the Mono Lake 

Headwaters conservation watershed, three watersheds are rated being poor and two in fair 

condition. Lee Vining Creek is rated as poor because of dams on the creek. Rush Creek below 

Grant Lake and Walker Creek below Walker Lake are located almost entirely on private land 

and/or Los Angeles Department of Water and Power lands and are minimally affected by 

management or plan components in this conservation watershed. 

There is little discernable difference between alternatives B and alternative B-modified in regards 

to water quantity. Alternative B-modified proposes conservation watersheds that provide for large 

landscape, long-term maintenance of watershed and riparian characteristics to provide for species 

habitat and water quality compared to critical aquatic refuges, which are generally much smaller 

in scale. This difference is unlikely to lead to any measurable differences in water quantity 

between the alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

277

In addition to the effects discussed in alternative B, this alternative would manage more acres of 

wildfire for resource benefit and would reduce the potential for high-intensity wildfires. Reducing 

the risk that high-intensity wildfires would kill vegetation, particularly within riparian areas, 

would maintain cooler water temperatures by providing more stream shade (Westerling, Hidalgo, 

Cayan, and Swenam 2006) and reduce accelerated runoff and erosion. Restoration of riparian 

areas and meadows, combined with upland reintegration of fire into the landscape, would likely 

foster greater infiltration and recharge shallow groundwater as compared to alternative A. There 

would likely be a slight, long-term beneficial effect to water quantity in streams and in shallow 

groundwater.

Climate change is likely to reduce effective precipitation. Overall, shallow groundwater recharge 

and storage is likely to be slightly reduced under all alternatives due to climate change. 

Alternative B-modified would help somewhat to maintain shallow groundwater recharge and 

storage under warming climate conditions as discussed above.

Watershed Conditions

About 89 percent of the watersheds on the Inyo National Forest are in “good/functioning” 

condition, while the remaining 11 percent are in “fair/at risk” condition. Alternative B-modified

proposes four new conservation watersheds, largely located within existing wilderness and 

inventoried roadless areas, on the Inyo National Forest. The opportunity to focus ecological

restoration within the conservation watersheds to benefit watershed health, at-risk species and 

water quality would be similar to and in some places, slightly increase restoration compared to 

alternative B for the following reasons:

• Potential Management Approaches places priority on ecological restoration projects and 

monitoring in conservation watersheds. The intent of the national direction of the 

Watershed Condition Framework complements plan components for conservation 

watersheds in that the priority is to protect high-value watersheds already in good 

condition, maintain the condition of watersheds to keep them from becoming threatened 

and, improve those in an impaired (at-risk) condition. The focus of the conservation 

watersheds and national direction for the Watershed Condition Framework is to protect and 

enhance high value watersheds. 

• Active ecological restoration opportunities are limited in designated wilderness. 

Opportunities are limited to managed activities such as recreation, and managing wildfire 

for ecological benefit. In addition, limited amounts and types of meadow/stream restoration 

can occur. About 77 percent of the total acreage of conservation watersheds are located 

within designated wilderness areas with the remainder, about 23 percent, outside of these 

areas, which is where the focus of additional active restoration activities would occur. 

Development of conservation watersheds for the Inyo National Forest (project record) 

displays Watershed Condition Framework indicator ratings for the four proposed 

conservation watersheds. There are a total of 14 watersheds with all but one rated as 

functioning. Standard (MA-CW-STD-01), and guideline (MA-CW-GDL-03) emphasizes 

the need to design projects to attain functional Watershed Condition Framework indicators. 

• Priority watersheds on the Inyo are not located within proposed conservation watersheds. 

Site-specific work will continue within priority watersheds across all alternatives, including 

Alternative B and alternative B-modified. In addition, even though critical aquatic refuges 

are not designated in this alternative, species that occur in these areas have forest-wide 

direction that provides management for suitable habitat; have specific plan components 

identified for them or are cover by other regulatory direction. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

278

• The conservation watershed objective (MA-CW-OBJ-01) states:

Within 20 years of plan approval, 5 percent of the indicators within the Watershed 

Condition Framework with a condition rating of 2 or 3 will be improved to a higher 

rating leading to or trending towards a functional condition rating.

There are 12 core national indicators in the Watershed Condition Framework. It is 

recognized that a 5 percent change, which is less than 1, will have minor effects on the 

overall condition rating of a HUC-12 watersheds contained within the conservation 

watersheds. If indicators are taken as a whole (see 1 above), out of the 56 indicators rated 

less than good less than 3 would be required to be moved to a good condition over the 

course of 20 years. This objective is trying to establish a change to these lower rated 

indicators, off of which are changed at a finer-scale and may not lead to an overall 

improvement in the “functioning” condition, but would change the individual indicator.

Conservation watersheds represent a long-term prioritization for maintenance and restoration of 

watersheds and watershed function. This alternative will maintain and in some cases improve the 

functional rating of some Watershed Condition Framework indicators including but not limited to 

fire regime/wildfire, water quality, and aquatic habitat over the long term. 

Consequences Specific to Alternative C

Alternative C proposes to reduce high-intensity fire risk by increasing the use of prescribed fire 

and actively managing wildfire to meet resource objectives. However, because there would be 

less opportunity to pre-treat fuels in this alternative due to the increase in recommended 

wilderness areas (325,359 acres compared to 37,029 in alternatives B and B-modified), there is 

uncertainty in how much area would have wildfires managed to meet resource objectives. This in 

turn leads to a high degree of uncertainty regarding how alternative C would affect the landscape 

condition (see “Terrestrial Ecosystems” section). Although alternative C proposes to reduce fuel 

loading more than alternative A using fire as the primary treatment method, the challenges of 

actively managing fire without mechanical treatment to lower fuels in the landscape may not 

result in treating more acres than alternative A. For this analysis, it is assumed that alternative C 

would result in approximately the same treatment area as alternative A, but treatment would be 

achieved through different means.

The development of fixed-width riparian conservation areas and associated standards and 

guidelines in the current forest plans has provided an effective level of protection to water quality 

throughout the Southern Sierra Nevada. The riparian conservation areas have resulted in reduced 

soil disturbance and erosion in areas of highest risk of sediment entering a stream.

The current plans also have the critical aquatic refuges as described in the “Aquatic and Riparian 

Ecosystems” section. Critical aquatic refuges can be areas of focused restoration when needed for 

species conservation and water quality improvement. The Inyo completed restoration work in 

several critical aquatic refuges over the past 10 years. Where roads are used for management 

actions, managers would look for opportunities to maintain, repair, reroute, or improve aquatic 

organism passages across them through stewardship or partnership opportunities. 

Water Quality

Alternative C requires the use of best management practices, standards, and guidelines in project 

design and implementation that are effective in reducing soil compaction, erosion, and sediment 

delivery to streams to protect watersheds. Short-term sediment impacts from emphasizing 

prescribed fire and managed wildfire to achieve restoration goals would be similar to alternative 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

279

A. Given the large increase in proposed wilderness, alternative C would reduce ground 

disturbance from mechanical thinning, but would likely increase the risk of large high-intensity 

wildfire (see “Terrestrial Ecosystems” section). Prescribed fire under these conditions is likely to 

burn at greater intensity than other alternatives because of greater fuel loading on the landscape 

due to less mechanical treatment.

Indirect impacts from high-intensity wildfire are greater than alternatives B and B-modified and 

similar to alternative A over the long term. High-intensity fires are trending larger and may affect 

entire or multiple watersheds causing adverse effects to hillslopes, stream channels, infiltration, 

and runoff. It is these effects that contribute to accelerated soil erosion, impaired water quality, 

and reduced watershed function (Neary et al 2005).

Alternative C would treat only a small proportion of the lands needing treatment to substantially 

reduce the risk of high-intensity wildfire. The staff identified lands in need of treatment, including 

all wildland-urban intermix zones and upland areas of low to moderate slopes. The pace and scale 

is not sufficient to reduce the long-term negative effects from high-intensity wildfire across the 

landscape. Since climate change is likely to increase the risk of high-intensity wildfire, the overall 

water quality and watershed function would decline under alternative C.

Water Quantity

Alternative C would potentially cause reduced flows due to higher evapotranspiration by 

vegetation over broad landscapes and across watersheds exacerbated by climate change. The 

decrease of winter snowpack and increased proportion of rain versus snow reduces the infiltration 

and increases runoff compared to the past. This will potentially cause earlier peak flows, lower 

late spring and early summer runoff from snowmelt and lower base flows during the dry season. 

Where high-intensity wildfires occur, evapotranspiration would be greatly reduced for a time, but

the runoff increases reflect additional effects from hydrophobic soils. Alternative C would likely 

reduce annual water yields from surface water.

Shallow groundwater recharge and storage is also potentially reduced due to maintaining a 

similar pace and scale of terrestrial and meadow restoration as alternative A, exacerbated by 

climate change effects. Deep percolation through the soils is reduced by evapotranspiration in 

unburned and untreated areas and infiltration is reduced where high-intensity wildfire has caused 

hydrophobic soils.

Since alternative C does not limit watershed restoration, the pace and scale may increase as new 

opportunities and funding sources evolve and partnerships are enhanced to bring such projects to 

completion. The increase in proposed Wilderness areas could limit the amount of mechanical 

treatment for meadow and stream restoration compared to other Alternatives. However, where 

meadow and other aquatic restoration activities would remain at their current pace and scale, 

shallow groundwater recharge would increase only where the meadows have been restored, but 

generally decline overall on the forest.

Watershed Conditions

Alternative C emphasizes fuel reduction within the Wildland-urban Intermix Defense Zone and a 

greater reliance on prescribed fire and managed wildfire to reduce the threat of large highintensity wildfires compared to alternative A. Alternative C would provide similar direction for 

protection of riparian conservation areas and would place similar emphasis on watershed 

restoration as alternative B to maintain or improve watershed conditions. However, overall 

watershed conditions would continue to be at risk due to large high-intensity wildfire. Alternative 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

280

C does not limit watershed restoration and could utilize additional sources of funding and 

assistance through partnerships to address watershed conditions, though as mentioned above the 

increase in proposed wilderness would limit the amount of mechanical treatment of degraded 

meadows and stream channels. 

Riparian and aquatic restoration work to help offset impacts of climate change on stream 

temperatures and availability of water would likely be limited to existing and new priority 

watersheds and completing essential projects within those watersheds. Riparian areas would not 

likely change in the short term but would decline over the long term due to the limited pace and 

scale of ecological restoration of adjacent uplands, except where restoration of riparian structure 

and native species occurs.

Alternative C requires the use of best management practices and maintains riparian conservation 

areas like alternative B, but would have less mechanical treatment so the effects are almost all fire 

related. The emphasis on prescribed fire and managing wildfire to meet resource objectives would 

result in less soil disturbance and compaction related to equipment use but increased soil impacts 

from fire. Alternative C would have approximately the same effect on soils as alternative A 

because the long-term risk of high-intensity wildfire would remain high and the fire intensity of 

prescribed fire and managed wildfire for resource objectives may be greater than other 

alternatives. There is more uncertainty in analyzing the potential impact to soil sustainability for 

alternative C.

Alternative C is not likely to adequately address watershed condition factors such as water 

quantity, fire regime, forest cover, and some forest health issues such as widespread tree mortality 

because these require an increase in the pace and scale of terrestrial restoration to achieve

equilibrium at a landscape scale, which may be more difficult given the increase in proposed 

Wilderness acres. Although alternative C addresses the need to emphasize managed fire to 

maintain and enhance riparian areas, the riparian areas overall may decline due to increased risk 

of high-intensity wildfire within the riparian conservation areas.

Alternative C proposes additional critical aquatic refuges for the benefit of various aquatic 

species. These critical aquatic refuges are well distributed throughout the forest both inside and 

outside wilderness area boundaries. Alternative C presents a wide variety of opportunities to 

focus restoration to benefit specific aquatic species such as the Yosemite toad and terrestrial 

species that need moist habitat such as slender salamanders, as well as aquatic biodiversity in 

critical aquatic refuges across the landscape. Management under alternative C assumes that as 

restoration work is completed and new priority watersheds would be identified. Since many 

proposed critical aquatic refuges are within areas to be actively managed, additional opportunities 

would be available to restore both terrestrial and aquatic habitats within the critical aquatic 

refuges for the benefit of species and biodiversity.

Consequences Specific to Alternative D

Alternative D proposes to double ecological restoration across the forest compared to alternatives 

B and B-modified and would address 30 to 60 percent of areas identified as needing this 

treatment to substantially reduce the risk of high-intensity fire. These treatments are expected to 

reduce the likelihood of large high-intensity fire compared to current conditions more than the 

other alternatives (see “Fire Management” and “Air Quality” sections).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

281

The development of fixed width riparian conservation areas and associated standards and 

guidelines in the current forest plans has provided an effective level of protection to water quality 

throughout the Southern Sierra Nevada. The riparian conservation areas have resulted in reduced 

soil disturbance and erosion in areas of highest risk of sediment entering a stream.

The current plans also have the critical aquatic refuges as described in the “Aquatic and Riparian 

Ecosystems” section. Critical aquatic refuges can be areas of focused restoration when needed for 

species conservation and water quality improvement. The Inyo completed restoration work in 

several critical aquatic refuges over the past 10 years. Where roads are used for management 

actions, managers would look for opportunities to maintain, repair, reroute, or improve aquatic 

organism passages across them through stewardship or partnership opportunities. 

Water Quality

Alternative D would require the use of best management practices, standards, and guidelines in 

project design and implementation, and would maintain riparian conservation areas similar to 

alternatives B and B-modified. These would be effective at reducing soil compaction, erosion and 

sediment delivery to streams to protect watersheds. Short-term sediment impacts from increasing 

the pace and scale of restoration would likely be higher than the other alternatives because of the 

increase in treated acres. However, project implementation of best management practices, 

standards, and guidelines should minimize impacts to water quality.

Alternative D emphasizes restoring ecological integrity to the landscape at an overall pace and 

scale that would reduce the current upward trend of wildfire frequency and intensity. The longterm potential for indirect impacts of sediment delivery to streams is lower than all other 

alternatives considered in detail because alternative D would be most effective across more areas 

at reducing high-intensity wildfire. The emphasis on low- and medium-intensity fires across the 

landscape (including within the riparian areas) would limit the accumulation of fuels, restore 

understory plants of cultural importance to Sierra Tribes, and encourage vigorous riparian 

habitats. The long-term benefits of an increased pace and scale of restoration would be reduced 

impacts to watersheds, soils, riparian areas, streams, and aquatic habitats from large highintensity wildfires (Neary et al 2005).

Water quality would be improved in the long term where restoration of watersheds occurs, 

especially in areas where restoration of meadows and riparian areas provide greater shallow 

groundwater storage, base flow, and shading of streams. This restoration would be focused in 

priority watersheds and potentially critical aquatic refuges, as compared to Alternative Bmodified, which would focus long-term restoration of conservation watersheds for maintenance 

of species habitat and water quality. In the short term, the more rapid and larger scale fuels 

reduction proposed in alternative D could cause some local degradation of water quality;

however, project-level protections would minimize increases in sediment due to fuels reduction 

efforts.

Stream temperature may be improved due to slightly higher base flows caused by lower 

evapotranspiration on the treated adjacent upland areas. Groundwater recharge of surface water 

should be greater due to slightly higher infiltration rates across the landscape and restoration of 

meadows, resulting in higher base flows and lower water temperatures during the dry season.

Water Quantity

Like alternatives B and B-modified, mechanical thinning of trees and low-intensity underburning 

of vegetation would reduce evapotranspiration and slightly increase or extend the timing of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

282

stream flows (Hunsaker and Long 2014). However, alternative D would increase the amount of 

treated area more than other alternatives considered in detail. Combined with potentially more 

meadow restorations, alternative D could increase infiltration on a landscape level and encourage 

more groundwater storage. Encouraging shallow groundwater storage potentially mitigates some 

of the impacts from climate change by increasing aquatic ecosystem resilience, providing more 

stable stream flows, and benefitting wildlife dependent on springs.

Climate change is likely to reduce effective precipitation. Deep percolation through the soils is 

reduced by evapotranspiration in unburned and untreated areas and infiltration is reduced where 

high-intensity wildfire has caused hydrophobic soils. Overall, alternative D would likely maintain 

current shallow groundwater recharge and storage under conditions of warming climate better 

than the other alternatives.

Water quantity may be increased slightly where managers actively restore the watersheds. Since 

alternative D does not limit watershed restoration, the focus is on priority watersheds and other 

areas needing active restoration, the pace and scale will increase as new opportunities and 

funding sources evolve and partnerships are enhanced to bring such projects to completion.

Watershed Conditions

Alternative D would address watershed condition factors such as water quantity, fire regime, 

forest cover, and some forest health issues through an increased pace and scale of both terrestrial 

and aquatic restoration.

Like alternative B, alternative D proposes a new critical aquatic refuge for the benefit of the black 

toad. The opportunity to focus restoration within existing critical aquatic refuges to benefit 

species is the same as alternative A. The additional critical aquatic refuge in alternative D is 

outside of areas to be actively managed so impacts would be similar to alternative A except where 

new opportunities may present themselves to maintain and enhance amphibian habitat. 

Models indicate that alternative D is the alternative that best achieves landscape-scale reductions 

to the risk of high-severity wildfire and provides the greatest resilience to the effects of climate 

change. Riparian conditions may decline due to increased activity within riparian conservation 

areas in the short term but they would improve over the long term from the ecological restoration 

of adjacent uplands and where restoration of riparian structure and native species occurs. The 

potential for short-term effects from an increased pace and scale of restoration would be balanced 

against the long-term benefits to riparian areas.

Similar to alternatives B and B-modified, soil conditions may decline slightly in the short term 

due to ground disturbance by restoration activities but would improve where restoration has 

reduced the risk of high-intensity wildfire. The critical factors to maintain and enhance soil 

productivity are to reduce soil disturbance and compaction. The increased pace and scale of 

ecological restoration, especially using ground-based mechanical equipment, could cause soil 

disturbance and compaction. The riparian conservation areas and equipment exclusion zones are 

designed to limit soil disturbance adjacent to streams and to provide filter strips to capture erosion 

from adjacent uplands. Alternative D maintains similar riparian conservation area protections and 

requires the use of best management practices similar to alternatives B and B-modified. The 

potential for short-term effects from the increased pace and scale of restoration would be 

balanced against the long-term benefits to soil sustainability in alternative D.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

283

Alternative D would increase the pace and scale of ecological restoration, to reduce likelihood of 

large high-intensity fires more than the other alternatives. As a result, alternative D restoration 

treatments would provide benefits to maintaining water and soil quality and watershed condition 

over the long term. As forest managers increase the pace and scale of restoration, including 

mechanical tree thinning and managed fire, the forests should become more resilient to climate 

change. Alternative D would increase the pace and scale of acres of riparian vegetation improved 

and meadows restored compared to alternative A. The pace and scale is similar (slightly more 

acres proposed for treatment) to alternatives B and B-modified with an emphasis on priority 

watersheds.

Cumulative Effects

The present and foreseeable actions of forest managers and landowners determine cumulative 

consequences to water quality, water quantity, and watershed condition. The watersheds on the 

Inyo National Forest are part of the greater southern Sierra Nevada and Great Basin ecosystems

and are administered or owned by the Forest Service, the National Park Service, the Bureau of 

Land Management, the State of California, the Los Angeles Department of Water and Power, 

Southern California Edison, several Tribes, and thousands of private landowners. The Forest 

Service manages most of the headwaters of Sierra Nevada rivers, some watersheds in their 

entirety, and shares management in parts of many watersheds where ownerships overlap.

Successful management of shared and adjacent watersheds requires a concerted effort of the 

various landowners and a variety of partners. The Forest Service will continue to work with State 

agencies in the development of total maximum daily load (TMDL) strategic action plans for 

303(d)-listed streams. If sources of impairment are identified related to Forest Service 

management, the action plans may identify mitigation strategies including implementation of best 

management practices, maintenance or decommissioning of facilities, roads, and trails, 

implementation of currently planned restoration projects, and removal of existing stressors. The 

operators of the various dams on these rivers will adapt their operations to meet Federal Energy 

Regulatory Commission relicensing requirements and to respond to effects of climate change on 

runoff and baseflows. The Federal Energy Regulatory Commission and the power companies in 

conjunction with the Forest Service will need to address issues as they arise in the future. Private 

landowners and the Forest Service will need to work together to achieve stream and meadow 

restoration where ownership overlaps these areas.

The effectiveness of Forest Service management under all alternatives may be reduced or 

enhanced by the cumulative efforts of adjacent landowners. For all alternatives, without concerted 

efforts by many landowners, especially in the foothill and lower montane zones, the potential for 

long-term adverse cumulative watershed impacts from high-intensity wildfire remains high.

Analytical Conclusions

The alternatives considered in detail outline different approaches to achieving the same overall set 

of goals for maintaining and enhancing watershed health. This section summarizes how well 

these alternatives are expected to achieve these goals expressed in terms of the indicators: water 

quality, water quantity, and watershed condition.

Water Quality

The alternatives vary in how they emphasize water quality impacts over the short term or long 

term. Alternatives A and C emphasize reduction of impacts over the short term through effective 

filter strips within the riparian conservation areas and less mechanical treatment, while 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

284

alternatives B, B-modified and D emphasize a long-term approach through an increased pace and 

scale of ecological restoration across the landscape. Alternative D best reduces the overall risk of 

high-intensity wildfire on the Inyo. While short-term impacts of alternatives B, B-modified, and 

D have a potential for sediment delivery to streams due to the increased amount of treatment, 

however, these alternatives provide long-term benefits to water quality by reducing the risk of 

large high-intensity wildfire and resulting sediment more than alternative A or C.

Climate change is causing a risk for higher water temperatures throughout the region and requires 

restoration of meadows and riparian areas to mitigate this effect. Alternative D provides the 

greatest opportunity to mitigate the effect of higher air temperatures and subsequent changes in 

precipitation patterns because it treats the greatest amount of acreage.

Water Quantity

The alternatives differ in approach, pace and scale of ecological restoration and may affect 

shallow groundwater recharge and storage. Alternatives A and C would likely maintain shallow 

groundwater at current levels if not for the changing climate tending toward warmer and drier 

conditions in the Sierra Nevada. Even if precipitation remains the same, more rain and less snow 

would reduce recharge and storage and increase runoff. Combined with greater 

evapotranspiration, the precipitation provides less soil moisture for healthy forest vegetation, soil 

infiltration, and recharging the shallow groundwater. Alternatives B, B-modified, and D would 

reduce evapotranspiration at a landscape scale and would likely increase the opportunities for 

infiltration across many watersheds.

Watershed Conditions

The watershed condition framework provides a means to evaluate the alternatives considered in 

detail in how they would affect watershed conditions. Critical aquatic refuges provide additional 

protection to watersheds that have high biodiversity of native species or contain sensitive, 

threatened, or endangered species in alternatives A, B, C and D. Alternative B-modified proposes 

conservation watersheds instead of critical aquatic refuges and also address maintaining at-risk 

species habitats and downstream beneficial uses over the long-term. Priority watersheds are 

carried forward in all the alternatives and provide a means of restoring watershed function in the 

short-term. Projects developed to maintain and enhance watersheds would continue to move 

forward in all alternatives, with emphasis of larger-scale watershed restoration under conservation 

watersheds in alternative B-modified. This restoration work would be balanced with projects in 

priority watersheds as well. Although the principles behind conservation watersheds are a little 

different than critical aquatic refuges, conservation watersheds still provide suitable habitat and 

refugia for at-risk species, both terrestrial and aquatic, that occur within them. Conservation 

watersheds are areas prioritized for maintenance or restoration activities that have long-term 

benefits. 

As watershed restoration action plans in priority watershed are completed, new priority 

watersheds will be identified considering restoration needs that are developed and implemented 

over a 5- to 7-year period. All the alternatives offer additional opportunities for restoration within 

these priority watersheds through partnerships. Conservation watersheds, in alternative Bmodified, represent a long-term prioritization for maintenance and restoration of watersheds 

particularly focused on aquatic resources. Achievement of desired conditions could take one or 

more planning cycles and would include additional opportunities through partnerships.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

285

Alternative C creates the greatest number of new critical aquatic refuges, many outside of 

wilderness boundaries, which could benefit from watershed restoration activities focused on 

enhancing habitat and improving water quality.

Since the Watershed Condition Framework is composed of various indicators, each alternative 

was evaluated on how it would likely affect six key indicators (water quality, water quantity, fire 

regime, forest health, riparian areas, and soils). For fire regime and forest health, alternatives A 

and C are insufficient to maintain current conditions when they are influenced by climate change 

combined with insect and disease outbreaks. Alternatives B and B-modified perform better due to 

the increased pace and scale of ecological restoration and increased acres of wildfire managed for 

resource benefit and alternative D would show more long-term improvement of these indicators. 

The soils indicator would likely be maintained by alternatives A and C, but could decline in the 

short term under alternatives B, B-modified, and D due to the increased amount of mechanical 

treatments as described in the Consequences section above.

Plan components and potential management approaches for the conservation watersheds 

specifically address attaining functional Watershed Condition Framework indicators within 

several planning cycles, which differs from alternatives A, B, C, and D. 

A key driver for improving watershed condition across the Inyo National Forest is restoration of 

the fire regime and forest health indicators, because long-term water quality and quantity are 

closely linked to these ecosystem conditions. Alternatives A and C would take longer than 

alternatives B, B-modified, or D to restore fire regime and forest health at a landscape level. 

Alternative D would be most likely to maintain watersheds at properly functioning or improve the 

condition of the greatest number of watersheds. Alternative D would also create the greatest 

number of watersheds on the Inyo that would be resilient to the impacts of climate change.

Aquatic and Riparian Ecosystem Integrity

Background

This section summarizes the current conditions in aquatic and riparian ecosystems on the Inyo

National Forest, and the consequences of adopting the revised plan or its alternatives. Much of 

the analysis is based upon the premise that the natural range of variation provides important 

background for evaluating ecological integrity and sustainability (Wiens et al. 2012). It was used 

to develop plan direction and select indicators and measures for the analysis. Also important in 

the analysis of ecological integrity and sustainability of riparian and aquatic ecosystems was

consideration of climate and associated ecological and watershed level conditions that are outside 

the natural range of variation. Natural range of variation is a concept that focuses on the dynamic 

nature of ecosystems, recognizing they are not static (Landres, Morgan, and Swanson 1999b). It 

recognizes that disturbances, such as drought, floods, or fire, are natural processes. Legacy land 

uses and the uncertain future due to a variable climate were also incorporated into the analyses. 

To address aquatic and riparian ecosystem integrity, the proposed plan includes desired conditions 

designed to:

• provide resilience to climate change;

• restore or maintain the function of streams, meadows, riparian areas, seeps, and springs;

• avoid invasive species;

• conserve biodiversity;
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

286

• preserve and reestablish ecological connectivity; and

• promote resilience to fire in riparian ecosystems.

The extent the alternatives would move toward the proposed desired conditions is analyzed in this 

section. The riparian and aquatic ecosystems are interconnected with watershed conditions, water 

quality, and water quantity. Watershed condition and function are further discussed recognizing 

these connections in the “Water Quality, Water Quantity, and Watershed Condition” section.

Ecological integrity is a measure of an aquatic and riparian ecosystem’s functional and structural 

conditions. Functional conditions include the surface water flow that sustains aquatic and riparian

habitats; shallow groundwater recharge; water temperatures; carbon and nitrogen sequestration; 

and nutrient cycling. Structural conditions include habitat type and availability, migration 

corridors among habitats, and structure and composition of riparian vegetation. These ecosystem 

conditions affect suitability of habitat, biodiversity, connectivity and resilience to climate change. 

Aquatic and riparian ecosystem conditions in the southern Sierra Nevada vary depending on the 

amount of past and current land disturbance that has and is occurring within the area, and the 

effect of climate changes on the natural integrity of the ecosystems. The severity of effects is 

influenced in part by the elevation, fire regime, precipitation, and management of these areas.

Analysis and Methods

This qualitative analysis is based primarily on the best available scientific information derived 

from the Inyo forest assessment (USDA Forest Service 2013a), the Bio-Regional Assessment 

(USDA Forest Service 2013d), the Science Synthesis (Long et al. 2014), recent reports and 

publications that assess trends in current conditions (Isaak 2015), and where available, assessment 

of effects of management actions. Aquatic habitats and diversity, groundwater-dependent systems, 

and riparian ecosystem functions that were assessed at a broad scale are evaluated. Key 

ecosystem characteristics are used to predict whether future conditions will provide for ecological 

integrity under the different alternatives. Only key ecosystem characteristics that could be 

influenced by management following plan direction or by climate change were selected. For this 

analysis, these indicator measures were assessed at the landscape level or across the southern 

Sierra Nevada and great basin ecosystems of the White Mountain and Inyo Mountain ranges.

Indicators and Measures

Sustainability of aquatic habitat (including presence of invasive species), ecological connectivity, 

biodiversity (includes plant and animals), resilience to climate change, and riparian vegetation 

were selected indicators because they could be assessed across the landscape, were indicators of 

the desired conditions, and were important measures of aquatic and riparian ecosystem integrity. 

All aquatic ecosystems including fens, wet meadows, seeps, springs, stream, lakes, ponds and 

rivers are referred to as aquatic ecosystems in the analysis. Aquatic indicators cover all the 

various aquatic and semi-aquatic habitats.

Sustainability of Habitat

• Management to maintain or improve habitat for all life stages of aquatic and riparian 

species. 

• Management direction to reduce invasive aquatic species.

Ecological Connectivity

• Management to reduce or improve road crossings and small dams and diversions affecting 

aquatic at-risk species.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

287

• Management of connectivity among habitats for aquatic or riparian associates.

Biodiversity

• Management that improves biodiversity of riparian and aquatic associates to including both 

plant and animal (terrestrial and aquatic), at-risk species, rare and common native species

and nonnative desirable species (e.g. tule elk, chukar, brown, rainbow, or brook trout).

Resilience to Climate Change

• Rate of restoration to improve resilience to climate change, including the change in timing 

and availability of water from snowmelt, of priority habitats for all life stages of aquatic or 

riparian associates, including at-risk species.

Riparian Vegetation

• Management of riparian conservation areas to promote native species including understory 

vegetation, as indicated by management direction.

• Rate of ecological restoration to reduce risk of high-intensity wildfire and promote native 

shrub diversity in riparian areas.

• Rate of restoration of riparian areas to promote native species, reduce the risk of highintensity wildfire, and promote wildfires managed to meet resource objectives.

The environmental consequences section provides a qualitative assessment of forecasted trends in 

indicator measures by alternative based on the effects from potential watershed restoration 

activities; meeting objectives for meadow, stream, aquatic organism passage, and riparian area 

restoration; forest vegetation restoration activities; recreation activities; trails and road crossings 

management; invasive species management, and climate change management on these indicator 

measures.

Assumptions

There are several key assumptions about why, when, where, and how restoration treatments 

would occur in aquatic and riparian areas that were used in the analysis.

• Functioning watersheds deliver the highest quality water. 

• Target restoration in conservation watersheds where the greatest ecological gains can be 

made with the least amount of funding.

• The headwaters for most streams and lakes are located in remote, high elevation wilderness 

areas, ensuring that impacts to water quality are minimal.

• Restoration of aquatic organism passage would be examined to determine effects on aquatic 

and riparian at-risk species from projects, such as culverts, beaver dams, and creek 

crossing, so that desired barriers are maintained to prevent invasive fish and organisms 

from entering habitats that might impact at-risk species. 

• National forest managers would use an integrated restoration approach to designing 

projects that strive to balance watershed restoration with terrestrial restoration. Partnerships

may provide increased funding and capacity for restoration treatments of all types, and 

build opportunities to restore aquatic habitats on the Inyo National Forest and adjacent 

lands using an “all lands approach.”

• Within riparian areas, vegetation treatments would occur to move vegetation toward the 

desired conditions. This would be primarily to restore native species composition and 

reduce the encroachment of conifer trees, salt cedar, sagebrush, etc., where appropriate. The 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

288

end result of the treatments would generally be more diversity of riparian hardwood species 

and sizes, as well as vigorously growing herbaceous vegetation.

• Most riparian vegetation restoration would occur in areas where the adjacent upland areas 

are being restored.

• Aquatic habitat restoration in streams, meadows, and other special aquatic habitats would 

be primarily to improve habitats for at-risk species and to improve downstream beneficial 

uses. Aquatic habitat restoration would be integrated into landscape treatment designs 

where appropriate. Partnerships and additional funding opportunities from sources outside 

the Forest Service would be sought to increase the pace and scale of aquatic habitat 

restoration.

Table 48 outlines the objectives for the number of acres of riparian vegetation improved; number 

of meadows enhanced or improved; and miles of streams restored for each of the plan revision

alternatives. These numbers are the basis for the aquatic and riparian ecosystem effects analysis. 

Table 48. Water, aquatic and riparian restoration activities by alternative per decade

Type of Restoration

Alternative 

A

Alternative 

B

Alternative 

B-modified

Alternative 

C

Alternative 

D

Acres of riparian vegetation 

improved (MA-RCA-OBJ-01) 300-400 400-500 At least 400 400-500 500-600

Number of meadows 

enhanced or improved 

(RCA-MEAD-OBJ-01)

3-5 5-10 At least 5 20-25 5-10

Miles of streams restored 

(RCA-RIV-OBJ-01) 10-20 10-20 At least 10 20 - 30 10 - 20

Affected Environment

Aquatic habitat integrity within the Inyo National Forest is generally better in the higher elevation 

portions of the analysis area and within existing protected areas due to fewer alterations (water 

diversions) than lower elevation areas. There are some aspects of aquatic habitat integrity that are 

outside the natural range of variation within the forest including species assemblages and flow 

regimes altered by fish stocking, diversions, and dams.

The Inyo uses the Watershed Condition Framework data to evaluate the condition class of 

watersheds (HUC 12 size class) and 89 percent are functioning properly. Out of 132 watersheds 

(HUC 12 size class) in the plan area, 118 are functioning properly, 14 are considered functioning 

at risk while zero are rated as impaired (see table 47 on page 267). These are based on several 

criteria ratings from vegetation condition, water quality and quantity, soil, cover, invasive and 

rangeland condition to name a few (see “Water Quality, Water Quantity, and Watershed 

Condition” section). These data are baseline indicators and provide valuable information for both 

managing for resources and recreation as well as to downstream users who rely on these high 

beneficial uses for municipal uses, agriculture, and economic value.

The current plan has critical aquatic refuges, which are brought forward (alternative A) and 

expanded in alternatives B, C, and D and are designed to preserve, enhance, restore or connect 

habitats for aquatic species at the local level and to ensure the persistence of aquatic species.

Table 49 summarizes critical aquatic refuges by alternative and the overall watershed condition 

rating in the watersheds. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

289

Table 49. Summary of critical aquatic refuges (conservation watersheds in alternative B-Modified) 

and watershed conditions on the Inyo National Forest

Alternative

Number of 

Critical Aquatic 

Refuges*

Watersheds in Good 

Condition 

(Functioning Properly)

Watersheds in Fair 

Condition 

(Functioning At Risk)

Watersheds in Poor 

Condition

(Impaired Function)

A 17 15 2 0

B 18 16 2 0

C 25 22 3 0

D 18 16 2 0

* Types of species provided are amphibians, fish, and aquatic snails

Alternative A has 17 critical aquatic refuges totaling 170,600 acres (table 50).

Alternative B and D would both have the same 18 critical aquatic refuges totaling 191,567 acres. 

Alternative C would have 25 designated critical aquatic refuges totaling 322,500 acres. 

Critical aquatic refuges provide additional protection to watersheds that contain Regional Forester 

sensitive species, or federally listed threatened or endangered species. Critical aquatic refuges 

were developed as a management area within the 2001 Sierra Nevada Forest Plan Amendment 

and retained in the 2004 Supplemental Sierra Nevada Forest Plan Amendment. Critical aquatic 

refuges (CARs) had been defined:

to preserve, enhance, restore or connect habitats distributed across the landscape for 

sensitive or listed species to contribute to their viability and recovery. In many cases, 

CARs supported the best remaining populations of native fish, amphibian, and plant 

species with substantially reduced distributions elsewhere in the Sierra Nevada. CARs are 

managed as RCAs [riparian conservation areas]; standards and guidelines that apply to 

RCAs also apply in CARs. Existing activities that are determined to be inconsistent with 

riparian conservation objectives (RCO) may be mitigated or removed to ensure 

consistency with RCOs. New projects and activities will be consistent with RCOs. New 

activities, such as development of dams or diversions or mineral extraction, are generally 

not appropriate within CARs. CARs also have high priority for watershed restoration 

activities. CARs will be evaluated and proposed for withdrawal from mineral entry, as 

appropriate. (USDA FS 2004 – ROD, appendix B).

The Inyo National Forest has critical aquatic refuges of various sizes associated with a particular 

species. Many critical aquatic refuges are encompassed within areas of high aquatic integrity and 

inventoried roadless areas or wilderness, particularly those delineated for Lahontan and Paiute 

cutthroat trout, California golden trout, Yosemite toad, and yellow-legged frogs. 

Alternative B-modified brings forward four conservation watersheds in place of critical aquatic 

refuges. The development of conservation watersheds are explained fully in “Consequences

Specific to Alternative B-modified.”

Implementation of the current Inyo National Forest grazing management strategy (USDA Forest 

Service 1995a) is expected to improve, or continue to improve vegetation and watershed 

condition trends, for the next 20 years, particularly within riparian conservation areas. There are 

50 livestock allotments administered by the Inyo National Forest. Thirty-six of the allotments are 

active, 11 are vacant and 3 are closed. Closed allotments are those where livestock grazing has 

been found to be incompatible with the desired conditions or result in substantial and permanent 

impairment of the land. Approximately 1,216,142 acres or 59 percent of National Forest System

lands administered by the Inyo National Forest are considered not suitable for livestock grazing 

and production. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

290

Across the Sierra Nevada, aquatic biodiversity is vulnerable, as indicated by declining trends in 

native fish, amphibians, and other species (Moyle and Randall 1998; Moyle, Katz, and Quiñones 

2011; Baumsteiger and Moyle 2017; Purdy, Moyle, and Tate 2012; Viers and Rheinheimer 2011; 

Viers et al. 2013; Vredenburg et al. 2007; Frissell, Scurlock, and Kattelmann 2012). Depending 

on the species groups, 40 to 80 percent of all aquatic species in California are now facing 

extinction, unless current trends are reversed by active management and conservation (Frissell, 

Scurlock, and Kattelmann 2012; Howard et al. 2015; Katz et al. 2013; Quiñones and Moyle 

2015). In 2010, the primary threats to aquatic biodiversity were ranked as follows: invasive alien 

species were considered the most detrimental threat (34 percent), followed by major dams and 

associated water diversions (24 percent), agriculture (18 percent), hatcheries (14 percent), and 

estuarine alteration (12 percent) (Moyle, Katz, and Quiñones 2011). Specific to the plan area, the 

primary threats to aquatic biodiversity are historic fish stocking practices of nonnative fish that

pose a threat from hybridization to native trout species, and the prevalence of diseases from 

chytrid fungus (Bd) infestations that results in mass die offs of native amphibian species. 

Aquatic and riparian ecosystems are also experiencing illegal marijuana cultivation on public 

lands that can have alarming effects on soil, water, and wildlife. Eradication and remediation of 

illegal marijuana growing operations turn up miles of irrigation piping used to divert water to 

support growing marijuana plants. Fertilizers, pesticides and poisons are used in the propagation 

and protections of such grow sites. Routinely detected is one of the most toxic carbamate 

pesticide ever produced, Carbofuran, which is used both to reduce insect damage to marijuana 

plants and poison mammals. As such, it is banned by the Environmental Protection Agency and 

California Department of Pesticides and Regulations (since 2009); it is also banned in Canada and 

the European Union because it is a human and safety risk. Invertebrates can accumulate 

rodenticide compounds in their tissue without negative effects and move beyond the grow site, 

thereby facilitating secondary poisoning (Gabriel et al. 2012). Therefore, contamination of 

watercourses from runoff, or direct placement of rodenticides at these sites, could expose aquatic 

biota and terrestrial species that are dependent on these water sources to these toxicants (Primus, 

Wright, and Fisher 2005, Rueda et al. 2016).

Illegal marijuana eradication and remediation has occurred on the Inyo using water sources from 

perennial systems. These grow sites have led to poisoning of native species, but it is unknown if 

this lead to effects to aquatic species. Aquatic habitats were impacted by these sites due to water 

diversions from piping out of natural water sources. 

Rivers and Streams

The Owens, South Fork of the Kern, and Middle Fork of the San Joaquin Rivers originate on the 

Inyo National Forest and contain headwaters of water systems in the eastern Sierra Nevada, 

White, Inyo and Glass Mountain ranges. The Owens River drains the east side of the Sierra 

Nevada and the west side of the White Mountains. Because the eastern slope is in a rain shadow 

and drier, permanent streams, meadows and springs are especially important for wildlife and 

fisheries. The upper Owens River and smaller permanent streams historically flowed into Owens 

Lake but much of the flow is now diverted to Los Angeles for beneficial uses, such as domestic 

consumption or irrigation. 

The South Fork Kern River flows north to south through the Kern Plateau, which is shared by the 

Inyo and Sequoia National Forests. The Kern Plateau is home to many springs and meadows that

maintain perennial streams. Angling opportunities on the Forest also include the chance to catch 

California golden trout in their native habitat of the South Fork Kern River and Golden Trout 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

291

Creek. The San Joaquin River drains a small part of the west side of the Inyo National Forest in 

its upper reaches and flows west through the Sierra National Forest.

Springs and perennial streams flow off the east side of the White and Inyo Mountain range 

providing water to Nevada, Death Valley, and lands administered by the Bureau of Land 

Management. Currently, Cottonwood Creek and Cabin Creek have established refuges that 

provide for populations of Paiute cutthroat trout that originated through stocking means. Cabin 

Creek is managed as a blue ribbon angler’s location while North Fork Cottonwood Creek is 

managed for restocking and augmenting of natal sites experiencing population declines. In 2017,

a coordinated effort between agencies successfully transported 87 individuals with use of Forest 

Service pack stock to augment the Silver King Creek above Llewellyn Falls in the Carson Iceberg 

Wilderness area of the Humboldt-Toiyabe National Forest. 

Watershed condition ratings for stream reaches within grazed allotments at 67 reaches (59 

percent) are properly functioning, 42 reaches (37 percent) are functioning at risk (with different 

trend ratings), and five reaches (5 percent) are non-functioning. The clear, cold waters that flow 

through the Inyo National Forest are prime habitat for cold water salmonid fish, which have been 

introduced in to these waters to provide quality fishing experiences. The Inyo offers suitable 

habitat for nonnative trout species (rainbow, brook, and brown trout) and golden trout. Although 

the Inyo is often thought to be dry, there is an estimated 1,640 miles of perennial streams, the 

majority of which offer angling opportunities. Common native species found in these systems 

include a variety of stream-dwelling macro-invertebrates, such as mollusk, caddis flies, mayflies, 

and stone flies. Seventy-eight percent of streams were found to be in good condition on national 

forest lands in the southern Sierra Nevada based on assessment of macro-invertebrate populations 

(Furnish 2013).

Within the last 100 years, native mountain yellow-legged frogs in the Sierra Nevada mountain 

range have gone from most abundant frog to the rarest due to fish stocking practices and the 

arrival of chytrid fungus (Bd) in Kings Canyon National Park (1960-70) that resulted in complete 

extirpation of some frog populations (Knapp 2017). Brown trout and rainbow trout were 

introduced into eastside Sierra streams and lakes as they are prized by anglers, but they prey on 

native amphibian populations. The California Department of Fish and Wildlife manages the 

fishery resources in the state and has changed fish stocking policies using triploid fish that are 

unable to reproduce, and work to remove stocked species from streams and lakes to in effort to 

restore native species where possible (Frissell, Scurlock, and Kattelmann 2012). The Forest 

Service works closely with California Department of Fish and Wildlife to return native species to 

the landscape in balance with managing for recreational fishing opportunities.

Aquatic nonnative, invasive vertebrate and invertebrate, and pathogen species are present within 

the plan area and can be attributed to reduced angling opportunities, mass frog die offs, and 

increased maintenance concern of hydroelectric and hydropower infrastructure. Fish stocking is 

known to be detrimental to native species, especially amphibians (Schwartz, Thorne, and Holguin 

2013). The New Zealand mud snail is established in the Owens River watershed and has been 

found to cause disruptions in stream food chains throughout the western states (Moore et al. 

2012).Aquatic invasive species will likely continue to spread throughout streams, rivers and 

reservoirs on boats, fishing equipment, and other water sports gear (CDFW 2008). Nonnative and 

invasive species are a continual and pervasive threat to native species in lakes and streams as it 

can be difficult and expensive to control them once they become established. The Inyo National 

Forest continues to manage Bd persistent frog populations (e.g., Mulkey Meadow) and Bd
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

292

negative aquatic habitats in partnership with California Department of Fish and Wildlife and the 

U.S. Fish and Wildlife Service. Plans are in place to respond to mass frog die offs that include Bd

inoculation efforts and rearing tadpoles to frogs in efforts to reintroduce disease free individuals 

back into Bd affected environments. 

Dams and water impoundments block movements of fish, amphibians, and aquatic insects 

resulting in a lack of habitat connectivity. However, the eastern Sierra streams have natural 

barriers and no native trout species move throughout the water systems similar to those of the 

west side of the mountain range. The only example in the plan area where dams create large 

barriers is on the San Joaquin. Its tributaries block salmon from reaching former habitat on the 

adjacent Sierra National Forest. By contrast, where at-risk fish or amphibian species are present it 

is often desirable to maintain barriers to aquatic connectivity to keep nonnative fish out of these 

waters. Examples of species managed beyond natural (or manmade) barriers, include golden 

trout, Lahontan cutthroat trout, and Paiute cutthroat trout. 

Meadows, Fens, and Springs 

Meadows

The Inyo National Forest has more than 25,000 acres of meadows. Although the overall area of 

meadows is a small proportion of the landscape (around 2 percent of national forest lands higher 

than 6,000 feet elevation), they provide critical ecosystem function. The Kern Plateau on the Inyo 

and Sequoia National Forest is an exception to this general pattern where meadows occupy an 

estimated 10 percent of the landscape. In general, wet meadows tend to have lower amounts of 

bare soil compared to dry meadows that have a wider spacing of vegetation and more exposed 

soil. Dry meadows occur in the most arid topographic positions and are primarily precipitationdependent. 

There are 1,479 meadows on the Inyo National Forest, of which 384 are in active grazing 

allotments and 202 in vacant grazing allotments (Roche et al. 2015). Meadows occupy between 

26,000 and 50,000 acres on National Forest System lands, depending on the definition and the 

scale of mapping. When dry alpine or subalpine meadows are included, the area is increased. The 

landscape of meadows extent depends on location. There have been no systematic condition 

assessments of all the meadows on the Inyo National Forest. Researchers sampled 10 randomly 

selected meadows on the Inyo National Forest, as part of a Sierra Nevada study (Fryjoff-Hung 

and Viers. 2013). Otherwise, assessments have focused on key grazing area meadows within 

active grazing allotments and packstock use areas. Rangeland conditions for these are described 

below. The condition rating of key grazing areas may not represent overall condition of special 

aquatic features across the national forest (USDA Forest Service 2013a).

Meadow condition depends on vegetation, hydrology, stream channel condition, and invasive 

species (Purdy, Moyle, and Tate 2012). Viers et al. (2013) found during drought in the Sierra 

Nevada that vegetation cover and bare ground cover ranged from natural condition to moderately 

or heavily impacted, depending on the montane meadow location. Meadows with incised 

channels are less resilient to water flow changes over time and face increased risk of damage 

from wildfire. Where meadow conditions are degraded, restoration may be necessary to restore 

hydrologic functions for dependent vegetation such as perennials, annuals, and willows (Frissell, 

Scurlock, and Kattelmann 2012).

In 1999, the Forest Service Pacific Southwest Region Range Program initiated a regionwide, 

long-term meadow condition and trend monitoring program. The primary purpose of the program 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

293

was to (1) document baseline meadow conditions as these new riparian standards and guidelines 

were coming into use, and (2) examine long-term trends in meadow condition following 

implementation of these riparian standard and guidelines. The program currently includes 618 

permanent meadow vegetation monitoring sites established in key meadows across the region 

including the Inyo National Forest. Vegetation composition is measured at the time a plot is 

established and then every 5 years following. There are 496 plots within the 10 national forests 

covered under the Sierra Nevada Forest Amendment. As of summer 2012, a total of 246 plots had

been reevaluated over the past 10 years, across 127 grazing allotments.

Specific to the Inyo National Forest, Freitas et al. (2014) examined the same Forest Service data 

set for 25 monitoring sites on the Kern Plateau within two vacant allotments and two active 

allotments. Freitas et al. concluded that riparian conservation grazing strategies implemented on 

the active allotments neither degraded nor hampered recovery of meadow conditions relative to 

non-grazed meadow conditions in the vacant allotments. 

Meadows and Rangelands: In 2012, the Forest Service Pacific Southwest Region and the 

University of California, Davis Rangeland Watershed Laboratory established a partnership to 

conduct the first comprehensive analysis of this unique dataset examining, meadow conditions 

and trends and the relationships between meadow conditions and trends, livestock management, 

weather, and environmental drivers (Roche et al. 2015). In this analysis, the number of plots 

available with at least 8 years between their earliest measurement (1997 to 2002) and the latest 

measurement (2007 to 2012) was 42 on the Inyo National Forest. The meadow plant community 

condition metrics analyzed included relative frequency data, Ratliff Vegetation Score and 

Condition Classification, and species richness and diversity. The comprehensive analysis found a 

significant increase in mean species richness and species diversity. There was no significant 

change in Ratliff condition class between the readings.

Five percent of these rangeland plots on the Inyo National Forest showed excellent to good 

vegetation condition with an upward trend: 74 percent were in excellent to good vegetation 

condition with a stable trend; 14 percent were in good vegetation condition with a downward 

trend; no plots were in a fair vegetation condition with an upward trend; 2 percent were in fair 

vegetation condition with a stable trend; 5 percent were in fair vegetation condition with a

downward trend; and no plots were in poor vegetation condition (USDA FS 2013a).

Because no systematic assessment of meadows exist in the Southern Sierra Nevada, the forest 

assessments provide information about a subset of meadows overall. Other meadow and stream 

assessments covering the Kern Plateau, and other areas on adjacent forests, indicated that a 

majority of meadows exhibited features such as ingrowth of trees, unstable banks, off-highway 

vehicle trails, headcuts, and gullies (Fryjoff-Hung and Viers. 2013)

Another study on the Inyo National Forest, which included the Kern Plateau, found that meadow 

plant species richness, diversity, evenness, and frequency of soil-substrate stabilizing species 

were not significantly different between grazed and ungrazed sites (Freitas et al. 2013). Modest 

increases in richness and diversity were observed over the 10-year study period, while evenness 

and frequency of soil-substrate stabilizing species were constant.

Fens

Fens are special sensitive habitat types with deep organic soils found at high elevation on the Inyo

(Wolf and Cooper 2015, Kattelmann and Embury 1996). Peatlands are at the wettest end of this 

hydrologic spectrum, occurring primarily as fens in the plan area. While the exact number of fens 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

294

on the Inyo National Forest is not known (and no consistent assessment exists), fens are estimated 

to represent about 10 percent of the meadows on the adjacent Sequoia National Forest and about 

1 percent of the landscape (M. Linton, personal communication). Further north, fens in Sequoia 

and Kings Canyon National Parks cover approximately 0.2 percent of the landscape (Hopkinson 

et al. 2013). On the Inyo National Forest, proper functioning condition information for fens that 

have been evaluated indicate that most either are properly functioning, or have an upward trend, 

or no trend (USDA Forest Service 2013a).

There are a total of 235 known fens on the Inyo National Forest. Generally, these fens are found 

within the larger meadow complexes. A total of 129 fens are within grazing allotments; 59 in 

active allotments and 70 in vacant allotments (University of California 2017, USDA Forest 

Service 2017d). Within these meadow complexes, fens play an important role in nutrient cycling 

and groundwater discharge, provide habitat for rare species, and are a major sink for atmospheric 

carbon (Weixelman and Cooper 2009). Proper functioning condition information for fens 

indicated that most either were properly functioning, or had an upward trend, or no trend. A small 

proportion was found to have a downward trend.

Springs and Seeps

Springs and seeps are a result of both precipitation and geologic structure and are generally found 

throughout the plan area. From the highest passes and valleys into the lower elevations, springs 

are found throughout the southern Sierra Nevada and the White and Inyo Mountains. Fully 

functioning springs are typically considered “biodiversity hotspots” supporting many species that 

only occur there, most notably spring snails. Spring habitats are vulnerable to damage from on- or 

off-site changes of water or land uses and species associated with springs typically have limited 

mobility; therefore, effective protection of springs is necessary to protect endemic species 

(Frissell et al. 2012). There is little information about the current trends for springs across the

landscape. However, drought has influenced flow in many springs, so the uncertainty of climate 

change may influence this habitat.

Lakes

Lakes on the eastern side of the Sierra Nevada Mountains in the Inyo National Forest range in 

size from 1 acre to hundreds of acres. No lakes occur in the White, Inyo, or Glass Mountains. 

Mono Lake is a vast inland saline lake of 44,480 acres. Approximately 478 freshwater lakes that 

are larger than 2 acres occur on the Inyo National Forest (USDA Forest Service 2013a). Ponds 

and other small waterbodies, such as tarns and pools, occur throughout the higher elevations 

within the Sierra Nevada Mountains. 

Historically, the lakes of the high Sierra Nevada were fishless and supported native fauna such as 

amphibians, aquatic insects, abundant zooplankton, and phytoplankton. However, many of the 

high-elevation lakes now support introduced brook, brown, rainbow and golden trout, which has 

had an impact on native frog populations (Knapp, Boiano, and Vredenburg 2007; Knapp and 

Matthews 2000a and 2000b). The historic introduction of trout into lakes throughout the Sierra 

Nevada mountain range has had the effect of eliminating the yellow-legged frog from over 95 

percent of its historic range (Vredenburg et al. 2007). The introduction of trout into these lakes 

has also altered the life-cycle and reduced the population numbers of macro-invertebrates and 

zooplankton within lakes (Knapp 2005; Schindler, Knapp, and Leavitt 2001). The loss of these 

keystone species changes the food web, and changes biodiversity. Aquatic ecosystem biodiversity 

in many of these lakes is outside the natural range of variation. A few lakes have remained 

fishless, or have had fish removed to protect amphibians and are being protected from additional 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

295

fish stocking by changes in stocking rules by the State fish and wildlife agencies. These fishless 

lakes provide important refuges for some amphibians to support their persistence. The stocking 

program allows for the persistence of trout species to occur throughout the plan area and provides 

the availability of angling in these areas. Fishing is an important economic benefit to the local 

communities and lake systems make up a high use of visiting anglers during open fishing season.

The California Department of Fish and Wildlife determines the schedule for stocking lakes and 

streams within and adjacent to the Inyo National Forest. Angler surveys and creel samples help 

determine where to stock hatchery resources.

Riparian Ecosystems

Riparian vegetation composition and structure are influenced by the size and type of stream, the 

amount of flooding, and the surrounding upland ecosystems and vegetation (Kondolf et al. 1996)

Kattelmann and Embury 1996). The diversity is also reflected by three major biological 

provinces: Sierra Nevada Mountains, Great Basin Desert, and Mohave Desert. In the Eastern 

Sierra Nevada region, the elevation gradient is abrupt, creating rapid transitions from desert and 

sagebrush vegetation at the lowest elevations, to pinyon-juniper woodlands, coniferous forests, 

and alpine areas. At lower elevations on the east slope of the Sierra Nevada, often only a few trees 

such as cottonwoods, willows, and birch are found. These systems are naturally drier and the 

riparian areas are limited in width. Similarly, at higher elevations throughout the Inyo National 

Forest, riparian vegetation is more limited in width in the subalpine and alpine areas with narrow 

bands of herbaceous riparian plants and often deciduous shrubs (such as creek dogwood or 

willow) are interspersed with upland forest trees (mostly conifers) growing next to the streams. 

Riparian plants can include grasses, sedges, shrubs, and trees (birch, aspen, cottonwood and black 

oak). Along larger streams, willow shrubs are common and plant communities vary by elevation

and aspect. The White and Inyo Mountains region is situated in the rain shadow of the Sierra 

Nevada, and receives less precipitation, as evident in the arid-adapted vegetation. Here too 

riparian areas are also naturally drier and limited in width. Several riparian areas are supported by 

springs and seeps in remote areas and several creeks experience year round flows that support 

meadow systems that include grasses, sedges, and shrubs. Willows are not as common among the 

riparian here, introduction of willow occurred along the north fork of Cottonwood Creek to 

provide refugia for reaches where Paiute cutthroat trout are managed. Aspen grooves occur within

the White Mountain and Sierra range and are associated with springs, creeks, uplands, and snow 

pockets. 

In the absence of fire within the natural range of variation, conifers have grown into riparian areas

and often are taller and now shade riparian hardwood trees, shrubs, and herbaceous plants in 

many areas of the east slope of the Sierra Nevada. Encroachment in aspen stands increases the 

fuel loads. This has occurred especially at low and middle elevations where fire was historically 

more frequent and trees grow relatively fast. Many riparian areas have become more uniform 

with dense overstory cover (especially of conifers), and fewer vigorous and diverse understory 

deciduous shrubs, grasses, sedges, and herbaceous plants. Many riparian plant species are adapted 

to disturbances such as floods, and vigorously resprout after disturbance. This makes them 

resilient to fire as well (Pettit and Naiman 2007). When composition and structure of riparian 

vegetation becomes dominated by conifers, especially at a high density, it becomes less resilient 

to fire. Many of the riparian areas in the analysis area are in this condition of low resilience. Fire 

return intervals are not within the natural range of variation over much of the landscape, and thus 

not within the range of variation for the interspersed riparian areas. 2015). A key aspect of 

understory composition that is affected by vegetation conditions and management is presence, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

296

condition and abundance of native sun-loving and fire enhanced plants. These two groups of 

plants have presumably had the greatest departure from the natural range of variability (Stevens 

and Safford in press). If implementation of the current Inyo National Forest grazing management 

strategy (USDA Forest Service 1995a) were to continue, vegetation and watershed condition 

trends are expected to improve, or continue to improve, for the next 20 years, particularly within 

riparian conservation areas.

Climate Change Influences to Aquatic and Riparian Ecosystems

The climate in the southern Sierra Nevada and White and Glass Mountains is normally variable 

by season and from year to year, and highly dependent on elevation, slope and aspect. Average 

annual precipitation ranges from 9 to 20 inches at lower elevations along the southern end of the 

Sierra Nevada, Kern River, and eastern slope; and up to 49 to 59 inches at higher elevations (Wolf 

and Cooper 2015, Kattelmann and Embury 1996). The White Mountains are generally drier than 

the Sierra Nevada and precipitation ranges from 6 inches in the lower valleys to 20 inches on the

crest of the range (Powell and Klieforth 1991). Changes in climate have influenced the quantity, 

quality, or seasonality of water and can have significant impacts on the ecological integrity of 

aquatic systems. Warming temperatures, particularly when combined with less precipitation, 

results in loss of stream flows, drying of shallow lakes or ponds, and changes in seasonal 

availability of aquatic habitat. Resilience of streams to climate change is influenced by sources of 

water, riparian forest cover, and meadow area (Frissell et al. 2012).

Changes in timing of snowmelt are already influencing stream flow patterns (Hunsaker, Long, 

and Herbst 2014b). Flood potential is predicted to increase, as is the proportion of precipitation 

falling as rain instead of snow (Safford, North, and Meyer 2012). This is likely to continue (Null 

et al. 2010) and will impact aquatic ecosystems through seasonal changes, decreased water flows 

and increased water temperatures. Stream flows in summer are declining and floods are occurring 

in winter rather than spring in areas dominated by snowmelt (Luce and Holden 2009, Isaak and 

Rieman 2013). These changes along with increases in stream temperature are expected to shift 

distributions of native fishes according to their water temperature requirement (Isaak et al. 2012;

Rieman et al. 2007; Wenger, Isaak, Dunham et al. 2011; Wenger, Isaak, Luce et al. 2011).

Over the next century, climate change is predicted to alter hydrologic and precipitation patterns, 

riparian vegetation, and the role of fire in riparian areas. This will have important effects on 

aquatic and riparian ecosystems, since they are shaped and are dependent on the amount and 

pattern of water. 

Climate change has the potential to affect surface and groundwater flows. If there are more severe 

floods that follow severe droughts, erosion of stream channels could increase. The rain-snow 

interface zone is predicted to occur at higher elevations, causing warming of streams earlier in the 

season. Streambank vegetation could decrease in vigor and extent if summer base flows become 

much lower or some perennial streams become intermittent. Then, when high flows occur, there 

would be a greater chance of channel scour and possible widening or gully incision.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

297

Environmental Consequences to Aquatic and Riparian Ecosystems

Consequences Common to all Alternatives 

Sustainability of Habitat

All alternatives provide basic protection of aquatic habitat from sedimentation, erosion, and 

nutrient mobilization; impediments to connectivity; and undesirable vegetation conditions is 

essential to ensure the resilience of aquatic habitats in the face of climate change, drought, and 

fire. Aquatic and riparian areas are a focus under all alternatives, and all alternatives incorporate 

riparian conservation area direction to ensure the Inyo staff considers effects to aquatic and 

riparian habitat in all project decisions. Plan components in all alternatives address treatment of 

existing headcuts in meadows and streams; impaired hydrologic connectivity and ecological 

connectivity; lack of mature willows, alders, and cottonwoods; sediment impacts from roads; 

legacy grazing impacts; and impacts from recreation use [are all identified as areas in need of 

restoration. All alternatives would also continue to implement work in priority watersheds as 

defined by the Watershed Condition Framework, for short-term restoration focus. While these 

project-level decisions and site-specific restoration actions could be similar under all alternatives, 

the broader-scale view of watershed restoration and landscape-level management focus should 

help create greater resilience to climate change and stochastic effects on a watershed and 

forestwide scale, as discussed by alternative below.

All alternatives require the use of best management practices in project design and 

implementation. Implementation of range best management practices are effective in reducing 

soil erosion and sediment delivery to streams, and annual monitoring of best management 

practices implementation and effectiveness will continue to help the Inyo modify practices to 

further reduce adverse impacts to riparian habitat. The aquatic and riparian plan components 

include forestwide watershed and riparian conservation area direction for the desired ecological 

conditions, and objectives outline a reasonable rate of progress given resources available. 

Monitoring and re-assessing indicators and attributes to assess watershed functioning condition

facilitates adaptive management. Continuing to implement restoration projects within priority

watersheds also contributes to achieving desired conditions. A watershed restoration action plan is 

developed for all priority watersheds that identify essential projects to restore legacy erosion sites 

and degraded aquatic and riparian habitats (including streams and meadows) are designed to 

improve overall biodiversity and ecosystem conditions. 

Dams and diversions would be managed the same way in all alternatives, with their management 

mostly outside of the control of the Forest. There would continue to be effects to aquatic and 

riparian ecosystems that are fundamentally altered from their natural condition. These effects 

would continue to improve over time, as they have over the past few decades, as the Forest 

Service and other agencies work through Federal Energy Regulatory Commission relicensing 

projects and other processes to alter flow patterns and diversion methods to minimize effects to 

aquatic and riparian systems. However, these water uses are important national forest uses and 

they will remain fundamentally the same as the current altered condition.

All alternatives would have the same livestock management guidance. Grazing levels may change 

over time with changing conditions, but those decisions would be made on a project-specific 

basis. All permits contain language that livestock will not enter the allotment prior to range 

readiness. Within the plan area, California golden trout and the Mountain and Sierra yellow 

legged frog overlap with active allotments. Typically, spawning and egg-laying timing coincides 

with spring melt-off in suitable habitats and is a consideration addressed in determining the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

298

timing of “range readiness,” for grazing (see “Production Livestock Grazing” section). Nothing in 

any of the alternatives will change methods for determining range readiness and preventing 

impacts to breeding habitat.

Forest plan components include grazing management in meadows (MA -RCA-STD-10-13 and 

17; MA-RCA-GDL-03 and 05). These standards and guidelines and others (DA-RNA-SUIT-08; 

SPEC-SHP-STD-01; RANG-FW-STD-01-07) are anticipated to improve grazing management, 

and result in positive meadow and riparian conservation area trends over time. These actions 

improve vegetative conditions, stability and resilience over time. 

Consequences Specific to Alternative A

Alternative A would continue to follow the current forest plan direction of the Inyo National 

Forest for management of aquatic species and habitats. The aquatic management strategy would 

continue to provide direction for riparian habitat according to riparian conservation objectives 

designed to maintain the ecology of riparian areas and reduce the risk of sediment from entering 

aquatic ecosystems. Standards and guidelines for alternative A emphasize protecting water quality 

and protecting riparian conservation areas by limiting active management within a variable buffer 

distance around riparian features offering protections in narrow bands for species specific needs 

(amphibians, fish, and aquatic snails). 

The emphasis on limiting active management in riparian areas, critical aquatic refuges, and 

meadows (which are considered to be riparian conservation areas) means that while projects will 

continue to minimize short-term effects to riparian and aquatic habitat, there will also continue to 

be a smaller-scale view of restoration, and watershed-wide restoration will be less likely to occur. 

Therefore, the resilience of aquatic and riparian habitat will be less than in the plan revision

alternatives on a watershed scale in the long term, on a landscape scale. Alternative A has the 

fewest acres of riparian habitat improved, and the least number of meadows enhanced. In 

alternative A, prescribed fires could not originate in riparian areas, limiting the ability to return 

natural fire into riparian ecosystems. Further, conifer or shrub removal in meadows in less likely 

to occur, and there is less focus on restoration, limiting the ability to restore as many meadows.

Community wildfire safety concerns would be addressed by an emphasis on fire suppression. 

There would continue to be limited restoration of riparian vegetation. Few areas would have 

conifers removed to restore hardwood dominance where conifers have grown in and are outside 

the natural range of variation. Although wildfire is recognized as an essential ecosystem process, 

wildfire managed to meet resource objectives would generally be limited to select areas, such as 

wilderness and remote areas. This would reduce the ability to use natural fire to thin riparian 

areas that currently have very thick growth. These riparian areas often act as a conduit for severe 

fires during wildfire, increasing the sediment input and reducing stream stability. These effects 

can have major impacts to aquatic and riparian ecosystems than the more frequent, less severe 

fires expected forestwide under the plan revision alternatives. While effects may not be different 

on any individual stream, on a forestwide scale, this alternative would have the greatest potential 

for negative effects from uncharacteristically large and severe wildfires.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

299

Table 50. Critical aquatic refuge name and acres in alternative A

Critical Aquatic Refuge

Name

Acres in 

Riparian 

Conservation 

Areas

Acres out of 

Riparian 

Conservation 

Areas

Acres not in 

Riparian 

Conservation 

Areas, but within 

Wilderness

Total 

Acres

Baker Creek 4,402 15,920 2,085 20,322

Barrel Springs 563 1,265 1,264 1,828

Cottonwood Creek 7,590 21,648 17,891 29,238

Crater Meadow 2,301 4,341 4,338 6,642

Crooked Meadow 321 956 0 1,276

Dry Creek 349 1,340 0 1,688

Elderberry Canyon 502 1,845 1,581 2,348

Gable Lakes 584 1,658 1,657 2,242

Glass/Deadman/Big Springs 3,846 12,733 6,691 16,579

Golden Trout/Volcano Creeks 10,341 27,761 27,761 38,102

Haiwee Canyon 1,297 5,896 6 7,192

Harvey Monroe Hall RNA 3,557 6,761 5,189 10,318

Lead Canyon 2,519 8,631 8,631 11,150

Little Hot Creek 787 2,738 0 3,526

O'Harrel 311 1,353 0 1,664

Olancha 816 2,960 2,751 3,776

Upper Convict/McGee (Mono) 3,874 8,836 8,833 12,709

Total Acres 43,960 126,642 88,678 170,600

Sustainability of Habitat

Alternative A focuses on developing resilience to fire with prioritization of areas around 

communities. This alternative includes the implementation of the aquatic management strategy. 

Current plan direction emphasizes restoration of hydrologic connectivity but does not include 

specific direction for the restoration of habitat for all life stages of aquatic or riparian associates. 

Restoration of aquatic ecosystems is a priority for the Inyo National Forest following the 

“Ecological Restoration Leadership Intent” established by the Regional Forester (USDA Forest 

Service 2015g). Improvement of aquatic habitat conditions is primarily related to mitigating the 

effects of roads and addressing hydrologic connectivity. 

Under this alternative, limited implementation of restoration is anticipated, leaving many areas 

containing at-risk aquatic species untreated. Direction under this alternative has allowed for 

improvements to increase ecological integrity of streams by actions such as reducing trail and 

road density in riparian areas and meadows and removing or mitigating effects of dispersed 

camping from the edges of meadows and streams. These standards and guidelines have been in 

place since 2004, and along with best management practices, have worked well to protect most 

stream habitats from sedimentation, other than sedimentation from uncharacteristic fires. Riparian 

and aquatic ecosystems would remain vulnerable to increased sediment input from 

uncharacteristically large fires without increased restoration and fuels treatment. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

300

Ecological Connectivity

Hydrologic connectivity is addressed under this alternative through maintenance of ecological 

connectivity among habitats for some aquatic species and riparian associates. Restoration of 

ecological connectivity by improving road crossings or mitigating water diversions would be 

expected to occur at a slow pace under this alternative because the focus is on relatively smallscale treatments which can only improve local or reach-scale conditions.

Biodiversity

In the current plans, direction and best management practices reduce the impacts of management 

actions locally but do not by themselves address the biodiversity, sustainability, or persistence of 

aquatic and riparian associates. Plan direction is primarily prescriptive and restrictive to limit 

management activities that would restore forest vegetation and improve habitats that support the 

persistence of all life stages of aquatic or riparian species. Similarly, plan direction in alternative 

A does not emphasize management of invasive species or restoration of ecological connectivity as 

well as the other alternatives.

Resilience to Climate Change

Adaptively managing aquatic habitats for resilience to future climate change, or improving 

adaptive capacity of aquatic ecosystems through ecological restoration and climate adaptation 

actions are not explicitly addressed in the current forest plans. Therefore, resilience of riparian 

and aquatic systems to climate change is expected to be less than in other alternatives. Climate 

changes may alter riparian habitats substantially (Perry et al. 2015), especially those that are 

outside the natural range of variation. Projects designed under the current plans incorporate 

actions to increase resilience to the extent they are consistent with other sections of the plan.

Riparian Vegetation

Resilience of riparian composition and structural heterogeneity to climate change and increased 

risk of wildfires would not be improved in alternative A except on the occasional basis. Thom and 

Seidl (2015) investigated the role of natural disturbance (fire, wind, and bark beetles) in riparian 

areas and found effects on ecosystem services were negative but effects on native riparian species 

diversity was positive. There is some ability to restore riparian vegetation structure and 

composition in alternative A but it is limited by restrictions on mechanical treatments within 

riparian conservation areas. Prescribed fire restrictions in riparian areas limit direct fire ignitions,

which reduces the ability of fire managers to create a patchy mosaic within riparian areas to lower 

the risk of riparian vegetation burning at high intensity during wildfires. There is less control of 

fire intensity and spatial pattern of fires when they back down into riparian areas compared to 

when fire managers are allowed to use ignition patterns to more closely control the fire behavior. 

The limited amounts of restoration would result in most riparian areas continuing to trend toward

a decrease in heterogeneity and degraded condition of hardwoods. Less fuel reduction within 

watersheds under alternative A can lead to future larger fires that burn at high intensity and 

impact upland and riparian vegetation and cause more intense fire in riparian ecosystems. 

Alternative A has the most limited area where wildfires could be managed to meet resource 

objectives, primarily in wilderness areas, leaving most riparian areas with an altered fire regime.

Consequences Specific to Alternative B

Alternative B improves resilience of terrestrial ecosystems to climate change by increasing the 

pace and scale where vegetation is being restored, decreasing the threat of large, high-intensity 

wildfires, and increasing the local capacity to restore vegetation and reduce fuels. Riparian 

conservation area widths can be adjusted to meet or improve riparian conservation area desired 

conditions if identified at the project level through an interdisciplinary analysis. Riparian 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

301

conservation area buffers would be adjusted based on site-specific conditions and new scientific 

information as it becomes available. 

This alternative manages the same riparian conservation areas as alternative A using the full suite 

of plan components (desired conditions, standards, guidelines, goals) to move riparian ecosystems 

toward resilience to fire and climate change. While they still use riparian conservation areas, all 

plan revision alternatives would adjust riparian conservation area direction relative to the current 

plan to allow for greater use of prescribed fire within riparian areas, and allow for more acreage 

of riparian restoration using a wider range of methods. The flexibility within the riparian 

conservation area direction is designed to reduce the negative effects of wildfire more effectively 

than the limited treatment approach of alternative A and alternative C. Treatments to improve fire 

resilience in riparian ecosystems over the long term would be guided by desired conditions, 

standards, and guidelines that protect water temperature, riparian vegetation and other conditions 

that provide quality habitat for dependent wildlife over the short term.

Alternative B provides management direction that would likely increase restoration activities or 

opportunities on adjacent lands and wilderness in part because of how this alternative’s strategic 

fire management zones could have a positive effect on ecosystem integrity at the watershed scale

compared to alternative A.

Alternative B would continue the use of critical aquatic refuges to protect aquatic species, using 

the same direction as riparian conservation areas for the critical aquatic refuge areas. Table 4 in 

chapter 2 shows that about 191,500 acres of critical aquatic refuges would be designated under 

alternative B, which is about 20,000 more acres than alternative A, with one more critical aquatic 

refuge designated. These are expected to help protect aquatic and riparian habitat in the short term 

by limiting mechanical treatments and prescribed fire within the relatively small refuges, and by 

requiring that all projects are analyzed to determine their effects on water quality, habitat 

connectivity, and riparian health. However, this alternative does not focus on watershed-wide 

restoration, and therefore would continue the current level of vulnerability to uncharacteristically 

large and severe wildfires that could severely affect riparian and aquatic habitat within and 

downstream of these fires.

Sustainability of Habitat

Some management activities like vegetation management and maintenance and development of 

infrastructure, like roads, trails and campgrounds, have the potential to cause both short- and 

long-term adverse impacts to aquatic and riparian habitat (Frissell et al. 2012). Desired 

conditions, standards, and guidelines in this alternative are designed to protect aquatic habitats. 

The reduction of high-intensity wildfire risk, especially within riparian areas, would improve 

watershed and aquatic habitat conditions over the long term compared to alternative A.

The proposed increase in ecosystem restoration is not expected to result in substantially increased 

amounts of sediment and other disturbances to streams. All projects would be designed to 

incorporate best management practices to mitigate soil and sediment impacts and would be 

designed to maintain or improve riparian and aquatic ecosystem desired conditions. Best 

management practices and standards and guidelines are designed to reduce the risk of sediment 

from entering aquatic ecosystems. Alternative B would allow for more improvement of 

watersheds and riparian ecosystem function. The goal of increasing restoration of aquatic habitats 

through partnerships would help increase the pace and scale of restoration under alternative B, 

compared to alternative A. The potential for short-term effects from the increased pace and scale 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

302

of restoration would be balanced against the long-term benefits to aquatic habitats for alternative 

B.

Ecological Connectivity

While there is uncertainty about the magnitude of climate change, connectivity can be affected,

especially where barriers block species movements. Desired conditions address the maintenance 

and restoration of ecological connectivity among habitats for aquatic or riparian associates. The 

increase in the pace of restoration compared to alternative A, especially in concert with an 

increased use of partnerships, should allow for an increase in the restoration of aquatic 

connectivity. The increase in vegetation restoration projects would increase the potential to 

replace and improve road culverts to improve hydrologic and aquatic connectivity. For 

amphibians associated with streams and meadows, connectivity requires movement between 

habitat islands to allow dispersal among subwatersheds.

Riparian conservation areas aim to improve conditions of stream corridors for movement and 

foraging habitat of at-risk species. Plan direction would guide projects that occur within riparian 

conservation areas to consider connectivity of riparian habitats and related needs of at-risk 

species. Connectivity among streams for aquatic species would improve over the landscape as 

undesired barriers are removed or restored to reduce fragmentation and maintenance of desired 

barriers to separate invasive species from native species. A greater emphasis on partnerships will

result in increased resources to restore riparian and aquatic habitats and provide for greater 

ecological connectivity.

Biodiversity

Restoration of degraded habitats would lead to increased resilience for aquatic and riparian 

associates. Desired conditions address native aquatic species and encourage aquatic restoration 

across the landscape to provide for the persistence of species. An increase in terrestrial ecosystem 

restoration could have localized, short-term negative effects to aquatic and riparian associates, but 

would be offset by long-term benefits where actions would restore riparian vegetation, improve 

hydrological function or increase fire or climate change resilience. 

Increased partnerships to restore riparian habitats would improve ecological conditions that 

support the persistence of native species and biodiversity. Existing critical aquatic refuges are 

managed similar to alternative A with one new critical aquatic refuge added around populations of 

the black toad. Desired conditions, standards, and guidelines would guide management of habitat 

for all aquatic species. 

Alternative B has potential for localized, short-term impacts for slow-moving species 

concentrated in moist riparian areas due to mechanical treatments and prescribed burning. Timing 

of prescribed burning and other ground-disturbing activities outside of species’ activity periods 

could minimize these effects and can be determined at the project level for specific at-risk 

species. Minimizing short-term consequences on aquatic species when restoring aquatic and 

riparian habitat in conjunction with the long-term benefits of more sustainable and resilient 

landscapes would improve persistence of species. Overall, the goal to increase restoration of 

aquatic and riparian habitats would address species needs and improve biodiversity more than 

alternative A.

Resilience to Climate Change

Managing aquatic habitats for resilience to future climate change and improving adaptive 

capacity of aquatic ecosystems through ecological restoration and climate adaptation actions are 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

303

addressed in the desired conditions for alternative B. Riparian plants provide shade over streams 

and can be restored or protected to cool streams across the landscape to counteract the warming 

temperatures that are already occurring. The risk of large intense fire in riparian areas would be 

reduced with this alternative (see “Fire Trends” section). 

Riparian Vegetation

There would be more emphasis on ecosystem restoration, including riparian vegetation 

restoration in alternative B, than in alternative A. As national forest managers increase the pace 

and scale of restoration, including mechanical thinning, prescribed fire, and managing wildfire to 

meet resource objectives, the forests and riparian areas should become more resilient to climate 

change.

All restoration that results in a reduction of conifer encroachment and an increase in 

heterogeneity in riparian areas would move riparian vegetation composition and structure toward 

the natural range of variation. This would improve growing conditions for riparian hardwoods 

and shrubs that are often shaded out by upland trees and shrubs. Prescribed fire and wildfire 

managed to meet resource objectives would improve the condition, vigor and health of most 

native riparian plants. Many native riparian plants sprout as an adaptation to flooding and this 

often allows them to respond positively to fire as well (Fites-Kaufman, Bradley, and Merrill 2006, 

van Wagtendonk and Fites-Kaufman 2006). The trend in composition and structural heterogeneity 

of native species would increase. The Final Revised Plan contains plan components that address 

water quality in the forestwide desired conditions section (WTR-FW-DC-02 and 03), forestwide 

standards (WTR-FW-STD-01), riparian conservation area standards (MA-RCA-STD-01, 03, 10, 

17), and riparian conservation area guidelines (MA-RCA-GDL-02). Temperature is specifically 

addressed in MA-RCA-STD-01. Also, while water quality was not specifically noted in every 

riparian conservation area and conservation watershed plan component, all plan components that 

aim to restore hydrologic function and riparian health would have a positive impact on water 

quality. 

An increased emphasis on wildfire managed to meet resource objectives would continue to 

provide improved riparian vegetation conditions and reduce the risk of intense fire across large 

landscape areas, especially those in higher elevations where there are fewer opportunities for 

more direct restoration. The reduction in risk of severe wildfire can improve the overall resilience 

of these systems over the life of the plan. Alternative B would lead to more improvement of 

riparian ecosystem resilience to fire and climate change compared to alternatives A and C.

Consequences Specific to Alternative B-modified

Alternative B-modified updates the approach for aquatic and riparian resource conservation; it 

considers recently available data on aquatic biological diversity in the Sierra Nevada and the scale

of megafires that have been increasing in frequency over the last 15 years. The updated approach 

includes plan direction for watersheds, riparian conservation areas and conservation watersheds. 

Conservation watersheds replace critical aquatic refuges as a management area. 

Conservation watersheds are intended to maintain large landscapes where high quality water 

contributes to beneficial uses and conservation of at-risk species. The average size of critical 

aquatic refuges is 10,000 to 40,000 acres; conservation watersheds are typically larger than 

40,000 acres. In alternative B-modified, four conservation watersheds encompass almost 379,000

acres. Table 51 shows the acreage of conservation watersheds across the Inyo National Forest 

under alternative B-modified.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

304

Because conservation watersheds operate at larger scale, they are expected to provide better 

resilience in the face of large wildfires. Conservation watersheds include plan direction using

indicators and measure to reach desired conditions (MA-CW-DC-01-03), objectives to improve 

landscape conditions (MA-CW-OBJ-01), standards for balancing recreation uses (MA-CW-STD01), and guidelines that accept short-term effects when long-term objectives are supported (MACW-GLD-01-03) that increase the pace of restoration. Also potential management approaches 

prioritize restoration work in conservation watersheds. The four conservation watersheds (table 

51) associated with Alternative B-modified can be recommended for future consideration as part 

of the National Fish and Aquatic Strategy26 as criteria are developed to select conservation 

watersheds across all national forests and grasslands by 2020. Partnership with local clubs, 

schools, and Tribes as well as grant funding through state and national fish, wildlife, and 

motorized have ongoing investments within these four conservation watersheds and are expected 

to continue. 

Conservation watersheds will complement, not replace, priority watersheds identified through the 

agency’s 2011 Watershed Condition Framework. By definition, priority watersheds under the 

Watershed Condition Framework are designated as such for relatively short periods of time (3 to 

5 years) chosen to improve an indicator’s functional rating. In contrast, implementation of 

conservation watershed direction is intended to help protect and maintain functioning aquatic 

systems as well as restore degraded watersheds, which will benefit aquatic and riparian resources 

over the long term. The forestwide watershed plan components are designed to maintain or 

improve overall functional character and the Watershed Condition Framework provides the data 

necessary to measure such progress.

Table 51. Acres of conservation watersheds under alternative B-modified

Conservation Watershed

Acres in 

Riparian 

Conservation 

Areas

Acres out of 

Riparian 

Conservation 

Areas

Acres not in Riparian 

Conservation Areas, 

but within Wilderness

Total 

Acres

Cottonwood-Crooked 

Creek Headwaters 15,070 47,646 26,784 62,716

Middle Fork San Joaquin 

River Headwaters 17,606 31,070 28,395 48,676

Mono Lake Headwaters 23,372 60,515 39,180 83,887

South Fork Kern River 

Headwaters 45,275 138,173 124,902 183,447

Total Acres 101,323 277,404 219,262 378,727

The change to conservation watersheds from current critical aquatic refuges (alternative A) is that

13 out of the 17 critical aquatic refuges (table 50) do not overlap with conservation watershed 

boundaries. However, 10 of the 13 contain federally listed species that are protected under the 

Endangered Species Act and 8 of these critical aquatic refuges are currently provided protections

by designated critical habitat. The remaining 6 refuges not within conservation watersheds have 

species coverage by relevant plan components under special habitat (see Terrestrial Vegetation 

direction), riparian conservation areas, and/or species specific plan components. Unlike critical 

aquatic refuges that focused on aquatic species, conservation watershed plan direction recognizes 

the value of biodiversity collectively in adjacent uplands habitat and aquatic and riparian 

 26 https://www.fs.fed.us/naturalresources/fisheries/resources/risetothefuturestrategynov2017.pdf
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

305

ecosystems and incorporates direction that supports long-term functionality of these terrestrial 

systems (MA-CW-GDL-01). 

Alternatives B, B-modified, C, and D all propose increased use of wildland fire for ecological 

benefit. This activity can occur in designated wilderness, promoting ecological restoration of the 

conservation watersheds. In terms of actual active watershed restoration, current Forest Service 

manual direction limits what can be done in wilderness areas:

Watershed improvements may be used to restore watersheds where deteriorated soil and 

hydrologic conditions caused by humans or their influences create a serious threat or loss 

of wilderness values. Watershed condition improvements are also appropriate where 

natural conditions present a definite hazard to life or property; or where such conditions 

could cause serious depreciation of important environmental qualities outside of the 

wilderness. Promote natural healing where such dangers are not imminent or where 

natural vegetation would return in a reasonable time (FSM 2300, Chapter 2323.43).

Restoration activities or opportunities on adjacent lands and wilderness in part can occur because 

of how strategic fire management zones could have a positive effect on ecosystem integrity at the 

watershed scale compared to alternative A.

Only Cottonwood-Crooked Creek Headwaters conservation watershed contains alternatives B 

and B-modified proposed wilderness designation (see table 52). This would have nominal effects 

because alternative B-modified provides management direction that would likely increase 

restoration activities on adjacent lands and wilderness compared to alternative A, which would be 

beneficial to watershed condition ratings.

Table 52.Proposed wilderness areas within Cottonwood-Crooked Creek Headwaters conservation 

watershed

Proposed Wilderness Area 

(Alternatives B, B-modified) Total Acres

Acres in 

Conservation 

Watershed

Percentage in 

Conservation 

Watershed

White Mountain Wilderness 

Addition - West 5,062 4,999 99 percent

White Mountain Wilderness 

Addition - East 2,505 2,482 99 percent

The Final Revised Plan contains plan components that address water quality in the forest wide 

desired conditions section (WTR-FW-DC-02 and 03), forest wide standards (WTR-FW-STD-01), 

riparian conservation area standards (MA-RCA-STD-01, 03, 10, 17), and riparian conservation 

area guidelines (MA-RCA-GDL-02). Temperature is specifically addressed in MA-RCA-STD-01. 

Also, while water quality was not specifically noted in every riparian conservation area and 

conservation watershed plan component, all plan components that aim to restore hydrologic 

function and riparian health would have a positive impact on water quality.

Sustainability of Habitat

Unlike critical aquatic refuges, the conservation watersheds include entire hydrologic systems 

from headwaters to community water districts, in management areas beyond wilderness and 

inventoried roadless area land allocations. Inclusion of public lands near or adjacent to wilderness 

and inventoried roadless areas can maximize benefit to conservation watershed; an assumption 

based on the conservation biology literature where scale helps achieve landscape connectivity.

Based on adjacency and the large scale landscape approach, conservation watersheds capture
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

306

greater diversity of habitats that allow for desired conditions to be achieved and sustained, over 

the long term.

If proposed White Mountain East and West additions are designated wilderness, approximately 

7,481 acres would limit future development of roads and infrastructure resulting in preservation 

of existing suitable habitat and connectivity within Cottonwood-Crooked Creek Headwaters 

conservation watershed. Although it would maintain or improve the watershed condition 

framework rating, fuels reduction and restoration could be impeded.

Unmanaged recreation can adversely affect aquatic and riparian ecosystem integrity caused by 

user-created trails, dispersed camping, and motorized vehicle use outside of designated travel 

routes. Likewise, as the trend of visitors increases, managed recreation could result in negative 

impacts and require more maintenance of authorized trails and camps in aquatic and riparian 

ecosystems. Sustainable recreation presented in alternative B-modified could provide for 

expansion of recreational opportunities under the General Recreation Area. Recreation direction 

within conservation watersheds requires that any site-specific activities that occur within the 

Destination or General Recreation Areas will continue to promote the maintenance or restoration 

of the Watershed Condition Framework indicators (MA-CW-STD 01). Recreation opportunities 

such as hunting, hiking, pack stock use, fishing and other water-based opportunities would likely 

enhance areas associated with aquatic systems (hardening water crossings, bridge maintenance, 

and creek crossings) from watershed improvements done in conservation watersheds as the health 

of watersheds is improved.

Although alternative B-modified emphasizes fire’s role in restoring ecological integrity to the 

landscape and would moderate the upward trend of wildfire frequency and intensity, the effects of 

climate change and insect and disease outbreaks over the long term increase the risk of highintensity wildfire over current conditions. The emphasis on restoring low- and medium-intensity 

fires across the landscape within conservation watersheds would include riparian areas, limit the 

accumulation of fuels, restore understory plants of cultural importance to Tribes, and encourage 

vigorous riparian habitats.

Ecological Connectivity

Conservation watersheds are made up of multiple HUC 12 watersheds to the point that the sum 

total meet several criteria such as beneficial downstream uses, biodiversity and opportunity of 

projects. In the plan area 143 HUC 12 watersheds occur. Of these, 118 overlapped with 

inventoried roadless areas and out of those, 84 overlapped with wilderness. The four selected 

conservation watersheds connect aquatic and riparian habitats and serve as corridors thus 

providing ecological connectivity at the landscape scale. Connectivity is important for migration 

of game species like deer and bear who travel great distances from winter grounds to summer 

grounds. Local and migrating bird, bat and pollinator species rely on connected riparian corridors 

for dispersal, foraging, and breeding habitat. Surface and groundwater systems important to 

aquatic biota are often interconnected hydrologic systems connecting or supporting headwater, 

springs, meadows and seeps. Use of HUC 12 watersheds are assumed to contain these 

interconnections that contribute to the overall quantity of water within such basin. 

The importance of a landscape-scale approach to establish functioning aquatic and riparian 

ecosystems is now pervasive in the literature. Proposing new critical aquatic refuges and having 

existing critical aquatic refuges at high elevation may not serve to restore large rivers and lower 

elevation habitats for aquatic species (Frissell et al. 2012). In the Sierra Nevada, one of the first 

considerations of this approach was in Moyle (1996). This approach was used in the Northwest 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

307

Forest Plan based on the report of the Forest Ecosystem Management Assessment Team 

(FEMAT) in July 1993. It is a fundamental premise for the National Fish Habitat Partnership 

(http://www.fishhabitat.org/) in advancing aquatic and riparian conservation across the country. In 

addition, literature has emerged over the last 20 years that suggests that positive synergies can be 

achieved when managing both for forest (terrestrial) and aquatic outcomes. Over 20 years of 

monitoring of management outcomes that were informed by large landscape scale planning have 

demonstrated that such an approach contributes to maintenance and restoration of aquatic 

systems. For instance, enhancing the connectivity of riparian species (water birch, narrow-leaved 

cottonwood, and black oak) and priority habitats unique to Inyo National Forest would encourage 

genetic diversity and dispersal to enhance resilience. While some of this literature does not focus 

on the Sierra Nevada per se, much is applicable.

Ecological connectivity criteria was used to select for conservation watersheds. The difference is 

conservation watersheds provide for resilience to large-scale, unpredictable events over four 

contiguous areas and twice the acreage as compared to 17 noncontiguous areas of critical aquatic 

refuges. The cumulative beneficial effects of restoration on ecological connectivity within 

conservation watersheds are expected to be greater than in critical aquatic refuges because of this

difference in scale. Therefore, alternative B-modified could result in more connectivity associated 

with conservation watersheds than all other alternatives. 

Biodiversity

Biodiversity is addressed in this alternative through the consideration of conservation watersheds, 

which include both terrestrial and aquatic at-risk species and special aquatic features within 

functioning watersheds (see Development of Conservation Watersheds for the Inyo National 

Forest 2017, project record)). Under alternatives A, B, C, and D, diversity is limited to aquatic 

species within critical aquatic refuge designation. When critical aquatic refuges were designated, 

Yosemite Toads and yellow-legged frogs were not federally listed. They are now listed as 

federally endangered or threatened, along with Paiute and Lahontan cutthroat trout, which have 

been listed for decades. Where critical aquatic refuges now have federally listed species, there 

exist Endangered Species Act requirements to regulate the management of these species 

regardless of which alternative is selected. Plan standards (which are mandatory constraints on 

national forest actions), are included for at-risk species that critical aquatic refuges were 

developed around including Yosemite toad and yellow-legged frogs (SPEC-AMPH-STD), golden 

trout (SPEC-GT-GOAL), Lahontan cutthroat trout (SPEC-LTC-STD). Aquatic and riparian 

special habitats (desert springs, seeps, and fens) are considered special aquatic features and 

relevant plan components are in the “Riparian Conservation Area” section of the plan. These 

special habitat components provide greater protection than critical aquatic refuges for spring 

snails, for example, but are inclusive of native plants, pollinators, long-term sustainability 

(TERR-SH-DC-01-03), and management priority. They provide greater protection by improving 

watershed resilience to climate change, fire and other unpredicatable events, while providing the 

same short-term protection during project implementation.

The diversity of at-risk plant species was a driver for designating conservation watershed areas. A 

high level of species richness and biodiversity is expected in conservation watersheds because 

they score high in overall condition rating in water quality and quantity, which are critical 

elements for most living organisms. In properly functioning watersheds, aquatic and riparian 

systems are expected to provide for biodiversity. Conservation watersheds capture a diversity of 

habitats (including terrestrial upland) expected to provide suitable habitat necessary for various

life stages particularly those that experience metamorphism like amphibians or butterflies. One of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

308

the main drivers for designating cottonwood-crooked creek headwaters conservation watershed 

was the diversity of at-risk plant species. Including upland habitat with aquatic and riparian 

systems provides for overwintering, foraging of pollinator plants and use of migration corridors 

for dispersal. Monitoring watershed condition indicators like aquatic biota condition and forest 

health condition can be important indicators of species diversity which did not happen with

critical aquatic refuges. Therefore alternative B-modified is expected to provide for biodiversity 

compared to all other alternatives. 

Resilience to Climate Change

The large scale of conservation watersheds compared to critical aquatic refuges is the primary 

difference between all other alternatives in regards to climate change. Without more active 

watershed-level restoration as well as restoration of aquatic habitat, no increase in habitat or 

species resilience to climate change would occur (Moyle et al. 2013, Viers et al. 2013). To 

highlight the differences, conservation watershed acres would be 387,680 versus 191,010 for

critical aquatic refuges. One conservation watershed is located in White Mountain landscapes 

which benefits Nevada as well as California; none of the critical aquatic refuges provided this.

This alternative would reduce the risk of high-intensity wildfire impacts to riparian areas and 

adjacent uplands as well as other alternatives due to the decreased area with fuel reduction 

treatments. Where changes in temperatures and amounts and timing of precipitation have led to 

earlier peak stream flow rates in most Sierra Nevada streams, with higher spring flows and lower 

summer flows will be more detectable within conservation watersheds than critical aquatic 

refuges. If overall precipitation increases over time, streamflow volumes during peak runoff will 

increase even more, leading to notably higher flood risk in downstream areas forest priorities may 

shift to protect such infrastructure and resources. As national forest managers increase the pace 

and scale of restoration, including mechanical thinning and increasing the use of managed 

wildfire to meet resource objectives, riparian areas would become more resilient to climate 

change. Therefore, alternative B-modified differs slightly from all other alternatives if pace and

scale of restoration in conservation watersheds occurred; the result broadens the level of 

resilience to climate change.

Riparian Vegetation

All alternatives provide riparian vegetation management and protections using both priority 

watersheds and riparian conservation areas. Alternative B-modified differs in using conservation 

watersheds and eliminating critical aquatic refuges. Because of the conservation watershed focus

(MA-CW-CDL, MA-CW-DC) on restoring entire watersheds across various ecosystem types, it 

should help improve watershed conditions on a watershed scale and better protect from large, 

severe fires, heavy rainfall, and other events. While the emphasis on restoration within riparian 

conservation areas and conservation watersheds, and reduction of fuels and return to natural fire 

intervals may have some short-term effects, the plan explicitly accepts these impacts in order to 

improve the overall long-term functionality of watersheds. This should help protect and enhance 

riparian habitat greater than the other alternatives. 

The emphasis on project activities, both restoration and other uses, would be designed to attain 

functional watershed condition indicators; have short-term, site-specific impacts that support the 

long-term functionality of systems; and reduce impacts. Although similar to alternatives B, C, and 

D, alternative B-modified plan direction provides latitude and flexibility with the intent to

increase the pace and scale of restoration in riparian areas, meadows, and streams. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

309

Consequences Specific to Alternative C

Alternative C would have the least restoration using mechanical treatment of all alternatives, and 

an increased emphasis on the use of prescribed fire and managing wildfires to meet resource 

objectives. Riparian conservation areas would be managed similar to alternative B. Although 

there is more emphasis on managing wildfire to meet resource objectives proposed for alternative 

C, there is a high uncertainty about how much would actually occur because of low levels of 

mechanical restoration used to create strategic areas to “anchor” large prescribed fires and 

wildfires managed to meet resource objectives. If there is more fire, there could be a greater 

benefit in alternative C, because more small fires and prescribed fires could reduce sediment 

input relative to larger, more severe wildfires. The benefit would be in more limited locations 

compared to the other alternatives and the intensity of prescribed fire might be higher than in the 

other alternatives due to higher densities of fuels being burned without any previous mechanical 

treatment to thin before burning. 

In alternative C, the Wildfire Maintenance Zone would be the most likely to have benefits to

wilderness characteristics, where wildfires could be safely managed while still restoring fire as an 

ecosystem process. The general wildfire zone may make it more difficult to evaluate wildfire risk 

resulting in slightly less wildfires managed to meet resource objectives within existing wilderness 

areas.

Sustainability of Habitat

Desired conditions, standards, and guidelines in alternative C would provide for maintenance of 

aquatic habitat and protections of aquatic habitats. The large-scale landscape approach has the 

potential to address national forest infrastructure such as roads, trails, and dispersed campgrounds 

within sensitive areas. This should improve watershed and aquatic habitat conditions over the 

long term compared to alternative A. The goal of increasing restoration of aquatic habitats 

through partnerships would help increase the pace and scale of restoration under alternative C, 

when compared to A. Equipment use would be more restricted in riparian conservation areas 

compared to the alternatives B, B-modified, and D. The potential for short-term effects from the 

increased pace and scale of restoration under alternatives B, B-modified, and D would be reduced 

under alternative C. Alternative C would increase new critical aquatic refuges compared to

alternatives A, B, and D, although most of them are in existing designated wilderness areas or 

areas recommended for management as wilderness. The goal to restore aquatic habitat could 

improve the resilience and sustainability of aquatic and riparian habitat under alternative C and is 

similar to alternative B-modified.

Simply setting aside critical aquatic refuges does not in itself improve resilience and 

sustainability of aquatic habitats and ecological integrity. Proposing new critical aquatic refuges 

and having existing critical aquatic refuges at high elevation may not serve to restore large rivers 

and lower elevation habitats for aquatic species (Frissell et al. 2012). The increase in the number 

of stream miles restored and meadows restored under this alternative would increase the pace of 

restoration compared to alternative A, but would not be sufficient to achieve the restoration 

needed to reverse past legacy land use degradation of habitat. Restoration of aquatic habitat with 

partners could improve sustainability and resiliency of aquatic ecosystems to climate change.

Ecological Connectivity

Alternative C would provide for ecological connectivity among habitats for aquatic or riparian 

associates similar to alternative A, but with more emphasis on restoring connectivity associated 

with critical aquatic refuges. There would be less potential for short-term impacts to connectivity 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

310

from restoration compared to alternatives B and D, but there would also be less potential to 

restore aquatic connectivity related to existing roads compared to those alternatives and as 

compared to alternative B-modified. Goals to address aquatic restoration including restoring 

connectivity and increasing the involvement of partners and stakeholders would help improve 

connectivity of habitat similar to alternatives B and D.

Biodiversity

Alternative C identifies additional areas as critical aquatic refuges in watersheds that contain atrisk aquatic species. Aquatic restoration could be focused on habitat to maintain biodiversity or 

at-risk species, especially in conjunction with restoration in priority watersheds. With restoration 

of aquatic habitats, aquatic diversity is expected to be sustained or increase in the short term. 

However, the long-term consequences of this alternative would be an increased risk of large, 

high-intensity fire. Intense wildfire can have a negative effect on aquatic and riparian species. 

Although these effects are generally short lived, landscape changes in forest vegetation from large 

wildfires has longer consequences. Like alternatives B, B-modified, and D, the goal to increase 

restoration of aquatic habitats would address species needs and improve aquatic biodiversity.

Resilience to Climate Change

Adaptively managing aquatic habitats for resilience to future climate change, or improving 

adaptive capacity of aquatic ecosystems through ecological restoration and climate adaptation

actions are addressed in this alternative similar to alternatives B, B-modified, and D.

Adaptively managing aquatic habitats for resilience to future climate change, or improving 

adaptive capacity of aquatic ecosystems through ecological restoration and climate adaptation 

actions would be hampered if sustainability and resilience to climate changes in the rest of the 

watershed and landscape are not restored. 

Riparian Vegetation

Limited restoration using mechanical treatments and an increased emphasis on fire, both 

prescribed and wildfire managed to meet resource objectives, would be the basis for managing 

riparian areas under this alternative. Although there is more managed wildfire proposed for 

alternative C, there is a high uncertainty how much would occur because of low levels of 

mechanical restoration used to create strategic areas to “anchor” large prescribed fires and 

wildfire managed to meet riparian resource objectives. If there is an increase in low- to moderateintensity wildfire, there could be a benefit to riparian species and composition in alternative C 

similar to alternatives B, B-modified, and D. However if the rate of managed wildfire and 

prescribed fire remains low, then riparian vegetation restoration and improvement in ecological 

conditions would not be achieved as well as in alternatives B, B-modified, or D. Overall, there is 

substantially less vegetation restoration in alternative C.

Consequences Specific to Alternative D

Alternative D would treat more area in total than alternatives B, B-modified, and C. The modified 

approach for riparian conservation areas would be the same as alternatives B and B-modified. 

Increased use of mechanical equipment in the riparian conservation areas would be designed to 

improve conditions of riparian areas, especially to restore fire within the landscape and riparian 

areas. Fuel reduction treatments are designed to reduce risks of wildfire more effectively than the 

scattered treatment approach of alternative A and limited treatment approach of alternative C. 

Alternative D plans to improve resilience of terrestrial ecosystems to climate change by 

increasing the rate and extent of the land area where vegetation is being restored, decreasing the 

threat of large, high-intensity wildfires; and increasing the local capacity to restore vegetation and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

311

reduce fuels. As national forest managers increase the pace and scale of restoration, including the 

use of mechanical thinning and increased area where wildfires are managed to meet resource 

objectives, the national forest should become more resilient to the effects of climate change, 

especially increases in wildfire. Alternatives D would provide management direction that would 

likely increase pace and scale of restoration activities on adjacent lands to existing wilderness 

compared to alternative A, which would be beneficial to working in critical aquatic refuges that 

overlap existing wilderness.

Sustainability of Habitat

The large-scale landscape approach under alternative D has the potential to address national forest 

infrastructure such as roads, trails, and dispersed campgrounds within sensitive areas to a greater 

degree than alternative B, and is similar to alternative B-modified. This should improve 

watershed conditions over the long term compared to alternatives A, B, and C. Vegetation 

management activities and maintenance and development of infrastructure, like roads, have the 

potential to cause both short- and long-term adverse impacts to habitat (Frissell et al. 2012). 

Desired conditions, standards, and guidelines would provide for maintenance of aquatic habitat 

and protections of aquatic habitats. The proposed increase in ecosystem restoration, including 

increased allowance for equipment use in riparian conservation areas would not be expected to 

result in substantially increased amounts of sediment and other disturbances to streams. All 

projects would be designed to incorporate best management practices to mitigate soil and 

sediment impacts and projects would be designed to maintain or improve riparian and aquatic 

ecosystem desired conditions. The goal of increasing restoration of aquatic habitats through 

partnerships would help increase the pace and scale of restoration under alternative D, as

compared to A. The potential for short-term effects from the increased pace and scale would be 

balanced against the long-term benefits to aquatic habitats for alternative D.

Alternative D would reduce the risk of uncharacteristically large wildfires, thus reducing the risk 

of undesirable short-term impacts to aquatic ecosystems while still allowing for the historically 

beneficial role of fire to be expressed. The goal of encouraging restoration of habitats using 

partnerships could address many legacy restoration needs in areas prioritized for species and is 

similar to alternatives B, B-modified, and C.

Ecological Connectivity

Desired conditions in alternative D address the maintenance and restoration of ecological 

connectivity among habitats for aquatic or riparian associates, and an increased pace and scale of 

restoration compared to alternatives A, B, B-modified, and C. With an increased use of 

partnerships, this alternative should allow for the greatest increase in the number of projects 

designed to protect aquatic connectivity. The increase in vegetation restoration projects would 

increase the potential to replace and improve road culverts to improve hydrologic and aquatic 

connectivity more than in the other alternatives.

Riparian conservation areas would provide conditions for species to use these areas close to 

streams as corridors for movement and foraging habitat. Plan direction would guide projects that 

occur within riparian conservation areas to consider connectivity of riparian habitats and the 

needs of at-risk species. Connectivity among streams for aquatic species would improve over the 

landscape as undesired barriers are removed to reduce fragmentation and desired barriers are 

maintained to separate invasive species from native species.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

312

Biodiversity

An increase in terrestrial ecosystem restoration could have localized, short-term negative 

consequences to aquatic species, particularly where mechanized treatments are used to restore 

riparian vegetation, and roads are reopened to accomplish restoration actions. This alternative 

may have negative short-term consequences for species concentrated in moist riparian areas, but 

these short-term consequences on riparian biodiversity are balanced favorably against the longterm benefits of creating more sustainable landscapes that have more resilience to changes from 

wildfire, climate change, and other stressors. The goal to support aquatic restoration using 

partnerships would encourage restoration of aquatic habitat to improve persistence of species and 

sustain aquatic diversity.

Resilience to Climate Change

As national forest managers increase the pace and scale of restoration, including mechanical 

thinning and increasing the use of wildfire managed to meet resource objectives, riparian areas 

should become more resilient to climate change. The risk of large intense fire on riparian areas 

would be reduced the most with this alternative because of the increased amount of planned 

restoration in the riparian areas and adjacent upland vegetation and surrounding watersheds. 

Restoration and protection of aquatic habitat would improve resilience as in alternatives B, Bmodified, and C but on an increased number of acres under alternative D. Increased fire resilience 

would confer long-term benefits to watersheds and riparian areas more than all other alternatives.

Riparian Vegetation

With the increased pace and scale of restoration in this alternative, riparian areas should become 

more resilient to fire and the vegetation community would more closely reflect the natural range 

of variation. There would be similar environmental consequences to alternatives B and Bmodified, but with more riparian area restored. The greater amount of area proposed for 

restoration in alternative D would result in a greater amount of riparian area restoration in 

sagebrush and pinyon-juniper, and all montane areas. All of these areas would be the focus of 

both mechanical and prescribed fire restoration treatments in uplands. Both upland and adjacent 

riparian areas would be incorporated in large landscape projects. Upper montane riparian areas 

would have more restoration of wildfire primarily to meet resource objectives. In all of these 

types of restoration, there would be beneficial impacts to composition, structure, and function of 

riparian vegetation. There would be a decrease in conifer or upland shrub density and cover that 

is outside the natural range of variation and an increase in heterogeneity. There would be 

increased light for hardwood shrubs, trees and understory plants. The likelihood of large, highintensity fires would decrease under this alternative in many areas of the landscape compared to 

all other alternatives (see “Fire Trends” section).

Cumulative Effects

The geographic area included in this section is the southern Sierra Nevada, and the White and 

Inyo Mountains. For aquatic ecosystems, the long-term cumulative effects of future management 

actions across the landscape would continue to emphasize protection of water quality and riparian 

ecosystem function while increasing resilience to disturbance. At lower elevations, user-created 

motorized trails, motorized trails in riparian areas and adjacent to meadows, and dispersed 

recreations sites on streams and adjacent to meadows can influence aquatic habitat and ecological 

integrity and would be a focus for restoration when opportunities exist. Dams on major rivers and 

Los Angeles Department of Water and Power water use and management practices from the 

eastern slope of the Sierra Nevada would continue to have effects on connectivity of habitat and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

313

biodiversity within aquatic ecosystems. Commercial livestock grazing opportunities on the Inyo 

National Forest will continue to be constrained at or near current levels.

Recreational fishing is a valued pastime in the Sierra Nevada and is expected to continue, 

although some changes would occur as State wildlife agencies adjust their policies and practices. 

Introductions of nonnative rainbow, brown, and brook trout for sport fishing will continue to be a 

management challenge for native trout. Native fish will continue to decline if conditions begin to 

dry and get too warm and dams prevent species from seeking refuge at higher elevation. Another 

management challenge that relies greatly on continued research and adaptive management 

principles while our knowledge increases are the effects to aquatic and riparian ecosystems 

caused by disease, pathogens and aquatic invasive species. 

Analytical Conclusions

Sustainability of Habitat

The Inyo reconsidered the utilization of critical aquatic refuges (alternatives A, B, C, and D) 

based on several factors: direction for critical aquatic refuges was too restrictive, prescriptive, and 

there was limited connectivity of habitats. Alternative B-modified contains flexible plan 

components, includes terrestrial upland habitat, and uses a larger-scale landscape approach via 

conservation watersheds to capture greater diversity of habitats that allows for desired conditions 

to be achieved and sustained, over the long term. Conservation watersheds will complement, not 

replace or take away from priority watersheds or riparian conservation areas.

Ecological Connectivity

Unlike critical aquatic refuges (alternatives A, B, C, and D), the conservation watersheds 

(alternative B-modified) include entire hydrologic systems from headwaters to community water 

districts, in management areas beyond wilderness and inventoried roadless area land allocations. 

Inclusion of public lands near or adjacent to wilderness and inventoried roadless areas can 

maximize benefit to conservation watershed; an assumption based on the conservation biology 

literature where scale helps achieve landscape connectivity. The cumulative beneficial effects of 

restoration on ecological connectivity within conservation watersheds (alternative B-modified) 

are expected to be greater than in critical aquatic refuges because of this difference in scale.

Biodiversity

Under alternatives A, B, C, and D, biodiversity was limited within the critical aquatic refuges 

designation, as these only addressed aquatic fish, amphibian, and snail species, some of which are 

now federally listed. Alternative B-modified provides for biodiversity among living organisms

including at-risk plants, pollinators, and terrestrial and aquatic vertebrates and ecosystems.

Resilience to Climate Change

Alternative B-modified differs slightly from all other alternatives if pace and scale of restoration 

in conservation watersheds occurs; cumulative beneficial effects at a large-scale landscape 

broadens the level of resilience to climate change.

Riparian Vegetation

The emphasis on project activities, both restoration and other uses, would be designed to attain 

functional watershed condition indicators; have short-term, site-specific impacts that support the 

long-term functionality of systems; and reduce impacts. Although similar to alternative B, C, and 

D, alternative B-modified plan direction provides latitude and flexibility with the intent to 

increase the pace and scale of restoration in riparian areas, meadows, and streams. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

314

Wildlife, Fish and Plants

Introduction

The diverse landscapes of the Inyo National Forest provide a rich assortment of ecosystems and 

habitat types that supports thousands of wildlife, fish, and plant species. These diverse landscapes 

are primarily indicative of the east side of the Sierra Nevada with portions along the crest and 

with smaller areas that are similar to those found on the west side of the Sierra Nevada. 

Elevations extend from approximately 3,800 feet to 14,494 feet above mean sea level at Mount 

Whitney. The ecological conditions on the Inyo are shaped by a variety of topography, geology 

and soils, influenced by a wide range of precipitation and temperature regimes. As stated 

previously, the Inyo National Forest contains all or part of 125 HUC-12 watersheds that are 

generally between 10,000 to 40,000-acres in size. There is an estimated 1,640 miles of permanent 

streams (USDA Forest Service 2013a). The diversity is also reflected by three major biological 

provinces: Sierra Nevada Mountains, Great Basin Desert, and Mohave Desert. This diversity of 

habitats supports the following species diversity: approximately 300 wildlife species consisting of

160 birds, 100 mammals, 30 reptiles, 10 amphibians, and 4 native fish species; countless 

invertebrates; and more than 1,300 plant species (USDA Forest Service 2013a).

The analysis presented in this section is subdivided into three subsections: at-risk terrestrial 

species, at-risk aquatic species and at-risk plant species.

The Evaluation of At-risk Species

Forest plans are developed to guide the maintenance or restoration of the structure, function, 

composition, and connectivity of ecosystems; to provide ecological conditions that will maintain 

a diversity of plant and animal communities, and support the persistence of most native species in 

the plan area. This analysis focuses on evaluating the consequences of the plan alternatives on atrisk species. Forest Service at-risk species include two categories: (1) federally designated species

listed as threatened or endangered, species that are proposed or candidates for federal listing, and 

species with proposed or designated critical habitat, and (2) Forest Service-designated species of 

conservation concern.

In contrast to categories of federally designated species described and derived under the 

Endangered Species Act, species of conservation concern is a new category developed and used 

by the Forest Service under the 2012 Planning Rule to describe animal and plant species that are 

known to occur in the plan area, and for which the Regional Forester has determined that the best 

available scientific information indicates substantial concern about the species' capability to 

persist over the long-term in the plan area.

27 In coordination with the Inyo National Forest, and 

pursuant to responsibilities and authority under the 2012 Planning Rule (36 CFR 219.7(c)(3)), the 

Regional Forester determined the terrestrial wildlife, aquatic wildlife, and plant species of 

conservation concern for the Inyo National Forest. Designation of these species is not a forest 

plan decision. The Regional Forester has authority to change species of conservation concern lists 

to reflect new information.28 The Forest Service “sensitive species” concept is not carried 

forward as part of the 2012 Planning Rule and species of conservation concern replaces that 

concept in land management plans going forward. The land management plan includes plan 

 27 36 CFR 219.9

28 See Forest Service Handbook 1909.12 chapter 20, section 21.22b
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

315

components that help provide ecological conditions for these species and the Final Environment 

Impact Statement evaluates the effects of management on these species.

The primary context for the evaluation of at-risk species, including species of conservation 

concern, is that forest plan components for ecological conditions provide for ecosystem integrity 

and ecosystem diversity. The 2012 Planning Rule requires that forest plan direction be integrated 

across resources and that the plans need to provide for the ecological conditions that will provide 

for the persistence of at-risk species within the inherent capabilities of the national forest plan 

area (36 CFR 219.5 and 219.8-219.9). This evaluation of plan direction that provides for species 

persistence is done first by examining the ecosystem level plan direction and then individual 

species-specific plan direction is added if needed. For the purpose of this analysis, a viable 

population is defined as a population of a species that continues to persist over the long term with 

sufficient distribution to be resilient and adaptable to stressors and likely future environments (36 

CFR 219.19). However, for many species of conservation concern on the Inyo National Forest

there is uncertainty as to whether a viable population truly exists, in those cases we assess 

implementation of plan components on individuals and how well the alternatives address known 

threats to persistence. Several at-risk species have only a few known occurrences on the Inyo 

National Forest and have limited potential habitat. In some cases, little is known about the 

distribution of species that are not well surveyed.

The basis for the analysis of at-risk species requires a determination of whether plan components 

such as desired conditions, objectives, standards, guidelines, and goals support direction to 

provide the ecological conditions necessary to contribute to the recovery of federally recognized 

species and maintain the persistence of species of conservation concern within the plan area. Plan 

components were developed in an iterative way, including identifying desired conditions and 

potential threats to species, and identifying whether proposed plan components are sufficient to 

address species and their habitat needs (Forest Service Handbook 1909.12 12.52, c-d). It is

recognized that due to circumstances that are either not within the authority of the Forest Service 

or not consistent within the inherent capability of the land, the plan area may be unable to provide 

the ecological conditions necessary to maintain a viable population of a particular species. The 

analysis also discloses the uncertainty of moving towards desired conditions given the wide 

departure of the current condition in some areas and the limited opportunity for restoration 

treatments on the Inyo National Forest. When this occurs, the analysis documents this and where 

possible, focuses on other efforts that are within the capability and authority of the Forest Service.

Revising the forest plan does not have direct effects because the forest plan provides a strategic 

framework for planning but no actions are compelled or authorized by the forest plan decision. 

The analysis of consequences considers indirect and cumulative effects that could reasonably 

result from implementation of the plan overall.

Conservation Planning As It Relates To Forest Plans

Conservation strategies and assessments provide science-based guidance for conserving and 

recovering species and their habitat. Typically, these are developed as decision-support tools to 

implement conservation measures to achieve conservation goals and objectives specific to a 

single or logical grouping of species. Because scientific information is constantly evolving under 

continually changing conditions, an adaptive planning framework is necessary to allow for 

adjustments in conservation strategies over time.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

316

Conservation strategies and assessments, as opposed to conservation agreements, are not 

themselves “decision” documents because they have not undergone environmental analysis and 

public review. In addition, management recommendation in conservation strategies are often 

developed to optimize benefits to the species regardless of the authority and responsibility of the 

Forest Service and other multiple-use considerations. Where appropriate, the forest plan 

alternatives have incorporated some of the science-based management recommendations from 

various strategies and assessments, but the elements incorporated may vary by alternative. These 

documents are referenced because they serve as a tool to guide forest plan development.

The various conservation strategies, assessments, and agreements and approved species recovery 

plans and other related recovery documents are also used by forest managers when analyzing the 

consequences of site-specific project activities. These guiding documents are expected to be 

revised, replaced, or supplemented as new scientific information based on new data and reports 

becomes available over time. Therefore, the list below only includes those documents known to 

be available at this time and is not intended to be a complete or exhaustive list.

• Bi-State Action Plan: Conservation of the Greater Sage-Grouse Bi-State Distinct 

Population Segment29 (Bi-State Technical Advisory Committee Nevada and California 

2013)

• Conservation Agreement for Abronia alpina (Ramshaw Meadows abronia) (USDA Forest 

Service, USDI Fish and Wildlife Service 2015)

• Lahontan cutthroat trout (Oncorhynchus clarki hensawi) Recovery Plan (USDI Fish and 

Wildlife Service 1995a)

• Mountain Yellow-legged Frog Conservation Assessment for the Sierra Nevada Mountains 

of California, USA (Brown et al. 2014)

• Owen Basin Wetland and Aquatic Species Recovery Plan Inyo and Mono Counties, 

California (United States Department of the Interior 1998)

• Revised Recovery Plan for the Paiute Cutthroat Trout (Oncorhynchus clarkia seleniris) 

(United States Department of the Interior 2004)

• Sierra Nevada Bighorn Sheep (Ovis candensis sierrae) Recovery Plan (United States 

Department of the Interior 2007)

• Willow Flycatcher Conservation Assessment (Green, Bombay, and Morrison 2003)

• Yosemite Toad Conservation Assessment (Brown et al. 2015)

Federally Listed and Candidate At-risk Species

For each at-risk species that is federally listed or a candidate for listing, we evaluate whether 

alternatives (1) maintain or restore habitats in the plan area to provide the ecological conditions 

necessary to contribute to recovery of threatened and endangered species, and (2) contribute to 

preventing candidate species from becoming federally listed in the future.30

 29 The term Bi-State distinct population segment was used when the greater sage-grouse was proposed for federal 

listing under the Endangered Species Act. Since listing was not warranted, the term distinct population segment is 

not relevant and the population is now referred as the Bi-State population of greater sage-grouse.

30 Forest Service Handbook 1909.12
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

317

When developing ecosystem and species-specific plan components to conserve federally listed 

species, we:

• Considered recovery actions and recovery tasks in approved recovery plans for listed 

species.

• Considered limiting factors and key threats to species identified in published rules from the 

U.S. Fish and Wildlife Service for species listing and designation of critical habitat 

• Considered limiting factors and key threats to whitebark pine identified in candidate 

species assessments from the U.S. Fish and Wildlife Service.

• Solicited and considered comments and feedback from the U.S. Fish and Wildlife Service 

in the evaluation of plan components designed to conserve federally listed species.

• Considered collaboration and cooperation beyond the plan area boundary with the U.S. 

Fish and Wildlife Service, States, Tribes, other partners, landowners, and land managers to 

support an all-lands approach to conserve proposed and candidate species.

• Considered conservation measures identified in existing conservation strategies relevant to 

federally listed species in the plan area.

Some existing forest plan directions has been retained because it supports existing conservation 

measures or conservation recommendations from past biological opinions. For example, the 2014 

Programmatic Biological Opinion for the Sierra Nevada Yellow-legged Frog, northern distinct 

population segment of the mountain yellow-legged frog and Yosemite toad applies to ongoing 

project activities under the current forest plan direction. Some, but not all, of this direction was 

applied as ecosystem or species-specific plan components, primarily because of clarifications in 

the definition of plan components in the 2012 Planning Rule. In some cases, existing forest plan 

direction was rewritten to provide flexibility to adapt to site conditions that can vary widely when 

direction is applied at the project level.

A biological assessment for the preferred alternative has been prepared and submitted to the U.S. 

Fish and Wildlife Service for formal consultation in compliance with section 7 of the Endangered 

Species Act and in accordance with agency policy and practices (USDA Forest Service 2017a).

Table 53 summarizes the number of federally listed, proposed or candidate species by taxonomic 

grouping.

Table 53. Number of federally threatened, endangered, proposed or candidate species by listing 

status and taxa for the Inyo National Forest

Listing 

Status Mammals Birds Reptiles Amphibians Fish Invertebrates Plants

Total 

by 

Status

Endangered 1 0 0 2 1 0 0 4

Threatened 0 0 0 1 2 0 0 3

Candidate 0 0 0 0 0 0 1 1

Proposed 0 0 0 0 0 0 0 0

Total by 

Taxa 1 0 0 3 3 0 1 8
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

318

Relationship between Forest Plans

and the Endangered Species Act Consultation Process

Information and science based recommendations for federally listed species is included in species 

recovery plans, species reviews and assessments, conservation assessments, and critical habitat 

designations. This information was considered in developing plan components that are designed 

to provide, as appropriate, ecological conditions in the plan area necessary to meet the 

requirements for each federally designated species.

The Forest Service has initiated formal consultation with the U.S. Fish and Wildlife Service under 

the provisions of section 7 of the Endangered Species Act. A biological opinion was requested 

regarding the selected alternative and revised forest plan. Following resolution of any objections, 

if any substantive changes are made to the forest plan that affect the species addressed in the 

biological assessment, consultation will be reinitiated to determine if an amendment to the 

biological opinion is needed. The Forest Service will receive and consider the final biological 

opinion from the U.S. Fish and Wildlife Service prior to signing a record of decision.

Forest plans are intended to be adaptive, and changes can be made for newly listed species, new 

critical habitat designations, or as new information becomes available. Once approved, 

consultation will be reinitiated on the forest plan, as needed. Consultation obligations will still 

apply to site-specific Forest Service actions independent of the forest plan, as required by section 

7 of the Endangered Species Act and agency procedures.

Species of Conservation Concern

Species of conservation concern are defined as “a species, other than federally recognized 

threatened, endangered, proposed, or candidate species that is known to occur in the plan area and 

for which the Regional Forester has determined that the best available scientific information 

indicates substantial concern about the species’ capability to persist over the long-term in the plan 

area” (36 CFR 219.9(c). Table 54 summarizes the total number of species of conservation 

concern for the Inyo National Forest by taxonomic grouping.

Table 54. Number of species of conservation concern by taxa

Mammals Birds Reptiles Amphibians Fish

Terrestrial 

invertebrates

Aquatic

Invertebrates Plants Total

3 6 0 3 1 7 3 105 128

The 2012 Planning Rule requires that plan components provide ecological conditions necessary to 

maintain “a viable population” of each species of conservation concern and defines (Sec. 219.19) 

a viable population as one “that continues to persist over the long term with sufficient distribution 

to be resilient and adaptable to stressors and likely future environments.” The concept of 

ecological conditions as defined in the 2012 Planning Rule includes more than vegetation 

composition and structure: it is designed to encompass those factors as well as others, including 

stressors that are relevant to species and ecological integrity. Examples of ecological conditions 

include the abundance and distribution of aquatic and terrestrial habitats, connectivity, roads and 

other structural developments, human uses, and invasive species. 

As required by section 219.8(a) of the Planning Rule, plan components were developed that 

provide ecological conditions that promote species persistence with “sufficient distribution to be 

resilient and adaptable to stressors and likely future environments’ in the plan area, within the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

319

capability of the area.” The plan area is defined as National Forest System lands covered by a 

plan (36 CFR 219.19). Plan components include broader coarse-filter standards and guidelines 

that maintain or restore the structure, function, composition, and connectivity of ecosystems. In 

some cases, where ecosystem level plan components could not adequately address species 

persistence, species-specific plan components were also developed.

As with federally listed and candidate at-risk species, the extent and condition of habitat are the 

indicators used to determine if such ecological conditions are present to conserve species and to 

contribute to preventing species from becoming listed. The analysis also considers the authority 

of the Forest Service and the inherent capability of the plan area to provide for each species of 

conservation concern. We considered the range of potential plan components (desired conditions, 

objectives, goals, suitability of areas, standards, and guidelines) beginning with approaches that 

emphasize management of ecosystem properties and evaluated the characteristics of the 

alternatives to verify that the necessary ecological conditions were provided for at-risk species 

(Hayward et al. 2016). For each species of conservation concern in the plan area, we assessed 

whether each of the alternatives addressed known threats to the species persistence with one of 

four possible outcomes, or determinations: 

1. The ecosystem plan components should provide the ecological conditions necessary to 

maintain a viable population of the [SPECIES NAME] in the plan area. No additional 

species-specific plan components are warranted.

2. The ecosystem plan components should provide the ecological conditions necessary to 

maintain a viable population of the [SPECIES NAME] in the plan area. Nonetheless, 

additional species-specific plan components have been provided for added clarity and/or 

measures of protection.

3. The ecosystem plan components may not provide the ecological conditions necessary to 

maintain a viable population of the [SPECIES NAME] in the plan area. Therefore, 

additional species-specific plan components have been provided. The combination of 

ecosystem and species-specific plan components should provide the ecological conditions 

necessary to maintain a viable population of the [SPECIES NAME] in the plan area.

4. It is beyond the authority of the Forest Service or not within the inherent capability of the 

plan area to maintain or restore the ecological conditions to maintain a viable population 

of the [SPECIES NAME] in the plan area. Nonetheless, the plan components should 

maintain or restore ecological conditions within the plan area to contribute to maintaining 

a viable population of the species within its range.

In the case of outcomes 3 and 4 where species viability is currently uncertain, proposed plan 

components are designed to maintain or restore habitat toward a condition that will contribute to 

maintaining a viable population of the species within its range.

Relationship between

Regional Forester Sensitive Species and Species of Conservation Concern

Under the current forest plan, rare wildlife and plant species are managed according to the agency 

direction for sensitive species. Sensitive species are identified by the Regional Forester as plant 

and animal species for which population viability is a concern, where there is a significant current 

or predicted downward trends in population numbers or density or in habitat capability that would 

reduce a species' existing distribution. Sensitive species identified for the Inyo National Forest 

were designated by the Regional Forester following direction in the Forest Service Handbook 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

320

(FSH 2609.26, chapter 30): “the Regional Forester...must consider those species that are known, 

reported, or suspected to occur on, or in the immediate vicinity of National Forest System lands in 

the Region” (USDA Forest Service 2013i). In contrast, the 2012 Planning Rule directs that the 

species of conservation concern lists are specific to each national forest, and species must be 

known to occur in the plan area. “A species is known to occur in a plan area if, at the time of plan 

development, the best available scientific information indicates that a species is established or is 

becoming established in the plan area.”31

During the evaluation of species of conservation concern, over 115 terrestrial and aquatic wildlife 

species and over 215 plant species were considered32, including consideration of all species on 

the Pacific Southwest Region’s Regional Forester’s sensitive species list for the Inyo National 

Forest. The Regional Forester’s sensitive species list of wildlife, fish, and invertebrate and the list 

of plant sensitive species on the Inyo National Forest are based on the September 9, 2013 

versions of the USDA Forest Service Pacific Southwest Region Sensitive Animal and Plant 

Species by Forest (USDA Forest Service 2013i). Of the 27 wildlife sensitive species on the Inyo 

National Forest, 15 are carried forward as species of conservation concern. Of the 67 sensitive 

plant species on the Inyo National Forest, 46 are carried forward as species of conservation 

concern. In general, sensitive species were determined not to meet the established criteria as a

species of conservation concern for one or more of the following reasons:

• It is a federally recognized threatened, endangered, proposed, or candidate species under 

the Endangered Species Act and would be considered under the other category of at-risk 

species.

• The species does not occur on the national forest.

• Previous occurrence records were determined to be incorrect identifications of the species 

and/or could not be re-located.

• Recent surveys indicated the species is more common than originally thought.

• Natureserve, California Natural Diversity Database, California Native Plant Society Rare 

plant inventory, or other best available scientific information or data sources indicate 

threats to the species were not substantial.

• There was no information about threats to the species. This was a relatively uncommon 

circumstance, because information about threats could be inferred from threats to the 

ecosystems upon which the species depend. Lack of information generally only limited 

species inclusion on the list if the species had not been observed for decades or more, 

leading to uncertainty about the condition of its specific habitat.

The specific reasons a sensitive species was determined to meet or not meet the established 

criteria as a species of conservation concern are provided in the species rationales found in the

animal or plant rationale documents (USDA Forest Service 2018b, a) in the project record, or the 

biological evaluations for animals and plants (USDA Forest Service 2017b, 2017c), or the 

biological assessment (USDA Forest Service 2017a). For the species that did not meet the 

established criteria, we also provide a brief summary of our findings in table 55 and table 56.

 31 Forest Service Handbook 1909.12 § 12.52.c-d

32 Forest Service Handbook 1909.12 § 12.52 c-d
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

321

Table 55. Summary of the rationale that a Regional Forester’s animal sensitive species did not meet 

the established criteria as a species of conservation concern

Common Name and

Scientific Name Rationale For Not Meeting Criteria

Northern goshawk

(Accipiter gentilis)

There are 38 known northern goshawk nest sites distributed across the 

forest. Territories remain well-distributed in the plan area despite the past

widespread changes in the amount and distribution of mature forest habitat.

Goshawks use multiple vegetation types. The increase in drought and bark

beetle related tree mortality is much less than west-side forests, however

impacts to goshawk are unknown at this time. Climate change and potential

drought related effects will likely exert pressure on the key ecological

conditions for this species, but the long-term effects are unknown. At this

time, the best available scientific information does not indicate substantial

concern about the species’ capability to persist over the long-term in the 

plan area.

Western yellow-billed

cuckoo

(Coccyzus americanus

occidentalis)

Federally listed as a threatened species. No known occurrence in the plan 

area.

Pallid bat

(Antrozous pallidus)

There are few studies on bat detections on the Inyo National Forest but the 

species has been documented in the Inyo Mountains and the White

Mountains and was detected in the McNally fire area post-fire. Many

records occur in the Owens Valley, including museum records, but mostly

outside of the plan area. The greatest threats to the persistence of pallid

bats are those most closely associated with the Central Valley and urban 

areas, not National Forest System lands. Since they use a wide diversity of

roosting structures, threats to tree roosting sites are not considered a 

limiting factor within the plan area. At this time, the best available scientific

information does not indicate substantial concern about the species’

capability to persist over the long-term in the plan area.

Townsend's big-eared bat

(Corynorhinus townsendii

townsendii)

The primary roosting habitat is in caves and mines. There is one known 

maternity colony on the forest and habitat for maternal roosts may be 

naturally limited and suboptimal due to the high elevations on the forest. 

There have been no documented disruptions or reductions to maternity

colonies. Roosting in conifer snags is less likely as the majority of the mixed 

conifer and Jeffrey pine types have minimal overlap with known 

Townsend’s bat detection sites. Bat usage at monitored roosting sites

appears to at least be stable across the forest and adjacent BLM lands. At

this time, the best available scientific information does not indicate 

substantial concern about the species’ capability to persist over the longterm in the plan area.

Fringed myotis

(Myotis thysanodes)

The Inyo is within the species’ range and potential habitat exists, however,

no contemporary occurrences were detected during comprehensive bat

surveys in the White-Inyo Mountain Range and there are no known 

documented maternity colonies on the forest. It is unknown how

widespread this species is within suitable habitat, if at all, on the Inyo 

National Forest. The biggest threat on the planning unit appears to be loss

of habitat through fire and climate related disturbance events, though it is

difficult to predict what effect this would have on potential habitat in the long 

term. Based on the consideration of factors evaluated, there is currently

insufficient information to demonstrate substantial concern for long-term 

persistence in the plan area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

322

Common Name and 

Scientific Name Rationale For Not Meeting Criteria

Pygmy rabbit

(Brachylagus idahoensis)

The pygmy rabbit’s range on the forest is primarily in Nevada but does 

include a slight portion of California at the northeast corner of the Mono 

Lake Ranger District border with Nevada. There is no available scientific 

information that indicates populations are in decline on the forest. There is 

a potential loss of habitat by wildfire but the sagebrush habitat occurs on 

sandy soils which, based on knowledge of local fire behavior, does not tend 

to result in high intensity burns or loss of large sections of intact sagebrush. 

At this time, the best available scientific information does not indicate 

substantial concern about the species’ capability to persist over the longterm in the plan area.

Wolverine

(Gulo gulo)

Federally listed as a proposed threatened species. No contemporary 

verified or documented occurrences in the plan area.

Sierra Nevada Red Fox

(Vulpes vulpes necátor)

Federally identified as a candidate species. No known occurrence in the 

plan area.

Yosemite toad

(Anaxyrus canorus)

Federally listed as Threatened. Analyzed as at-risk species

Mountain yellow-legged 

frog

(Rana muscosa)

Federally listed as Endangered. Analyzed as at-risk species

Sierra Nevada yellowlegged frog

(Rana sierrae)

Federally listed as Endangered. Analyzed as at-risk species

Panamint alligator lizard

(Elgaria panamintina)

The best available scientific information suggests that the number of 

populations is stable and likely greater than what is currently known, but 

specific trends are unknown. Change in water surface flow and riparian 

integrity are potential threats to persistence, but these threats are minimal

where the species exists. Habitat within the plan area is at low risk of loss 

or degradation due to anthropogenic activities; however, climate change 

could influence daily temperatures, precipitation amounts and timing and 

type of precipitation. At this time, the best available scientific information 

does not indicate substantial concern about the species’ capability to 

persist over the long-term in the plan area.

Table 56. Summary of the rationale that a Regional Forester’s plant sensitive species did not meet 

the established criteria as a species of conservation concern

Species Rationale For Not Meeting Criteria

Abronia nana ssp. 

covillei

There are many populations and individuals known from a relatively large area on 

the Inyo National Forest, and though they are constrained to limestone 

substrates, they are not highly specific to elevation, and thus occupy major 

vegetation zones from sagebrush to pinyon-juniper, mountain mahogany, and 

bristlecone pine-limber pine. The threats of mining and grazing do not appear to 

be substantial because the plant is so widely distributed that impacts are unlikely 

to affect more than a small proportion of individuals on the Forest. Finally, 

monitoring and surveys have not indicated a downward trend for this species. The 

best available scientific information does not indicate substantial concern about 

the species’ capability to persist over the long term in the plan area.

Boechera evadens Boechera evadens grows on rock outcrops around 2600 m elevation in the 

southern High Sierra Nevada. None of the four CNDDB records is on the forest. 

There is also evidence that the species hybridizes with B. lemmonii and possibly 

other Boechera species, making identity of populations uncertain. The occurrence 

of this species in the plan area is not documented in the best available scientific 

information
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

323

Species Rationale For Not Meeting Criteria

Botrychium lunaria There is insufficient information about its status on the Inyo National Forest. A 

single available record is based on a 35-year old collection that appears to be 

from a private parcel where no follow-up surveys have been conducted. In 

addition, taxonomic research for this species is strongly needed.

Botrychium 

paradoxum

No known occurrence in the plan area. 

Botrychium tunux No known occurrence in the plan area. 

Botrychium 

yaaxudakeit

No known occurrence in the plan area. 

Cladium 

californicum

No known occurrence in the plan area. 

Cryptantha incana This species occurs on both the Inyo and Sequoia National Forests. Numerous 

collections from the plan area indicate this species is much more common than 

previously thought, and that several occurrences could be added to CNDDB. In 

addition, no threats have been documented. Natureserve indicates that ranks 

were assigned based on the very small number of occurrences, and that ranks 

have not been reviewed since 2005, and, thus, may need revision. There is no 

substantial concern about the species’ capability to persist over the long term in 

the plan area.

Draba asterophora

var. asterophora

No known occurrence in the plan area.

Draba cruciata No known occurrence in the plan area.

Draba incrassata There are no verified occurrences of this species in the plan area. A single 

collection was made more than 50 years ago, potentially outside the Forest 

boundary, with no other information available for the species in the plan area.

Erigeron aequifolius There is little occurrence information for this species in the plan area. There is no 

substantial concern about the species’ capability to persist over the long term in 

the plan area because no threats are known. 

Erigeron multiceps There is a single known occurrence in the plan area, occurring on a steep, rugged 

slope with difficult access. There are no known threats. There is no substantial 

concern about the species’ capability to persist over the long term in the plan 

area.

Hulsea vestita spp. 

inyoensis

Reported occurrences have not been relocated in 40+ years; there is insufficient 

information positively documenting its current occurrence in the plan area

Lupinus lepidus var. 

culbertsonii

No collections from the plan area could be verified to be this variety of L. lepidus, 

and no occurrences have been relocated in over 30 years. There is insufficient 

information about the species, best available science does not support the 

occurrence of the species in the plan area.

Meesia uliginosa No known occurrence in the plan area.

Peltigera gowardii There is no substantial concern about the capability of Peltigera gowardii to 

persist over the long term in the plan area because no threats were identified for 

this species in the plan area. In addition, it is likely that additional field surveys by 

qualified personnel would identify additional occurrences in the plan area

Phacelia 

novenmillensis

No known occurrence in the plan area.

Pinus albicaulis Federally identified as Candidate species; analyzed as at-risk species

Senecio 

pattersonensis

There is a single known occurrence in the plan area, occurring on a steep, rugged 

slope with difficult access. There are no known threats. There is no substantial 

concern about the species’ capability to persist over the long term in the plan 

area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

324

For each sensitive species that is not species of conservation concern, the biological evaluations 

for wildlife (USDA Forest Service 2017b) and for plants (USDA Forest Service 2017c) provide 

an analysis of the consequences for alternative B-modified. The effects analyses in the biological 

evaluations are completed by examining occurrence and habitat information for each sensitive 

species, and identifying the potential effects of the revised forest plan and plan components to 

ecosystem types (habitat) in which species occur and on the species or groups of species. Threats 

to species or groups of species or to habitats and habitat conditions were identified as indicators 

because they are measures to maintain viable populations.

While some sensitive species are not carried forward as species of conservation concern, forest 

plan direction is written broadly enough to provide ecological conditions that support ecosystem 

integrity and ecosystem diversity that should support their persistence in the plan area. For some 

species of conservation concern, the plan revision alternatives provide direction to manage for 

“special habitats” that surround the individual species occurrence locations in order to provide the 

necessary ecological conditions that allow for their persistence. This might benefit some sensitive 

species that occur in association with other species of conservation concern. For the northern 

goshawk, although not a species of conservation concern, a forestwide guideline for Animal and 

Plant Species provides that known nest, roost, or den trees used by raptors should not be 

purposefully removed except for hazard tress or unless otherwise required by state or federal 

regulations. This was expanded from applying only to species of conservation concern to also 

apply to raptors and it was expanded to also protect surrounding trees that provide beneficial 

thermal or predatory protection. For the bat species that are not species of conservation concern, 

plan guidance provides protection for bat hibernacula or maternity colonies that may be adversely 

affected by recreational, management, or other activities by considering either installing bat gates 

at the entrances of caves and mines or restricting access by other means. In addition, a forestwide 

desired condition applies to habitats and the ecological conditions and processes that would guide 

all projects to provide for sustainable populations of native species.

Adaptive procedures under the 2012 Planning Rule provide for continued consideration of species 

included on the species of conservation concern list, including revisions of the list to add or 

remove species if necessary. Under the plan revision alternatives, if new information indicates 

that an additional species meets the criteria for being added as a species of conservation concern, 

the responsible official for the national forest where the species occurs may recommend the 

addition to the Regional Forester for the Pacific Southwest Region of the Forest Service. If the 

Regional Forester approves the change, the responsible official then determines if a change in 

forest plan direction is needed. Likewise, new scientific information regarding an existing species 

of conservation concern may lead to their removal from the list if there is no longer a substantial 

concern for its persistence in the plan area; or new information may lead to a need to change the 

forest plan to add, remove, or change plan components. Since the process of identifying and 

managing species of conservation concern is adaptive and can be changed, longer term 

environmental consequences to former sensitive species is not expected. If ecological conditions 

change, new scientific information about species becomes available, or new or emerging threats 

are recognized, former sensitive species can be re-evaluated to determine if they should become 

species of conservation concern.

Migratory Birds

Migratory birds are birds that have a seasonal and somewhat predictable pattern of movement. 

For the sake of forest planning, migratory birds are defined as all species covered by the 

Migratory Bird Treaty Act. Generally, this includes all native birds in the United States, except 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

325

those non-migratory species such as quail and turkey that are managed by the States. The Forest 

Service implements its migratory bird conservation responsibilities under the Act as described in 

its respective memorandum of understanding developed with the U.S. Fish and Wildlife Service 

in accordance with Executive Order 13186. The current memorandum of understanding between 

the Forest Service and the U.S. Fish and Wildlife Service to promote the conservation of 

migratory birds was signed in 2008 and extends to December 31, 2017. In 2016, the Forest 

Service and U.S. Fish and Wildlife Service agreed to an extension of the memorandum of 

understanding and currently work is underway on an additional extension. The intent of the 

memorandum of understanding is to strengthen migratory bird conservation through enhanced 

collaboration and cooperation between the Forest Service and the U.S. Fish and Wildlife Service 

as well as other Federal, State, tribal and local governments. Within the National Forests, 

conservation of migratory birds focuses on providing a diversity of habitat conditions at multiple 

spatial scales and ensuring that bird conservation is addressed when planning for land 

management activities. The Forest Service agreed to address the conservation of migratory bird 

habitat and populations when revising forest plans by considering the list of Birds of 

Conservation Concern published by the U.S. Fish and Wildlife Service (United States Department 

of Interior 2008). This list was considered when determining the species of conservation concern 

for the Inyo National Forest. Migratory birds that met the criteria of species of conservation 

concern for the Inyo National Forest include bald eagle, California spotted owl, bi-state greater 

sage-grouse, and willow flycatcher. These species are evaluated in this document and in the 

document “Rationales for Animal Species Considered for Species of Conservation Concern, Inyo 

National Forest” (USDA Forest Service 2018a).

In January of 2000, the Forest Service released a Landbird Strategic Plan (USDA Forest Service

2000). The primary purpose of the strategic plan was to provide very general guidance for the 

agency’s landbird conservation program. Among the suggested actions was the incorporation of 

landbird management into forest plans. Recent reports produced by the North American Bird 

Conservation Initiative and known as “State of the Birds” reports have been issued by several 

organizations and Federal agencies to summarize the general condition of birds across the United 

States. These “State of the Birds” reports use the latest bird monitoring and scientific data to 

assess the status and health of all U.S. bird species and promote birds as indicators of overall 

environmental health and human well-being. These reports paint a picture of declines in multiple 

species across a variety of habitats. Climate change was one of the contributing factors to these 

declines, and is likely to continue impacting birds into the future. As the climate warms, breeding 

seasons and migrations are being altered and may become out of sync with prey abundance and 

availability. This reinforces the need to have resilient and diverse habitat that can help species 

adapt to climate change. The 2011 report focused on public lands and waters and stated that 

“[n]atural processes must be restored to ensure functional and resilient ecosystems through 

management actions such as control of nonnative species and diseases, prescribed cuts and burns 

to reinvigorate forests and grasslands, and water delivery and management to sustain wetlands”

(North American Bird Conservation Initiative 2011). For arid lands, the report identified the need 

to focus on “control of invasive plant species; keeping fire and other forms of disturbance within 

normal limits; promoting natural patterns of plant succession; and helping birds and other 

biodiversity adapt in the face of climate and land-use change” (Ibid.). For western forests, the 

report identified the need to focus on the “loss of pines, especially pinyon and whitebark pine, 

due to spread of white pine blister rust, mountain pine bark beetle, and other invasive pests” and 

“restoration of natural fire regimes” (Ibid.). The coordinating group, Partners in Flight, also 

produced a North American Landbird Conservation Plan in 2004 (Rich et al. 2004) and a revision 

of the plan in 2016 (Rosenberg et al. 2016), and keeps a Strategic Action Plan updated (current 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

326

version 1.2). These plans promote the conservation of migratory and other birds and have two 

main components: (1) helping bird species at risk, and (2) keeping common birds common.

The Inyo forest plan revision addressed this by considering the habitat upon which migratory 

birds depend during the development of plan components for the plan revision alternatives. Such 

considerations are already in place under alternative A. Migratory birds are ubiquitous and use 

virtually all habitat types across a range of elevations. Therefore, restoration of many vegetation 

types at various elevations would benefit habitat for migratory bird species, especially in cases 

where restoration focuses on moving the vegetation toward the natural range of variation, 

improving resilience to wildfire and changing climate conditions, protecting and restoring 

riparian and watershed conditions, and controlling or eradicating invasive species (see discussion 

in the “Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” sections).

In the plan revision alternatives, plan components help identify and guide projects to address

threats and other risks to ecological conditions important for at-risk species, including migratory 

birds that are species of conservation concern. Some plan components are broader and apply to all 

native species that occur within the plan area. In general, forest plan components and plan content 

were designed to meet the needs of migratory birds and other species by addressing high priority 

habitats and their associated vegetation type or aquatic system where they depart from desired 

ecological conditions. These components include guidance on restoration approaches that reduce 

and limit short-term impacts while focusing on improving landscape resilience. Examples of 

emphasis habitats include systems that are highly altered such as some meadows where water 

tables have been lowered or vegetation reduced, altered montane forests and riparian areas that 

lack resiliency to wildfire under changing climatic conditions, and sagebrush ecosystems that 

have been impacted by conifer encroachment and invasive annual grasses.

Common migratory birds, by definition are expected to persist on the landscape because the plans 

strive to retain ecosystem diversity to provide for a range of habitats and provide the ecological 

conditions expected for the plan area to provide for ecological integrity. Since the forest plan is a

programmatic document, although the different alternatives emphasize different approaches to 

moving towards desired conditions and would have different rates of movement over the life of 

the forest plan, they all include plan components to provide for the essential elements of 

migratory bird habitat when later projects are proposed and projects would continue to assess sitespecific effects to migratory birds. Habitat for migratory birds is anticipated to persist under all 

alternatives.

At-risk Terrestrial Species

Background

This section evaluates and discloses the potential environmental consequences of the five forest 

plan alternatives on at-risk terrestrial wildlife species and habitat. This analysis evaluates the 

effectiveness of the alternatives to provide direction to create the ecological conditions to 

contribute to the recovery of federally listed threatened and endangered species, conserve 

proposed and candidate species, and maintain a viable population of species of conservation 

concern within the plan area.

The need for plan revisions is guided by three primary topics, including “Ecological Integrity” 

which addresses the need to restore the resilience of vegetation and aquatic and riparian 

ecosystems to fire, drought, and climate impacts; restore wildlife and plant habitat and diversity; 

and reduce the risk of wildfire impacts to species and wildlife habitat. An issue related to at-risk 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

327

terrestrial species includes the concern that the perceived accelerated pace and scale of potential 

management activities to restore resilience may not provide adequate habitat for wildlife species 

that use forests with large trees and dense canopy cover. Conversely, a second issue is that 

overemphasizing wildlife habitat needs overshadows the resilience and sustainability need of the 

forest itself. There is a concern that wildfires that could be managed to meet resource objectives 

will continue to be suppressed instead. There is also a concern that aquatic and riparian systems 

that provide habitat for many terrestrial wildlife species are under increasing stress and in need of 

restoration in order to increase their resilience to the effects of climate change and drought. The 

five alternatives present a range of approaches that address the revision topics and issues, 

including the issues related to at-risk terrestrial wildlife species and habitat.

Analysis and Methods

This analysis uses a complementary ecosystem and species-specific approach to assess the 

alternatives’ potential for providing the habitat characteristics to support wildlife diversity and the 

persistence of native species in each plan area. This is sometimes referred to as a coarse-filter and 

fine-filter approach, where the coarse-filter assumes that wildlife diversity is broadly dependent 

upon the integrity of the function, composition, and structure of the forest’s terrestrial, riparian, 

and aquatic ecosystems. This analysis compares the current abundance and condition of various 

habitats with ecological reference conditions (natural range of variation) based on the dynamic 

nature of ecosystems, recognizing they are not static (Landres, Morgan, and Swanson 1999a). It 

recognizes that disturbances or processes like fire, flooding, insects, and disease, and responses to 

those disturbances, are part of natural ecosystem processes. However, because integrity of whole 

ecosystems does not necessarily address all species’ needs, additional species-specific or finefilter analyses were conducted to ensure that persistence is provided for at-risk wildlife species.

As described in the “Agents of Change” section, a disruption of natural processes (such as the

legacy of fire suppression) can impact diversity and lead to a departure from the natural range of 

variation. Maintaining or mimicking natural processes and naturally occurring structural 

diversity; promoting natural patterns and connectivity; restoring ecosystems, communities, and 

species; and protecting the ecological characteristics required by at-risk species are all means to 

maintain biodiversity in an ecosystem. The coarse-filter and fine-filter approaches used in this 

analysis help to disclose how well each alternative addresses these needs.

Overall, we used a qualitative approach for this analysis. It is based on scientific literature about 

species, their habitat, and effects of management. The analysis of habitat is based largely on that 

described in the “Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” sections 

(coarse filter components). The evaluation of environmental consequences to habitat that supports 

species persistence is framed as a risk assessment in terms of alternative effectiveness. However, 

there is a level of uncertainty about the possible effects of forest management and activities on 

habitat that supports species persistence because of gaps in knowledge about the complex 

interaction between species and their habitats (Holthausen 2002) and how some species respond 

to varying degrees of habitat alteration.

The analysis area includes all National Forest System lands within the Inyo National Forest. In 

some cases, the best available scientific information for at-risk species’ ecological relationships 

originated outside the analysis area. However, indicator measures and threat information from 

within the analysis area were used in making conclusions. Because there is more detailed and 

site-specific biological and threat information for federally recognized threatened, endangered, 

and candidate species than for species of conservation concern, and because the Forest Service 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

328

Handbook outlines different intents when identifying plan components necessary to provide for 

the two groups of species, the level of analysis is more general for most species of conservation 

concern.

Indicators and Measures

Federally Listed Species

The analysis evaluates two primary aspects for federally listed species. First, the adequacy of plan 

direction in each alternative to protect, maintain, and restore habitat elements identified for 

species and primary constituent elements of designated critical habitat. Second, the adequacy of 

plan direction to avoid, minimize, or mitigate potential adverse effects to federally listed species 

and candidate species focusing on the relevant threats on the Inyo National Forest to individuals 

within occupied and critical habitat. The analysis also considers the authority of the Forest 

Service and the inherent capability of the plan area to provide for federally listed at-risk species.

An analysis for the selected alternative is documented in detail in the biological assessment 

submitted to the U.S. Fish and Wildlife Service and available in the project record.

Species of Conservation Concern

The key indicators for the terrestrial species analysis are trends in habitat quantity and habitat 

condition considering a landscape scale. Primary habitat associations and associated threats are 

described for each at-risk species. Habitat quantity is evaluated by the potential trend in relative 

amount and distribution of habitat types in the plan areas over the next 15 years. Habitat 

condition is evaluated by the potential trend in resiliency and ability of habitats to be adaptable to 

large-scale disturbances (such as wildfire, insect outbreaks, and drought).

When we examined habitat quantity, we determined that there are no expected changes in the 

overall quantity of habitat as a result of the forest plan revision under any alternative during the 

life of the forest plan. In other words, the forest plan alternatives do not envision different 

amounts of a particular habitat as part of the desired condition, but we do recognize that different 

alternatives might achieve desired conditions at different rates. We also recognize that habitat 

conditions might be affected in the short-term by restoration activities when projects are 

developed and implemented that varies by alternative because different methods are preferred or 

slightly different priorities would established.

These indicators were selected because they provide a reasonable assessment of ecological 

conditions needed to support the persistence of species of conservation concern and because 

relative differences among alternatives could be readily compared. We made qualitative, rather 

than quantitative comparisons. The amount of habitat provides a relative measure of habitat 

condition and extent to maintain species persistence and is also an appropriate measure for a 

programmatic-level analysis. The condition of habitat is used as an indicator only when it can be 

estimated adequately at the programmatic-level, such as assessing not only the amount of impact 

from wildfire but also the type of fire and the resulting effects on habitat quality.

Management directions that may alleviate or exacerbate threats to habitat are evaluated at a 

programmatic level. The forest plan does not authorize site-specific projects or activities; 

therefore there are no direct effects from adopting the forest plan. The direct and indirect sitespecific effects will be analyzed when future projects are proposed. Although potential short-term 

consequences may be described where appropriate from implementing the programmatic 

approach, this evaluation focused on longer term indirect and cumulative effects that may occur 

over the 15-year life of the forest plan.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

329

Much of the analysis is based upon the premise that the natural range of variation provides 

important background information for evaluating ecological integrity and sustainability (Wiens et 

al. 2012). The natural range of variation was used in development of plan direction (desired 

conditions) and the selection of indicators and measures for the analysis because the condition 

and quantity of habitat available to a species helps predict the potential for species distribution 

and abundance within that habitat. Also important in the analysis of ecological integrity and 

sustainability of vegetation are consideration of climate and associated fire trends that may be 

creating a combination of conditions that are outside of the natural range of variation (Safford et 

al. 2012, Millar and Stephenson 2015).

Coarse-filter plan components (largely centered on desired conditions within the natural range of 

variation) are expected to provide for ecological conditions necessary to maintain the persistence 

or contribute to the recovery of native species within the plan area including at-risk species.

33 The 

coarse-filter approach is considered the primary context for evaluating at-risk species. Where 

coarse-filter components would not provide sufficient conditions for one or more at-risk species, 

fine-filter (species-specific) plan components, including standards and guidelines, were 

incorporated.

The analysis involves:

• Identifying habitat associations of and threats to at-risk species,

• Reviewing plan components that have potential to influence habitat conditions, thereby 

influencing the ecological conditions that would support species persistence,

• Evaluating the proposed magnitude of change in the management approach by alternative 

and potential consequences from the management approach, and

• Revising plan components (including incorporating fine-filter components where 

necessary) to provide needed ecological conditions

Sources of information include:

• Peer-reviewed published literature, general technical reports and other reports by the Forest 

Service and other agencies;

• Various databases (such as the California Natural Diversity Database, Forest Service 

Natural Resource Information System Wildlife database, and eBird34);

• Personal communications with researchers, species experts, and California Department of 

Fish and Wildlife staff;

• U.S. Fish and Wildlife recovery plans for threatened and endangered species;

• Final Inyo National Forest Assessment (USDA Forest Service 2013a);

• Science Synthesis to Support Sociological Resilience in the Sierra Nevada and Southern 

Cascade Range (Long, Quinn-Davidson, and Skinner 2014c);

• Resource reports for terrestrial ecology, fire ecology, and aquatic ecosystems; and

• Natural Range of Variation Assessment reports for the various habitats in the Sierra Nevada 

as prepared by the Forest Service (Gross and Coppoletta 2013, Estes 2013b, Meyer 2013a, 

b, Safford et al. 2013a, Merriam et al. 2013, Sawyer 2013b, Slaton and Stone 2015a, b).

 33 Forest Service Handbook 1909.12

34 eBird is a citizen science site for reporting bird observations: http://ebird.org/content/ebird/)
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

330

Analysis Area

In general, the analysis area for indirect effects includes all lands managed by the Inyo National 

Forest; however, for the purposes of this document it may include areas outside the national forest 

boundary. In some cases National Forest System lands may provide all or a high percentage of the 

habitat for a given species; however, in most instances, wildlife generally move from area to area 

and habitats on National Forest System lands may be important to the overall persistence of the 

species within its range. Cumulative effects analyses generally include lands within other 

ownerships immediately adjacent to the national forest, including adjacent national parks 

(Sequoia and Kings Canyon and Death Valley), national monuments (Devil’s Postpile), land 

managed by the Bureau of Land Management (particularly along Highway 395), and 

comparatively smaller sections of State, county, and privately owned lands. For some wideranging species, the analysis area was a little larger and included an evaluation of connectivity 

between larger areas of habitat. For species with migratory or travel routes that extend far beyond 

the Sierra Nevada, management direction under alternatives B, B-modified, C, and D would only 

influence habitat persistence (both quantity and condition) within the national forest plan areas, 

but actions that occur outside of National Forest System lands is beyond the authority of the 

Forest Service to influence.

Assumptions

• If a species is associated with a particular habitat, then the condition, amount, and 

distribution of those habitat elements available to the species on the landscape help to 

predict its distribution and abundance within that habitat.

• Habitat abundance and distribution similar to that which supported associated species 

during conditions as a consequence of evolutionary time, will likely contribute to their 

maintenance in the future (Haufler 1999). Therefore, habitat abundance, distribution, and 

condition similar to that within the natural range of variation for the habitats will likely 

contribute to species maintenance in the future. (See also the “Terrestrial Vegetation 

Ecology” section).

• In general, the further a habitat is departed from desired conditions (natural range of 

variation), the greater the risk to persistence of associated species. Conversely, the closer a 

habitat is to desired conditions, the lower the risk to persistence of associated species 

Therefore, comparing the degree to which the alternatives trend conditions toward desired 

conditions provides a comparison of each alternative’s effectiveness at providing habitats 

that contribute to maintaining species persistence.

• For the purposes of analysis, we are assuming the plan alternatives will be implemented as 

described and objectives will be realized over the life of the plan.

Species Evaluated

Federally Listed Terrestrial Species

Table 57 lists the federally listed terrestrial species and status of critical habitat considered in the 

analysis. Table 58 lists species that were identified in initial species lists from the U.S. Fish and 

Wildlife Service but were determined to not occur within the Inyo National Forest and are not 

considered in detail in this analysis. Further information regarding these species can be found in 

the biological assessment in the project record.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

331

Table 57. Federally designated terrestrial threatened, endangered, proposed, and candidate species 

and critical habitat that occur in the Inyo National Forest plan area

Common Name* Scientific Name Status Critical Habitat

Sierra Nevada bighorn sheep Ovis canadensis sierra Endangered Final Designated

* DPS = Distinct Population Segment

Table 58. Federally designated terrestrial threatened, endangered, proposed, and candidate species 

and critical habitat that do not occur in the Inyo National Forest plan area and are not analyzed in 

detail

Common Name Scientific Name Status*

Critical 

Habitat

North American wolverine Gulo gulo luscus Proposed Threatened Not applicable

California condor Gymnogyps californianus Endangered Final 

Designated

Least Bell's vireo Vireo bellii pusillus Endangered Final 

Designated

Yellow-billed cuckoo, 

western U.S. DPS Coccyzus americanus Threatened Final Designated

Western snowy plover, 

Pacific Coast DPS Charadrius alexandrines nivosus Threatened Final Designated

* E = Endangered; T = threatened; PT = Proposed Threatened

Terrestrial Wildlife Species of Conservation Concern

Table 59 lists the terrestrial wildlife species of conservation concern separated by the taxa or type 

of animal, such as mammals, birds, and types of invertebrates.

Table 59. Terrestrial wildlife species of conservation concern for the Inyo National Forest

Taxa (Type) Common Name Scientific Name

Mammal Nelson desert bighorn sheep Ovis canadensis nelsoni 

Mammal Pacific fisher Pekania pennanti

Mammal Sierra marten Martes caurina sierra

Bird Bald eagle Haliaeetus leucocephalus

Bird Bi-state greater sage-grouse Centrocercus urophasianus

Bird California spotted owl Strix occidentalis occidentalis

Bird Great gray owl Strix nebulosa

Bird Mount Pinos sooty grouse Dendragapus fuliginosus howardi

Bird Willow flycatcher Empidonax trailii brewsteri and E.t. adastus

Terrestrial invertebrate Sierra sulphur Colias behrii

Terrestrial invertebrate Square dotted blue Euphilotes battoides mazourka

Terrestrial invertebrate Mono Lake checkerspot Euphydryas editha monoensis

Terrestrial invertebrate Boisduval’s blue Plebejus icarioides inyo

Terrestrial invertebrate San Emigdio blue Plebulina emigdionis

Terrestrial invertebrate Apache fritillary Speyeria nokomis apacheana

Terrestrial invertebrate A cave obligate pseudoscorpian Tuberochernes aalbui
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

332

Affected Environment

The diverse landscape of the Inyo National Forest includes a variety of topographic, geologic, and 

soil conditions, and is influenced by a wide range of precipitation and temperature regimes

shaped by the unique conditions of being on the east side of the Sierra Nevada crest and at the 

edge of the Great Basin. The east side of the Sierra Nevada, Glass Mountains, White Mountains 

and Inyo Mountains are the major mountain ranges and influence the distribution of major 

ecosystems across the forest.

Many of the terrestrial ecosystems that support wildlife species in this portion of the Sierra 

Nevada are outside the range of natural variation due to a variety of past and current land use 

practices and changing climate conditions. Past activities like water diversion, livestock grazing, 

mining, various kinds of timber harvest, and fire suppression have contributed to these vegetation 

types changing away from their natural states. Changing climate conditions like drought and 

warming temperatures are also fostering increasingly stressed vegetation conditions that are 

vulnerable to high-severity effects of large and frequent wildfires, and pest and insect outbreaks, 

among other disturbances.

As described in the “Fire Trends” and “Terrestrial Vegetation Ecology” sections, large fires with 

high-severity effects are occurring more frequently in the Sierra Nevada, particularly in the dense 

forested stands in montane vegetation. While this trend is greatest on the west side of the Sierra 

Nevada, larger and more severe wildfires are also occurring on the Inyo National Forest. 

Although specific effects are generally not known, these fires are having adverse consequences 

on many species associated with forested landscapes. For example, fires with high-severity 

effects can completely remove nesting and denning trees, roost trees, structurally complex 

understories that support prey, and denning and cover structures. In addition to fire, large trees 

and groups of trees are dying from widespread insect outbreaks and the spread of diseases and 

pathogens. Drought stress is not only weakening these trees and making them more vulnerable to 

insects, diseases, and pathogens, but it is also causing many trees to die. Tree densities in the 

forests of the Sierra Nevada and Great Basin ranges, as well as prolonged drought conditions pose 

a significant and growing threat of levels of tree mortality outside of the natural range of variation 

to montane forest habitat and the species associated with them.

Terrestrial ecosystems of the Sierra Nevada are expected to continue to be dramatically 

influenced by changes in climate in the coming decades (Mallek, Safford, and Sawyer 2012, 

Safford et al. 2012). Consequently, the future range of variation in climate exposure for these 

ecosystems will almost certainly exceed the natural range of variation. Changing climate 

conditions have been influencing, and are projected to continue to have effects on terrestrial 

wildlife species. In California, a total of 128 (36 percent) of 358 bird species are considered 

vulnerable to climate change, including at-risk species like greater sage-grouse and great gray owl

(Gardali et al. 2012).

Climate change has also been correlated with latitudinal and altitudinal range boundary shifts in 

some species (Parmesan 2006, Moritz et al. 2008, Crimmins et al. 2011) as well as phenological 

shifts (changes in timing of migration and blooming) for a variety of plants and animals 

(Parmesan and Yohe 2003, Root et al. 2003). Uphill and higher elevation range shifts in response 

to historical warming have been well documented (Lawler, Safford, and Girvetz 2012). For 

example, in Yosemite National Park, one study found four species expanded their upper 

elevational range limit, nine species contracted their lower range limit, and changes occurred in 

community composition at mid- and high-elevations (Moritz et al. 2008). Some of these shifts in 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

333

distribution are associated with changes in precipitation and temperature (Tingley et al. 2009). 

Upward shifts were found in elevation range of some butterfly species in the Sierra Nevada

(Forister et al. 2010).

Despite general trends of upslope or northward movement of a number of plant and animal 

species, many species are idiosyncratic with respect to shifts in geographic distribution with 

climate change. For example, although the regeneration of several tree species appear to be 

shifting towards colder climates, this trend is often masked by other factors such as disturbance 

and land use history, precipitation patterns, biotic interactions, and the presence of local climate 

refugia (Monleon and Lintz 2015). These non-climate factors often result in spatially-variable 

distributions of tree regeneration, including localized hotspots that are more closely linked to 

natural and anthropogenic disturbances than climate (Serra-Diaz et al. 2016). Moreover, most tree 

species in California show little evidence of shifting towards higher latitudes or elevations due to 

the particular responses of individual species to climate and non-climate factors (such as fire 

history). This individualistic pattern to changes in climate is evident in other taxa from the Sierra 

Nevada and California, including small mammals (Moritz et al. 2008), birds (Tingley et al. 2009), 

and plants (Rapacciuolo et al. 2014). The individual nature of species’ responses to climate and 

nonclimate factors makes it difficult to predict future changes in plant and animal distributions 

with climate change. Species distribution models have better accuracy when considering the 

essential features of species’ climate vulnerability, including climate exposure, sensitivity, and 

adaptive capacity (Rapacciuolo et al. 2014).

At the ecosystem level, community composition will change as the ranges of species shift. It 

appears that related species and species in the same ecological community may respond 

differently to changing environmental variables and these disparate responses may result in the 

breaking up of existing ecological communities and formation of novel communities (Root et al. 

2003, Moritz et al. 2008, Stralberg et al. 2009). This reshuffling of species in communities can 

present species with new challenges such as changes in predator and prey relationships, 

parasitism, and competition.

Terrestrial Wildlife Habitat

Subalpine and Alpine Vegetation Zone

(Subalpine Woodlands and Forests, Alpine Vegetation)

Above the upper montane zone are the subalpine and alpine zones. The subalpine landscapes 

consist of a mosaic of subalpine forests and woodlands, extensive rock outcrops, scrub 

vegetation, meadows, and riparian corridors (Fites-Kaufman et al. 2007). Since alpine 

environments are found at the extreme end of the temperature gradient in the Sierra Nevada, the 

life forms that are narrowly adapted to those conditions essentially have nowhere to go as their 

environment changes, making them among the most vulnerable to climate change (Sydoriak et al. 

2013a). These alpine ecosystems are more threatened due to rapid climate change (Loarie et al. 

2008).

Coniferous forests in the subalpine zone in California typically support fewer species of birds and 

mammals than any other major forest type in the state (Verner and Purcell 1988). The reasons, 

though not clearly established, probably involve some combination of climate, short growing 

season, lower primary productivity, moisture stress, and lower production of insects and other 

invertebrates that provide food resources for many vertebrates (Verner and Purcell 1988). 

Additionally, some species of conservation concern butterfly populations have been located in 

high-elevation dry and wet meadows and rocky habitat. This zone also includes the areas of talus 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

334

and rock outcrops that support a variety of at-risk species. For example, Sierra Nevada and 

Nelson desert bighorn sheep use the upper montane, alpine, and subalpine habitats of the plan 

area, particularly rugged, rocky areas. Sierra marten and Mt. Pinos sooty grouse use some 

portions of the subalpine zone where dense patches of forest are interspersed with meadows and 

riparian areas. 

Old forests are located across various elevations and ecosystems. Although old forests tend to 

contain old and usually large trees, tree size varies based on species and site productivity (see 

“Terrestrial Ecosystem Processes and Functions,” “Special Habitats” subsection). The density, 

size and arrangement of individual trees also varies by ecosystem type with higher elevations 

having a more open and scattered arrangement. Old forests at lower elevations tend to contain 

larger trees in a wide variety of densities and canopy covers. Old forests often contain large snags 

and logs in addition to large live trees. The densities of all of these old forest components varied 

widely in the past. Much of the montane mixed conifer and pine forests that contain large, old 

trees are more uniformly dense, with high tree cover, than they were in the past (Safford 2013, 

Stephens et al. 2015, Collins et al. 2015). There are increased rates of old growth trees dying from 

competition with younger trees for water, climate change that influences carbon balances and 

growth reserves, insect-related mortality, and increased high-intensity fire. Pacific fisher and 

Sierra marten are associated with old forests.

For this analysis, complex early seral habitat is defined as the stage of forest development that 

follows a significant mortality event in a mature forest (see “Terrestrial Ecosystems Processes and 

Functions,” “Special Habitats” subsection). Typical major disturbance events in the Sierra Nevada 

currently include large wildfires with high-severity effects and wide-scale insect outbreaks. The 

death of many overstory trees creates openings that allow other plants and tree seedlings to 

reoccupy the site. The complex early seral habitat is often characterized by high densities of 

snags, the development of shrub cover and other native vegetation, downed wood and natural 

conifer regeneration. This transitional seral stage provides important habitat for a variety of birds 

and small mammals. This habitat can also be important for woodpeckers and cavity-nesting birds 

that benefit from the increase in snag habitat and food resources associated with dead and dying 

trees. With the change of vegetation from the natural range of variation, the size and distribution 

of complex early seral habitat in both location and timing has changed with large fires creating 

very large areas of high-severity fire.

Sierra Nevada Montane Zone (Dry Mixed Conifer Forests, Jeffrey Pine Forests, Red Fir 

Forests, and Lodgepole Pine Forests) 

The eastside Jeffrey pine and dry mixed conifer forest-dominated montane zone occurs on the 

Kern Plateau and also on the eastern escarpment. Here, the montane zone contains dry mixedconifer forests with varied mixtures of Jeffrey pine, white fir, and sometimes lodgepole pine and 

at higher elevations some red fir (Safford 2013, Fites-Kaufman et al. 2007, Safford and Stevens 

2017). The mixed conifer forests in this zone support a variety of wildlife species including 

Pacific fisher, Sierra marten, California spotted owl, great gray owl, and Mt. Pinos sooty grouse. 

Overall, vegetation and fire regimes of this zone are outside the natural range of variation. Fire 

exclusion and past timber harvest has resulted in higher forest densities, increased and more 

uniform canopy cover of trees, greater small and medium tree density, and lower large tree 

density than desired (see “Terrestrial Vegetation Ecology” section) (Safford and Stevens 2017). 

Due to these factors, there is less heterogeneity within stands of trees, which reduces habitat 

diversity and habitat quality for species such as California spotted owl (Stephens et al. 2016). In 

addition to trees killed from fires, the amount of large trees dying has doubled in the last two to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

335

three decades across the western U.S. (Van Mantgem et al. 2009). Trees are stressed by a variety 

of factors such as drought, air pollutants, insects, pathogens, competition, and climate change. 

Within most of this zone, wildfires are burning much less frequently than historic conditions 

(Safford and Van de Water 2014), but evidence is strong that wildfires in this zone are on average 

larger and more severe than they were pre-European settlement (Safford 2013, Collins and 

Skinner 2014c). Overall, resilience of these forests to drought, large and severe wildfires, and 

other stressors has decreased considerably under current conditions (Safford and Stevens 2017).

Upper elevation montane zone forests largely consist of conifer forests where snow is the primary 

precipitation (Meyer 2013a). A mosaic of red fir and Jeffrey pine forests dominate, along with 

interspersed meadows, rock outcrops, lodgepole pine and montane chaparral. Red fir and 

lodgepole pine forests vary widely from open to closed-canopied. Red fir forests provide habitat 

for a variety of wildlife including great gray owl and sooty grouse. Red fir and lodgepole pine 

forests are the primary habitat of Sierra marten. These forests are less departed from the natural 

range of variation than the montane forests, with fewer changes in forest density, heterogeneity, 

and resilience (Meyer 2013a).

Eastside Shrublands and Woodlands

(Pinyon-Juniper, Sagebrush, and Mountain Mahogany)

This zone is occupied by xeric shrub-blackbrush communities, mountain mahogany, sagebrush, 

and pinyon-juniper communities. Changes in climate, fire, and grazing regimes in the late 19th 

and 20th centuries have been particularly important factors influencing the structure, function, 

and distribution of arid shrublands and woodlands in this area (Slaton and Stone 2015a). There 

has been an increased expansion of nonnative invasive species, increased density of woody 

shrubs and trees into shrublands, and an overall change in successional pathways, particularly 

related to changing fire regimes. Some pinyon-juniper woodlands have grown into sagebrush 

shrub communities, due to a combination of factors including grazing, fire suppression, and 

climate change. Some terrestrial invertebrate species of conservation concern are supported by 

habitats like desert scrub, pinyon-juniper, chaparral, and sagebrush habitats. Sagebrush is 

important habitat for all life history requirements for the bi-state greater sage-grouse. Various atrisk butterflies that forage in sagebrush habitats are associated with sagebrush.

Caves, Cave-like Habitat, and Cliffs

Large cliffs provide habitat for a variety of raptors. Caves and cave surrogates (such as mines, 

adits, and vacant buildings and structures) can provide habitat for many bat species, as well as a 

cave obligate pseudoscorpion (Tuberochernes aalbui). Natural caverns and large, abandoned mine 

shafts exist in the plan area and many are currently gated or closed to public access to provide for 

public safety or to protect resources.

Aquatic Wildlife Habitat (Relevant to Terrestrial Species)

Meadows

Meadows play an important role in hydrology, water storage, erosion control, nutrient cycling, 

wildlife habitat, and recreation (see “Aquatic and Riparian Ecosystem” section). The condition of 

meadows in the Sierra Nevada bio-region (including the Inyo National Forest) was assessed and 

65 percent of meadow indicators (13 of 20 indicators) were outside the natural range of variation 

for various characteristics related to composition, structure, and process (Gross and Coppoletta 

2013). In addition, the total area of meadows in the Sierra Nevada has decreased due to past and 

current land use practices such as dams, diversions, and recreation; upland vegetation 

encroachment from conifers and sagebrush as a result of fire suppression; or from drying due to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

336

stream channel incision (Gross and Coppoletta 2013). Meadows will continue to be at risk if the 

precipitation pattern in the southern Sierra Nevada shifts to more rain than snow because many 

meadows are dependent on snowpack to sustain the water table throughout the long dry period of 

summer.

Meadows provide nesting, burrowing, cover, and foraging habitat for a variety of terrestrial 

wildlife species including mammals that burrow in the ground (like gophers and voles) and are

prey for a variety of species like great gray owl and other raptors, meadow nesting birds, 

herbivores, insectivorous bats, and carnivores. Meadows support one or more life history 

requirements for several species of conservation concern.

Lakes and Ponds

Many terrestrial wildlife species depend on habitat surrounding lakes, ponds, and associated 

habitats like marshes to support one or more life history requirements, particularly breeding or 

foraging. This is especially true for the Inyo National Forest where water sources can be scarce in 

the arid portions of the national forest. For example, bald eagles forage in lakes and other large 

bodies of water and butterflies often persist adjacent to aquatic habitats.

Riparian Forests and Woodlands

Riparian forests and woodlands occur throughout the Inyo National Forest and have an 

exceptionally high value for many wildlife species, often supporting a higher concentration of 

species diversity than most terrestrial ecosystems. These areas serve as a link between aquatic and 

terrestrial ecosystems. Overall, within the Sierra Nevada and Great Basin bio-regions, riparian 

areas are outside the natural range of variation at low and mid-elevations, where fire suppression, 

land uses, and water development have been concentrated (Sawyer 2013). Many montane riparian 

communities have had an ingrowth of conifers due to the absence of fire. Without fire, this 

ingrowth of riparian forest woodlands will continue. Over the next century, climate change will 

continue to alter hydrologic and precipitation patterns, and the role of fire in riparian areas.

Riparian areas provide water, thermal cover, migration and movement corridors, and diverse 

nesting and feeding opportunities for wildlife (Grenfell 1988). The shape of many riparian zones, 

particularly the linear nature of streams, maximizes the development of a natural edge that is used 

by a variety of mammals, birds, and other taxa as movement corridors. For example, riparian 

habitats are also especially important for a variety of invertebrates that forage and persist near 

aquatic features like streams. Some species of conservation concern such as willow flycatcher are 

dependent on riparian forests and woodlands for requisite life history needs (Green, Bombay, and 

Morrison 2003). Other species of conservation concern such as Sierra marten benefit from the 

increased prey availability, mast availability, or cover and access to free water riparian forests and 

woodlands provide (Spencer, Barrett, and Zieliski 1983).

Status and Threats for At-risk Terrestrial Wildlife Species

This section provides information for the species status, occurrence on the Inyo National Forest, 

and primary stressors or threats for at-risk terrestrial wildlife species. Primary ecological zones or 

ecological types are described above in the “Terrestrial Vegetation Ecology” section.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

337

Federally Listed Terrestrial Wildlife Species

Sierra Nevada Bighorn Sheep

The Sierra Nevada bighorn sheep is the only federally listed wildlife species on the Inyo National 

Forest. Its ecological zones, key conditions, and primary stressors or threats to persistence are as 

follows:

• Primary Ecological Zone(s) or Ecological Type(s): Upper Montane Forest, Alpine and 

Subalpine Zones; Meadows

• Special Habitat Needs/Key Ecological Conditions: Cliffs and rocky features, escape 

terrain

• Primary Stressors under Forest Service Control: Increasing tree and shrub cover

• Primary Stressors not under Forest Service Control: Epizootic pneumonia and contact 

with stray goats and sheep; climate change and loss of snow pack

Table 60. Acres of Sierra Nevada bighorn sheep critical habitat herd units in wilderness and total 

acres on the Inyo National Forest

Herd Unit 

Number

Herd Unit 

Name

Recovery 

Unit

Total Herd 

Unit Acres

Total Herd 

Unit Acres

Total Herd Unit 

Acres Wilderness

1 Mt. Warren Northern 36,005 27,474 23,483

2 Mt. Gibbs Northern 29,698 21,134 20,425

3 Convict Creek Central 36,519 35,042 32,240

4 Wheeler Ridge Central 80,985 55,981 51,449

5 Taboose Creek Southern 28,816 21,644 21,036

6 Sawmill Canyon Southern 30,521 13,470 13,028

7 Mt. Baxter Southern 32,234 18,851 18,621

8 Mt. Williamson Southern 32,576 28,427 27,981

10 Mt. Langley Southern 32,862 26,693 24,982

12 Olancha Peak Southern 30,438 30,089 29,703

Status: The Sierra Nevada distinct population segment of California bighorn sheep was listed as 

an endangered species in 2000, following emergency listing in 1999 (USDI Fish and Wildlife 

Service 1999, 2000). At the time of the emergency listing, the population was thought to total no 

more than 125 animals distributed across five separate areas of the southern and central Sierra 

Nevada (United States Department of the Interior 2000). The Sierra Nevada distinct population 

segment of the California bighorn sheep (Ovis canadensis californiana) was classified as its own 

Sierra Nevada bighorn sheep subspecies (Ovis canadensis sierrae) in 2005 (Wehausen, Bleich, 

and Ramey II 2005). In 2008 the taxonomic name change to the Sierra Nevada bighorn sheep 

(Ovis canadensis sierra) was officially recognized (United States Department of the Interior 

2008a).

In 2008, the U.S. Fish and Wildlife Service designated approximately 417,577 acres of critical 

habitat for this species in Tuolumne, Mono, Fresno, Inyo and Tulare Counties (USDI Fish and 

Wildlife Service 2008a). Critical habitat includes 12 herd units within the recovery area on 

portions of the Humboldt-Toiyabe, Inyo, and Sierra National Forests and in Yosemite, Sequoia, 

and Kings Canyon National Parks. Ten of these herd units occur on the Inyo National Forest as 

listed in table 60. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

338

Of these 10 herd units, 75 percent, approximately 278,805 acres, occur on the Inyo National 

Forest. The majority of the remaining portions of the herd units occur in designated wilderness 

managed by the National Park Service. Ninety-four percent of the herd units on the Inyo National 

Forest, approximately 262,948 acres, occur with designated wilderness and much of the 

remaining acres occur in adjacent inventoried roadless areas.

Within critical habitat, the U.S. Fish and Wildlife Service identified primary constituent elements, 

which are physical or biological features considered essential to the conservation of the species 

and that may require special management considerations or protection (USDI Fish and Wildlife 

Service 2008a). Relevant to management on the Inyo National Forest, these include:

1. Non-forested habitats or forest opening within the Sierra Nevada from 4,000 feet to 

14,500 feet in elevation with steep (greater than or equal to 60 percent slope), rocky 

slopes that provide for foraging, mating, lambing, predator avoidance, and bedding as 

well as seasonal elevation movements between these areas.

2. Presence of a variety of forage plants as indicated by the presence of grasses (e.g., 

Achnanthera spp.; Elymus spp.) and browse (e.g., Purshia spp.) in winter, and grasses, 

browse, sedges (e.g., Carex spp.) and forbs (e.g., Eriogonum spp.) in summer.

3. Presence of granite outcroppings containing minerals such as sodium, calcium, iron, and 

phosphorus that could be used as mineral licks in order to meet nutritional needs.

The Final Recovery Plan for Sierra Nevada Bighorn Sheep was completed in 2007 (USDI Fish 

and Wildlife Service 2007). The recovery area for Sierra bighorn includes four recovery units: 

Northern, Central, Southern, and Kern. Within these recovery units there are 16 herd units, and 

the Inyo National Forest contains portions of the 10 herds as shown in table 60 above.

The total population of bighorn sheep in the Sierra Nevada prior to settlement is unknown, but it 

probably exceeded 1,000 individuals (USDI Fish and Wildlife Service 2007). At the time of 

emergency endangered listing in the spring of 1999, a minimum of 117 sheep could be accounted 

for. Bighorn numbers have increased dramatically in the Sierra Nevada since the time of the 

listing. The “2010-2011 Annual Report of the Sierra Nevada Bighorn Sheep Recovery Program: A 

Decade in Review” reported that the population as of 2012 was above 400 bighorn sheep and had 

expanded into ten of the twelve essential herd units needed for recovery (Stephenson et al. 2012). 

Recent population estimate shows the population climbing over 600 animals and range expansion 

into all twelve essential herd units (Runcie et al. 2015).

Threats: The vast majority of the herd units are comprised of the alpine and subalpine vegetation 

type with smaller amounts of other vegetation types. Due to the rocky and harsh conditions, the 

alpine and subalpine vegetation types are still largely similar to the expected natural range of 

variation with some increases in small tree densities as a result of fire suppression (Meyer 2013b).

The main mortality factors for Sierra bighorn include diseases and parasitism and predation. 

Numerous diseases of bighorn sheep have been documented (Bunch et al. 1999), of which 

pneumonia and psoroptic scabies have had the greatest population-level effects. Bighorn sheep 

show a high susceptibility to pneumonia, usually caused by bacteria Mycoplasma ovipneumoniae. 

Just recently researchers have learned that the bacteria M. ovipneumoniae influences the immune 

system, allowing secondary infections, like Mannheimia haemolytica to destroy lung tissues and 

often, lead to morality (Besser et al. 2008, Besser et al. 2014). The greatest risk of disease 

transmission is between bighorn sheep and domestic sheep and goats, which are carriers of 

Pasteurella-family bacteria. The potential for the transfer of disease from domestic sheep to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

339

bighorn sheep was a key factor in the endangered species listing (USDI Fish and Wildlife Service

2000).

To address the risk of disease spread from domestic livestock grazing, the Inyo National Forest

worked with the U.S. Fish and Wildlife Service and the California Department of Fish and 

Wildlife to evaluate the risk of contact between bighorn sheep and authorized domestic sheep 

grazing using a risk assessment model (Clifford et al. 2009) to identify allotments or portions of 

allotments that posed a high risk of contact (Baumer et al. 2009, Croft et al. 2010) Considering 

the risk assessment for livestock and bighorn sheep contact and disease spread, the Inyo staff

made site-specific decisions to close portions of active livestock grazing allotments west of 

Highway 395 to domestic sheep grazing where there was an identified high risk of contact.

In the Sierra Nevada, mountain lions have been identified as the primary predator of bighorn 

sheep (USDI Fish and Wildlife Service 2007). The amount of predation increased in the 1970s 

possibly contributing to Sierra Nevada bighorn sheep decreasing the use of winter range

(Wehausen 1996). The California Department of Fish and Wildlife has the primary responsibility 

for managing mountain lions and has implemented an adaptive management strategy with regard 

to mountain lion predation. Since listing in 1999, the California Department of Fish and Wildlife, 

working with USDA Wildlife Services, has selectively removed mountain lions that preyed on 

bighorn sheep in the Central and Southern Recovery Units (Stephenson et al. 2012), lessening the 

pressure on bighorn sheep populations.

Species of Conservation Concern

Mammals and Birds: Summary of Key Ecological Conditions and Key Risk Factors

The key ecological conditions for these species and the key risk factors affecting those conditions 

(table 61) can be generally described as: 

• Meadows and riparian habitat (great gray owl, Sierra marten, willow flycatcher, bald eagle).

• Loss of riparian habitat due to changes in water levels or diversion.

• Alpine and subalpine habitats (Nelson desert bighorn sheep, Sierra marten, Mount Pinos 

sooty grouse, Kern Plateau salamander).

• Temperate and habitat change related to climate change. Species dependent on seeps and 

springs in high elevation areas which are susceptible to climate change. 

• Structurally diverse mature forests (Pacific fisher, Sierra marten, great gray owl, Mount Pinos 

sooty grouse, California spotted owl).

• Risk of loss of habitat and habitat fragmentation of conifer forest from wildfire outside the 

natural range of variability. While the current trends do not show a significant increase in the 

extent of forest change from wildfire on the Inyo NF, substantial areas are at a low and very 

low fire resiliency index indicating they are susceptible to higher amounts of crown fire than 

expected.

• Large trees and snags (Pacific fisher, Sierra marten, great gray owl, Mount Pinos sooty 

grouse, and California spotted owl).

• Risk of inadequate number, distribution, and quality of large living trees and dead trees 

(snags) of sufficient density, size, area and age to support key life history needs of species. 

Due to fire suppression, there may be fewer total patches of snags created from fire across the 

landscape. However, some fire-created patches of snags are exceedingly large and are created 

from burning older forests which competes with the habitat need for other at-risk species that 

need large living trees such as the Pacific fisher and Sierra marten.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

340

Table 61. Mammal and bird species of conservation concern, ecological zones or types, key ecological conditions, and primary stressors or threats to 

persistence (primary stressors not under Forest Service are not necessarily discussed further)

Species

Primary Ecological Zone(s)

or Ecosystem Type(s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under 

Forest Service Control

Primary Stressors not under 

Forest Service Control

Nelson desert 

bighorn sheep

Upper Montane Forest, Alpine 

and Subalpine Zones; 

Meadows

Cliffs and rocky features, escape 

terrain

Increasing tree and shrub 

cover

• Epizootic pneumonia and contact 

with stray goats and sheep.

• Climate change and loss of snow 

pack

Pacific fisher Mixed conifer, Upper Montane 

Forests,

Old growth components including 

large diameter trees and snags, 

multi-layered canopies, large down 

wood, moderate to high canopy 

closure, structurally diverse forest

Fuels reduction and 

vegetation management, 

recreation, high severity fire, 

insect outbreaks; loss of 

connectivity/movement 

corridors.

• Insecticide and pesticide use;

illegal marijuana growing.

Sierra marten Mixed conifer, Riparian Areas;

Meadows, Upper Montane 

Forests, Subalpine, and Alpine 

Vegetation

Old growth components including 

large diameter trees and snags 

(e.g. > 20-30 in DBH) multi-layered 

canopies, large down wood, 

moderate to high canopy closure, 

complex early seral habitats; Red 

fir, lodgepole pine

Fuels reduction and 

vegetation management, 

recreation, high severity fire, 

insect outbreaks; loss of 

connectivity/movement 

corridors.

• Insecticide and pesticide use;

illegal marijuana growing.

• Climate change and drought.

• Ski resort development; roads.

Bald eagle Large bodies of water (lakes or 

reservoirs) or free flowing large 

rivers; Montane Forest

Large live trees or snags. Changes in timing and flow 

of water and water 

availability resulting forest 

management activities (fire, 

veg).

• Changes in timing and flow of 

water and water availability 

resulting from climate change 

and/or hydroelectric power.

Willow 

flycatcher

Riparian Meadow and Riparian 

meadow non ecosystem 

assessment types.

Dense willow or other shrub 

thickets within large (> 10 acres) 

wet meadows between 3,900-

7050 feet elevation. Meadows with 

standing or running water needed 

for breeding.

Loss in connectivity between

habitat patches; 

declining/drying meadow 

conditions; forest 

management activities (fire, 

veg); invasive species;

livestock grazing

• Changes in timing and flow of 

water and water availability 

resulting from climate change

(drought) and/or hydroelectric 

power.

• Increasing demands for water by 

humans.

• Nest parasitism from brown 

headed cowbirds/residential bird 

feeders. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

341

Species

Primary Ecological Zone(s)

or Ecosystem Type(s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under 

Forest Service Control

Primary Stressors not under 

Forest Service Control

Bi-State SagegrouseSagebrush, Riparian Meadow,

Pinyon juniper

Large and contiguous sagebrush 

stands mixed with areas of wet 

meadows, riparian, or irrigated 

agriculture fields. 

Pinyon-Juniper expansion 

and conifer encroachment,

Invasive species and noxious 

weeds, Vegetation 

Management, Wildfires, 

Inadequate forage, Livestock 

grazing

• Human development

• Bouldering/recreation on adjacent 

BML lands.

• Nest predation

• Changes in timing and flow of 

water and water availability

Mount Pinos 

sooty grouse

Subalpine Forest, mixed 

conifer

Relatively open coniferous and 

pine habitat with little understory 

cover. Woodlands and subalpine 

forests, large trees

Veg/fuels management,

livestock grazing

• Climate change and loss of snow 

pack; high endemism (relict 

species)

• Hunting

Great gray owl Mixed Conifer and Upper 

Montane Forest (Red fir, 

Jeffrey pine, lodgepole pine); 

Meadows

Meadows greater than 26 acres in 

size, Old growth components 

including large diameter trees and 

snags, multi-layered dense

canopies/forest complexity. 

Livestock grazing, conifer 

encroachment, Veg/fuels 

management, Wildfire,

insect outbreaks, Recreation, 

forest fragmentation/loss of 

connectivity

• Roads, trails, and structures that 

modify hydrologic flows within the 

meadows

• Vehicle collisions

• Predation from great horned owl

• Drought stress 

California

spotted owl

Upper Montane and Mixed 

conifer (red fir, Jeffrey and 

lodgepole pine)

Mature forests with tree canopy 

cover greater than 70 percent, 

multilayered canopies, and an 

abundance of large trees and 

snags; pine-oak

Vegetation/fuels 

management, high severity 

wildfire,

insect outbreaks, noise 

disturbance/recreation

• Genetic introgression from barred 

owls

• Drought stress/climate change
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

342

Additionally some risk factors are not directly associated with a key ecological condition. For 

example, vehicles traveling at high speeds on primary roads can be a source of direct mortality to 

some species such as Sierra marten and great gray owl, while epizootic pneumonia is the primary 

risk factor for Nelson desert bighorn sheep. The increasing use of insecticides and pesticides, 

many banned from use in the United States and used exceeding label requirements, associated 

with illegal marijuana growing is known to directly and indirectly kill Pacific fisher, Sierra 

marten and other species that prey on small animals (Gabriel et al. 2012).

Nelson Desert Bighorn Sheep

Status: There is an isolated population of Nelson desert bighorn sheep within the plan area in the 

White Mountains at elevations ranging from 6,000 to 12,000 feet. This is the northernmost 

population of desert bighorn sheep in California. California Department of Fish and Wildlife has 

estimated this population to be about 300 sheep and the population appears stable. Most of these 

animals occur in the White Mountain Wilderness, with approximately 30 animals (or roughly 10 

percent of the population) occurring outside this area in Silver Canyon.

Threats: Exposure to disease is the most immediate and primary risk to Nelson desert bighorn 

sheep persistence on the Inyo National Forest. Domestic sheep and goats are host animals for a 

lung disease, epizootic pneumonia caused by Mycoplasma ovipneumoniae (M. ovi), that is easily 

spread through direct contact with bighorn sheep. Epizootic pneumonia is widely reported to have 

resulted in die-offs of entire bighorn sheep herds in the western United States, including die-offs 

in the White Mountain herd (Besser et al. 2008). The White Mountain bighorn population has had 

this respiratory disease since 2009 (California Department of Fish and Wildlife 2015b). Concerns 

about potential spread of disease from private livestock were specifically identified in the 

Chalfant and Hammil Valleys west of the White Mountains (California Department of Fish and 

Wildlife 2015b). Some private land parcels are located immediately adjacent to the Inyo National 

Forest, but the majority is buffered by lands managed by the Bureau of Land Management. The 

Lone Pine and Silver Peak areas east of Fish Lake Valley (to the east of the Inyo National Forest

in Nevada) have bighorn sheep located in those areas. These sheep have exhibited disease issues 

and those sheep have been observed crossing Fish Lake Valley and entering the White Mountains 

on the Inyo National Forest (California Department of Fish and Wildlife 2015b). These adjacent 

mountains are managed by the Bureau of Land Management, where the Forest Service has no 

jurisdiction. Occasional stray sheep have been observed in the past to trespass onto the Inyo 

National Forest in areas closed to livestock grazing in the White Mountains. To date, there has 

been one documented case of pneumonia on the Inyo, an 11-year-old male in 2016 (Nelson 

2016).

Future habitat loss due to warming temperatures and climate change is also a threat, as is loss of 

genetic diversity. Almost all (95 percent) of the alpine habitat type is within designated 

wilderness, where human impacts are relatively minor. Larger scale influences such as climate 

and air pollution are exceptions. The relative inaccessibility of alpine habitat puts it at less risk 

from human induced changes. However, continued increases in tree/shrub cover and density 

related to climate change are expected to be significant. Recent climate models forecast a 

complete loss of alpine ecosystems from the White Mountains in the next 50 to 60 years. Lack of 

genetic diversity resulting from habitat loss and limited connectivity is another general concern; 

however, genetic diversity is not known to be a limiting factor at this time for the White 

Mountains herd within the plan area. Maintaining connectivity will be an important focus for 

management, especially with warmer, drier climates. Populations to the south have a high 

probability of extinction over the next 50 years, whereas populations in the Inyo appear to be 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

343

secure (Epps et al. 2004). The populations on the Inyo National Forest may, therefore, become 

more important for ensuring persistence of the subspecies.

Pacific Fisher

Status: The Sierra Nevada bioregional carnivore monitoring program includes 26 sample units on 

the Inyo National Forest. Of these 26 sample units, four have detected fisher using track plates 

and remote cameras at various times over the last fifteen years (Tucker 2018). While reproduction 

has not been confirmed in this area, genetic analysis of hair samples have detected females 

multiple times, and in 2012 surveyors detected multiple individuals with genotypes consistent 

with a mother and 2 offspring (Tucker 2018).

Spencer et al. (2015) and Spencer et al. (2016) describe seven fisher population core areas in the 

southern Sierra Nevada region, five of which are occupied, and two of which are currently 

unoccupied. Fishers on the Inyo National Forest occupy only a small part of the Core 1 

population which occurs on the Kern Plateau. This core is mostly on the Sequoia National Forest

in the southeastern portion of the fisher assessment area and is the only core not on the west slope 

of the Sierra Nevada. Only a small portion occurs on the Inyo National Forest (13,500 acres out 

of 106,000 acres). The Kern Plateau has unique environmental conditions, due to differences in 

climate, geology, and vegetation, compared to the west-slope cores (Miles and Goudey 1998). It 

receives less annual precipitation than other fisher cores, and the vegetation is somewhat more 

open. Pinyon-juniper woodlands, canyon oak woodlands, and birch-leaf mountain mahogany are 

a greater component of the vegetation of the Kern Plateau than other portions of the fisher range, 

and California black oak, an important component of fisher habitat where it occurs, is rare or 

absent. The lesser accumulation of snow in this core may explain why fishers occupy higher 

elevations here than elsewhere in the assessment area and why martens (which are more snowadapted than fishers) are absent (Tucker 2018).

Core 1 is the smallest occupied core area, has the lowest predicted habitat value of any core, and 

appears to lack potential suitable resting and denning habitat (Spencer et al. 2015). Further, 

Spencer et al. (2016) model the core as containing no currently suitable fisher cells. Fisher 

occupancy in Core 1 suggests that the current habitat models are unable to capture both the 

breadth of habitat that fisher will use, as well as the factors determining habitat selection in the 

Kern Plateau area, an area that is ecologically distinct from the rest of the fisher range in the 

Southern Sierra Nevada. Additional research and monitoring are warranted in Core 1 to better 

understand fisher habitat selection and population characteristics. Spencer et al. (2016) note that 

“In the meantime, all [habitat] predictions for Core 1 should be considered unreliable.”

The fisher detected at sample units on the Inyo National Forest are part of the population 

occupying Core 1 on the Sequoia National Forest and it is unlikely that sufficient habitat or 

individuals exist within the Inyo National Forest to sustain a viable population within the plan 

area.

Threats: Key limiting factors affecting Pacific fisher and their habitats are climate change that 

reduces mature forest canopy cover and key structural elements and habitat fragmentation by 

vegetation management, fire, and insect and disease tree mortality. Since the occupied habitat in 

Core 1 is atypical of other cores as described above, it is unknown how vegetation changes 

related to climate change may affect continued fisher use. Maintaining habitat connectivity to the 

west with the Sequoia National Forest is necessary to allow individual animals using the Inyo 

National Forest to interact with the other populations within the species range in the southern 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

344

Sierra Nevada. Anticoagulant rodenticide poisoning is an emerging threat, particularly associated 

with illegal marijuana cultivation on public lands (Gabriel et al. 2012). Large snags and downed 

logs are key structural elements important for resting and predator avoidance, as well as for 

denning and raising young.

A vulnerability assessment for the Sierra Nevada region ranked overall vulnerability of the 

Pacific fisher as moderate, due to its moderate to high sensitivity to climate and non-climate 

stressors, moderate adaptive capacity, and moderate exposure (Kershner 2014).

Sierra Marten

Status: In addition to historic harvest of old forest habitat, marten were trapped for fur in 

California until 1954 and it is thought that these actions contributed to declining numbers of 

Sierra marten across its range (Zielinski 2014). In the southern and central Sierra Nevada, the 

marten is still considered well distributed but not in the northern Sierra Nevada (Kurcera, 

Zielinski, and Barrett 1996, Zielinski et al. 2005). Marten occur in forested areas that receive 

considerable snowfall (Zielinski 2014). The upper montane forests serve as primary habitat for 

this subspecies. Forest structure for upper montane forests in the southern Sierras at both the 

stand and landscape scales is more uniform and less heterogeneous than reference conditions; 

there has been a decrease in the density of large-diameter red fir trees in many areas but overall 

the upper montane forests are considered to be within the range of natural variation (Meyer 

2013a). Marten locations have been observed almost exclusively west of Highway 395, with only 

one occurrence east of the highway in the Jeffery pine forest. Occurrence is predominantly on the 

western side of the national forest near Mammoth Lakes and on the Kern Plateau adjacent to the 

Sierra National Forest.

Threats: Key limiting factors affecting Sierra marten and their habitats are climate change, 

habitat fragmentation by vegetation management, fire, insect and disease tree mortality, and 

recreation. Anticoagulant rodenticide poisoning is an emerging threat, particularly associated with 

illegal marijuana cultivation on public lands (Gabriel et al. 2012) and residential rodenticide use. 

The capacity of the marten to adapt to climate change is limited by its reliance on deep snow for 

access to prey in winter through subnivean (under snow) foraging and caching of food (Hauptfeld 

and Kershner 2014b). The other key risk factor is fragmentation (primarily due to roads) and, at 

lower elevations, past timber harvest. In the future, the forested habitat the marten relies upon 

may be further fragmented by changes in macro and micro forest conditions or reduced by 

increasing wildfires associated with climate warming (Zielinski 2014, Hauptfeld and Kershner 

2014b). A vulnerability assessment (Kershner 2014) ranked overall vulnerability of the marten as 

moderate/high, due to its moderate/high sensitivity to climate and non-climate stressors, moderate 

adaptive capacity, and moderate/high exposure. Sierra martens are also listed as “climate 

vulnerable” in the 2015 California State Wildlife Action Plan (California Department of Fish and 

Wildlife 2015a). 

The southern extreme of the range for marten is within the southern Sierra Nevada and generally 

populations at the edges of their range are more at risk than those in the center. Marten are 

extremely sensitive to the loss and fragmentation of mature forest habitat (Zielinski 2014). It has 

been predicted that the range of marten in California will contract to the north and become less 

common and more fragmented (Lawler, Safford, and Girvetz 2012). High-intensity fires have 

been increasing in upper montane red fir forests and this trend is expected to increase with 

climate change (Schwartz et al. 2015). Changes could include a loss of red fir (Lenihan et al. 

2003) and lodgepole pine habitat (replacement by white fir or loss by high-intensity wildfire) and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

345

increased competition from other carnivores no longer constrained by snow levels. Also, because 

of the marten’s aversion to crossing large openings, large fires may fragment marten habitat and 

isolate populations leading to localized extirpation. The increase in large trees killed by bark 

beetles will create new snags at the expense of living trees used for resting and denning. Finally, 

increased drying conditions would lead to further deterioration of montane meadows. Drier 

meadows would likely reduce the prey populations on which martens depend. Recreational 

activities and roads that fragment contiguous habitat or compact snow may also affect marten. 

Bald Eagle

Status: The bald eagle is currently protected under the Bald and Golden Eagle Protection Act of 

1940, and remains listed as endangered in California by the California Department of Fish and 

Wildlife. Bald eagles have long been known to occur on the Inyo National Forest during winter 

months; with three nests observed on the forest since 2004 in the Upper Owens River and June 

Lake areas. The nest location in the Upper Owens River area may have subsequently been 

abandoned; only one adult bird has been observed in recent times and nesting activity has 

presumably stopped in that area. Another potential nest site may be present in the Hilton Lakes

area where juvenile and adult bald eagles have been observed.

Threats: Threats to habitat include any source of extensive tree mortality within suitable nesting 

and perching habitat adjacent to large lakes and rivers that support bald eagle food supplies. High 

severity fire can eliminate large tree nesting and perching habitat. Extensive tree mortality caused 

by insects and diseases also remove suitable habitat. Additional threats to habitat include 

degradation of aquatic habitats that affect fish populations that serve as the bald eagles’ primary 

food source. Exceptional drought conditions can increase tree mortality as well as reduce 

reservoir levels and prey availability. Climate change could potentially accelerate the rate at 

which habitat is lost (Siegel et al. 2014).

A variety of human activities can potentially interfere with bald eagles, affecting their ability to 

forage, nest, roost, breed, or raise young. Territories have been abandoned after disturbance from 

logging, recreational developments, and other human activities near nests (Zeiner et al. 1990). 

Bald eagles may not begin nesting if human disturbance is present near nests (Zeiner et al. 1990). 

Human recreational activities such as boating, jet skiing, fishing, and low flying aircraft can cause 

disturbances to nesting birds, but some individual eagles show a moderate tolerance to the 

presence of humans (Buehler 2000). The U.S. Fish and Wildlife Service has provided 

recommendations for reducing disturbance to bald eagles, as well as recommendations for habitat 

management. The National Bald Eagle Management Guidelines are used for reducing disturbance 

at nesting, foraging, and communal roosts from a variety of human activities. These guidelines

provide a sound scientific basis for reducing the effects of human disturbance on bald eagles 

(USDI Fish and Wildlife Service 2007).

California Spotted Owl

Status: Forest level surveys have detected California spotted owls on the west side bordering the 

Sequoia National Forest in wilderness, and at the farthest south end of Inyo National Forest. In 

the past, forest management projects on the south end of the Inyo National Forest were proposed 

and implemented by the Sequoia National Forest because of road systems and access, hence there 

was confusion about the status of spotted owls on the Inyo National Forest. According to the 

California Department of Fish and Wildlife spotted owl database, there are 19 data points for 

California spotted owl on the forest with 6 positive detections all occurring in the area just 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

346

northwest of Monache Mountain. At the north end of the forest, there are also two historic 

occurrences in the Boundary Creek and Red Meadows area. Overall, there are only six positive 

detections on the Inyo National Forest with no documented nesting. The detections do not meet 

the criteria to establish a protected activity center or associated home range core area.

Threats: Relevant threats include habitat loss, degradation, or loss of connectivity from highseverity fire and management activities such as vegetation management or fuels management that 

reduces dense canopy cover, removes larger trees, or simplifies forest structure affecting prey 

species. Across the range of the species and relevant to the plan area but not entirely under the 

control of the Forest Service are identified threats from barred owls and some effects such as 

increased wildfires or increased tree mortality that are likely to occur from climate change.

Great Gray Owl

Status: While the great gray owl is not currently known to breed on the Inyo National Forest, 

there have been incidental sightings on the national forest as well as detections close to the 

national forest boundary making it relevant to the plan area. Even if there are no breeding pairs, 

owls from the neighboring Sequoia and Sierra National Forests as well as Yosemite National 

Park, may use the Inyo as dispersal or foraging habitat. The fragmented nature of upper montane 

forests on the Inyo National Forest, coupled with declining and or small population numbers of 

the owl, may put the species at future risk, particularly given the Inyo’s location at the edge of the 

species range. Recent surveys and genetic sampling of the Sierra Nevada great gray owl 

population indicate that it is a geographically isolated population of only a few hundred 

individuals in the central Sierra Nevada (Hull et al. 2010).

Threats: The primary threats to habitat in the plan area are vulnerability of meadow habitat to 

climate change and conifer encroachment, degradation of suitable meadow habitat for foraging, 

and degradation or loss of conifer forest habitat especially adjacent to foraging meadows.

Future changes in climate (increasing temperatures) combined with a change from a snowdominated to a rain-dominated system may impact meadows due to changes in the hydrologic 

regime. Total meadow area may decline and wet meadows may shift to dry meadows (Gross and 

Coppoletta 2013). This drying would decrease herbaceous biomass, which could in turn affect 

health rodent populations for the owl. Conifer forests are also vulnerable to climate change. 

Anticipated trends for red fir forest, Jeffrey and lodge pole pine and mixed conifer are similar; 

trending towards higher fuel loading, and changes in forest structure and composition associated 

with fire suppression coupled with a changing climate (Slaton 2013). 

In addition, projected increases (2006-2050) in mountain pine beetle activity for high-elevation 

pine forest will have substantial cascading impacts on subalpine forest ecosystems, leading to 

outbreaks that can cause significant changes in forest structure, function, and composition (Meyer 

2013a). Habitat degradation from livestock grazing and timber harvest are considered significant 

threats to great gray owl persistence (Wu et al. 2016) because livestock grazing can result in the 

removal of vegetative cover required by critical prey species (Beck and Winter 2000; Kalinowski, 

Johnson, and Rich 2014a), and because timber harvest may result in reduced canopy cover, 

removal of nest structures, and potentially disturb breeding owls. Disturbance from increased 

recreation is also a concern because in Yosemite National Park, human disturbance related to 

campgrounds and their development has been documented (Maurer 2006, Bull and Duncan 

1993).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

347

The fragmented nature of upper montane forests on the Inyo National Forest, coupled with 

declining and or small population numbers of the great gray owl, and reductions in meadow 

habitat from climate change and conifer encroachment put this species at risk. Species viability of 

great gray owl on the Inyo National Forest is currently uncertain.

Bi-state Greater Sage-grouse 

Status: The sage-grouse has experienced significant range and population reductions in many 

areas of eastern California and western Nevada where the species is a permanent resident. It is 

designated as a (third priority) California species of special concern in its nesting and breeding 

(lek) grounds. The U.S. Fish and Wildlife Service recognized this species as a distinct population 

segment under the Endangered Species Act and proposed the bi-state distinct population segment 

of greater sage-grouse as threatened under the Endangered Species Act in 2013 (USDI Fish and 

Wildlife Service 2013). Through collaborative efforts, a bi-state action plan was developed (BiState Technical Advisory Committee Nevada and California 2013) and funding commitments 

were made which led the U.S. Fish and Wildlife Service to make a final decision in 2015 that 

listing the species under the Endangered Species Act was not warranted (USDI Fish and Wildlife 

Service 2015b).

The bi-state population of greater sage-grouse occurs in portions of Carson City, Lyon, Mineral, 

Esmeralda, and Douglas Counties in Nevada, and of Alpine, Inyo, and Mono Counties in 

California and is only found on the Inyo National Forest. The State wildlife agencies in Nevada 

and California have jointly identified five bi-state area population management units (PMUs): 

Pine Nut, Desert Creek-Fales, Mount Grant-Bodie, South Mono and White Mountains. The most 

recent population study showed that sage-grouse populations within the bi-state area were stable 

from 2003 to 2012 (Coates et al. 2014). One exception was the Parker Meadow population in the 

South Mono Population Management Unit; the study showed that this subpopulation is at risk of 

extinction (Coates et al. 2014). However, this subpopulation has relatively low influence on the 

overall population trend averaged across the entire bi-state area (Coates et al. 2014).

Threats: Key risk factors to sage-grouse include pinyon-juniper expansion and ingrowth of 

conifers into sagebrush habitats, the spread of invasive species and noxious weeds, predation by 

ravens, and human development. On the Inyo National Forest, pinyon pine has grown into lower 

elevation sagebrush ecosystems at a high rate due to many factors such as wildfire suppression, 

historic livestock grazing, and changing climate (Slaton and Stone 2015a, b). Jeffery pine has also 

grown into sagebrush ecosystems and threatens the condition of sage-grouse habitat.

In addition to conifer ingrowth, cheatgrass is invading sagebrush ecosystems and adversely 

affecting habitat condition. Cheatgrass becomes established after wildfire or other disturbance 

and changes the structure and composition of sagebrush habitat. Consequently, cheatgrass also 

makes habitat more flammable and susceptible to subsequent wildfires (Brooks and Minnich 

2006).

Past land management practices and weather patterns may be correlated with a decrease in 

understory and shrub cover in sage-grouse habitats that has been linked with increased nest 

predation by ravens (Coates and Delehanty 2010). Although it has not been measured, the extent 

of human development impacting sage-grouse habitat has been limited and most impacts have 

probably occurred on private land development in the Chiatovich Creek area east of the White 

Mountains in Nevada. In addition to reducing and degrading habitat condition, developments can 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

348

impact sage-grouse use and movement in habitats, especially winter range use where new roads 

and housing development fragment habitat.

Infrastructure (fences and posts) has been identified as an additional threat to greater sage-grouse 

because they may increase predation risk (USDI Fish and Wildlife Service 2015; Hall, Gardner, 

and Blankenship 2008). The study by Hall et al. additionally suggest West Nile virus as a 

potential threat; however, U.S. Fish and Wildlife Service did not consider West Nile to have 

“serious consequences” for the population. 

Mount Pinos Sooty Grouse

Status: The Mount Pinos sooty grouse has likely been extirpated from much of its historic range,

which occurred from Kings Canyon south and west to the Mt. Pinos region of Kern and Ventura 

Counties (Bland 2013a, Zeiner et al. 1990). It is now most abundant at the northern limits of its 

current range which occurs south of 37 degrees north latitude. On the Inyo National Forest, this 

includes areas south of the town of Independence in suitable habitat found in Kearsarge Pass, 

Onion Valley, Mt Whitney and Mt Whitney Portal, Olancha Creek, and Haiwee Canyon (Bland 

2013a, 2017). Surveys over the past century indicate the range of Mt. Pinos Sooty Grouse has 

receded roughly 100 miles and recent data suggest that the northward decline is continuing 

(Bland 2013a). 

Threats: Threats include incompatible timber harvest, fire suppression and altered fire regime, 

livestock grazing, land development, recreational use of habitat, hunting, and climate change.

Sooty grouse are associated with upper elevation conifer forests that may be affected by 

vegetation management and climate change. In early spring, sooty grouse congregate in open 

mature stands of conifers near the crests of ridges (Bland 2013a). These “hooting sites,” or 

“spring activity centers” are traditional, and are returned to year after year, generation after 

generation. Loss of large trees from these areas are detrimental to grouse (Bland 2013b). In late 

spring and summer through fall, females and their young are associated with meadows and other 

mesic areas. Degradation of meadow and mesic areas can negatively effect brood production. In 

winter, sooty grouse seek dense conifer stands at high elevations where they subsist almost 

entirely on fir needles and buds. Forest heterogeneity is important to maintain for grouse. Groups 

or clumps of conifers, especially in fir stands provide important food and thermal and hiding 

cover for grouse.

Willow Flycatcher 

Status: Once common throughout the western United States, the willow flycatcher is gone from 

much of its range. The willow flycatcher is a polytypic species, with three subspecies breeding in 

California: E. t. brewsteri in isolated patches in northern California and along the western slope of 

the Sierra Nevada; E. t. adastus along the eastern slope of the Sierra Nevada; and E. t. extimus

(southwestern willow flycatcher) breeding in riparian areas of southern California. Two of the 

three subspecies of willow flycatcher are known to occur on the Inyo National Forest; the 

federally endangered southwestern willow flycatcher, E. t. extimus, is not known to occur on the 

Inyo. It is not possible to identify the subspecies apart visually, only genetically. The 2004 Sierra 

Nevada Forest Plan Amendment (USDA Forest Service 2004d) listed willow flycatcher sites on 

eight sites on the Inyo National Forest. These sites were considered occupied, historically 

occupied or conditionally occupied based on records of detection. More recently, The Institute for 

Bird Populations (IBP) synthesized data on willow flycatcher detection sites from numerous 

entities (Federal, State, and private) and found that the Inyo National Forest has a total of 32 

active flycatcher sites (2,238 acres), constituting 7 percent of all currently used flycatcher habitat 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

349

in the Sierra Nevada (N= 285 sites, 33,367 acres total). The authors of that study note that post

and pre-breeding willow flycatchers in meadow habitat are regularly detected at MAPS stations 

and during point counts in Yosemite National Park and the Stanislaus, Sierra and Inyo National 

Forests (Loffland et al. 2014).

On the Inyo National Forest, potential habitat can be found in the riparian meadow and riparian 

non-meadow ecological assessment types. The largest riparian meadow systems on the Inyo occur 

on the Kern Plateau (approximately 10 percent) while about 1.5 percent of the land area in the 

Ansel Adams and John Muir Wildernesses is meadow. However, the willow flycatchers 

documented on the Inyo National Forest in the lower Rush Creek area occur in atypical habitat. 

Lower Rush Creek is at roughly 6,500 feet above sea level and lies within a matrix of Great Basin 

big sagebrush scrub. After decades of heavy diversion, it has been under passive restoration for 

22 years. Livestock grazing, once heavy on lower Rush Creek, has been excluded from the 

riparian corridor for over 10 years by the Inyo National Forest and the Los Angeles Department 

of Water and Power. Although lower Rush Creek (often referred to as the “Rush Creek 

Bottomlands”) has one of the widest riparian corridors in the Eastern Sierra, the corridor’s 

riparian vegetation can be patchy, with significant amounts of sagebrush scrub mixed within 

patches of riparian obligates that are supported by current and historic side channels (McCreedy 

2005).

Threats: Key threats to willow flycatcher include loss of meadows and riparian habitat due to 

changes in water levels, diversions, grazing, meadow drying and conifer encroachment, snow 

pack and changes in spring precipitation related to climate change. Livestock grazing can 

negatively affect flycatcher habitat, however, on the Inyo National Forest no known willow 

flycatcher sites currently co-occur on active livestock allotments. Unpublished Inyo National 

Forest data indicate that all stream reaches through meadows in grazed and rested allotments fell 

within expected values for width and width-to-depth ratios, except for Monache Meadow, which 

showed that widths were wider and depths shallower than they should be for a functioning 

hydrologic system. In the past 20 years, much restoration work has been completed in meadows 

on the Inyo, especially the Kern Plateau. Observations by national forest staff suggest that even in 

allotments that remain open to livestock grazing, restoration and changes in grazing management 

appear to have improved stream and meadow condition overall. During the recent forest plan 

assessment process, grazing monitoring data for 69 key meadow areas show that 35 percent were 

in excellent condition, 35 percent were rated as good, 23 percent as fair, and 7 percent as poor. 

Lower ratings indicated lack of surface litter, greater bare ground cover, soil compaction and/or 

rilling. Higher ratings were correlated to greater plant diversity and vegetation cover. 

Additional risk factors that affect nest success through increased predation rates and nest 

parasitism can occur both on and off the forest. Placement of bird feeders in residential areas 

outside the Inyo is known to attract brown-headed cowbirds, which in turn leads to nest 

parasitism of willow flycatchers. Brown-headed cowbird nest parasitism has also led to direct loss 

of nest productivity and recruitment on the national forest, especially in the lower Rush Creek 

area where it is the primary cause for low productivity (McCreedy and Burnett 2011). Loffland et 

al. (2014) note historic locations on the Inyo National Forest in close proximity of one another, 

including the area west of Mono Lake in the vicinity of Rush Creek and Lee Vining Creek. These 

areas may be candidates for meadow restoration efforts; however, it is believed that high cowbird 

densities in this area resulting from backyard bird feeders and other human-induced attractions 

(rather than livestock grazing) would need to be addressed before attempting to attract willow 

flycatchers into those areas. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

350

Outside the Inyo National Forest, water diversions have impacted willow flycatcher habitat. As 

stated in the Conservation Assessment, riparian vegetation in the Owens Valley located 

downstream of the intake to the Los Angeles aqueduct has dramatically changed to a more xeric 

condition due to the lack of water, and no longer provides habitat for nesting willow flycatchers

(Green, Bombay, and Morrison 2003). Increased water demands coupled with more frequent 

drought events and drying conditions will continue to act as negative stressors on flycatcher 

habitat, although some willow flycatchers species were found to be at lower risk (out of 358 total 

bird taxa analyzed) with regard to climate change vulnerability than other bird species (Gardali et 

al. 2012).

Terrestrial Invertebrates: Summary of Key Ecological Conditions and Key Risk Factors

Butterflies

The butterflies are limited to areas with suitable host plants and other, often unknown factors. The 

San Emidgio blue is known to be limited by other factors since it doesn’t occur in some areas, 

even if the host plant is present. It has a complex symbiotic relationship requiring an ant 

(Formica pilicornis), a scale species (Ceroplastes irregularis), and one of three Atriplex or 

shadscale plant species (Atriplex lentiformis, A. cannescens, and A. polycarpa) are necessary to 

complete its lifecycle. Climate change is a substantial risk factor for many of these species 

because they have very limited distributions, and frequently disjunct populations. Butterflies can 

be affected by changed seasonality of rain and temperature that might cause a shift in the survival 

or flowering season of host plants.

Status: The various butterfly species of conservation concern occur mostly at high elevations and 

are primarily associated with wet meadow or riparian habitats. Butterflies inhabit virtually every 

part of an ecosystem largely determined by their dispersal ability, feeding and reproductive habits. 

However, the butterflies of conservation concern are, as a rule, highly endemic, meaning 

populations occur only in very localized areas and those areas are extremely rare. Habitat 

suitability for many species depends on microsite conditions that can vary with each life stage. 

Having both host and nectar plants available are usually critical requirements, and where both are 

present it may limit populations to the boundary of such habitats. For some, the majority of their 

life stages are limited to one or a few plants for larval, juvenile or pupa, and adult stages.

Threats: The primary threat for butterflies of conservation concern is restricted distribution and 

endemic populations. This condition makes populations very susceptible to subtle habitat changes 

and perturbations that may result from water withdrawal, overgrazing, invasive species, conifer 

encroachment, pesticide use, unauthorized off-highway vehicle use, road expansion, 

development, mining, and climate change.

The host plants of all of these species can be susceptible to ground disturbance and some are 

threatened due to climate change. Most species of butterflies have evolved to be very selective 

and will only lay their eggs on one or two specific species of plants which also serves as a 

primary food source. Changes in temperature extremes and precipitation could affect host plant 

availability. Fires that burn with low to moderate severity can regenerate flowering plants in fireadapted ecosystems and an altered fire regime is typically a threat to these taxa. Grazing likely 

has different impacts on different species of butterfly depending on intensity, mostly through 

impacts on host plants. Application of pesticides that are used to control nuisance insects or other 

pests or to kill target plants are threats to many butterflies if they are not selective or if they affect 

larval plants or habitat. Hobby collecting of butterflies can also impact populations and more 

information needs to be gathered with respect to this potential threat.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

351

Table 62. Terrestrial invertebrate species of conservation concern, ecological zones or types, key ecological conditions, and primary stressors or 

threats to persistence (primary stressors not under Forest Service are not necessarily discussed further)

Species

Primary Ecological Zone(s)

or Ecosystem Type(s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under Forest 

Service Control

Primary Stressors not under 

Forest Service Control

Apache Fritillary 

(Apache Silverspot 

Butterfly)

Meadows in the Alpine zone, 

Springs and Seeps

Host larval plant is Viola 

neprhropylla. Presence of bull 

thistle Cirsium vulgare and 

lavender thistle Cirsium 

neomexicanum also appear 

important. 

Loss of meadows and riparian 

habitat due to changes in water 

levels, diversions, grazing, 

meadow drying and conifer 

encroachment. Invasive species 

and pesticide applications that 

inadvertently impact host plant 

species. 

Municipal water diversions, loss 

of snow pack and changes in 

spring precipitation related to 

climate change. Restricted 

distribution.

Boisduval’s blue Riparian Conservation Areas 

(Meadows, Springs and 

Seeps

Perennially wet marshes and 

wet meadows near springs, 

seeps and riparian areas 

where host plant Collinsia 

parvifloria occurs.

Invasive species (e.g. cheatgrass) 

and pesticide applications that 

inadvertently impact host plant 

species. Recreation. Roads 

construction.

Mining, Restricted distribution, 

drying of meadows due to climate 

change.

Mono Lake 

Checkerspot

Riparian Conservation Areas 

(Meadows, Springs and 

Seeps

Perennially wet marshes and 

wet meadows near springs, 

seeps and riparian areas 

where host plant Collinsia 

parvifloria occurs.

Pesticide applications that 

inadvertently impact host plant 

species. Recreation, Roads 

construction, Conifer 

encroachment, timber harvest and 

livestock grazing.

Restricted distribution, drying of 

meadows due to climate change.

San Emigdio Blue Desert scrub, Special 

Habitats.

Washes, alluvial fans and 

habitats that include desert 

saltbush species (Atriplex) and 

associated scale insects and 

ants.

Invasive species and pesticide 

applications that inadvertently 

impact host plant species. Ground 

disturbing activities including fire 

management, unauthorized OHV 

travel, and road expansion.

Restricted distribution/isolated 

populations and ant/larval 

symbiotic relationship. 

Agricultural and urban 

development (potential expansion 

of Highway 395). Drying of 

meadows due to climate change 

and

Sierra Sulphur Riparian Conservation Areas 

(Meadows, Springs and 

Seeps

High elevation, perennially wet 

marshes and wet meadows 

near springs, seeps and 

riparian areas where host 

plant Vaccinium cespitosum

occurs.

Any activities that that alter 

hydrology/water flow and increase 

sedimentation including grazing

and water impoundments, ground 

disturbing activities such as timber 

harvest.

Endemism/ restricted distribution; 

Municipal water diversions, loss

of snow pack and changes in 

spring precipitation related to 

climate change that cause 

meadow drying.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

352

Species

Primary Ecological Zone(s)

or Ecosystem Type(s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under Forest 

Service Control

Primary Stressors not under 

Forest Service Control

Square Dotted 

Blue

Alpine and Subalpine Zones, 

Meadows.

High elevation, scree slopes, 

barren ridges and pumice 

fields where host plant 

Eriogonum (buckwheat plants) 

occur.

Invasive species and pesticide 

applications that inadvertently 

impact host plant species, any 

ground disturbing activities that 

damage microsite conditions.

OHV travel in Badger Flats and 

Mazourka Peak. 

Restricted distribution (only one 

location on the forest), Mining 

(pumice harvest).

Invasive species and pesticide 

applications that inadvertently 

impact host plant species.

A cave obligate 

pseudo-scorpion

Caves Poleta Cave Recreational caving Mining, high endemism 

(relict/ancestral population).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

353

A Cave Obligate Pseudoscorpion

Status: Found only on the Inyo National Forest, this species is similar looking to a scorpion.

Pseudoscorpions, commonly known as “false scorpions,” pose no threat to humans and are 

members of the spider family. This species type locality is only known from one cave in the InyoWhite Mountains, at about 7,200 feet in elevation. The cave is gated and locked.

Threats: Recreation or potential mining use could impact this species. Disturbance to occupied 

caves that could impact this species include smoke from fires, trampling, and changes in moisture 

or temperature conditions. Climate change may be the greatest threat to cave habitats by altering 

temperature and humidity; most troglobites have narrow environmental tolerances (Badino 2004).

Environmental Consequences to At-risk Terrestrial Wildlife Species

Environmental consequences are first evaluated for the major ecological zones and vegetation 

types to provide context for potential changes in habitat or conditions which is then evaluated for 

each at-risk terrestrial wildlife species. While old forest habitat elements and complex early seral 

habitat can occur in any ecological zone, these two specific habitats are described as part of the 

Sierra Nevada montane ecological zone as they are most relevant to conifer dominated forests. 

For the plan revision alternatives, the evaluation focuses on the ability of the coarse-filter 

components to achieve the desired conditions and provide habitat sufficient to support the 

persistence of associated species. Where fine-filter plan components exist for a species, those 

plan components are evaluated under the various alternatives for their ability to provide habitat 

sufficient to support the persistence of that particular species.

Consequences Common to All Alternatives

Range Management

All alternatives maintain the same level of livestock grazing as the current plan in alternative A 

and permitted livestock grazing would be managed the same as under current practices, unless 

changed by future project-specific decisions. In the plan revision alternatives, parts of the current 

forest plan and amendments related to monitoring protocols and processes for grazing permit 

administration have been moved to a forest supplement for range program management where 

they can more regularly be updated with new scientific information.

Grazing can adversely affect habitat for terrestrial wildlife species, particularly those that nest or 

forage in meadows, riparian areas, and grasslands. Direction for livestock grazing management

and direction for riparian conservation areas for desired conditions and livestock grazing in 

meadows is would not vary by alternative. The plan direction is anticipated to improve livestock 

grazing management, and result in positive meadow and riparian conservation area trends over 

time. These actions improve vegetative conditions, stability and resilience over time.

Grazing can cause structural changes to willow flycatcher habitat that could “expose nests, reduce 

substrate for insects, and diminish foliage cover that protects nests” (Mathewson et al. 2007). 

While poorly managed grazing can change the hydrologic and vegetative characteristics of 

meadows and contribute to poor quality habitat for nest selection and increased visibility 

(vulnerability) of nests to predation (Brookshire et al. 2002; Auble, Friedman, and Scott 1994;

Scott, Skagen, and Merigliano 2003), grazing management direction is designed to minimize and 

avoid these effects.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

354

Some grazing can be beneficial for butterflies, but heavy grazing can degrade habitat. Livestock 

grazing, especially in and near Sierran meadows, may affect breeding success of the Sierra 

marten by reducing understory vegetation (Zielinski 2014). Livestock grazing levels have been 

substantially reduced over the last several decades and some grazing allotments are now currently 

vacant and ungrazed. Specific decisions on the numbers, types, seasons, and level and intensity of 

livestock grazing are made during allotment management planning. Allotment management plans 

also include monitoring of grazing activities so that the need for adjustments to livestock grazing 

practices and amounts can be identified and addressed in annual operations or in the allotment 

management plans. This would be the same under all alternatives. If new grazing allotments or 

activities are proposed in habitat that supports a threatened, endangered, proposed, or candidate 

species, the U.S. Fish and Wildlife service would be consulted prior to making allotment 

management plan decisions.

Wilderness

Management of designated and recommended wilderness can benefit species by precluding 

certain ground-disturbing management activities (like timber harvest and road building) that 

might reduce habitat quality, and by limiting mechanized and motorized activities such as 

mountain biking and off-highway-vehicle use that could cause disturbance to individuals during 

sensitive times of year such as breeding periods. This conservation approach of restricting 

activities has long been employed as a means to help protect natural resources, including wildlife,

from degradation and disturbance associated with human actions that alter the environment. The 

benefit of precluding these activities is somewhat limited, however, because many of the areas 

proposed for recommended wilderness are already managed as inventoried roadless areas or they 

are areas that are steep and remote with limited access and where the risk of ground-based 

activities is minimal.

Wilderness management areas are also locations where wildfires are often managed to meet 

resource objectives, such as restoring fire as a key ecosystem process, which can substantially 

improve habitat condition, heterogeneity, structural diversity, and species composition of 

vegetation. Fire management activities in designated and recommended wilderness employ 

minimum impact suppression tactics to the extent possible to reduce the human impact on 

wilderness character which tends to minimize impacts to wildlife habitats. All alternatives 

encourage managing wildfires to meet resource objectives when it is safe to do so, but the plan 

revision alternatives provide clearer plan direction than alternative A, which should result in more 

wildfires being managed and more acres having fire restored over time, especially in designated 

and recommended wilderness areas. Over time this is expected to improve the resilience of 

habitat by lessening the risk of uncharacteristic changes in habitat from wildfires.

However, designated and recommended wilderness management direction can also impact 

species by precluding or limiting restoration activities. In areas where vegetation and fuels have 

been impacted by past management, wildfires are becoming increasingly large and often have 

high-severity impacts to habitats that are outside the natural range of variation. Despite the desire 

to restore fire as an ecosystem function, many wildfires will be difficult to manage safely given 

the current condition and wilderness management direction generally limits the use of prescribed 

fire. The amount of wildfire is predicted to increase in the future in all alternatives (See “Fire 

Trends” section) and increased wildfires could cause the loss of forest habitats in designated and 

recommended wilderness areas.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

355

Wilderness areas are expected to have a continuing risk of disturbance to wildlife from wilderness 

users, which is projected to increase overall with population increases. Visitor use may change in 

some areas that are managed as recommended wilderness areas. If areas already have visitor use 

the change could be slightly more if people are attracted to trails that are associated with 

wilderness but use could also be slightly less if existing users want pursue activities that were 

allowed but may be discontinued after an area is managed as recommended wilderness. If

substantial conflicts with recreation uses and wildlife are known, all alternatives have direction to 

manage the conflict. Some species like Sierra Nevada bighorn sheep have specific direction and 

others would apply forestwide guidance.

Ground-disturbing activities are generally limited within designated and recommended 

wilderness areas, including when the purpose is ecological restoration. This may limit the 

opportunities for restoration of some sagebrush dominated areas important to sage-grouse. In 

some cases, alternate methods may be used that are compatible with maintaining wilderness 

character but they may have higher implementation costs resulting in fewer acres restored or 

causing other restoration activities to be deferred or delayed. This is discussed in more detail for 

the bi-state sage-grouse below.

Climate change has been associated with and will continue to influence shifts in ecological 

processes and patterns, and species ranges, movements, and phenologies (Bradley et al. 1999, 

Safford et al. 2012, Cole and Yung 2012) among other newly emerging patterns. Biotic 

communities may shift in complex ways, such as some species may shift sooner or later than 

others, or in different geographical directions than others causing disruptions in ecosystem 

functions. In this way, novel species assemblages may form with new predatory or competitive 

interactions (Stralberg et al. 2009). While wilderness designation can benefit terrestrial wildlife 

species, protection of species and community assemblages may be limited to a snapshot in time 

and may not be protective in the future if natural processes aren’t sufficient to maintain habitat 

conditions due to factors such as climate change, large high-intensity fire, nonnative species 

invasions (like invasive plants and barred owl), insect outbreaks, and pathogens, among others.

Consequences Common to Alternatives B, B-modified, C, and D

Recreation Management

As explained in the “Sustainable Recreation” and “Economic Conditions” sections, there is an 

expected increase in recreation demand as regional populations grow. This trend, coupled with 

improved recreation site conditions and recreation access across the alternatives, has the potential 

to increase the amount of recreation use in both dispersed and developed areas. This could

increase the potential for disturbance during the breeding season and other sensitive time periods 

for at-risk species and could result in localized impacts to habitat conditions. Some areas like 

meadows, riparian habitats, and ponds and lake shores provide important habitat to at-risk species 

but are more sensitive to trampling and compaction and are also attractions to recreationists in the 

hot and dry summer months. Some areas like cliffs and rocky outcrops may experience greater 

impacts than other habitats from increased recreation use because these areas tend to receive more

intense or frequent recreation use due to the popularity of rock climbing and bouldering. Cave 

exploration can directly and adversely affect bat species that may be roosting or rearing young 

and cause site abandonment. Human disturbance from various kinds of recreation activities like

camping, rock climbing, road and trail use, off-highway or over-the-snow vehicle operation, is a 

known threat for species like bald eagles, Sierra marten, and great gray owl which are more 

sensitive to human disturbance.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

356

In these alternatives, plan direction for sustainable recreation more explicitly recognizes the need 

to avoid or mitigate recreation impacts to at-risk species compared to alternative A, especially for 

dispersed recreation and when siting new recreation facilities. As projects are planned, the 

alternatives include forestwide plan direction to include mitigations to reduce impacts on at-risk 

species in order to reduce the ecological impact of recreation facilities and recreation uses. For 

some species or circumstances more focused direction was developed. For example, these 

alternatives include guidance to install bat gates at cave and mine entrances or restrict access by 

other means when bat maternity colonies or hibernacula may be adversely affected. Under these

alternatives there would be an emphasis on addressing the backlog of deferred maintenance at 

developed recreation sites and on trails. These alternatives would benefit at-risk species over the 

plan period by mitigating the disturbance and habitat impacts from recreation uses, but it will be 

increasingly challenging to mitigate impacts in the future as recreation demand continues to grow.

Plan Components Developed for At-risk Terrestrial Wildlife Species

Alternatives B, B-modified, C, and D share most of the same vegetation-focused desired 

conditions. The desired conditions by major terrestrial vegetation types were listed in table 26 and 

table 27 in the “Terrestrial Vegetation Ecology” section. These ecosystem level plan components 

provide for a broad range of ecological conditions important to ensure habitat diversity for 

wildlife. In addition, other desired conditions specific to wildlife.

Table 61 and table 62 list the threats and principal habitats for each terrestrial wildlife species of 

conservation concern. For each species, appendix F (persistence analysis for species of 

conservation concern) lists the primary applicable plan components that provide for the 

ecological conditions necessary to ensure or contribute to the persistence of the species. While 

many other plan components may also provide generally for ecological conditions that would 

benefit a species, only the primary plan components are identified. The consequences of plan 

direction are described in the analysis presented by species below.

Consequences to Major Ecosystem Zones, Ecosystem Types, and Habitats

The analysis by vegetation zone is based in part on the “Terrestrial Vegetation Ecology” and 

“Agents of Change” sections. These sections describe consequences to vegetation that affect 

habitat. The alternatives vary in their ability to reduce the risk of habitat degradation across large 

forested areas from large-scale disturbances like drought-related vegetation mortality, large highintensity fire, and insect outbreaks (see “Agents of Change” section). The alternatives also vary in 

their ability to move toward the desired conditions for structure, composition, and resilience of 

each vegetation type (see “Terrestrial Vegetation Ecology” section).

Subalpine and Alpine Zone

(Upper Montane Forests, Subalpine, and Alpine Vegetation)

This section compares the environmental consequences of the five alternatives on the dominant 

habitat types associated with the at-risk terrestrial wildlife that inhabit this zone, such as red fir 

and conifer forests, sagebrush (White Mountains), rocky terrain, and barren habitat. 

Environmental consequences for high elevation aquatic habitats such as meadows, riparian 

woodlands and forests, and lakes and ponds are described below in the “Aquatic Habitat” effects 

analysis within this section.

Under all alternatives, vegetation treatments are not prioritized in the upper montane zone except 

where needed around communities, developed recreation sites, and various assets like 

communication towers, water supplies, and powerlines. Much of this zone is in designated 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

357

wilderness or has limited access. Habitat within wilderness areas would remain generally 

undisturbed by management activities because natural processes are the primary mechanism of 

habitat maintenance in these areas. Relatively low amounts of mechanical treatment are expected 

in this zone, and a heavier focus is on the use of wildfires managed to meet resource objectives. 

There is very little to no mechanical treatment expected in subalpine and alpine zones except 

potentially along strategic roads and ridgelines outside of designated wilderness where treatment 

might facilitate prescribed burning or managing future wildfires to meet resource objectives. 

Natural features like rock outcrops, areas of talus, or barren areas that are naturally open with 

little to no vegetation and fuels.

Limited mechanical treatment would occur in forested portions of these zones. Where restoration 

is conducted, the emphasis would be on the use of managed wildfire due to the more remote 

locations. Due to limited mechanical restoration treatments under this alternative, vegetation in 

these zones would likely have the lowest resilience to climate change and would continue to be 

susceptible to large, high-intensity wildfire, except for portions of the Kern Plateau where the 

restoration of fire has been occurring (see the “Fire Trends” section). In alternative A, habitat 

conditions would be likely to remain the furthest from the natural range of variation of all 

alternatives. Condition of forested habitat would be more vulnerable to degradation than under 

other alternatives. Vegetation management under this alternative is generally prohibited from 

removing large-diameter trees. Where they occur in high density clusters, this leaves these large 

trees at a greater risk of dying from insect outbreaks, spread of diseases and pathogens, and large 

wildfire with high severity impacts. Although wildfires in forested areas in these higher elevation 

zones tend to occur less frequently than in lower elevations and most are small with mixed 

severity effects, under alternative A, burned area, fire size, and fire intensity are predicted to 

increase two to four fold (see the “Fire Trends” section).

Ecosystems in these zones are among the most vulnerable to climate change and would continue 

to have low resilience to climate change (see “Terrestrial Vegetation Ecology” section), especially 

under alternative A because of the limited ability to restore habitat in these zones. Warming 

temperatures and drought conditions have the potential to seriously degrade habitat condition 

over time, including drying of high alpine water sources that are particularly important to the 

Sierra Nevada bighorn sheep and of higher elevation meadow systems important to sage-grouse 

brood-rearing.

Restoration under alternatives B and B modified would result in improved structure and resilience 

of habitat condition in these zones because it would provide a greater opportunity to treat 

vegetation and uses more managed wildfire for resource benefit than alternative A. Although fires 

are naturally infrequent in the upper montane, subalpine and alpine zones, they are an important 

part of the disturbance regime (see “Terrestrial Vegetation Ecology” section). These alternative 

also have specific desired conditions for these habitats to more clearly direct management actions. 

However, these treatments are strategically placed to try and prevent loss of large areas of habitat 

from large wildfire and there are plan components to incorporate consideration of habitat 

fragmentation and connectivity at fine scales during project design. Overall these alternatives

would be better at improving and sustaining the condition of wildlife habitat over the long term 

than alternative A.

Although the emphasis of treatments in the upper montane zone under alternatives B and B 

modified is mostly on Jeffrey pine forests, this emphasis is not anticipated to adversely affect 

habitat condition or quantity for species more strongly associated with other forest types. There 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

358

would also be some restoration in red fir forests and in white pine stands at risk from white pine 

blister rust that are greatly deviated from desired conditions and at high risk from climate change. 

Jeffrey pine forests are more departed from desired conditions (and the natural range of variation) 

than many of the other forest types in this zone. Therefore, treatments focused on this forest type 

(and particularly on reclaiming the dominance of Jeffrey pine trees) would likely benefit many 

terrestrial wildlife species, particularly where these treatments also improve heterogeneity, 

structural complexity, and resilience. 

However, treatments would be relatively less focused in habitats that are known to support some 

at-risk terrestrial wildlife species like the California spotted owl and Sierra marten that are 

associated with high elevation closed canopy red fir forest. These forest types will be restored in 

this zone for structural complexity, heterogeneity, and resilience but not to the degree that Jeffrey 

pine forests will be restored. These habitats are generally not as far departed from desired 

conditions as Jeffrey pine forests and can continue to support wildlife needs. Still, focused 

treatments in these forests to promote resilience would be conducted with the needs of these 

species in mind during project development, such as considering Sierra marten habitat strategies. 

These restoration treatments would promote resilience to large-scale disturbances like highintensity fire that can remove large areas of habitat. 

In the Kern Drainage, where upper montane forests (Jeffrey pine, red fir, lodgepole pine, aspen) 

have been restored in the last 15 years through wildfires managed for resource objectives (FitesKaufman, Noonan, and Ramirez 2005, Ewell, Reiner, and Williams 2012, Vaillant 2009, Meyer 

2015b), at least one-third to one-half of the area is similar to desired conditions (see “FireTrends” and “Terrestrial Vegetation Ecology” sections). Most of this area is in the wildfire 

maintenance zone and would continue to have wildfires managed for resource objectives to 

maintain and further restore conditions similar to the natural range of variation for vegetation, 

fire, and climate resilience. Habitat in these areas would be resilient.

Alternatives B and B modified include desired conditions for climate change resiliency in 

subalpine and alpine ecosystems. Although the more rapid pace and larger scale of restoration 

under these alternatives (especially the use of managed wildfire) is anticipated to create more 

resilience to climate change in the upper montane, subalpine, and alpine zones, the zones would 

continue to have low resilience to climate change overall (but better than under alternative A) 

because of limited restoration rates and the high climate exposure of these areas (see “Terrestrial 

Vegetation Ecology” section).

Overall, treatments to increase upper montane heterogeneity and resilience, and improve 

conditions for whitebark pine under Alternative C have a greater potential than alternative A but 

less than B or B modified to improve habitat condition for terrestrial wildlife species because of 

limited treatment rates. Habitat under alternative C would continue to be at risk to large, highintensity wildfire similar to alternative A. Although alternative C emphasizes prescribed fire and 

wildfire managed to meet resource objectives, techniques that are most likely to be used in the 

wildfire maintenance and general wildfire zones, this alternative proposes fewer total acres of 

treatment than alternatives B, B modified or D. There is additional area in recommended 

wilderness, increasing the proportion of upper montane and subalpine zones in areas with limited 

management (wilderness, wild and scenic river corridors, and inventoried roadless areas) from 74 

to 79 percent of the upper montane zone as compared to alternative A. With 98 percent of the 

subalpine and alpine zone already in less managed areas, these combined areas would provide for 

more extensive connecting area for wide-ranging species like Sierra marten.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

359

Alternative C also has less ability than alternatives A, B, B modified and D to use mechanical 

techniques that could better reassert Jeffrey pine trees as the dominant tree type in these forests 

and promote overall heterogeneity and structural diversity. This alternative does not treat at the 

landscape scale like would occur in alternatives B, B modified or D. Landscape treatments have a 

greater potential to restore resilience. Alternative C would result in lower climate change 

resilience than the other action alternatives due to the lower treatment rates. It would have slightly 

better climate change resilience than alternative A by focusing some treatment to improve 

conditions for whitebark pine. Overall alternative C is not as able as alternatives B, B modified or 

D to improve habitat condition for at-risk terrestrial wildlife species.

Effects to the condition of habitats that support at-risk terrestrial wildlife species under 

alternative D are the same as described under alternative B but the increased pace and scale of 

restoration under alternative D is anticipated to more rapidly achieve resilience, heterogeneity, 

structural complexity, and composition than alternatives B or B modified. Alternative D is also 

anticipated to have the greatest resilience to climate change, and large high-intensity fires 

(followed by alternative B and B modified) because of the faster restoration rates and more acres 

treated (see “Fire Trends” and “Terrestrial Vegetation Ecology” sections). More short-term 

(implementation-related) impacts could occur to habitat as a result of the faster pace and scale of 

restoration treatments. But as described under alternative B and B modified, these potential 

impacts are intended to improve long-term habitat condition and reduce the risk of loss from the 

landscape. Such impacts would be project- and site-specific and would be evaluated during 

project development.

Sierra Nevada Montane Zone

When comparing the alternatives on their impacts to the Sierra Nevada montane zone, alternative 

A would continue providing direction under the current forest plan components. It would continue 

applying the three strategic wildfire management zones. As a result, due to limited resources, 

limited operating conditions for prescribed burning and other restrictions, and higher priority 

setting for the two (Wildland-urban Intermix Defense and Wildland-urban Intermix Threat) of the 

three management zones, benefits in the form of restoration efforts to the Sierra Nevada montane 

zone is limited to developed areas and near communities primarily. 

When reviewing the historical management practices and changing environmental conditions 

(such as fire exclusion, vegetation management practices, and sheep grazing), the Sierra Nevada 

montane zone has also been affected, as have other ecological zones. Areas of forest have become 

dense or habitats fragmented over landscapes. Tree mortality in this zone is likely at the upper 

end of its natural range of variability due to drought and other stressors due to climate change. 

The existing forest plan (alternative A) describes the need to address forest stand density to 

reduce the risk of trees dying due to stresses related to prolonged droughts. However, the single 

species specific habitat management direction along with restrictions on prescribed fire within 

riparian conservation areas and critical aquatic refuges, limits the amount of treatment that can 

occur within the “general fire management zone” that overlaps with the majority of the Sierra 

Nevada montane zone. 

Common to alternative B, B-modified and D is the development of four strategic fire

management zones providing for more options on managing the landscape, including managing 

fires for resource benefits within zones containing communities, if safe to do so and the 

conditions are appropriate. This has the potential to benefit species associated with this ecological 

zone. Alternative B also identified four strategic fire management zones and is similar to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

360

alternatives B-modified and D, however, the changes to alternative B-modified and D are mostly 

in the low elevation sagebrush (moving them to the general protection zone rather than restoration 

zone) to protect sagebrush habitat from negative fire effects. Alternative C identifies three 

strategic fire management zones and like the other plan revision alternatives, provides 

management more options to use managing wildfires for resource benefits in more zones and 

acres if safe to do so, and therefore should benefit Sierra Nevada montane zone. All plan revision 

alternatives will be more beneficial and an improvement over alternative A when addressing the 

restoration and protection of habitat associated with species of conservation concern within the 

Sierra Nevada montane zone. 

Eastside Shrublands and Woodlands Ecosystem Type

(Sagebrush, Pinyon-Juniper, Mountain Mahogany and Xeric Shrub and Blackbrush)

Of these ecosystem types, sagebrush and pinyon-juniper cover the most area and are the primary 

habitats that support at-risk terrestrial wildlife species. There is analysis of eastside arid 

shrublands and woodlands, especially sagebrush, pinyon-juniper and eastside Jeffrey pine 

vegetation in the “Terrestrial Vegetation Ecology” section. This analysis builds upon that analysis 

and emphasizes wildlife habitat and species requirement aspects.

Habitat condition for at-risk terrestrial wildlife species in this zone would be relatively unchanged 

by management activities due to limited proposed treatments. Alternative A proposes the least 

amount of restoration of all alternatives. Treatments to reduce invading pinyon in sagebrush 

would occur focused primarily on sage-grouse habitat, but not at an increased pace as under 

alternatives B, B-modified, C, and D. this alternative is the least able to prepare the landscape to 

adapt to changing climate conditions. The landscape under this alternative would continue to have 

a low resilience to large high-intensity wildfire. The amount of habitat could be reduced more 

than under any other alternative due to habitat type conversion from increases in cheatgrass, loss 

of quality habitat due to the spread of pinyon and Jeffrey pine into sagebrush habitat, and the 

increasing risk of large high-intensity wildfires.

Alternative B would increase restoration levels compared to alternative A but would still treat 

relatively little of the woodland habitat in this zone. Eastside Jeffrey pine habitats are the most

outside of the natural range of variation and at the greatest risk to stressors and, therefore would 

have increases in treatment. This alternative proposes to treat more habitat in this zone (including 

sagebrush and pinyon-juniper) than alternative A, focused on restoration of sage-grouse habitat 

and areas around communities at risk. There would be restoration of riparian areas, most of which 

would occur in this area on the Inyo National Forest. There would be an increase in the area 

treated to reduce nonnative invasive plants. There are specific goals and management approaches 

to increase emphasis on cooperation with adjacent landowners and other interested collaborators 

in managing habitat. Management approaches include the following:

Continue coordination and communication with the California Department of Fish and 

Wildlife, Nevada Department of Wildlife and the U.S. Fish and Wildlife Service during 

project development for all projects occurring within sage-grouse habitat.

Coordinate with research and other organizations to evaluate the potential effects of 

climate change on the spread of invasive, nonnative species.

Habitat condition for at-risk terrestrial wildlife species is more likely to improve under 

alternatives B and B modified and risk of habitat loss from large-scale disturbances is more likely 

to be less than under alternative A. These alternatives have clear desired conditions for the 

resiliency, structural diversity, recruitment, functioning, and connectivity of these habitats. These
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

361

alternatives also take a landscape-level approach to restoration that would translate into largescale improvements to habitat condition, including connectivity. The composition and structure of 

vegetation in restored areas in this zone would likely move from low similarity to desired 

conditions under alternative A to low-moderate similarity to desired conditions in restored areas 

under this alternative as described in the “Terrestrial Vegetation Ecology” section. Encroaching 

pinyon and Jeffrey pine would be more effectively removed from large zones of sagebrush. 

Although the use of prescribed fire would be somewhat limited (although not as limited as in 

alternative A), this restoration technique would move the structure of these habitats toward the 

desired conditions. There are specific standards and guidelines to guide restoration project design 

to enhance or limit impacts to wildlife habitat, especially for sage-grouse and other at-risk 

species. 

Where these habitats occur in wilderness and support at-risk terrestrial wildlife species, the 

restoration approach proposed under alternatives B and B-modified would be better positioned to 

use managed wildfire to restore habitat condition (see “Fire Management” section). Most 

wilderness areas would be in the wildfire maintenance zone where managing wildfires can safely 

be used to meet resource objectives is emphasized. This alternative is not expected to have as 

many severe and large, high-intensity fires like those predicted under alternative A (see “Fire 

Trends” section), which can completely remove this habitat from the landscape. Unlike 

alternative A, the management approach under alternatives B and B-modified move the landscape 

toward to a moderate resilience to large high-intensity fire and better positions the vegetation to 

adapt to changing climate conditions. Alternative B-modified would have a slightly greater 

beneficial effect to this ecosystem because it would allow for greater flexibility in using 

prescribed fire in critical aquatic refuges and riparian conservation areas, and would implement 

restoration on a conservation watershed scale in areas of this ecosystem identified as conservation 

watersheds. 

Although short-term effects to habitat condition could occur due to the increased pace and scale 

of restoration and more intensive management tools (such as mechanical equipment), these 

effects would be site and project-specific and cannot be fully assessed at this programmatic level. 

At the programmatic level of the proposed plan, the long-term benefit to habitat condition and 

reduction in potential for habitat loss under this alternative is expected to outweigh the potential 

for short-term effects.

Alternative C emphasizes the management of fire, both the active use in prescribed burning at 

greater landscape scales as well as through managing wildfires to meet resource objectives. 

However, alternative C proposes to treat far fewer acres than alternatives B and B-modified, 

especially in this zone. The exception is that restoration of sagebrush habitats important for sagegrouse would be slightly higher than alternatives B and B-modified. There is 3 percent more 

sagebrush and pinyon-juniper habitat in recommended wilderness in this alternative relative to B 

and B-modified.

This alternative is more limited in the use of mechanical equipment that can effectively target 

specific trees for removal and help move vegetation toward the desired conditions. Therefore, 

although the potential for short-term effects related to implementation could be less under this 

alternative than under alternatives B, B-modified and D, the long-term condition of many pinyonjuniper habitats that support a variety of at-risk terrestrial wildlife species would continue to trend 

away from desired conditions for structure, composition, function, and connectivity over time 

while conditions of sagebrush habitats would improve similar to alternatives B and B-modified. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

362

The forested habitat would be more vulnerable than alternatives B and B-modified to climate 

change and large high-intensity fire that can completely remove large areas of this habitat. 

Invasive species and encroaching pinyon and Jeffrey pine would continue to threaten sagebrush 

habitat where treatments are limited by restricting harvest to only smaller diameter trees.

In alternative D, benefits to habitat quantity and condition including structure, composition, and 

resilience to climate change and large high-intensity wildfire, and potential for short-term effects 

would be the same as those described for alternative B. This alternative proposes to treat about 

the same, or slightly more habitat in this zone than alternative. However, this habitat already faces 

threats due to invasive species (cheatgrass) and this alternative has the greatest risk of spreading 

invasive species due to more acres treated and more mechanical treatments.

Cave, Cave-like, and Cliff Habitats

The amount of cliff, cave, and cave-like habitat is not expected to change under any alternative 

because management activities would not substantially affect cliff, cave, or cave-like structures. 

Structures such as adits or buildings that support some cave-associated species could be altered 

by project-level decisions but this potential action would not differ by alternative and is beyond 

the scope of this programmatic analysis. The following species are supported by cave, cave-like, 

or cliff habitat:

• Pseudoscorpions are strongly associated with caves

• Although for the final environmental impact statement no bat species met the criteria to be 

identified as species of conservation concern, public comments supported retaining plan 

guidance for bats given their unique habitat requirements and sensitivity to diseases.

Under the current forest plan there are no specific plan components to address caves, cave-like, 

and cliff habitats. Projects that effect sensitive species are evaluated and mitigations incorporated 

when needed. Although there is no specific plan direction, many caves and abandoned mines have 

been gated or closed to the public through project-level decisions to provide for public safety or 

to prevent disturbance to wildlife.

Under alternatives B, B-modified, C, and D the forest plan recognizes the need to protect caves

through establishing direction for “Special Habitats,” which includes caves. A desired condition 

for special habitats recognizes the need to provide appropriate microclimates within caves and a 

standard ensures that maintenance and enhancement needs for special habitats are incorporated 

into project design and implementation. When restoration or action is needed in special habitats 

that contain at-risk species, the intent is to give them a management priority. 

In addition, to protect bats, alternatives B, C, and D protect bat hibernacula or maternity colonies 

by installing bat gates when there is adverse disturbance from recreation, management or other 

activities. Based upon public comments, alternative B-modified clarifies the plan guidance 

protecting bat hibernacula or maternity sites by considering either bat gates or restricting access 

by other means and adds plan guidance to work with state and federal agencies and other partners 

to provide education materials focused on awareness and prevention of spread of diseases like 

white-nose disease to caves on the forest. 

Vegetation management, prescribed fire, and managed wildfire are not anticipated to change the 

quantity of cave or cliff conditions in any alternative since these habitats are generally not 

vegetated. The quality of caves and cave-like structures for wildlife can be affected during 

vegetation management activities if nearby vegetation removal alters microclimate conditions 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

363

inside these habitats. Impacts could be either positive or negative depending upon how nearby 

vegetation affects microclimates, especially related to airflow or waterflow within caves or adits. 

Prolonged smoke exposure from prescribed fire and unmanaged and managed wildfire could have 

a short-term impact, particularly to adits and above ground cave-like structures which could 

disturb or displace wildlife. Reducing fuels through treatments and restoring fire regimes could 

also reduce smoke impacts to caves and cave-like structures from future wildfires, which would 

reduce impacts to wildlife. There would be more vegetation management under alternatives B, Bmodified and D than under the current condition in alternatives A and C. There would be more 

prescribed burning and wildfires managed to meet resource objectives under all plan revision 

alternatives. However, these site-specific activities would be evaluated at the project-level where 

measures to mitigate adverse impacts would be considered and incorporated into project design.

Aquatic Habitat (Meadows, Lakes and Ponds, Riparian Vegetation)

All alternatives would retain direction for riparian conservation areas that would protect aquatic 

habitat, including habitat that supports at-risk terrestrial wildlife species. All alternatives would 

continue to implement priority watershed restoration as funding permits. All alternatives would 

allow hand treatments in aquatic habitat. The following species are supported by aquatic habitat 

and/or specific aquatic habitat elements:

• Black toad is associated with springs and seeps.

• California golden trout is found in streams and rivers.

• Invertebrates (butterflies) are associated with meadows, and vegetation around lakes and 

ponds.

• Aquatic invertebrates such as the Western pearl shell, Owen’s Valley springsnail, and 

Wong’s springsnail are associated with riparian systems such as springs and seeps, or rivers 

and streams. 

• Willow flycatcher depends on dense willow thickets in large wet meadows.

• Greater sage-grouse in the bi-state distinct population segment depend on wet meadows 

and riparian areas as foraging habitat for young.

• Sierra marten use riparian stringers within mature forests.

• Bald eagles roost and nest near and forage in large waterbodies.

• Great gray owls forage in meadows.

Under alternative A, current forest plan direction would continue. The current plan generally 

limits disturbance and impacts within riparian conservation areas and critical aquatic refuges

through prescriptive direction, but does not prohibit activities. Because alternative A does not 

consider the change in temperature and precipitation related to climate change and other climate 

stressors to aquatic systems which may result in more conifer encroachment, invasive species, 

and wildfires, risks to the amount and condition of aquatic habitat are greatest relative to the other 

alternatives. 

Although managed wildfire is considered a tool and encourages the restoration of fire to the 

ecosystem using prescribed fire and allowing management of some wildfires when they can meet 

resource objectives as defined by the forest plan, under this alternative, the unnaturally dense 

conditions of riparian habitats and adjacent uplands can makes it challenging to meet the 

objectives, without prior vegetation treatments.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

364

The number of meadows and acres of riparian habitat maintained or improved is the least in 

alternative A. Since high elevation meadows and riparian areas (upper montane, subalpine, and 

alpine) are generally not prioritized for maintenance or improvement under any alternative, the 

focus on wildland-urban intermix treatments under alternative A makes it even more difficult to 

treat this vegetation zone. The habitat in these higher elevation areas are not as far outside of the 

natural range of variation, and therefore stressors that could be alleviated by vegetation treatment 

are not as crucial as those lower elevation habitats. Much of these high elevation zones are in 

designated wilderness or have limited access.

In alternative B, most of the riparian, meadow, and aquatic plan components are the same as in 

alternative A (see chapter 2). However, there are more specific ecological desired conditions and 

specific objectives to restore riparian and aquatic ecosystems.

Direction is modified in alternatives B and B-modified to allow prescribed burn ignitions and, 

where necessary, mechanical and hand treatments to restore ecological integrity and improve 

resilience of riparian ecosystems to fire, drought, and climate change. Riparian and meadow 

vegetation restoration under this alternative would be for the purpose of moving vegetation 

toward the desired conditions and would be intended primarily to restore native species 

composition, heterogeneity, resilience, and reduce the ingrowth of conifers where appropriate. 

Alternative B proposes to add one critical aquatic refuge relative to alternatives A and D. This 

additional refuge was created to protect the black toad on the east side of the White Mountains. 

This additional critical aquatic refuge will provide slightly greater protection of riparian habitat 

within that area.

The management approach under alternative B proposes to maintain, enhance, or improve more 

acres of riparian habitat and more meadows than alternative A and with a greater variety of 

restoration tools (mechanical thinning, prescribed fire, and wildfire managed to meet resource 

objectives). Alternative B is expected to have about the same acreage of riparian and meadow 

habitat as alternative B-modified, but the addition of conservation watersheds should help restore 

larger landscape areas. This larger watershed approach should allow for greater indirect 

improvement in riparian habitat than the other alternatives, because it would improve watershed 

processes and habitats for many species that may interact, rather than focus on one species. 

Prescribed fire and wildfire managed primarily for resource benefit would improve the condition, 

vigor and health of most native riparian plants that support forage and nesting habitat for a variety 

of species. Increased structural diversity of these habitats would favor use by a variety of species 

strongly associated with complex understory and overstory. Increased fire would result in 

increased sprouting, health, condition, and vigor of hardwood and understory plants, including 

host plants for a variety of invertebrates. The trend in composition and structural heterogeneity of

native species would increase.

Alternative B-modified is anticipated to improve habitat condition at the landscape scale. 

Riparian habitats would be treated where they are adjacent to upland habitat that is being restored. 

The synergistic benefit of restoring neighboring riparian and upland habitats can benefit species 

that use both habitat types to meet life history requirements. In addition, treating these features in 

the upland and riparian areas can reduce the ingrowth of conifers and invasive species in both 

these habitats. Further, conservation watersheds would focus on watersheds in need of some 

landscape scale restoration, and should improve a holistic ecosystem rather than habitat for a 

single species as is more the focus with critical aquatic refuges in the other alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

365

Alternatives B and B-modified would move the landscape from a low to a moderate resilience to 

large high-intensity wildfire (See the “Terrestrial Ecosystem Processes and Functions” section). 

Warming trends and drought conditions can cause a variety of stressors for many habitats, but 

particularly aquatic habitats. These habitats have suffered directly from drought and warming 

conditions but also indirectly by the ability of many invasive species to move into aquatic 

habitats, outcompeting native species for space, water, sunlight, and nutrients that support many 

terrestrial wildlife species. 

Although treatments are expected to have a variety of long-term benefits, there is potential for 

short-term effects during and immediately following project implementation. In general, 

manipulating more habitat under this alternative as opposed to alternative A would translate into 

more potential for disturbance to individuals and temporary disturbance to habitat condition from 

the use of equipment and fire, until the habitat recovers. Overall, over the long term, these 

restoration actions are anticipated to provide more productive site conditions, which would result 

in improved habitat conditions.

Alternatives B and B-modified include an increased emphasis on partnerships and stewardship 

funding to accomplish meadow restoration. In the montane zone, much of the aquatic habitat is 

threatened by large fires with high-severity effects, overcrowding by conifers, homogeneity of 

vegetation structure and composition, and the continued spread of invasive species. These areas 

would experience more treatments than other zones, although treatment intensity would be 

relatively light. In the upper elevations like upper montane, subalpine, and alpine zones, 

treatments of upland habitat are not prioritized and therefore aquatic habitat would receive fewer 

treatments. 

Alternative C proposes to designate 8 additional critical aquatic refuges on the Inyo National 

Forest. Therefore, there would be more emphasis on protection of aquatic habitat in these 

designated areas than the other alternatives. These additional critical aquatic refuges would not 

provide a landscape scale restoration emphasis, but would emphasis one species each. This may 

not provide as much habitat resilience for riparian habitat as alternative B-modified, which 

designates conservation watersheds and eliminates critical aquatic refuges.

However, the use of prescribed fire under alternative C to reduce stand density and create more 

open, safe burning conditions would be constrained because of the species-specific protections 

and inability to prepare the landscape with mechanical treatments first. This alternative does not 

treat at the landscape scale, which would make patches more vulnerable to a variety of stressors 

adjacent to this habitat as well as upstream and downstream of this habitat, including loss of 

habitat elements from wildfire, ingrowth of conifers in adjacent upland units, and spread of 

invasive species. Because this alternative has a lower ability than alternative B to move the 

landscape toward resilience to climate change and large high-intensity wildfire, aquatic habitat 

under this alternative would be at a greater risk to degradation from unabated stressors and largescale disturbances. The long-term effects may be more negative if fire destroys vegetation that 

supports specialized species (like butterflies), and the availability of nest trees and shrubs. Fewer 

landscape treatments may require more suppression of wildfires, which could allow conifers to 

grow into meadows.

Alternative C includes the same increased emphasis on partnerships as alternatives B and D. 

However, there may be fewer opportunities for stewardship funding under this alternative due to 

the fewer acres of upland vegetation to be treated. Funding of meadow maintenance, 

enhancement, or improvement may be a substantial constraint under this alternative.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

366

Although there is less potential for short term, implementation-related impacts under this 

alternative, the long-term negative impacts on habitat conditions because of the treatment 

limitations and lack of a landscape scale approach under this alternative could be greater than 

under the other alternatives.

By increasing the amount of ecological restoration overall under this alternative, more 

opportunities exist for implementing watershed restoration projects than any other alternative. 

Alternative D would maintain, enhance or improve the same number of meadows as alternatives 

A, B, and B-modified and about half of the meadows as alternative C, move the landscape to a 

greater resiliency to climate change, and more rapidly achieve improvements to structure, 

composition, and heterogeneity than any other alternative.

Similar to the other plan revision alternatives, alternative D also includes an increased emphasis 

on partnerships. Therefore, this alternative (followed by B-modified) should have the most 

funding to improve aquatic habitat condition and at a landscape scale.

The tradeoff of increased pace and scale of restoration, including the use of mechanical 

equipment, is the potential for more short-term impacts than any other alternative. For example, 

alternative D has the greatest potential to spread invasive species as a result of more acres treated. 

As with all alternatives, the potential short-term impacts of treatment proposed under this 

alternative would be evaluated on a project-specific basis as projects are developed.

Sierra Nevada Bighorn Sheep (Endangered Species)

Consequences Common to All Alternatives

Livestock grazing management would not vary by alternative, and therefore effects to Sierra 

Nevada bighorn sheep from livestock grazing would remain very minor under all alternatives. 

Although there is no goat grazing within authorized livestock grazing allotments, recreational 

pack goat use is currently allowed but actual use is believed to be very low. Although pack goats 

could potentially transmit disease to sheep because they can carry some of the same diseases,

there are no records of pack goat contact with bighorn sheep. Prescribed fires are not likely to 

occur within wilderness areas, where most of the critical habitat occurs but could occur in 

portions of the winter range outside of designated wilderness areas. The Sierra Nevada bighorn 

sheep 5-Year Review (United States Department of the Interior 2008b) identified a concern for 

degraded vegetation condition in the winter range due in part to a history of fire suppression. It is 

thought that reductions in winter range habitat quality, possibly amplified by other factors like 

mountain lion predation, may limit population growth and increase mortality for Sierra Nevada 

bighorn sheep. This may be especially true in harsher winters when bighorn sheep remain in high 

elevation ranges instead of migrating to lower elevation winter range. To date, although limited 

prescribed burning to improve conditions within bighorn sheep winter range has occurred, a list 

of specific areas for prescribed burning or restoring fire to benefit bighorn sheep has not been 

identified by the Forest Service, U.S. Fish and Wildlife Service, or California Department of Fish 

and Wildlife.

The California Department of Fish and Wildlife conducts actions to help restore the Sierra 

Nevada bighorn sheep population throughout its range, guided by the 2007 Recovery Plan. They 

are expected to continue to conduct population surveys, evaluate and monitor mortality in bighorn 

sheep, and evaluate and implement translocation efforts as determined necessary to meet recovery 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

367

plan distribution and population criteria. It is expected they will also continue to evaluate and 

oversee the management of mountain lions that are affecting species recovery.

Consequences Specific to Alternative A

Alternative A includes direction for bighorn sheep that applies to Sierra Nevada bighorn sheep but 

does not clearly separate the direction into distinct plan components. The direction applies to both 

the Sierra Nevada bighorn sheep and to Nelson desert bighorn sheep. Direction exists in the 

existing plan to limit disease transmission from domestic livestock and to maintain and expand 

bighorn sheep occupancy where feasible. Direction also exists in designated wilderness areas and 

mountain sheep habitat to reduce conflicts with recreation trails and other management activities 

such as locations of roads, helispots, hang gliding, and minerals operations. Most of this direction 

is functionally similar to the plan direction of the other alternatives.

The current forest plan only defines fire management zones around communities. No specific 

forest plan direction exists to guide fire management in the critical habitat which is primarily 

located in designated wilderness and remote alpine and subalpine habitats away from 

communities. Within designated wilderness the use of mechanized transport and motorized 

equipment is generally prohibited with exceptions. When fires occur within or near critical 

habitats or occupied habitats, fire management decisions are guided by agency policies and 

procedures where naturally ignited wildfires are considered for management to meet resource 

objectives on a case-by-case basis. Since forest plan resource objectives for wildfire management 

are only general in nature, many wildfires continue to be suppressed, slowing the restoration of 

fire as an ecosystem function to forest landscapes. There could be more immediate disturbance by 

firefighting actions under this alternative when fire management is focused on suppression. 

Continuing to suppress wildfires also allows vegetation to continue to become denser which 

increases predator hiding cover and lowers habitat use by bighorn sheep or could contribute to 

higher rates of predation by mountain lions.

There is a concern for disease spread from domestic goats to bighorn sheep. Although there are 

no livestock grazing allotments that permit domestic goats, there is currently a limited amount of 

recreational pack goat use that occurs. Since recreational pack goats are typically under close 

control of their handlers, the risk of contact with bighorn sheep is likely to be low. Alternative A 

does not have specific plan direction to address this but the forest would typically coordinate and 

cooperate with the U.S. Fish and Wildlife Service or California Department of Fish and Game to 

address known site-specific problems if they were identified.

Consequences Specific to Alternatives B, B-modified, C, and D

As Sierra Nevada bighorn sheep recover, the alternatives express the intent to manage population 

expansion areas occupied by bighorn sheep outside of current herd units in order to improve 

population distribution. The alternatives clarify the desired condition for bighorn sheep habitat to

better describe the different seasonal habitat needs and need to provide for movement between the 

herds. This contributes to a recovery plan task to maintain and enhance integrity of bighorn sheep 

habitat (USDI Fish and Wildlife Service 2007).

Wildfires will continue to burn across the national forest and they will continue to be actively 

managed using a range of fire management responses in all alternatives. Since these alternatives 

more clearly define resource objectives for wildfire management, it is expected that more 

naturally ignited wildfires would be managed to restore fire to the landscape instead of being 

immediately suppressed. This is particularly expected in designated wilderness and remote areas, 

which includes most of the critical habitats for this species. Over time, if more wildfires are 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

368

managed to restore the patchy distribution of fires, it’s expected that the opportunities to manage 

more wildfires will increase as new fire ignitions have areas with lower fuels surrounding them. 

To the extent this occurs, the magnitude and intensity of firefighters needed to manage these fires 

may decrease, which would lower the exposure to disturbance. Restoring a patchy distribution of 

fires would also help restore more open vegetation conditions which would decrease predator 

hiding cover and could improve habitat use by bighorn sheep.

Under the current plan and direction from the Sierra Nevada Bighorn Sheep Recovery Plan, the 

risk of disease contact from domestic sheep and goats has been minimized. However, these

alternatives strengthen that effort by also including direction that would increase the awareness of 

the risk of disease spread and importance of notifying officials when trespass livestock are 

discovered within the Sierra Nevada bighorn sheep range. The alternatives include an emphasis

on cooperating with partners and private landowners to encourage resource protection across 

ownership boundaries and guidance to help ensure state and federal agencies are aware of the 

procedures to report trespass livestock to the Inyo. A desired condition supports continuing to 

develop and distribute appropriate educational material to local residents and visitors about Sierra 

Nevada bighorn sheep and the actions needed to protect them which supports a recovery plan task 

(USDI Fish and Wildlife Service 2007) related to public education.

Compared to alternative A, all plan revision alternatives strengthen the cooperative relationship with 

the California Department of Fish and Wildlife to manage Sierra Nevada bighorn sheep populations 

by containing a goal to work with State agencies to restore and maintain essential habitat for at-risk 

species and implement other recovery actions according to species recovery plans. This would 

facilitate cooperation and support if those activities occur on National Forest System lands to 

support the desired condition that activities are designed to maintain or enhance self-sustaining 

populations of at-risk species within the inherent capabilities of the plan area by considering the 

relationship of threats (including site-specific threats) and activities to species survival and 

reproduction. Supporting these activities will contribute to a recovery plan task to temporarily 

protect Sierra Nevada bighorn sheep herds from predation losses where needed and could support 

a recovery plan task to reduce influences of predation on winter habitat selection, if the California 

Department of Fish and Wildlife determines this action is necessary.

Consequences Specific to Alternative B

Alternative B includes species specific plan direction and plan content for bighorn sheep that 

describe bighorn sheep habitat, provide guidance to reduce the risk of disease transmission from 

domestic sheep and goats, and provide guidance to manage disturbance from recreation.

The majority of the Sierra Nevada bighorn sheep habitat and critical habitat is located in the 

Wildfire Maintenance Zone and Wildfire Restoration Zone. Within these two strategic fire 

management zones, fires from natural sources such as lightning, would be evaluated to determine 

if they could be managed with less than a full fire suppression response, considering safety to 

firefighters and the public and potential positive and negative effects from expected fire behavior 

to various resources. Fires in the bighorn sheep range are expected to occur infrequently, and are 

expected to mostly be small in size with mixed severity fire effects given the sparse fuel 

conditions. Fire intensity is also expected to be highly variable in the subalpine zone with large 

higher severity fire patches usually limited in size to the matrix of clumpy forest and forested 

meadows. Fire management may have short-term effects but are expected to have minimal long-term 

adverse effects on suitable habitat considering the rugged rocky terrain favored by bighorn sheep. In 

the wildfire maintenance zone, the alternative encourages restoring fire to the landscape by 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

369

requiring documentation when naturally ignited wildfires are promptly suppressed. Within 

designated wilderness the alternative includes direction to use minimum impact strategies and 

tactics unless more direct action is needed for safety and to protect property. The intent is to use 

spatial support tools, wildfire risk assessments, and decision support systems to determine the 

appropriate wildfire management strategy. Since the location of designated critical habitat is 

included in these decision-support systems, the risk of adverse impacts to Sierra Nevada bighorn 

sheep and critical habitat from wildfire and fire management actions would be lessened. Effects 

of use of managed wildland fire may have some ephemeral adverse effects, but the desired 

condition is to restore fire as a natural ecosystem process for the long-term benefit of this species 

and would be designed to protect or restore vegetation structure and composition that would 

sustain or improve the ecological conditions needed by the species within critical habitat and 

improve the condition of forage and cover outside of critical habitats. Overall increasing the 

amount of fire within the bighorn sheep range would generally be beneficial where it restores 

more open conditions and increases visibility and reduces hiding cover for predators.

Implementing these fire management approaches is expected to increase the likelihood of restoring fire 

to areas occupied by Sierra Nevada bighorn sheep which will contribute to a recovery plan task to 

maintain or enhance the integrity of bighorn sheep habitat.

Although specific areas for prescribed burning within the winter range have not been identified, a 

goal in this alternative is to work with State and Federal wildlife agencies to identify such areas. 

There could be some disturbance to individual animals from prescribed fire management 

activities, but any adverse effects from those activities would be evaluated and mitigated during 

project-level decisionmaking that would require compliance with section 7 of the Endangered 

Species Act. Increasing the amount of wildfires managed to meet resource objectives and 

prescribed burning in the winter range would have short-term effects to forage but would be 

expected to have longer term benefits and would contribute to a recovery plan task to enhance 

bighorn sheep winter range habitat to increase visibility where appropriate.

Alternative B contains similar plan direction to manage the risk of disease transmission from 

domestic sheep and goats and consequences would be similar to alternative A.

Consequences Specific to Alternative B-modified

As a result of considering public comments, further clarifications were made to plan direction, 

particularly clarifying the desired condition for habitat, more clearly addressing the risk of disease 

transmission from domestic sheep and goats, and better addressing the potential for disturbance 

from recreation activities.

Although the risk of contact between domestic livestock and bighorn sheep has already been 

minimized within the areas identified as high risk, the plan direction from alternative B was 

clarified to support continuing to manage to minimize the risk of contact if conditions change and 

direction specifically identifies the use of risk assessment methods in evaluating where changes 

may need to be considered. A desired condition for bighorn sheep habitat addresses this by 

describing that the risk of disease transmission is reduced to the maximum extent possible. This 

recognizes that the extent is dependent upon the reliability of risk assessment modeling and 

therefore risk cannot be completely eliminated. Plan direction also directs that domestic sheep or 

goat grazing and pack goat use is not allowed in areas where there is a high risk of contact unless 

the risks of disease spread can be adequately mitigated. This plan direction would guide 

determining if there was a need to site-specifically evaluate and possibly adjust livestock grazing 

in specific areas if the risk of contact changes over the life of the forest plan.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

370

In response to public comments, about the risk of disease spread and pack goat use, alternative Bmodified includes the intent to coordinate with the California Department of Fish and Wildlife 

and the U.S. Fish and Wildlife Service to conduct a risk assessment of pack goat use and develop 

mitigations strategies to manage the risk of disease transmission, if needed. If upon completion of 

the risk assessment, risk mitigation actions are needed, plan direction would require that pack 

goat use not be allowed unless the risks can be mitigated in any areas having high risk of disease 

transmission. This more clearly contributes to a recovery plan task to prevent contact between 

bighorn sheep and domestic sheep or goats.

Although not currently known to be a substantial concern, alternative B-modified includes 

specific direction to evaluate areas and take action when needed where recreation or other 

disturbance is causing Sierra Nevada bighorn sheep to avoid important habitat areas. This more 

clearly contributes towards a recovery plan task to investigate and analyze human use patterns 

relative to habitat use patterns of bighorn sheep and another recovery plan task to manage human 

use locally where research finds human use is causing bighorn sheep to avoid important habitat,

which may compromise survivorship or reproductive success. Although the other alternatives do 

not specifically address this concern, the consequences are likely not substantially different since 

alternatives A, B, C, and D also include direction to contribute to the recovery of federally listed 

species and would likely address the concern in a similar manner.

The consequences of wildfire management and prescribed burning would be similar to those 

described for alternative B. In alternative B-modified, lower elevation portions of the herd units 

in the southern recovery unit that contain sagebrush are classified as the general wildfire 

protection zone instead of the wildfire restoration zone to recognize the sensitivity of sagebrush 

ecosystems to wildfire. This change would not likely result in a substantial difference in how fires 

are managed compared to other alternatives because the potential for not meeting resource 

objectives in sagebrush ecosystems would tend to guide fire management decisions toward fire 

suppression regardless of the strategic fire management zone classification.

Consequences Specific to Alternative C

The management direction for bighorn sheep and consequences of alternative C would be similar 

to those described for alternative B-modified regarding the risk of disease spread between Sierra 

Nevada bighorn sheep and domestic sheep and goats and the management of recreation impacts. 

Alternative C would have similar emphasis on managing wildfires to meet resource objectives in 

the wildfire maintenance zone as alternative B-modified, which includes much of the critical 

habitat in the alpine and subalpine zone. Management within the portions of the general wildfire 

zone that overlap with critical habitats would also be managed similarly to alternative B-modified

because most of this area is in designated wilderness or in inventoried roadless areas where onthe-ground management is limited by requirements for those management areas and wouldn’t 

vary substantially by alternative. Alternative C has an emphasis on prescribed burning so there 

would be more opportunity to restore fire to the portions of the lower elevation winter range 

compared to alternatives A, B, and B-modified and similar opportunity compared to alternative D. 

Prescribed burning in the winter range would improve forage conditions and reduce vegetation 

density to increase openness and visibility to decrease predation risk. To the extent that Sierra 

Nevada bighorn sheep begin to reuse winter range, it could reduce winter mortality in harsh 

winters compared to individuals that remain in the higher elevation portions of the range, 

although it is thought that mountain lion predation was a cause of the range shift in the past 

(Wehausen 1996).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

371

Consequences Specific to Alternative D

The consequences of alternative D overall would be similar to those described for alternative Bmodified as the management of disease risk, management of recreation conflicts, and the strategic 

wildfire management zones and direction within them would be the same. Under alternative D,

there would be more emphasis on increasing the amount of vegetation restoration and prescribed 

burning, which could result in slightly more opportunity to restore fire to the portions of the lower 

elevation winter range compared to alternatives A, B, and B-modified and may be similar in 

opportunity to alternative C. The benefits and consequences of restoring fire to the winter range 

would be similar to alternative C.

Nelson Desert Bighorn Sheep

Effects of all alternatives to Nelson bighorn sheep will be similar to Sierra Nevada bighorn sheep

as it relates to managing for the outbreak or continuation of disease contact or spread. Contact 

with disease or spread of it from infected domestic animals such as goats or sheep may occur off 

or on the national forest. The Inyo National Forest is not responsible for disease spread 

management outside the national forest. The risks of disease from recreational pack animals such 

as goats on the Inyo are very low due to very low probability of direct contact between both. The 

Inyo National Forest limits this threat by restricting goat and sheep use in areas of the White 

Mountains on national forest lands that overlap with bighorn sheep. This is accomplished through 

the permitting process. 

Alternative A includes direction for bighorn sheep that applies to Sierra Nevada bighorn sheep but 

does not clearly separate the direction into distinct plan components. The effects are similar to 

those for Sierra Nevada bighorn sheep. See “Consequences Specific to Alternative A” for Sierra 

Nevada bighorn sheep. 

Although the current plan designates three fire management zones on the Inyo National Forest, 

two of these are focused on wildland-urban intermix, and the third zone identifies the remainder 

of the national forest. This area encompasses other land allocations but home range core areas, 

old forest emphasis areas, general forest, and wilderness allocations predominate. Fuel treatments 

in the general forest areas, are designed to support fuel treatments in the Wildland-urban Intermix 

Threat Zone, to protect sensitive habitats, and re-introduce fire to fire-dependent ecosystems.

There is little direct management of subalpine and alpine vegetation in alternative A. Most of this 

vegetation is in wilderness areas, where natural processes are the dominate management

approach.

Habitats for at-risk species support self-sustaining populations within the inherent capabilities of 

the plan area. Ecological conditions provide habitat conditions that: contribute to the survival, 

recovery, and delisting of species under the Endangered Species Act; preclude the need for listing 

new species; improve conditions for species of conservation concern, including addressing threats 

(minimal impacts from diseases); and sustain both common and uncommon native species.

Consequences common to alternatives B, B-modified, C, and D are similar to each other in that 

they provide for opportunities for more overall restoration acres than alternative A. Restoration in 

the alpine zones habitat types would benefit this species to reduce the effects of climate change 

and predation. The difference in acres within the wildfire maintenance zone is approximately 

30,000 acres between any one of them. However, benefits to bighorn sheep will primarily result 

from natural fires managed for resource objectives that maintain alpine habitat including 

meadows, and reduce the spread of tree and shrub cover.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

372

Effects from alternative B are similar as described above in “Consequences Specific to 

Alternatives B, B-modified, C, and D” for Nelson’s bighorn sheep. Alternatives B and Bmodified are similar with the modified version clarifying direction related to disease risk from 

domestic livestock to continue to use a risk assessment approach, added direction to evaluate 

recreation impacts where potential conflicts to Sierra Nevada bighorn sheep are identified. 

In both alternatives B and B-modified the proposed wilderness additions of approximately 37,029 

acres would have no benefits to this species. The areas proposed for addition are not suitable for 

this species. Although management approach for sustainable recreation and designated areas vary 

between alternatives, all plan revision alternatives will adopt a framework for future management 

actions with regards to recreation management and resource protection.

Although consequences of alternatives B and B-modified identify new wildfire management 

zones, this species occurs primarily at the high elevations that overlaps with the proposed wildfire 

maintenance zone. This zone include the wilderness areas, where mechanical treatments are not 

allowed. However, wildfires that meet resource objectives occurring in this zone could be very 

beneficial to this species by reducing the amount of tree and shrub cover that otherwise could be 

used by predators.

Pacific Fisher

Pacific fisher have been detected (from systematic sample units) on the Inyo National Forest on a 

small forested portion of the Kern Plateau. However, detections are relatively few, and it is not 

likely that an independent viable population exists within the national forest boundary. Forests 

containing old forest characteristics (dense vegetation and canopy cover, snags, cavities, larger 

trees, and large down woody debris) in coniferous and mixed pine-oak forests provide the 

ecological conditions believed to be important to support the persistence of the species.

Alternative A provides plan direction for minimizing disturbance and activities near den sites for 

forest carnivores, which include fisher. However, it is difficult to identify den sites because the 

species is secretive and uses multiple den sites within a breeding season. Additional direction for 

the southern Sierra fisher conservation area does not apply to the Inyo National Forest since this 

area is mapped to stop at the national forest boundary.

Plan direction for fisher is improved under all of the plan revision alternatives as compared to 

alternative A by providing plan direction to manage identified habitat within fisher Core 1 and 

plan direction that will guide projects to conserve key habitat characteristics such as multi-storied 

canopies, understory vegetation, and woody debris, during the planning and implementation of 

projects. Under alternatives B and B-modified, none of the recommended wilderness additions 

are within the Sierra Nevada montane zone that might provide habitat for this species. Under 

alternative C, only the Golden Trout and a small portion of the South Sierra Wilderness East 2 

additions are within the Sierra Nevada montane zone that might benefit this species by limiting 

future development. Within recommended wilderness areas, options for managing habitat using 

mechanized equipment or other techniques that would not maintain wilderness character would 

not be allowed. Since most of the areas recommended for wilderness are currently managed as 

inventoried roadless areas or have limited access, there may be little difference in habitat 

restoration opportunity for this species between the alternatives, although restoration where it 

could occur might be more limited in alternative C that has a preference to using prescribed fire 

instead of mechanical treatments to manage vegetation and fuels.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

373

Since most of the habitat for Pacific fisher is within wilderness areas, inventoried roadless areas, 

and remote areas, habitats will be most influenced by how wildfires are managed over time. As 

described in the general consequences above, management of wildfires to meet resource 

objectives would be clearer under the plan revision alternatives compared to alternative A because 

it uses a risk-based approach and includes desired conditions and other plan direction to 

encourage restoring fire to the landscape when safe to do so. The extent that wildfires can be 

restored within the Sierra Nevada montane zone would increase resilience of fisher habitat.

Although management approaches for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

Sierra Marten

Alternative A provides plan direction for minimizing disturbance and activities near den sites for 

forest carnivores, which include marten. However, it is difficult to identify den sites because the 

species is secretive and uses multiple den sites within a breeding season. Plan direction for marten 

is improved under all of the plan revision alternatives as compared to alternative A by providing

plan direction to manage identified marten core habitat and plan direction that will guide projects 

to conserve key habitat characteristics such as multi-storied canopies, understory vegetation, and 

woody debris, during the planning and implementation of projects. 

Under alternatives B and B-modified none of the recommended wilderness additions are within

the Sierra Nevada montane zone that might provide habitat for this species. Under alternative C

only the Ansel Adams, Golden Trout, and South Sierra Wilderness East 2 additions are within the 

Sierra Nevada montane zone that might benefit this species by limiting future development. 

Within recommended wilderness areas, options for managing habitat using mechanized 

equipment or other techniques that would not maintain wilderness character would not be 

allowed. Since most of the areas recommended for wilderness are currently managed as 

inventoried roadless areas or have limited access, there may be little difference in habitat 

restoration opportunity for this species between the alternatives, although restoration where it 

could occur might be more limited in alternative C that has a preference to using prescribed fire 

instead of mechanical treatments to manage vegetation and fuels.

Since most of the habitat for Sierra marten is within wilderness areas, inventoried roadless areas, 

and remote areas, habitats will be most influenced by how wildfires are managed over time. As 

described in the general consequences above, management of wildfires to meet resource 

objectives would be clearer under the plan revision alternatives compared to alternative A because 

it uses a risk-based approach and includes desired conditions and other plan direction to 

encourage restoring fire to the landscape when safe to do so. The extent that wildfires can be 

restored within the Sierra Nevada montane zone would increase resilience of Sierra marten 

habitat.

Although management approaches for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

Bald Eagle

Bald eagle potential nesting habitat on the Inyo National Forest is somewhat limited. 

Nevertheless, when comparing the habitat within the ecological zones important for bald eagle
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

374

survival and persistence among alternatives, alternative B, B-modified, C, and D provide plan 

direction for desired conditions, standards, objectives, and guidelines for conserving key habitat 

characteristics during the planning and implementation of projects on the ground. Alternative A 

also provides plan direction for minimizing impacts to bald eagle. Plan direction for bald eagle is 

improved under all of the plan revision alternatives over alternative A. Alternative B-modified is 

fundamentally alternative B with modifications which include replacing critical aquatic refuges 

with conservation watersheds. This modification provides for the long-term maintenance and 

restoration of functioning watersheds providing habitat for the persistence of species of 

conservation concern. However, alternatives A, B, C, and D propose critical aquatic refuges and 

not the conservation watershed approach that alternative B-modified does. 

Alternatives B and B-modified are similar regarding the addition of proposed designated 

wilderness in that both propose the same amount (37,029 acres) and locations of the areas, 

compared to alternative C, which is proposing approximately 315,531 acres. Proposed new 

wilderness areas consisting of eagle habitat in proximity to larger lakes and rivers within the 

Sierra Nevada montane ecological zone would benefit this species if the habitat (primarily mixed 

conifer and Jeffrey pine forests of the Sierra Nevada montane zone) can be maintained and/or 

restored over time. Once designated wilderness, options for managing habitat using equipment or 

other techniques not meeting wilderness objectives may be problematic for management of this 

species within these areas. Alternatives A and D do not propose new wilderness areas, and 

therefore, forest plan direction would continue as described in the first paragraph above for bald 

eagle.

Management of wildfires as addressed in the range of alternatives, would result in alternative B, 

B-modified, C, and D benefiting bald eagle the most as compared to alternative A. Though 

options of mechanized equipment within wilderness is not likely for bald eagle habitat 

management purposes, managing wildfires for resource objectives will provide for benefits to this 

species. However, alternative C is limited in the use of mechanical treatments towards smalldiameter trees (outside wilderness). Furthermore, as described above related to the comparisons 

of wilderness additions, although the most acres proposed for new wilderness is within alternative 

C, and although managing wildfires for resources objectives is supportive under this alternative, 

the option of treating small-diameter trees in wilderness will not be an option. 

When comparing the alternatives as it relates to recreation, which is perhaps the biggest 

immediate risk factor affecting bald eagle on the Inyo National Forest, alternative B-modified is 

the most beneficial as a result of proposing an adaptive and integrated approach to designing and 

managing recreation infrastructure and managing visitor use and demands. Alternative A provides 

for the least of amount of recreation management that addresses bald eagle impacts, while 

alternatives B, C, and D are similar to each other in this regard. When comparing the range of 

alternatives on how they address threats of persistence to bald eagle as described above, and when 

looking at other important specific factors such as the loss of mature old forests from fire and 

disease and insects, climate change impacts, riparian areas, and water quality and quantity, 

alternative B-modified provides for the greatest opportunities as it relates to maintenance and 

restoration of principle bald eagle habitat and protection from human disturbance. Although 

management approach for sustainable recreation and designated areas vary between alternatives, 

all plan revision alternatives will adopt a framework for future management actions with regards 

to recreation management and resource protection.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

375

Bi-state Greater Sage-grouse 

All alternatives recognize the need to improve sage-grouse habitats by managing encroaching 

conifers and managing areas with invasive cheatgrass and their potential spread. Alternative A 

continues to implement restoration in the Bi-State Action Plan (Bi-State Technical Advisory 

Committee Nevada and California 2013) as funding allows, but it would result in the lowest 

restoration treatment rates of greater sage-grouse habitat than any of the other alternatives and 

therefore would take the longest to achieve desired conditions across many landscapes within the 

eastside shrublands and woodlands ecosystem type (sagebrush habitat). All plan revision 

alternatives incorporate some elements of the Bi-State Action Plan (Bi-State Technical Advisory 

Committee Nevada and California 2013) as species-specific desired conditions and plan 

components, which will better guide project development to provide for the ecological conditions 

important to sage-grouse than in alternative A. 

The plan revision alternatives include plan direction that limits disturbance at leks, reduces the 

risk of predation (ensures tall structures near lek habitat are absent or retro-fitted with perch 

deterring devices), and includes direction to manage livestock grazing activities that could impact 

sage-grouse. Alternatives B and B-modified establish plan objectives that propose moving a 

greater amount of sagebrush shrublands towards the desired condition and include a more 

landscape type of approach so restoration has greater long term benefits to sage-grouse habitat. 

Alternative C and alternative D both include plan objectives that propose moving more sagebrush 

habitat towards the desired condition, especially in sage-grouse habitat. However, alternative C 

would manage some portions of sagebrush habitats in the Glass Mountains area which is 

proposed as recommended wilderness. This would limit the types of sagebrush habitat restoration 

that could occur by limiting but not prohibiting mechanized methods and could result in habitat in 

that area remaining departed from desired conditions. To allow more opportunities for sagebrush 

habitat restoration, these areas were not included as recommended wilderness areas in alternatives 

B and B-modified.

Although management approach for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives would adopt a framework for future management 

actions with regards to recreation management and resource protection.

The plan revision alternatives also recognize the risk of nonnative invasive plants, such as 

cheatgrass invasion, that could occur with ground disturbing restoration actions and provides plan 

direction to minimize the risk of spread and to prioritize invasive species treatments where 

containment or eradication is possible. While many actions currently occur to manage invasive 

species that affect sage-grouse under alternative A, the focused plan direction (plan revision 

alternatives) is expected to result in more active treatment and a greater benefit to sage-grouse 

habitats.

The use of managed wildfires to meet resource objectives is similar between the plan revision 

alternatives. Strategic fire management zones are identified based upon the risks and benefits to 

highly valued resources and assets expected from future wildfires. In alternative B, much of the 

sagebrush habitats that are not in proximity to communities or assets are identified as the wildfire 

restoration zone, where some wildfires would be expected to be managed to meet resource 

objectives. However, given the sensitivity of sage-grouse habitats to degraded conditions from 

wildfire and due to the risk of cheatgrass invasion following wildfire, most fire management 

actions in sagebrush tends towards taking fire suppression actions. Alternatives B-modified and D 

reassign areas of low elevation sagebrush to the general wildfire protection zone rather than the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

376

wildfire restoration zone in order to recognize that fire suppression to protect sagebrush habitat 

from negative fire effects is the more likely expected outcome. Alternative C uses a different 

strategic fire management zone approach and most of the sagebrush habitats are in the general 

wildfire zone where the risks and benefits to resources are mixed and fire management decisions 

would be variable depending upon local conditions but overall, opportunities to restore fire to the 

landscape would be favored. Despite the differences in strategic fire management zones between 

alternatives, since fire management decisions are made site-specifically at the time that wildfires 

occur and consider local risks and benefits, it’s likely that little difference would exist between 

alternatives and most wildfires that are determined to likely adversely affect sage-grouse habitats 

would tend towards taking fire suppression actions.

When comparing the range of alternatives on how they address the threats of persistence to 

greater sage-grouse as described above, and when considering other important specific factors 

such as the expansion and encroachment of pinyon-juniper and conifers, invasive species, 

livestock grazing, riparian areas, climate change, and habitat fragmentation alternatives Bmodified and D would provide the greatest benefit by encouraging habitat restoration on

substantially more acres than under alternative A and having clearer direction to guide fire 

management decisions to provide the desired ecological condition in sagebrush habitats. 

Alternative C would restore more habitat than alterative B but some limitations would occur in 

the sage-grouse habitat that would be managed as recommended wilderness.

California Spotted Owl

California spotted owl have been detected (from surveys) on the Inyo National Forest on the west

side of the national forest, in wilderness, and the far south end of the Inyo. However, detections 

are relatively few, and it is unknown if a viable population exists on the national forest. Stands

containing old forest characteristics (dense vegetation and canopy cover, snags, cavities, larger 

trees and large down woody debris) in coniferous and mixed pine-oak forests provide the 

ecological conditions believed to be important to support the persistence of the California spotted 

owl. On the Inyo, these ecological conditions can be found in limited quantities in the Sierra 

Nevada montane ecological zones that consist of dry mixed conifer, red fir, Jeffrey pine, and 

lodgepole pine.

California spotted owl is a sensitive species and covered under the direction of the current forest 

plan components in alternative A. The current direction for this species is primarily designed for 

forest conditions and forest management activities typical of the west-side of the Sierra Nevada 

and require establishing 300-acre protected activity centers and 1,000 acre home range core areas 

around the best available habitat. Plan direction also guides projects to limit disturbance, maintain

moderate to dense canopy cover, and limit the extent of habitat change when designing fuels and 

vegetation projects in spotted owl habitat. Proposed projects that may impact this species are 

evaluated site-specifically in a biological evaluation and projects are designed to minimize 

adverse impacts. In the plan revision alternatives, the California spotted owl is managed as a 

species of conservation concern. In alternative C, direction for protected activity centers remains 

similar to alternative A, but direction for home range core areas is replaced with direction for a 

1,000-acre circular territory surrounding the activity center. Additional direction is provided to 

manage the larger home range for each territory. In alternatives B, B-modified and D, the 

direction for establishing and managing protected activity centers and spotted owl territories 

remains similar to alternative A but direction to manage for large home ranges is not included 

because of the limited extent of habitat in the plan area and because the habitats around the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

377

reported locations are somewhat atypical of the lower and mid-elevation west-side forests, which 

are the basis for most of the scientific studies and habitat descriptions.

Forest management has been identified as a continuing threat to spotted owl persistence in the 

Sierra Nevada (Gutierrez, Manley, and Stine 2016). Effects of vegetation treatments on 

persistence of spotted owl across its range are complex and not well understood. Treatments that: 

result in a reduction of canopy cover to less than 40 percent, remove surface and ladder fuels, and 

simplify vertical and horizontal stand structure with an increase in regularly spaced trees may 

have negative impacts on spotted owls (Tempel, Peery, and Gutierrez 2014; Stephens et al. 2014;

Tempel et al. 2014a). Studies on the west side of the Sierra Nevada have found the availability 

and amount of late seral forest (canopy cover greater than 70 percent and dominance of medium 

and large trees) were positively correlated with territory occupancy, survival, and population 

growth (Seamans and Gutierrez 2007; Tempel et al. 2014a). Habitat edge is considered beneficial 

to spotted owls, perhaps increasing prey populations and access to prey by foraging owls. Recent 

changes in silviculture prescriptions have been developed that are designed to retain the stand 

structure and heterogeneity predicted based on historic vegetative patterns and also selected for 

by spotted owls (Knapp et al. 2012). Effects of these prescriptions on spotted owl populations 

have not been studied in detail. 

Another threat to spotted owl persistence is habitat loss from high-severity fire. Spotted owls 

have been documented to use habitat that has burned at low to moderate burn severity that 

includes some proportion of high-severity fire (Roberts et al. 2011; Lee, Bond, and Siegel 2012;

Lee et al. 2013; Lee and Bond 2015). The amount of suitable habitat (green forest), the amount of 

suitable habitat that burned at high severity, and salvage logging likely affect continued 

occupancy by spotted owls (Gutierrez, Manley, and Stine 2016). High-severity fires that results in 

the loss of dense mature forest, large snags and downed logs effectively remove preferred nesting 

and roosting habitat and can take centuries to regrow. 

In the closely related northern spotted owl, while spotted owls did roost and forage within highseverity burn areas, the use was very low suggesting that this cover type was poor habitat for 

spotted owls (Clark, Anthony, and Andrews 2011). They found that annual survival rates were 

lower in northern spotted owls inhabiting burned areas or displaced by the wildfire as compared 

to owls that inhabited areas outside the burn perimeter (Clark, Anthony, and Andrews 2011). A 

radio telemetry study to examine California spotted owl use of habitat within multiple burn 

severities found that probability of use decreased with increasing severity, and also found that 

probability of use increased with low and high contrast patch edges compared to no edge (Eyes, 

Roberts, and Johnson 2017). This study suggests that a diversity of habitat types, including low 

and moderate severity fires, may be important foraging habitat for the species. While short-term 

benefits may be realized by spotted owls, such as increased prey and edge habitat, uncertainties 

remain regarding long-term occupancy and demographic performance of spotted owls at burned 

sites (Keane 2014). Specifically, uncertainty exists regarding how the amounts and patch sizes of 

high-severity fire will affect California spotted owl occupancy, demographics, and habitat over 

long time frames (Keane 2014). The results of simulation modeling research summarized in 

(Keane 2014) suggests that some fuels treatments can reduce fire risk and with minimal effects on 

owl reproduction, and may have long-term benefits of reducing wildfire risk that outweigh shortterm effects of treatments. 

There are limited opportunities to actively manage vegetation or fuels on the limited spotted owl 

habitats that occur on the Inyo National Forest due to the remote locations and generally limited 

access. If vegetation or fuels management projects are proposed, all alternatives include direction 

to limit treatment within protected activity centers with alternative C having the most restrictive 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

378

direction. Although all alternatives provide for a protected activity center, they have slightly 

different direction, but all are intended to ensure that key habitat characteristics are retained and 

that disturbance is minimized near breeding sites. Direction for delineating home range core areas 

(alternative A) or territories (plan revision alternatives) also differs; however, both are intended to 

achieve similar outcomes of providing additional ecological conditions to support breeding in an 

area adjacent to the protected activity center. Both of these are currently moot given that there are 

no known nesting or persistent roosting sites on the Inyo National Forest and vegetation and fuels 

projects are expected to be limited in potential spotted owl habitats.

Barred owls are an increasing risk factor for California spotted owls in the Sierra Nevada. Barred 

owls can hybridize and also out-compete spotted owls. Barred owls were first recorded within the 

range of the California spotted owl in 1989 on the Tahoe National Forest. Two sparred owls 

(hybrids of spotted and barred owls) were reported in the Eldorado National Forest during 2003 

to 2004 (Seamans, Corcoran, and Rex 2004). Barred owls were first recorded in the southern 

Sierra Nevada in 2004 (Steger, Werner, and Munton 2006). Ongoing research has documented 73 

records of barred or sparred owls in the Sierra Nevada to date, with the majority of records from 

the northern Sierra Nevada (Tahoe, Plumas, and Lassen National Forests). Of note, five new 

records of barred owls were documented in the Stanislaus and Sierra National Forests in 2012, 

indicating further range expansion of barred owls in the southern Sierra Nevada. In 2017, 

confirmed barred owls were on the Sequoia National Forest. Barred owl numbers are likely 

higher than documented in the Sierra Nevada, as there have been no systematic surveys for them 

to date. Climate change may have negative effects on spotted owls. Increasing temperatures may 

affect spotted owl survival, reproduction, recruitment, and population growth (Gutierrez, Manley, 

and Stine 2016). Although there are no known or suspected barred owls on the Inyo National 

Forest, the plan revision alternatives provide direction for invasive species that would consider 

management actions in coordination with the State of California and other agencies, if needed.

This would simplify coordination and developing and implementing or supporting plans of action 

compared to alternative A, which doesn’t have clarifying direction.

Although management approach for sustainable recreation and designated areas vary between

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

When assessing the risks (i.e. loss of habitat from high intensity wildfires, past timber harvests, 

geographical expansion of barred owl) to this species, and climate change, alternatives B, Bmodified, and D provide the largest amount of vegetation treatment and allow for the most 

flexibility on the use of tools, such as mechanical treatment, prescribed fire, or hand treatments. 

Alternative C proposes more use of prescribed fire over mechanical treatment. This approach 

would usually require some level of vegetation treatment prior to initiating prescribed burning. 

Weather conditions and other factors reduces the probability of treating areas as planned or as 

many acres. As a result, risks from large intensity fires are still a threat over a larger land area 

from alternative C.

Great Gray Owl

Great gray owl in other areas in the Sierra Nevada occupy meadows and early seral stage habitats 

adjacent to pine and fir forests between 3,500 feet and approximately 7,000 feet. Their presence 

on the Inyo National Forest is based on very few records and occurs at the extreme southeastern 

edge of their range. Because there are so few detections, it is difficult to know if they use 

different habitats on the Inyo National Forest compared to those typical of the west-side of the 

Sierra Nevada but their habitat is assumed to be within the Sierra Nevada montane zone in mixed 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

379

conifer stands consisting of red fir, Jeffrey pine, and lodgepole pine, and adjacent or close to 

meadows.

Under alternative A, the Inyo would continue to manage this species as a Pacific Southwest 

Region sensitive species and follow agency direction to minimize impacts from site-specific 

projects and conduct a biological evaluation. Alternatives B, B-modified, C, and D adopt the 

2012 Planning Rule requirement for the Forest Service to maintain or restore ecological 

sustainability, integrity, and diversity as the primary approach to provide for the persistence of 

species of conservation concern. All plan revision alternatives would identify riparian 

conservation area desired conditions and other plan direction that are designed to provide overall 

ecological integrity of meadow ecosystems, including habitat and ecological conditions to support 

all associated species. 

A recent study found a weak negative correlation between grazed meadows on Stanislaus 

National Forest allotments and vole abundance (Kalinowski, Johnson, and Rich 2014b). Although 

these findings indicate the need for further evaluation, there are a number of potentially 

confounding variables that influence these results, including the fact that some grazed meadows 

were surveyed before grazing for the season began, making it difficult to compare before and 

after or even grazed and ungrazed meadows. Under all alternatives, if a great gray owl nesting 

territory is discovered, plan direction would guide evaluating the impacts of activities on the 

territory. Under alternative A, plan direction would establish a protected activity center and limit

livestock grazing by establishing a residual stubble height to provide for prey species. The plan 

revision alternatives do not set a stubble height because meadow conditions can vary greatly on 

the national forest and they are different ecologically from those where nesting great gray owls 

are found on the west-side of the Sierra Nevada Range. Under the plan revision alternatives, if a 

nesting great gray owl territory is discovered on the Inyo, forestwide direction for at-risk species 

would provide for ensuring projects and land management activities are designed to maintain or 

enhance self-sustaining populations within the inherent capabilities of the plan area by 

considering the relationship of threats (including site-specific threats) and activities to species 

survival and reproduction. This would allow the best available scientific information to be used to 

determine if changes are needed to livestock grazing activities based upon actual conditions at 

nest sites.

Although management approaches for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives would adopt a framework for future management 

actions with regards to recreation management and resource protection.

Proposed plan components in the all alternatives are designed to move meadow and adjacent 

forest habitat conditions to a more desired ecological state than what currently exists. Alternative 

A would provide for the species by requiring analysis of effects to sensitive species during project 

planning and avoiding projects and activities that would lead to a trend towards federal listing.

The plan revision alternatives have a number of ecosystem level and species specific plan 

components in place to mitigate risks to the species within its management authority, but cannot 

mitigate all threats for persistence. The Inyo National Forest is at the very edge of the species’ 

range and it may not be within the inherent capability of the land to provide for a viable 

population of great gray owl in the plan area. Based upon this evaluation, for the plan revision 

alternatives, the final set of ecosystem plan components and the additional species-specific plan 

components, when carried out, would provide the necessary ecological conditions to maintain a 

viable population of great gray owl within its range. However, due to uncertainty about the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

380

species current viability, the limited amount of habitat on the Inyo National Forest, and potential 

future threats associated with climate change, it is not within the inherent capability of the land to 

maintain or restore the ecological conditions to maintain a viable population of great gray owl

within the plan area.

Mt. Pinos Sooty Grouse

Mt. Pinos sooty grouse occurs in high elevation suitable habitat (6,000 to 10,000 feet within the 

Sierra Nevada montane and subalpine and alpine ecological zones) on the Inyo National Forest 

south of the city of Independence. 

Alternative A does not provide specific forest plan direction for this species since it is not 

currently a sensitive species for the Inyo National Forest. The plan revision alternatives would 

manage this species as a species of conservation concern requiring management to manage for 

persistence over time. However, alternatives B, B-modified, and D provide a greater set of 

management tools such as mechanical and hand treatments, as well as prescribed fire and 

managing wildfires for resource benefits which can allow managers to strategically manage for 

Mt. Sooty grouse habitat so as to retain areas of dense forested stands, open pine and fir forest 

with large trees, and riparian areas. Alternatives B, B-modified, and D more effectively address 

climate change and ecosystem and watershed resilience than alternative C, and take more of a 

landscape and long-term management approach than does alternative C.

Although management approach for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

In summary, Mount Pinos Sooty grouse is currently found in a geographically restricted area and 

may be a relict population of a once more widespread species that occurred in the Southern Sierra 

Nevada. Due to this limited distribution and a moderate population decline throughout its range, 

the Inyo National Forest may provide important refugia habitat. However, taxonomic uncertainty 

about the species may be a potential barrier for conservation action and hunting pressure could be 

an additive factor if the subspecies is misidentified in the field. In addition, sooty grouse habitat, 

particularly in the subalpine forest, may be especially at risk from climate change and interrelated 

effects of wildfire and drought, further increasing viability risk. 

Species viability of Mt. Pinos sooty grouse is currently uncertain; however, proposed plan 

components are designed to move habitat conditions to a more desired ecological state than what 

currently exists. The Inyo has a number of ecosystem level and species-specific plan components 

in place to mitigate risks within its management authority, but cannot mitigate all threats for 

persistence. Based upon this evaluation, the final set of ecosystem plan components and the 

additional species-specific plan components, when carried out, would provide the necessary 

ecological conditions to maintain a viable population of Mount Pinos sooty grouse within its 

range. However, due to uncertainty about the species current viability, the limited amount of 

habitat on the Inyo National Forest, and potential future threats associated with climate change 

and taxonomic uncertainty, it is not within the inherent capability of the land to maintain or 

restore the ecological conditions to maintain a viable population of Mount Pinos sooty grouse 

within the plan area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

381

Willow Flycatcher

Willow flycatchers occupy riparian and wet meadow habitats. Alternative A would continue 

providing a level of protection to riparian conservation areas, including meadows. The current 

plan also includes standards and guidelines that guide livestock management through determining 

when livestock can graze in occupied meadows to protect breeding and limits the extent of 

utilization to protect willow habitats.

Alternatives B, B-modified, C, and D adopt the approach to species management of providing for 

ecological diversity and ecological integrity as the primary means to ensure the persistence of 

most species. Alternatives B through D provide forest plan direction to manage habitats and 

provide ecological conditions to provide for species of conservation concern, including the 

willow flycatcher. Alternative B allows for prescribed fire and mechanical as well as hand 

treatments to restore ecological integrity and improve resilience of riparian ecosystems to fire, 

drought, and climate change, but this would likely not affect the types of riparian habitats used by 

this species. Alternative B-modified proposes conservation watersheds, which includes areas on 

the Inyo National Forest occupied by willow flycatcher, such as the proposed Mono Lake 

Headwaters and the South Fork Kern River Headwaters conservation watersheds.

Alternatives B, B-modified, and D propose to change the way fire is managed by identifying 

strategic fire management zones that support greater opportunities for managing wildfire to meet 

resource objectives when it is safe to do so. This may improve the restoration of fire across larger 

landscapes and reduce the risk of fire burning outside of the natural range of variation in 

meadows and riparian areas that provide habitat. This would provide a greater benefit to this 

species by improving ecosystem and watershed resilience to climate change. Alternative D 

incorporates the same direction regarding at-risk species as alternatives B and B-modified. 

Alternative D focuses on the long recovery time for habitats of many at-risk species and is 

designed to lessen the rate of habitats adversely affected by large high-intensity fires by reducing 

fuels and restoring vegetation in upland areas and in some riparian areas that are outside the 

natural range of variability. Restoration would occur at an increased level. Alternative C does not 

strive for desired conditions with the natural range of variability for all habitat types. 

Specific to willow flycatcher, alternative C emphasizes maintaining and restoring nesting habitat 

in Mono Lake Basin, whereas alternatives B, B-modified, and D do not. 

Although management approaches for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

In summary, water use from expanding population pressure and human demands, coupled with 

increasing temperatures and temporal changes in precipitation and runoff events related to climate 

change, along with small declining populations that are subject to nest parasitism by brownheeded cowbirds will continue to put this species and its associated habitat components at risk on 

the Inyo National Forest. Historically, annual flooding was a major disturbance needed to 

maintain the vegetation levels necessary for many wildlife species that use riparian habitat. 

Riparian habitat is currently departed from historic conditions due in large part to growing 

population demands for water that result in stream diversions and impoundments. The watershed 

is not wholly contained within the national forest and the Inyo has little control over water 

management outside national forest boundaries. For this reason, it will be difficult for the Inyo 

staff to fully restore this habitat to reference conditions. Species viability of willow flycatcher on 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

382

the Inyo is currently uncertain; however, proposed plan components are designed to move habitat 

conditions to a more desired ecological state than what currently exists. The Inyo National Forest 

has a number of ecosystem level and species specific plan components in place to mitigate risks 

within its management authority, but cannot mitigate all threats for persistence. 

Based upon this evaluation, the final set of ecosystem-level plan components and the additional 

species-specific plan components, when carried out, would provide the necessary ecological 

conditions to maintain a viable population of willow flycatcher within its range. However, key 

risk factors including climate change, ground water pumping and water diversions that occur off 

forest are not within forest service management authority and will continue to threaten meadow 

riparian and wet meadow habitat, making it difficult to maintain viability in the plan area.

Butterflies (Mono Lake Checkerspot, San Emigdio Blue, Apache Fritillary, Sierra Sulphur, 

Square Dotted Blue, Boisduval’s Blue)

These 6 species of butterflies are found at higher elevation and are associated with similar habitat 

such as meadows, along dry river beds, riparian areas, or open habitat (forest openings). Two 

species (Boisduval’s blue and square dotted blue) occur in different habitat types such as scree 

slopes, barren rides, and pumice fields (square dotted blue) whereas the Boisduval’s blue occur in 

forest openings as well as sagebrush steppe, chaparral, and fields. All six species are relatively 

rare and limited where they occur. They are also susceptible to similar risks such as drying of 

microsite conditions, conifer encroachment, loss of habitat from human activities (such as

herbicide and pesticide treatment on invasive species, and recreation development), and climate 

change. 

Alternative A provides forest plan direction for aquatic and riparian ecosystems (riparian 

conservation areas) that most of these butterfly species depend on. Even though the Sierra sulphur 

butterfly is not a Pacific Southwest Region sensitive species, their habitat of high-elevation wet 

meadows receives protection (limiting management activities) from human-caused activities 

under alternative A. However, the square dotted blue and Boisduval’s blue butterflies are 

currently not sensitive species, and not associated with riparian habitats. Even though habitat 

(scree slopes, barren ridges, and pumice fields) for the square dotted blue butterfly does not 

consist of riparian systems, some current protection may exist from limiting collecting of pumice 

through the administration of Forest Service permitting systems for protecting unique ecological 

habitat. This species is only known in one location on the Inyo National Forest. However, the 

Boisduval’s blue has no species specific management plan under the current forest plan 

(alternative A) since its habitat does not consist of riparian systems, Alternative A would not be 

as beneficial for this butterfly species compared to the other alternatives.

Although management approach for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

Alternatives B, B-modified, C, and D all provide improved protection to all six species of 

butterflies compared to alternative A (see “Features Common to Alternatives B, B-modified, C, 

and D” for species of conservation concern in chapter 2). These alternatives provide protection to 

these species through direction under required plan components for species of conservation 

concern. Where meadows are important for any of these species, flexibility for management to 

keep conifers from encroaching into meadows will be beneficial. Although alternative C limits 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

383

mechanical treatments in conifer encroached riparian areas more than the other alternatives, the 

difference is small between alternatives B through D as it relates to these species. 

A Cave Obligate Pseudoscorpion (Tuberochernes aalbui)

This species is known in only one location on the Inyo national Forest. Its habitat is within a cave 

that provides certain microsite conditions. 

This species was not previously on the Pacific Southwest Region’s sensitive species list and 

therefore was not specifically addressed in the current forest plan under alternative A. However, 

caves and similar special habitats are often protected and managed to minimize impacts from the 

public and forest activities and to protect the public. This specific cave has been protected with an 

installed locked gate to prevent entrance by the public. Alternatives B, B-modified, C, and D 

would manage this species as a species of conservation concern with forestwide forest plan 

direction. Since the cave is currently gated and no change in management is expected over the life 

of the forest plan, all alternatives should provide similar protection. Since this species is known 

from only one location, under alternatives B, B-modified, C, and D, plan direction would guide 

adjacent projects to minimize or mitigate adverse effects to the cave microclimate or environment 

to ensure the persistence of this species on the national forest. This consideration would not be 

required under alternative A but could still be considered during site-specific project planning 

since the pseudoscorpion is a native species.

Although management approach for sustainable recreation and designated areas vary between 

alternatives, all plan revision alternatives will adopt a framework for future management actions 

with regards to recreation management and resource protection.

Special habitats such as caves are limited and even though can be adversely impacted by certain 

activities, can also be managed effectively to protect associated resources through the installation 

of gates, and emphasized with mitigation measures for activities proposed nearby.

Cumulative Effects

The proposed management approaches under each of the alternatives are generally consistent 

with management of other lands within the cumulative effects analysis area. Although the 

alternatives vary in their ability and pace to achieve the desired conditions and some alternatives 

present more risk than others, it is not expected that the management approach under any 

alternative, combined with actions on other lands, would have an adverse cumulative effect on 

terrestrial wildlife habitat within the analysis area.

The majority of the land within the analysis area is managed by Federal agencies, primarily 

Forest Service, National Park Service (west side), and Bureau of Land Management (east side) 

and these agencies have individual resource management plans or shared, collaborative programs 

in place to guide the protection of natural resources, particularly in the face of changing climate 

conditions and large, high-intensity wildfires. The new focus of the 2012 Planning Rule on 

ecosystem integrity, resilience, and diversity is in close alignment with new direction for the 

National Park Service, which is to build ecosystem resilience for coping with changing climates. 

Park units are now obligated to consider climate change adaptation and manage for climateresilient forests. The “Strategic Framework for Science in Support of Management in the South 

Sierra Nevada Ecoregion” was developed collaboratively by Federal land managers in the 

Southern Sierra Nevada ecoregion (including the Sierra and Sequoia National Forests and Giant 

Sequoia National Monument) to help mitigate impacts from, and adapt to, climate change 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

384

(Nydick and Sydoriak 2011b, a). The framework contains four goals: understanding where and 

why changes occur, anticipating possible futures, developing tools required to take effective 

action, and providing easy access to and delivery of information to target audiences. The 

framework will be carried out by the Southern Sierra Conservation Cooperative, a collaborative 

group of Government agencies and nonprofit organizations in the Southern Sierra Nevada 

Ecoregion. Sequoia and Kings Canyon National Parks, Sequoia National Forest, and Giant 

Sequoia National Monument are the first group of resource managers working together under the 

framework to carry out a pilot project to develop the capacity to manage fire under a “new lens” 

and to revise fire management objectives, tools, and methods. Therefore, given that the majority 

of the land in the analysis area is managed by Federal agencies and guided by individual resource 

management plans, as well as stronger, more relevant multi-agency partnerships, these strong 

consistencies in management direction are expected to provide for landscape-level resilience.

Large, high-intensity wildfires pose the most significant threat to wildlife habitat in the analysis 

area and many Federal agencies in this Southern Sierra Nevada ecoregion are working in 

partnership (and separately) to improve landscape resiliency to climate change and wildfires. The 

National Park Service uses managed wildfire and prescribed fire as resource tools where feasible 

and safe. The National Park Service has worked with the Sequoia National Forest in the past to 

manage wildfires for resource benefit, resulting in a high level of restoration (and lessened fire 

risk) in the area where the national forest meets the national park. The Inyo National Forest has 

an interagency fire program with the Bureau of Land Management in which staffs from both 

agencies participate in the planning of vegetation projects because of the proximity of lands, 

especially in the wildland-urban intermix.

Although each of the plan revision alternatives attempts to reduce the spread of large, highintensity wildfires, improved resilience to such wildfires is anticipated to be higher under some 

alternatives compared to others. Under alternatives A and C, wildfires are anticipated to have an 

increasing trend in burned area, fire size, and fire intensity. Although alternative C places a heavy 

emphasis on the use of fire to achieve vegetation restoration, resilience to fire over much of the 

plan area would remain at the same low and very low resilience because of the more limited areas 

where fuels are reduced lowering the risks of managing wildfires or the complexity of conducting 

prescribed burns. The Endangered Species Act defines “cumulative effects” as the “effects of 

future State or private activities, not involving Federal activities that are reasonably certain to 

occur within the action area of the Federal action subject to consultation.” The National 

Environmental Policy Act gives “cumulative impacts” a broader meaning, which includes the 

impact of the action when added to other past, present, and future actions, regardless of the 

agency or person undertaking the action. Therefore, while alternatives A and C might provide less 

benefit to resilience than alternatives B, B-modified, and D, they do not constitute adverse 

conditions under either the Endangered Species Act or the National Environmental Policy Act 

simply from a lack of action. 

Vegetation management activities are conducted on land managed by Bureau of Land 

Management, National Parks, and some State-managed lands. Both mechanical treatments and 

prescribed fire are used as management tools as they are on National Forest System lands. 

However, in national parks, the primary treatment methods include prescribed fire and managed 

wildfire; mechanical treatments are limited. Relatively fewer vegetation management projects are 

undertaken on county and privately owned land. The pace of restoration under alternatives B, B 

modified and D in treating both upland and aquatic systems may be more aggressive than those 

undertaken on other land ownerships in the analysis area but are expected to help more rapidly set 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

385

the trajectory for a positive trend in ecosystem resilience (especially alternative D). Conversely, 

under alternatives A and C there is a greater risk of not being able to achieve desired conditions in 

a timely manner for ecosystem integrity, resiliency, and diversity of upland and aquatic systems 

because of the limit on tools that can be effectively used and constraints on habitat modifications 

related to canopy cover and large trees in upland systems and the use of mechanical equipment in 

aquatic systems.

Climate change resulting in higher temperatures, greater moisture evaporation, and prolonged 

drought will continue to affect ecosystems that support terrestrial wildlife species throughout the 

analysis area. Unlike alternatives B, B-modified, C and D that formally provide direction to 

manage the landscape and various ecosystems and watersheds for resilience to climate change, 

alternative A presents the greatest risk to the ability of habitat within the analysis area to sustain 

wildlife habitat as climate conditions change. Alternative A recognizes the need to address density 

of forests to reduce the risk of trees dying due to stresses related to prolonged droughts but this 

alternative is limited in the ability to treat terrestrial habitat at a rapid and large enough pace to 

substantially reduce the risk. Furthermore, the desired conditions for aquatic and riparian 

ecosystems in alternative A that support many terrestrial wildlife species and their prey do not 

specifically consider the change in temperature and precipitation related to climate change and 

other climate stressors to these systems. Management under this alternative could put more 

pressure on adjacent lands to support resilient habitat or influence habitat in adjacent lands where 

widespread climate-induced changes (such as massive tree mortalities, meadow desiccation, or

large high-intensity wildfires) spread beyond the borders of the Inyo National Forest. 

In contrast, alternatives B, B-modified, C, and D include desired conditions that emphasize 

improving watershed resilience to wildfire and climate change by treating vegetation and 

reducing fuels over larger areas, and mitigating and restoring impacts from unmaintained roads 

when they impair watershed function. These alternatives also include direction to manage for an 

increased risk of insects and diseases and changed fire patterns and cycles, and include desired 

conditions that recognize climate stressors on aquatic and riparian systems. These alternatives all 

consider and incorporate at least some recommendations from various climate vulnerability 

assessments and adaptation strategies and as a result have a better ability than alternative A 

(which supports fewer climate assessments and strategies) to build adaptive capacity into the 

climate change approach on National Forest System lands in the analysis area.

For various species strongly associated with certain plants for foraging or nesting habitat (such as 

butterflies and willow flycatcher) the spread of invasive plant species threatens this habitat. 

Management direction under any alternative is not expected to have an adverse cumulative effect 

on the existence or spread of invasive species in the analysis area, but alternatives B, B-modified, 

C and D have specific plan components that address the prevention, control, and possible 

eradication of terrestrial invasive species more formally than the current plans. However, 

alternative D has the greatest indirect risk of spreading invasive species because of the increase in 

acres treated, particularly acres mechanically treated. Nonetheless, the spread of invasive species 

is not anticipated to have an adverse cumulative effect in the analysis area because of mitigation 

required under each of the three alternatives. Both Bureau of Land Management and National 

Park Service also conduct invasive weed treatments. Invasive species exist on State, county and 

privately owned land and treatments there are varied.

Within the analysis area, grazing is permitted on lands managed by the Forest Service and Bureau 

of Land Management, and county and private lands. Grazing can be a management tool used for 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

386

restoring habitats such as grassland important to various species (such as some invertebrates) but 

also has the potential to reduce habitat quantity and condition for other associated species. Some 

domestic sheep transmit life-threatening diseases to various native bighorn sheep. Allotments on 

National Forest System lands are managed following Forest Service utilization standards and this 

management direction does not vary by alternative. However, alternatives B, B-modified, C, and 

D more formally incorporate an implementation plan on the Inyo National Forest that focuses on 

reducing the risk of transmission of disease among domestic and native sheep. Domestic sheep 

and goats are found on private and county-managed lands adjacent to occupied Sierra bighorn 

sheep and therefore the risk of disease transmission in these areas is high regardless of 

management on National Forest System lands. In this way, under all alternatives, but especially 

B, B-modified, C and D, grazing on National Forest System lands is not expected to have an 

adverse cumulative effect on habitat or disease transmission elsewhere in the analysis area.

The entire analysis area receives a great deal of recreational use. Recreation can have varying 

degrees of adverse impacts on terrestrial wildlife such as habitat loss, degradation, and 

fragmentation; disruption of behavior (such as foraging or reproduction); reduction or change in 

supply and availability of food and cover; direct physical harm to individuals and offspring (eggs 

or young); and increased garbage, human food sources, noise, and pet presence. Roads and trails 

can be particularly problematic where they traverse otherwise undisturbed or minimally disturbed 

habitat, are unmaintained so they degrade habitat or inadequately contain users, or where a 

variety of user-created trails exist. Although recreation and access can adversely affect terrestrial 

wildlife and their habitat, the recreation approaches described under any of the alternatives are 

not likely to have an adverse cumulative impact on wildlife habitat in the analysis area. The 

approaches proposed under the various alternatives focus on addressing deferred maintenance 

(such as retrofitting existing sites to accommodate need, maintaining existing system trails) rather 

than creating new development or trails. Addressing deferred maintenance could improve wildlife 

habitat condition where sites or trails are degrading habitat (like passing through a meadow or 

wetland) and are upgraded or moved to higher capability lands. All alternatives continue to 

protect at-risk species from known threats associated with recreation. For example, all 

alternatives contain plan components to prevent nesting raptors from being disturbed from a 

variety of activities, including recreation activities.

Cumulative Effects under the Endangered Species Act. There are no foreseeable cumulative 

effects identified for federally listed or candidate species as well as critical habitat at this time. 

Those effects are not the same as how cumulative effects are defined under the National 

Environmental Policy At. Cumulative effects under the Endangered Species Act address nonFederal actions that are reasonably certain to occur because Federal actions will be subject to 

separate section 7 consultation when those projects are proposed. Cumulative effects are 

addressed fully in the biological assessment prepared for consultation with the U.S. Fish and 

Wildlife Service (USDA Forest Service 2017a).

For the Sierra Nevada bighorn sheep, cumulative effects from non-Federal actions include the 

continued management by the California Department of Fish and Wildlife. This includes 

activities such as continuing to conduct population surveys, evaluating and monitoring mortality 

in bighorn sheep, and evaluating and implementing translocation efforts as determined necessary 

to meet recovery plan distribution and population criteria. It is expected they will also continue to 

evaluate and oversee the management of mountain lions that are affecting species recovery. An 

additional non-Federal action is leasing of livestock grazing by Mono County in areas that could 

create a risk of contact with bighorn sheep. Mono County has recently allowed a sheep grazing 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

387

lease of grazing on county lands to expire which substantially reduces the risk of disease contact. 

These non-federal activities would serve to improve ecological conditions for Sierra Nevada 

bighorn sheep.

Analytical Conclusions

Alternatives A and C have the most limited ability to mitigate the continuing increase in large, 

high-intensity wildfires and build adaptive capacity of ecosystems to climate change, although 

alternative C is better than alternative A at addressing climate change. Large wildfires with 

expansive areas of high-severity impacts are a major threat to many at-risk terrestrial wildlife 

species because they completely remove important habitat elements from a large portion of the 

landscape (like large living trees, dense canopy cover, down woody debris, riparian vegetation, 

and structural complexity) or they lead to type conversions with invasive species (like cheatgrass 

invading sagebrush and other arid vegetation types). Climate change is influencing all species and 

their habitats in far more complex ways but the primary management responses are mostly 

limited to improving vegetation resilience and providing for habitat diversity and habitat 

connectivity. Therefore, alternatives A and C present a greater risk to the quantity and condition 

of habitat to contribute to the recovery of threatened and endangered species, conservation of 

proposed and candidate species, and support the persistence of species of conservation concern.

Although alternatives B, B-modified, C, and D all focus on moving the vegetation types toward

desired conditions, alternatives B, B-modified, and D are better positioned to achieve these 

desired conditions in a shorter timeframe because they focus on restoring resilience at a large 

landscape scale using a variety of tools that effectively decrease the expected amount of crown 

fire and large patches of high-severity fire effects toward the levels expected in the natural range 

of variation. The treatment pace and scale under alternatives B and B-modified are assumed to 

move the landscape to a moderate fire resilience within the first 10 years of plan adoption. The 

pace and scale of restoration proposed under alternative D is expected to surpass those 

alternatives in the ability to move the landscape to a more resilient position. These alternatives are 

also better than alternative A and slightly better than alternative C in building adaptive capacity of 

the ecosystems to climate change. There is greater uncertainty in the amount of restoration that 

would occur under alternative C because of the strong preference to use prescribed fire and to 

manage wildfires to meet resource objectives and limit the use of mechanical equipment 

whenever possible. This may result in fewer acres being restored due to higher costs or greater 

reliance on hand treatments with slow rates of treatment compared to alternatives B, B-modified

and D.

Alternative B and B-modified represents a balance between alternatives A and C in that they 

propose to restore ecosystems toward their natural range of variation faster and more effectively 

than alternatives A and C because of the landscape level approach, more acres proposed for 

treatment, and a wider variety of restoration tools that can be applied. Alternative B provides a 

more cautious approach than alternative D by tempering the pace of restoration and implementing 

more fine-filter plan components. Ultimately, though, habitat for at-risk terrestrial wildlife species 

under alternative B continues to be at risk of loss due to large, high-intensity wildfires. 

Alternative D would more quickly achieve resilience of the landscape to large-scale disturbances 

(such as insect outbreaks, high-severity wildfire effects, and drought-related tree mortality), 

thereby providing a greater long term benefit to terrestrial wildlife habitat quantity and condition. 

However the management approach has greater potential for short-term impacts to achieve 

improved habitat condition. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

388

Federally Listed Endangered, Threatened, and Candidate Wildlife Species Determinations

Key conclusions:

• The forest plan provides a programmatic framework for future site-specific projects and 

actions but does not prescribe specific projects or assign project locations. Plan components 

exist to ensure proposed actions avoid, mitigate or minimize impacts to Sierra Nevada 

bighorn sheep. All future project level activities that may affect this species will require 

project-specific assessments and consultation under section 7 of the Endangered Species 

Act.

• A combination of ecosystem level plan components and species-specific plan components 

for bighorn sheep provide for the ecological conditions that would contribute to the 

recovery of the species.

• The forest plan includes direction to avoid, mitigate or minimize the risk of disease spread 

from domestic sheep and recreational pack goats but cannot eliminate the risk entirely.

• The forest plan includes direction to evaluate areas where recreation uses may be adversely 

affecting Sierra Nevada bighorn sheep. Nonetheless, individual animals are likely to be 

affected by short-term disturbance and displacement by human activities.

• Critical habitat within wilderness areas will remain essentially undisturbed by management 

activity and may be benefited by restoring the ecological role of fire. There is an 

opportunity to improve portions of the winter range with prescribed burning and restoring 

fire which could improve forage quality and maintain open conditions to reduce predation 

risk. This could have short-term effects on habitat leading to long-term benefits.

For the purpose of consultation under the Endangered Species Act, we determined that despite 

plan components and plan content that would serve to avoid, mitigate, or minimize effects to 

federally listed species, some actions and activities may disturb and displace individuals and 

habitat could be affected by restoration activities. Since the forest plan is at a programmatic level, 

it cannot ensure that projects developed under it would have no effect or that all actions would be 

discountable, insignificant or beneficial to federally listed species. Therefore, we determined that 

adoption of the revised forest plan under all alternatives may affect, and is likely to adversely 

affect the Sierra Nevada bighorn sheep. We believe that because of the conservation measures of 

the alternatives, the U.S. Fish and Wildlife Service will determine that adopting any of the 

alternatives would not jeopardize the continued existence of the Sierra Nevada bighorn sheep

when they issue a biological opinion.

For the purpose of consultation under the Endangered Species Act, we determined that although 

all alternatives are designed to conserve critical habitat, because some restoration actions, such as 

restoring fire using prescribed burning in winter range habitat may have short-term adverse 

effects to critical habitat, adoption of the revised forest plan under all alternatives may affect and 

is likely to adversely affect designated critical habitats for the Sierra Nevada bighorn sheep on 

the Inyo National Forest. Due to the conservation approach of the alternatives, we believe that the 

U.S. Fish and Wildlife Service will determine that at the programmatic level, all of the 

alternatives are not likely to result in destruction or adverse modification of critical habitat.

For the purpose of revising the forest plan, we determined that all plan revision alternatives have 

developed adequate plan components (ecosystem and species-specific) to provide for ecological 

conditions that contribute to the recovery of Sierra Nevada bighorn sheep within the plan area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

389

Wildlife Species of Conservation Concern Outcomes

In analyzing persistence of wildlife species of conservation concern, each species was evaluated 

individually (see appendix F in Volume 2). For most species, the determination is that: It is 

beyond the authority of the Forest Service or not within the inherent capability of the plan area to 

maintain or restore the ecological conditions to maintain a viable population of these species in 

the plan area. Nonetheless, the plan components should maintain or restore ecological conditions 

within the plan area to contribute to maintaining a viable population of the species within its 

range. For example, due to circumstances that are neither within the authority of the Forest 

Service nor consistent within the inherent capability of the land, the plan area is unable to provide 

the ecological conditions necessary to maintain a viable population of the Nelson desert bighorn 

sheep. The reasons for this are that there is no authorized livestock grazing or permitting of 

uncontrolled domestic goats or sheep that are known to be in contact with the White Mountain 

bighorn sheep herd. However, the California Department of Fish and Wildlife has documented 

co-mingling of stray domestic goats with this bighorn population on private property (California 

Department of Fish and Wildlife 2015b). Because of this, the potential for population die-off is 

not caused by actions and cannot be addressed under Forest Service authority.

For the bi-state sage-grouse and cave obligate pseudoscorpion the determination is that: The 

ecosystem plan components may not provide the ecological conditions necessary to maintain a 

viable population of these species of conservation concern in the plan area. Therefore, additional 

species-specific plan components have been provided. The combination of ecosystem and speciesspecific plan components should provide the ecological conditions necessary to maintain a viable 

population of these species in the plan area.

All determinations provide both ecosystem and at-risk species-specific forest plan direction for 

persistence. The outcome for each species of conservation concern is displayed in appendix F. 

The emerging plan components under alternatives B, B-modified, C, and D when carried out, 

would provide the necessary ecological conditions to maintain viable populations of species of 

conservation concern. These alternatives include ecosystem coarse filter plan components aimed 

at protecting the broad habitats upon which these species depend and at-risk species-specific and 

ecosystem type-specific plan components. 

Differences in the effects of alternatives suggests minor to major differences as to which would 

favor a particular species or group of species under the different alternatives. This determination 

depends upon the assumptions of treatments reducing the rate of habitat loss from large, highintensity wildfires while providing for sufficient ecological conditions to meet the short-term 

needs of at-risk species. All determinations rely upon an adaptive approach to learning and 

making appropriate changes over time.

At-risk Aquatic Species

Background

This section summarizes current conditions of at-risk aquatic vertebrate and invertebrate species 

and the consequences of implementing the alternatives. At risk species include species listed as 

threatened or endangered (there are no aquatic candidate species on the Inyo National Forest), 

and aquatic species of conservation concern. The sections above on “Aquatic and Riparian 

Ecosystems” and “Terrestrial Vegetation Ecology” cover the general ecological integrity of the 

ecosystems upon which aquatic at-risk species depend, while this analysis focuses on effects to 

individual species.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

390

This evaluation was completed by examining conditions of and threats to individual at-risk 

aquatic species, and also by examining the collective distribution patterns of at-risk aquatic 

species within the plan area, by watershed and by ecosystem. This approach assisted in 

understanding the broad relationship between a programmatic land management plan and the 

desired conditions identified for the at-risk species in the plan area. Desired conditions for at-risk 

aquatic species emphasize habitat that supports self-sustaining populations, precluding the need 

for listing, and improving conditions for these species.

Analysis and Methods

This analysis uses the same ecosystem plan component and species specific plan component

approach as the “At-risk Terrestrial Wildlife” analysis to assess the alternatives’ potential for 

providing the habitat characteristics to support wildlife diversity and the persistence of native 

species in the plan area. The coarse filter approach assumes that diversity is broadly dependent 

upon the integrity of the function, composition, and structure of the Inyo’s terrestrial, riparian, 

and aquatic ecosystems to provide the ecological conditions that support the abundance, 

distribution, and long-term persistence of native species. This analysis compares the current 

abundance and condition of various habitats with ecological reference conditions (natural range 

of variability) based on the dynamic nature of ecosystems, recognizing they are not static 

(Landres, Morgan, and Swanson 1999a). It recognizes that disturbances or processes (fire, 

flooding, insects, and disease) and responses to those are part of the natural processes. However, 

integrity of whole ecosystems may not necessarily address all species’ needs, so additional 

analyses were conducted to determine how well species specific plan components provided for 

the ecological conditions on the national forest to address key threats to species persistence.

The analysis area includes all National Forest System lands administered by the Inyo National 

Forest. In some cases, the best available scientific information for at-risk species’ ecological 

relationships originated outside the analysis area. However, indicator measures and threat 

information from within the analysis area were used in making conclusions. Because of 

differences in available biological and threat information to federally recognized threatened, 

endangered, proposed, and candidate species versus species of conservation concern, and because 

the Forest Service Handbook outlines different procedures to identify plan components necessary 

to provide for the two groups of species, different approaches were used in their analyses.

Indicators and Measures

The indicators and measures for aquatic species are assessed the same as described for at-risk 

terrestrial species. For federally listed species, the adequacy of plan direction to protect, maintain, 

and restore habitat and the adequacy of plan direction to avoid, minimize, or mitigate potential 

adverse effects is evaluated for each alternative. An analysis for the preferred alternative 

(alternative B-modified) is documented in detail in the biological assessment submitted to the 

U.S. Fish and Wildlife Service and available in the project record. For aquatic species of 

conservation concern, we evaluate the extent and condition of habitat as indicators because they 

provide a reasonable estimate of ecological conditions needed to support the persistence of 

species of conservation concern and because relative differences among alternatives could be 

readily compared.

To evaluate extent and condition of habitat, we relied upon findings for environmental 

consequences from the “Aquatic and Riparian Ecosystems,” “Terrestrial Vegetation Ecology,” 

and “Fire Trends” sections. The extent and condition of each ecosystem or special habitat type
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

391

served as the habitat indicator for individual species and for assemblages of at-risk species. 

However, the ecosystem types outlined in the “Aquatic and Riparian Ecosystems” section are 

roughly, but not exactly aligned with watershed characteristics to which at-risk aquatic species 

populations are often associated. Therefore, for some species, we also discuss the extent and 

condition of watershed characteristics if they better reflect the ecological conditions needed by a 

species.

Assumptions

• If a species is associated with a particular habitat, then the condition, amount, and 

distribution of those habitat elements available to the species on the landscape help to 

predict its distribution and abundance within that habitat.

• Habitat abundance and distribution similar to that which supported associated species 

during conditions as a consequence of evolutionary time, will likely contribute to their 

maintenance in the future (Haufler 1999). Therefore, habitat abundance, distribution, and 

condition similar to that within the natural range of variation for the habitats will likely 

contribute to species persistence in the future. (See also the “Aquatic and Riparian 

Ecosystems” section).

• The planning timeframe for the effects analysis is 10 to 15 years; other timeframes may be 

specifically analyzed depending on the resource and potential consequences.

• Monitoring identified in the plan monitoring program and any broader-scale monitoring 

will occur and the land management plan will be amended, as needed during the life of the 

plan.

• There will be a general increase in recreational demand as the human population size 

increases.

• Funding levels will be similar to the past 5 years.

Species Evaluated

Federally Listed Aquatic Species

The following table shows at-risk federally listed (threatened or endangered) aquatic species that 

are known to occur on the Inyo National Forest, providing common name, scientific name, and 

listing status There are no proposed or candidate aquatic species. The explanation of which listed 

species are considered to occur on the Inyo is included in the biological assessment.

Table 63. Federally designated aquatic species and critical habitat that occur in the Inyo National 

Forest plan area

Common Name Scientific Name Status Critical Habitat

Mountain yellow-legged frog, northern 

Distinct Population Segment

Rana muscosa Endangered Final designated

Sierra Nevada yellow-legged frog Rana sierrae Endangered Final designated

Yosemite toad Anaxyrus canorus Threatened Final designated

Lahontan cutthroat trout Oncorhynchus clarkii 

henshawi

Threatened Not identified

Paiute cutthroat trout Oncorhynchus clarkii seleniris Threatened Not identified

Owens tui chub Gila bicolor snyderi Endangered Final designated
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

392

Aquatic Species of Conservation Concern

For the coarse-filter approach, we grouped species by coarse-scale ecosystems described in the 

“Aquatic and Riparian Ecosystems” section. The environmental consequence findings of that

section also compared existing and foreseeable future conditions of ecosystems to desired 

conditions, and this comparison was used as the basis of the coarse-filter evaluation. This coarsefilter approach assumes that persistence of species of conservation concern is broadly dependent 

upon the integrity of the ecosystems where they currently occur. However, because integrity of 

whole ecosystems does not necessarily ensure persistence of all species of conservation concern, 

particularly those with very limited distribution, we conducted additional fine-filter evaluations 

(species-specific and by special habitat) to ensure plan components provided ecological 

conditions that would maintain persistence for aquatic species of conservation concern.

The fine-filter evaluation was conducted by analyzing (1) special habitats that support suites of 

some species of conservation concern, and (2) known threats to each individual species of 

conservation concern. We grouped species by fine-scale habitats where possible, to enable a fine 

filter look at ecological conditions that affect populations. We also discussed documented threats 

that influence species trends in distribution and persistence.

Table 64 lists the seven aquatic species of conservation concern separated by taxa or type of 

animal. Note that terrestrial amphibian and invertebrate species are discussed in the “At-risk 

Terrestrial Wildlife” section.

Table 64. Aquatic species of conservation concern 

Taxa (Type) Common Name Scientific Name

Amphibian Black toad Anaxyrus exsul

Amphibian Inyo Mountains slender 

salamander Batrachoseps campi

Amphibian Kern Plateau salamander Batrachoseps robustus

Fish California Golden Trout Oncorhynchus mykiss 

aguabonita

Aquatic invertebrate Western pearlshell Margaritifera falcata

Aquatic invertebrate Wong's springsnail Pyrgulopsis wongi

Aquatic invertebrate Owens Valley springsnail Pyrgulopsis owensensis

Affected Environment

Aquatic ecosystems include standing waterbodies such as lakes, ponds, tarns, springs and 

reservoirs, and flowing waterbodies such as rivers, creeks, and streams. Meadows and riparian 

areas are also important features of aquatic ecosystems.

Six fish species were native historically on the Forest, including some species unique to the 

Owens Valley, but most waters were barren of fish prior to transplanting activities which started

in the late 19th Century (Moyle 2002).

The El Niño Southern Oscillation is partially responsible for approximately a decade-long interannual precipitation pattern in the southern Sierra Nevada. Drought years alternate with normal 

and extremely wet years during these decade-long oscillations. In recent years, the pattern has 

increased in variability. Within the same year, the Mediterranean climate may have long dry 

summer periods and highly seasonal winter precipitation.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

393

The following sections describe the major types of aquatic habitat environments, as well as the 

topography, climate, and other factors that influence aquatic ecosystems and habitats. It is useful 

to evaluate the coarse filter approach by grouping species by aquatic habitat types they are most 

commonly associated with. All aquatic at-risk species occur in at least one of the aquatic habitat 

types and many occur in two or more and some species do not have a strict affinity to a particular

habitat type but are identified to the most commonly associated type.

Rivers and Streams

The eastern side of the Sierra Nevada lies in the rain shadow of these mountains, which reach 

their highest elevations on the Inyo National Forest. This has created a dry, precipitationdependent and precipitation-driven aquatic system. Streamflow is dependent on total precipitation 

and timing of snowmelt. Water flows can vary greatly from one year to the next, depending on 

precipitation levels. Some years, streams can be completely dry. Climate change is likely to 

magnify these shifts in two ways: (1) with decreasing precipitation resulting in more dry years, 

and (2) with earlier snowmelt and shifts in seasonal timing of flows (Hunsaker, Long, and Herbst 

2014a). The rain-snow interface zone is predicted to occur at higher elevations, causing warming 

of streams earlier in the season. Rivers in valleys usually provide a consistent, abundant flow of 

water throughout the year, and support more complex faunal ecosystems.

Large rivers are predominately absent from the eastern Sierra Nevada mountains. Within the Inyo 

National Forest, there are valley bottoms including the upper Owens River, the South Fork of the 

Kern, a portion of the upper Kern River, and the San Joaquin River. There are many larger and 

smaller, sometimes seasonally flowing streams. Larger streams include Pine Creek, Bishop 

Creek, Big Pine Creek, and Rock Creek. An estimated 1,640 miles of perennial streams are on the 

Inyo National Forest.

Although most of the stream systems on the Inyo National Forest were fishless prior to stocking 

of nonnative trout, the South Fork Kern River and Golden Trout Creek and their tributaries, are 

within the range of the native California golden trout. This is unique because much of the west 

slope of the Sierra Nevada range above 5,000 feet was historically fishless due to glaciation 

during the Pleistocene and due to steep topography (Moyle 2002). 

Other important native species found in river and stream systems include a variety of streamdwelling macro-invertebrates (the aquatic life-cycle stage of many aquatic insects), such as caddis 

flies, mayflies, and stone flies which provide an important food source for native fish and other 

aquatic species.

Lakes and Ponds

Historically the lakes of the high Sierra Nevada were fishless and supported native fauna such as 

amphibians, aquatic insects, abundant zooplankton and phytoplankton. The mountain yellowlegged frog was an abundant resident of these lakes, with a life cycle that accommodated the 

seasons of ice in the high country (Knapp, Boiano, and Vredenburg 2007). Currently, many of the 

high-elevation lakes support introduced trout species of brook, brown, rainbow and golden trout, 

which has had an impact on frog populations (Knapp and Matthews 2000b and 2000c; Knapp, 

Boiano, and Vredenburg 2007). The historic introduction of trout into lakes throughout the Sierra 

Nevada mountain range has had the effect of eliminating the Sierra Nevada and mountain yellowlegged frog from over 90 percent of its historic range (Vredenburg et al. 2007). The introduction 

of trout into these lakes has also altered the life cycle and reduced the population numbers of 

macro-invertebrates and zooplankton within the lake (Knapp 2005; Schindler, Knapp, and Leavitt 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

394

2001). This reduction or elimination also affects the intensity of insect hatches that may affect 

bird migration patterns. The introduced and hatchery stocked trout are popular for recreational 

use, which is an important source of economic sustainability in the area. Climate change is 

expected to disrupt habitat for lake associated species. Both species of yellow-legged frogs are 

impacted by the fungal pathogen commonly referred to as chytrid fungus (Briggs et al. 2005;

Rachowicz et al. 2006; Reeder, Pessier, and Vredenburg 2012) in addition to introduced trout, 

climate change and other stressors (Bradford et al. 2011, Davidson and Knapp 2007).

Ponds and other small waterbodies, such as tarns and pools, occur throughout the higher 

elevations within the Sierra Nevada Mountains. For the purpose of this discussion, waterbodies

less than 2 acres were identified as ponds, of which there are 1,372 on the Inyo National Forest, 

with a total of 662 acres. Due to the shallow nature of these waterbodies, they are 

characteristically warmer during the summer months than lakes or streams. These features 

provide breeding habitat for the Yosemite toad and Pacific chorus frogs, which prefer meadow 

edges without deep water or adjacent steep terrain (Davidson and Fellers 2005). Most ponds 

occur in wilderness areas in the Sierra Nevada portion of the national forest. Little to no 

information is available on their condition or trend. Impacts have been observed, but not 

measured systematically, from recreation, grazing, or pack stock.

Lakes on the eastern side of the Sierra Nevada Mountains range in size from 1 acre to hundreds of 

acres. No lakes occur in the White Mountains, Inyo Mountains or Glass Mountains. 

Approximately 479 lakes larger than 2 acres occur on the Inyo National Forest, totaling about 

46,000 acres. 

Meadows, Seeps, and Springs

Meadows, seeps, and springs in the drier southern Sierra Nevada Mountains provide important 

habitat diversity and habitat for plants and animals.

Wet meadows are wetland habitats associated with groundwater seeps, stream and lake edges, and 

margins of seasonal drainages. This plant community is dominated by grass and grass-like species 

growing with varying combinations of herbaceous perennials and intermixed with the other 

habitat types noted in this section. Meadows play important roles in hydrology, erosion control,

nutrient cycling, wildlife habitat, and recreation. Meadows are also important in maintaining

hydrological processes downstream, conserving stream flows, channel erosion, and nutrient loads.

Fens are continually wet areas where soils rich in organic material form.

Springs are small areas of water that come to the surface, and are fed by groundwater (Sada and 

Pohlmann 2002); the water temperature is relatively constant and in parts of the Inyo National 

Forest, often provide the only water over vast areas. Because of this, they are usually biodiversity 

hotspots, supporting many species that only occur there.

Little information is available on springs and seeps on the Inyo National Forest. Springs are 

scattered throughout the national forest, throughout different habitats. Existing information 

indicates that there are approximately 1,472 springs. Stressors on these systems include spring 

development, recreation use, concentrated livestock grazing use, diversions and unauthorized offhighway-vehicle use. Groundwater pumping can affect springs even miles away from the 

pumping source, causing springs to cease flowing. Many springs have been fenced from livestock 

use, and this is expected to improve function and condition of these springs. Even with predicted 

decrease in water throughout the area as a result of climate change, it is expected that springs will 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

395

persist, but they may be the only water sources available for animals. Springs could receive 

additional impacts from species such as mule deer, burros, wild horses, and other animals as other 

stream sources dry, especially in the White and Inyo Mountains and Pizona area.

Meadows, seeps and fens are dependent on snowpack to sustain flow throughout the long dry 

period of summer. There is little information about the current trends for springs. As the rainsnow interface changes, lower elevation meadows and fens will be increasingly at-risk. 

Restoration of these systems holds great potential to provide multiple ecological and social 

benefits, despite their small share of the landscape. Evaluating the role of natural processes such 

as wildfire and management practices such as watershed restoration, on a larger, watershed scale, 

could aid the design of more effective strategies to promote long term resilience of these valuable 

systems.

The Inyo National Forest has over 25,000 acres of meadows larger than 1 acre. Meadows on the 

Inyo National Forest are experiencing increasing conifer densities and canopy cover over the past 

several decades that likely exceed the natural range of variability (Gross and Coppoletta 2013). 

Researchers sampled 10 randomly selected meadows on the Inyo National Forest as part of a 

Sierra Nevada study (Fryjoff-Hung and Viers. 2013). This study found vegetation cover and bare 

ground cover ranged from natural condition to moderately or heavily altered, depending on 

location. Encroachment (the ingrowth of trees) was the most common impact, with 60 percent 

moderately impacted and 10 percent slightly impacted. 

Unpublished Inyo National Forest data indicate that all stream reaches through meadows in 

grazed and rested allotments fell within expected values for width and width-to-depth ratios, 

except for Monache Meadow, which showed that widths were wider and depths shallower than 

they should be for a functioning hydrologic system. In the past 20 years, much restoration work 

has been completed in meadows on the Inyo, especially the Kern Plateau. Observations by 

national forest staff suggest that, even in allotments that remain open to livestock grazing, 

restoration and changes in grazing management appear to have improved stream and meadow 

condition overall (USDA Forest Service 2013a).

Riparian Ecosystems

Riparian ecosystems are a critically important component of biodiversity, supporting a higher 

concentration of species diversity than most terrestrial ecosystems. They serve in part as a link 

between aquatic and terrestrial ecosystems, and play numerous important roles within the broader 

landscape (such as providing for wildlife habitat including habitat corridors, nutrient cycling, and 

proper watershed function). Because they are cool and moist in the hot summer, they are also 

attractive for many uses such as grazing, camping, fishing, and hydropower production. Despite 

their importance, Kattelmann and Embury (1996) estimated that riparian vegetation currently 

makes up less than 1 percent of the Sierra Nevada bio-region.

Riparian ecosystems are formed by the interacting effects of flooding, soil wetness, water table 

level, proximity to streams, height above water level, sediment, and ice scouring. Riparian areas 

consist of vegetation commonly associated with standing or flowing water, such as willows, 

alders, aspen, and meadows (Manley et al. 2000). Meadows are areas where grasses, sedges and 

rushes are dominant and flowering plants common. Willows, alders, cottonwoods and other 

woody vegetation dominate non-meadow riparian ecosystems, but flowering plants, sedges, and 

grasses are often present. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

396

Riparian habitat is associated with the margins of seasonal and perennial drainages, and with 

seeps and wet meadow margins at scattered locations across the Inyo National Forest. Riparian 

habitat is dominated by willows including Lemmon’s willow (Salix lemmonii), Sierra willow (S. 

eastwoodii), Scouler’s willow (S. scouleriana), and mountain alder (Alnus incana spp. tenuifolia), 

with occasional quaking aspen (Populus tremuloides).

Riparian areas have an exceptionally high value for many wildlife species and are high in 

biodiversity due to the water, relative humidity, cooler temperatures and complex cover provided.

Riparian areas provide water, thermal cover, migration and movement corridors and diverse 

nesting and feeding opportunities for many species (Grenfell 1988). They also serve as important 

corridors for species dispersal. However, many montane riparian communities are currently 

grown in with conifers and other vegetation due to fire exclusion.

Status and Threats for At-risk Aquatic Species

Federally Listed Aquatic Species

Mountain Yellow-legged Frog (Northern Distinct Population Segment) and Sierra Nevada 

Yellow-legged Frog

Status: Both species of yellow-legged frog were petitioned for listing under the Endangered 

Species Act in 2000 and the U.S. Fish and Wildlife Service determined that listing was warranted 

as threatened or endangered for this species in 2003; however, the listing was precluded at the 

time based on other higher priorities (USDI Fish and Wildlife Service 2003). Both species were

listed as an endangered species in 2014 (USDI Fish and Wildlife Service 2014). Final critical 

habitat for each species was designated in 2016 (USDI Fish and Wildlife Service 2016a). For the 

mountain yellow-legged frog, there are seven designated critical habitat subunits covering 

approximately 221,498 acres within Fresno, Inyo and Tulare Counties, California. There are 

portions of three critical habitat subunits covering approximately 12,325 acres on the Inyo 

National Forest. For the Sierra Nevada yellow legged frog there are 24 designated critical habitat 

subunits covering approximately 1,082,147 acres within Lassen, Plumas, Sierra, Nevada, Placer, 

El Dorado, Amador, Calaveras, Alpine, Tuolumne, Mono, Mariposa, Madera, Fresno, and Inyo 

Counties, California. There are portions of six critical habitat subunits covering approximately 

97,046 acres occur on the Inyo National Forest. No recovery plan has been completed for either 

species.

The mountain yellow-legged frog occurs primarily west of the Sierra Nevada crest on the Sequoia 

and Kings Canyon National Parks near the border with the Inyo National Forest. On the Inyo, the 

California Department of Fish and Wildlife conducts surveys for this species and has determined 

that populations currently exist in the Mulkey Meadows and Coyote Creek areas (California 

Department of Fish and Wildlife 2017a).

The Sierra Nevada yellow-legged frog occurs primarily west of the Sierra Nevada crest in 

Yosemite and Kings Canyon National Parks. On the Inyo, the California Department of Fish and 

Wildlife conducts surveys regularly for this species and has determined that populations occur in 

10 management units identified by the State. These are located primarily in the Cathedral and 

Minarets critical habitat units in the Ansel Adams Wilderness west of Devil’s Postpile National 

Monument and June Lake and in the Mono Creek and Evolution/Le Conte critical habitat units in 

the John Muir Wilderness west of Bishop and Big Pine. A small portion of the Evolution/Le 

Conte critical habitat unit extends outside of wilderness in the Cow Creek and Baker Creek area. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

397

However, these populations are believed to have been extirpated in 2010 (California Department 

of Fish and Wildlife 2017a).

The California Department of Fish and Wildlife, in conjunction with the Inyo National Forest, has 

been removing nonnative fish in some lakes to allow for reintroduction of yellow-legged frogs 

(California Department of Fish and Wildlife 2017a). Other restoration efforts, such as inoculating 

the frogs against Bd fungus, have been attempted and may help recover the species in the future. 

These efforts are coordinated by the California Department of Fish and Wildlife or US Fish and 

Wildlife Service.

Threats: The 2014 conservation assessment for mountain yellow legged frogs provides a detailed 

examination of risks to the mountain yellow-legged frog complex throughout its range (Brown et 

al. 2014). Across the species range, it identified 13 risk factors relevant to land and resource 

management. Three are considered focal risk factors that are linked to declines: Introduced fish 

and other predators, disease, and habitat loss and fragmentation. Ten additional risk factors are 

within the authority of the Forest Service to address but are not currently linked to declines: fire 

suppression activities, habitat restoration, livestock grazing, locally applied pesticides, mining, 

recreational activities (including pack stock), research activities, roads, vegetation and fuels 

management, and water development and diversion. Of these, the most relevant to consider on the 

Inyo National Forest are: fire suppression activities, habitat restoration, livestock grazing, and 

recreational activities (including pack stock). These are similar to the risks identified by the U.S. 

Fish and Wildlife Service (USDI Fish and Wildlife Service 2016a).

• Introduced fish and predators: Predation by introduced fish, especially nonnative

salmonids (rainbow trout, golden trout, brook trout, and brown trout), is a recognized cause 

of decline of mountain yellow-legged frogs in the Sierra Nevada. In 2010, the California 

Department of Fish and Wildlife and U.S. Fish and Wildlife Service adopted direct that 

prohibits fish stocking where it conflicts with conservation goals of federal recovery plans 

or within federally designated critical habitat for considered species, which include the 

currently listed Sierran amphibian species (ICF Jones & Stokes 2010). Thus, fish stocking 

no longer occurs within the areas occupied by these species. Although continued fish 

stocking has ended, many trout populations are self-sustaining and are likely to continue to 

persist unless purposely removed. Study of areas with fish removal has shown success at 

improving yellow-legged frog populations. Some fish removal in native species restoration 

projects has been implemented by the California Department of Fish and Wildlife within 

the Inyo National Forest and additional opportunities for fish removal and subsequent 

reintroduction of yellow-legged frogs exist on the Inyo (California Department of Fish and 

Wildlife 2017a).

• Disease: The risk of disease, particularly chytridiomycosis, is a serious contributor to 

mountain yellow-legged frog declines. Major population crashes have resulted from 

chytridiomycosis infections, and the amphibian chytrid fungus, Bd, has been confirmed as a 

widespread threat to mountain yellow-legged frog persistence in the Sierra Nevada (Brown 

et al. 2014). Other pathogens may be contributors to declines, but their status is unknown. 

Of the 27 populations on Inyo National Forest, 10 of the 27 are Bd negative (California 

Department of Fish and Wildlife 2016). Populations that are Bd positive result in die offs or 

are persisting in the presence of Bd which is being investigated by researchers. The 

Conservation Assessment recognized that little can be done to manage for this risk factor 

unless vectors of these pathogens over which management can influence are identified and
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

398

unfortunately, the interactive effects between pathogens and other stressors remain largely 

unstudied (Brown et al. 2014).

• Habitat loss and fragmentation: Direct habitat loss is not a relevant factor for the Inyo 

National Forest given the extent of habitat and because the majority of populations and 

critical habitat are located in designated wilderness or in other remote areas. 

• Fire suppression activities: In the parts of the species’ range that occurs in wilderness 

areas, intensive fire suppression activities are rarely conducted and mechanized equipment 

generally is not used. In these remote areas, minimum-impact fire suppression techniques 

are used and may represent the best alternative to protecting mountain yellow-legged frogs 

and their habitat.

Concerns regarding the effects of aerial application of fire retardant on aquatic systems and 

federally listed species were addressed in the Forest Service decision that directs aerial 

retardant tanker pilots to avoid application of retardant or foam within 300 feet of 

waterways (USDA Forest Service 2011c). A “waterway” is considered to be any body of 

water including lakes, rivers, streams and ponds irrespective of whether they contain 

aquatic life. Although the initial analysis was completed prior to these species becoming 

federally listed, the analysis is being updated; areas to avoid for the mountain yellowlegged frog, Sierra Nevada yellow-legged frog, and Yosemite toad are currently included in 

aerial retardant avoidance maps.

• Livestock grazing: There is currently no livestock grazing within currently occupied 

habitats for Sierra Nevada yellow-legged frog, though active cattle allotments do contain 

designated but unoccupied critical habitat. One active cattle allotment, the Mulkey 

Allotment, does contain occupied mountain yellow-legged frog habitat. No other occupied 

mountain yellow-legged frog habitat is within any active allotment. As with the Sierra 

Nevada yellow-legged frog, there are other allotments that do contain currently unoccupied 

designated critical habitat. Within the Mulkey Allotment, as well as currently unoccupied 

allotments, riparian conservation area trampling standards minimize localized threats to 

habitat from livestock grazing. 

• Recreational activities, including pack stock: The risk level of recreational impacts to the 

mountain yellow-legged frog is unknown, but the nature of many recreational activities 

places humans in direct contact with mountain yellow-legged frogs or their habitat. Most 

recreational activities are localized, but in some cases, such as trails and campsites, 

activities are persistent and long term. In high-use areas, recreational activities are likely to 

add cumulatively to stressors on small populations, especially those already stressed with 

nonnative fish. Dispersed recreational activities such as hiking and camping, may pose a 

more moderate risk to the species because they may have localized impacts. Numerous 

areas in wilderness have restrictions on the number of visitors with or without pack stock 

and commercial pack stock is managed with quotas. These management restrictions are 

designed to limit the impact on resources while providing for the highest quality wilderness 

experience. No specific data exists for this risk factor relative to the mountain yellowlegged frog but the U.S. Fish and Wildlife Service stated that “[p]ackstock use is likely a 

threat of low significance to mountain yellow-legged frogs at the current time, except on a 

limited, site-specific basis” (USDI Fish and Wildlife Service 2014). Habitat changes due to 

pack stock grazing may pose a risk to some remnant populations of frogs and, in certain 

circumstances, may slow recovery of populations in heavily used areas, although no 

specific sites where this situation occurs are known.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

399

• Other risk factors: Locally applied pesticides, mining, research activities, and water 

development and diversion are other risk factors evaluated in the Conservation Assessment 

(Brown et al. 2014) that are not expected to be a substantial risk to yellow-legged frogs on 

Inyo National Forest. Since most occurrences are within wilderness, pesticide application, 

mining, and water development and diversion would rarely, or never, occur. Current Forest 

Plan direction (2004 Sierra Nevada Forest Plan Amendment) requires that any pesticide 

application within 500 feet of known occupied sites would avoid adverse effects to 

individuals or their habitats and future projects would require compliance with section 7 of 

the Endangered Species Act and consultation with the U.S. Fish and Wildlife Service as 

needed. Research activities affecting federally listed species require permits from the 

California Department of Fish and Wildlife and U.S. Fish and Wildlife Service, who will 

insure the species’ protection.

Four risk factors identified in the conservation assessment fall largely outside the authority 

of the Forest Service but have the potential to impact populations on a regional or global 

scale. These include acid deposition, airborne contaminants (including pesticides), climate 

change, and UV-B radiation. The Forest Service has few options to reduce the risk these 

factors pose to the two species of yellow-legged frogs and their habitat. The U.S. Fish and 

Wildlife Service determined that acid deposition, airborne contaminants, and UV-B 

radiation are not known to pose a threat (current or historical) to either species of yellowlegged frog (USDI Fish and Wildlife Service 2014). Climate change poses a substantial 

future threat to the persistence of both yellow-legged frog species given their highly aquatic 

nature. The effects can be expressed in a variety of ways such as changes in hydrological 

systems that reduce habitat quantity and quality or that contribute to other stressors that 

impact individuals and ultimately population persistence. Improving ecosystem integrity in 

the aquatic and riparian systems that provide yellow-legged frog habitats may ameliorate 

local risk factors by improving the resiliency of populations.

Yosemite Toad

Status: The Yosemite toad was listed as a threatened species in 2014 (United States Department 

of the Interior 2014). Final critical habitat was designated in 2016 to include approximately 

1,812,164 acres in Alpine, Amador, Calaveras, El Dorado, Fresno, Inyo, Lassen, Madera, 

Mariposa, Mono, Nevada, Placer, Plumas, Sierra, Tulare, and Tuolumne Counties, California. 

(United States Department of the Interior 2016a). Of the 16 critical habitat units, five are located 

on the Inyo National Forest, covering approximately 83,939 acres. Critical habitat Unit 15, Upper 

Goddard Canyon, has approximately 4 acres of overlap on the Inyo NF which are essentially 

small slivers along the national forest boundary with Kings Canyon National Park and are all in 

the John Muir Wilderness. A Recovery Plan for Yosemite toad has not been completed.

Yosemite toad occurs primarily along the Sierra Nevada crest and west of the crest. On the Inyo 

National Forest, populations occur in the Tuolumne Meadows/Cathedral critical habitat unit west 

of Mono Lake and in scattered populations in the Silver Divide and Humphreys Basin/Seven 

Gables critical habitat units from Devils Postpile National Monument south and east to the Gable 

Lakes area, which is west of Bishop. A small portion of critical habitat exists outside of 

designated wilderness in the Lake Mary area.

Threats: The conservation assessment for Yosemite toad was completed after the species listing 

and provides a detailed examination of risks to the Yosemite toad throughout its range (Brown et 

al. 2015). It identified several risk factors that currently are not likely to be major causes of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

400

rangewide declines but may be important in specific situations, particularly where toad 

populations are small. Seven of these factors are relevant to the Yosemite toad population on the 

Inyo National Forest, and could be affected by the Inyo’s management activities. These include 

(1) fire management, including fire suppression; (2) introduced fish and other predators; 

(3) livestock grazing; (4) locally applied pesticides; (5) recreational activities including pack 

stock; (6) roads; and (7) vegetation and fuels management. It further identified that legacy effects 

from some of these risk factors (such as livestock grazing) may have contributed to Yosemite toad 

declines, particularly those that resulted in meadow drying, shortened hydroperiods of breeding 

habitats, and potentially, lowered breeding success. Some improved management may have 

lessened the impacts of some of these risk factors but other legacy impacts may remain.

Other risk factors fall largely outside the authority of the Forest Service but have the potential to 

impact populations on a regional or global scale. These include acid deposition, airborne 

contaminants, including pesticides, climate change, disease, and UV-B radiation. The Forest 

Service has few options to reduce the risk these factors pose to Yosemite toads and their habitat. 

Climate change likely poses the most risk to the species given the Yosemite toad’s reliance on 

very shallow ephemeral water for reproduction. Reduced snowpacks may result in less available 

surface water, fewer breeding pools, and faster drying of breeding sites, all of which may lead to 

less successful reproduction. Early snowmelt and warmer temperatures may affect the Yosemite 

toad’s behavior, the timing of reproduction and other phenological events, the duration of tadpole 

development, and resulting effects on survivorship. Improving ecosystem integrity in the 

meadows and uplands that provide Yosemite toad habitats may ameliorate local risk factors by 

improving the resiliency of Yosemite toad populations.

• Fire management: Fire management, including suppression, has occurred since the early 

1900s and has resulted in changes to the fire regime with a longer fire return interval and 

subsequent increase in vegetation and fuels in some areas. This has led to an increase on 

many fires of higher fire severity effects when fires do occur and larger extent of fires 

where fuels have become more continuous. This effect has occurred slightly less in the 

higher elevations and remote areas where Yosemite toads occur due to naturally longer fire 

return intervals and sparser vegetation due to harsher conditions and shorter growing 

season. In addition there is an emphasis to use minimum impact fire suppression techniques 

within wilderness areas when fires do occur which has allowed some fires to burn more 

areas like they would have naturally.

• Introduced fish and other predators: Introduced fish and other predators is a legacy 

threat that lingers where introduced fish populations remain persistent. The California 

Department of Fish and Wildlife, working with the U.S. Fish and Wildlife Service, has 

reduced stocking to areas where native trout or other native aquatic species occurred (ICF 

Jones & Stokes 2010). While high mountain lake stocking ceased in 90 percent of 

previously stocked lakes by 2010 (Lentz and Clifford 2014); some high elevation waters 

still contain remnant populations from previously stocked fish. The conservation 

assessment discusses the risks of introduced fish on Yosemite toad and determined that the 

risk appears low and addressing the direct effects of introduced fish is not a high priority 

for conservation options (Brown et al. 2015). However, it recognizes that indirect effects to 

changes in food webs, nutrient cycling, and pathogen transmission are unknown and 

worthy of future studies.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

401

• Livestock grazing: Livestock grazing has not occurred within Yosemite toad habitat in 

recent years, as there are no active allotments within critical habitat. Therefore, livestock 

grazing does not affect the Yosemite toad on the Inyo National Forest. 

• Locally applied pesticides: While pesticides are rarely or never used within designated 

critical habitat for Yosemite toads, due to remoteness and lack of need, they could be used 

if an invasive weed species was thought to have potential for ecosystem impacts. Current 

forest plan direction (2004 Sierra Nevada Forest Plan Amendment) requires that any 

pesticide application within 500 feet of known occupied sites would avoid adverse effects 

to individuals or their habitats, and therefore pesticide use is not a threat within the plan 

area. 

• Recreation activities, including pack stock: Recreational activities, including pack stock 

grazing is widespread across the range of the Yosemite toad, and generally has high overlap 

with the species and its habitats because of the human attraction to meadows, ponds and 

other water bodies. The specific impacts of this risk factor to the species on Inyo National 

Forest are unknown. Recreation activities may locally affect meadow hydrology (as with 

pack stock grazing or a trail intercepting water flow) or potentially to the toads themselves, 

including in nonbreeding habitats. In general, the level of risk is low at the broader range 

scale because of the dispersed nature of many recreational activities. On the Inyo, 

numerous areas within wilderness have restrictions on the number of visitors with or 

without pack stock. Commercial pack stocks have limited quotas as well. These restrictions 

are designed to limit the impact on resources while providing for the highest quality 

wilderness experience. Commercial pack stock grazing is not allowed in occupied habitat 

until after the breeding cycle. The chronology is based on annual precipitation, for example 

in 2013 the “on-date” was July 23 and in 2017, following a record wet year, the “on-date” 

was determined to be August 10 for elevations between 6,000 feet to 8,000 feet and 

September 12 for elevations above 8,000 feet.

• Roads: The construction, reconstruction, and maintenance of roads as well as the use of 

roads can affect Yosemite toads by direct mortality of individuals moving overland or by 

impacts to habitat from changes in water flow or increased sediment. In the area of critical 

habitat outside Wilderness, several roads and campgrounds currently exist around Lake 

Mary, but are not known to be affecting the existing Yosemite toad population. The 

Yosemite toad sites near Crystal Lake and TJ Lake are within an inventoried roadless area 

and roads do not exist and road construction is unlikely.

• Vegetation and Fuels Management: Vegetation management could occur in the nonwilderness portions of the critical habitat near Lake Mary. Vegetation management would 

primarily be focused on improving the resilience of forest vegetation to contribute to the 

scenic character of this heavily used recreation area and providing for public safety by 

managing dead and dying trees. Fuels management, primarily management of surface and 

ladder fuels where they may increase the risk of adverse wildfire behavior and threaten 

recreation sites, could occur within around roads and campgrounds and facilities. This 

could involve large heavy equipment, but is more commonly accomplished by smaller 

equipment and work by hand and often involves piling and burning smaller fuels and 

prescribed burning.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

402

Lahontan Cutthroat Trout

Status: Lahontan cutthroat trout was listed as endangered in 1970 (USDI Fish and Wildlife 

Service 1970), but was subsequently reclassified as threatened in 1975 to facilitate management 

and allow regulated angling (USDI Fish and Wildlife Service 1975). Critical habitat has not been 

designated for this species. There is one “out-of-basin” population on the Inyo National Forest. 

Out-of-basin populations are those located outside of the historical range of the species. The 

species is managed according to the recovery plan published in 1995 (USDI Fish and Wildlife 

Service 1995b).

The Lahontan Cutthroat Trout Recovery Plan identified a criteria for delisting by population 

segment when management has been instituted to enhance and protect habitat required to sustain 

appropriate numbers of viable self-sustaining populations (USDI Fish and Wildlife Service

1995b).

The Lahontan cutthroat trout was established in O’Harrel Creek as an out-of-basin population and 

is the only occurrence of the species on Inyo National Forest. The fish occupy approximately onehalf mile of the 2-mile discontinuous stream that is located north of Benton Crossing in the Glass 

Mountains. The population is periodically surveyed by the California Department of Fish and 

Wildlife with population declines noted in recent years, which is suspected to be due to increased 

sediment from the 2007 “O’Harrel” fire.

In 2001, the 1,870 acre O’Harrel critical aquatic refuge was established to be managed for the 

recovery of this species (USDA Forest Service 2001b).

Threats: The severe decline in occupied range and numbers of Lahontan cutthroat trout in its 

endemic range is attributed to a number of factors including hybridization and competition with 

introduced trout species; alteration of stream channels and morphology; loss of spawning habitat 

due to pollution and sediment inputs from logging, mining, livestock grazing practices; 

urbanization; migration blockage due to dams; reduction of lake levels and concentrated chemical 

components in lakes; loss of habitat due to channelization; de-watering due to irrigation and 

urban demands; and overfishing (United States Department of the Interior 1995a). However, 

within the out-of-basin population along O’Harrel Creek, the following are relevant threats to 

consider.

• Loss of Habitat: For the out-of-basin O’Harrel population, the primary threat to the 

population is due to the habitat being essentially unsuitable for trout habitation. Streams on 

alluvial fans are subject to flashy flows and instability due to the alluvial nature of the 

substrate. Although much work has been completed within this channel to stabilize portions 

to create suitable habitat, portions of the stream are subject to low flows, high temperatures 

and constant re-location of the channel across the fan. Historic grazing in the area most 

likely created conditions that channelized the stream through the fan; however, now the 

channel is established and all occupied habitat is fenced and excluded from grazing. High 

volumes of sediment input, which define the geomorphology of alluvial fan development, 

are also a constant threat to the resident trout, as noted in the decline of population numbers 

resulting after the “O’Harrel” fire increased fine sediment input into the stream.

• Other Threats: Other threats include impacts from dispersed recreation activities and 

camping within the section of private land located at the middle of the available habitat. 

Since this activity occurs on private lands, it is outside the authority of the Inyo National 

Forest to manage.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

403

Paiute Cutthroat Trout

Status: The Paiute cutthroat trout was originally listed as endangered in 1967 (USDI Fish and 

Wildlife Service 1967) but was subsequently reclassified as threatened in 1975 to facilitate 

management and allow regulated angling (USDI Fish and Wildlife Service 1975). Critical habitat 

for this species has not been designated. A Recovery Plan for the Paiute cutthroat trout was 

developed in 1985, and revised in 2004 (USDI Fish and Wildlife Service 2004). The most recent 

5-Year Review was completed in 2013 (USDI Fish and Wildlife Service 2013).

The Paiute cutthroat trout occurs in two out-of-basin populations on Inyo National Forest in the 

North Fork of Cottonwood Creek and Cabin Creek, both in the White Mountains Wilderness. The 

North Fork of Cottonwood Creek population is limited to a 3.4 mile stretch of the uppermost 

portions of the creek that is isolated from other trout species by a natural barrier. The Cabin Creek 

population appears to have recently expanded downstream to Leidy Creek and appears isolated 

from other trout species by a diversion.

In 2001, the 28,770 acre Cottonwood Creek critical aquatic refuge was established around the 

genetically pure population of Paiute cutthroat trout. This population has been used in 2017 to 

augment existing populations in the native Silver King Creek on the Humboldt-Toiyabe National 

Forest.

Threats: The recovery plan (USDI Fish and Wildlife Service 2004) and subsequent 5-Year 

Review (USDI Fish and Wildlife Service 2013) was reviewed and two threats in the five-factor 

analysis were determined to be of higher concern to Paiute cutthroat trout and its habitat relevant 

to the plan area: Destruction or modification of habitat, and other natural or man-made factors.

• Destruction or modification of habitat: Nonnative fish pose a threat, primarily from 

hybridization that can result in loss of available habitat or range restrictions. Nonnative 

rainbow trout are present downstream of these two populations but are currently isolated by 

barriers: a natural barrier for the North Fork of Cottonwood Creek and an artificial barrier 

for Cabin Creek.

There are threats of population isolation and habitat fragmentation due to limited stream 

extents for these two locations, Neither of these populations meet long-term persistence 

criteria for the minimum amount of stream habitat thought to be necessary to sustain at 

least 2,500 individuals. The North Fork of Cottonwood Creek has approximately 3.4 miles 

of occupied habitat and Cabin Creek has approximately 1.5 miles of occupied habitat which 

are less than the 5.8 miles of stream habitat estimated to provide for persistence.

Historically, livestock grazing (both cattle and sheep) occurred over much of the high 

Sierra Nevada mountain range, wherever forage was available. Grazing of livestock is 

noted as having potential to degrade habitat for Paiute cutthroat trout. Considerable effort 

in the 1990s was put into reducing sediment input into the North Fork of Cottonwood 

Creek, along with the suspension of grazing in the Cottonwood Creek and Tres Plumas 

Allotments in 2000. The grazing allotments are in non-use status but are not closed. If 

stream and riparian conditions can be maintained or continue to improve, future use of the 

allotments could be considered but this would require a site-specific analysis that would 

require consultation with the U.S. Fish and Wildlife Service if it would affect this species. 

The removal of livestock has resulted in stabilized streambanks and the re-establishment of 

willows; however, spawning substrate is still a limiting factor in this high elevation, 

dolomitic-dominate landscape. Cabin Creek is located within the Cabin Creek Allotment 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

404

and grazing was authorized in the allotment in 2010 as a continuation of the grazing permit 

and is covered under Biological Opinion File No. 84320-2010-F-0088, dated June 1, 2010, 

by the Reno Field Office of the US Fish and Wildlife Service. However, the Cabin Creek 

area has not been grazed since 2005 due to restrictions in timing that are not compatible 

with the current grazing operation.

• Other Natural or Manmade Factors: Increases in water temperature as a result of 

increased summer air temperature and changes in precipitation affecting streamflow could 

increase stress levels which may increase the susceptibility to disease. Since a fungal 

disease already exists within the North Fork of Cottonwood Creek population, if stress 

levels increase, it could result in higher levels of post-spawning mortality which could 

affect the persistence of the population.

There is a risk of adverse effects if wildfires burn outside of the characteristic fire regime 

and affect occupied habitat because there are no opportunities for recolonization if the 

entire occupied segment is affected. Cottonwood Creek is a narrow boulder canyon with 

signs of single tree lightning strikes. North facing trees are widely spaced on the steep 

rocky slope. The opposite side is riparian vegetation then sage brush that is not likely to 

carry fire. Willows were planted following changes in grazing management and are well 

established in the creek and have enough dead woody debris to provide fuel. In 2017 the 

willow recruitment was in groups and not continuous, reducing the risk for fire to carry 

throughout the entire riparian of the North Fork of Cottonwood Creek.

Owens Tui Chub

Status: The Owens tui chub was listed as endangered and critical habitat was designated in 1985 

(USDI Fish and Wildlife Service 1985). Designated critical habitat in proximity to the Inyo 

National Forest includes portions of the Owens River Gorge and the springs and outflow channels 

at the Hot Creek Hatchery, which fall within private owned land within the Inyo administrative 

boundary but is mapped only on private lands and no critical habitat occurs on the Inyo. A small 

portion of the settling ponds of the Hot Creek Hatchery does extend on to the Forest but is not 

mapped as being critical habitat and genetic analysis has shown that the Owens tui chubs in this 

population are no longer pure and this population is not being managed for species recovery 

(California State Energy Commission 2012). Therefore, no designated critical habitat for the 

Owens tui chub occurs on lands managed by the Inyo National Forest and no critical habitat 

would be affected by any alternative.

When federally listed, the Owens tui chub was known from only two locations. Since listing, 

additional populations were established and there are now six recognized locations. Of those, 

three are located on the Inyo National Forest: Little Hot Creek Pond, Sotcher Lake, and a portion 

of the settling ponds at the Hot Creek Hatchery.

The Little Hot Creek Pond population is located in an artificial pond constructed in 1986 to 

enhance waterfowl habitat. In 2001, the Little Hot Creek critical aquatic refuge was established to 

protect these species. The area surrounding the pond is currently fenced to exclude livestock 

grazing and recreation use. The private land parcel upstream of the Little Hot Creek Pond is 

known as the Hot Creek Pit and is a former clay (kaolin) mine. It is unknown if any future 

activities are planned at this site. There are additional private land parcels downstream towards 

the Owens River. Agricultural and other land uses on the downstream parcels are expected to 

continue. The Little Hot Creek Pond is close to the national forest boundary and water 

withdrawals downstream and outside of the national forest are responsible for maintaining the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

405

barrier on Little Hot Creek which is required to avoid the risk of hybridization from contact with 

Lahontan tui chub.

The out-of-basin population in Sotcher Lake is believed to have originated from an accidental 

release associated with trout stocking from the Hot Creek Hatchery in the early 1950s (Chen, 

Parmenter, and May 2007). Sotcher Lake is in the heavily used recreation area around Reds 

Meadow near Devil’s Postpile National Monument. Little is known about this population.

The small portion of the settling ponds of the Hot Creek Hatchery extends onto the Inyo National 

Forest. However, the population of Owens tui chub in the settling pond have recently been 

studied by the California Department of Fish and Wildlife and it has been determined that they 

are not genetically pure because they have introgressed with Lahontan tui chubs. Since this 

population no longer contributes to the recovery of the species, it is not analyzed further in this 

document.

Threats: The Recovery Plan (United States Department of the Interior 1998) identified three 

categories of threats to be of higher concern to Owens tui chub and its habitat including: 

destruction, modification, or curtailment of habitat or range; disease or predation; and other 

natural and manmade factors.

• Destruction or modification of habitat: When originally listed, extensive habitat 

destruction and modification was the primary threat to the Owens tui chub (USDI Fish and 

Wildlife Service 1985). Currently, most streams and rivers in the Owens Basin have been 

diverted and some impounded. The Owens tui chub, which used to occur throughout the 

Owens River and its tributaries in the Owens Basin, is restricted to six isolated populations, 

five of which are within the historical range of the species. Of these five populations, three 

(Hot Creek Headwaters, Little Hot Creek Pond, and Upper Owens Gorge) are located in 

small, isolated, man-altered portions of these waterways. The other two populations (Mule 

Spring and White Mountain Research Station) exist in man-made ponds at upland sites with 

water supplied by artificial methods. The occupied habitat at Hot Creek Headwaters, Little 

Hot Creek Pond, White Mountain Research Station, and Mule Spring is 2 acres or smaller 

at each site. The habitats for these five populations are threatened by water diversions, 

failure of infrastructures that deliver water to these habitats, and/or emergent vegetation.

Most of the water rights in the Owens Basin are owned by the city of Los Angeles. 

Currently, the demand for water from the Owens Basin is high and growing as Los Angeles 

continues to grow. The Los Angeles Department of Water and Power operates and 

maintains dams, diversion structures, groundwater pumps, and canals to capture and 

convey much of the water from the Owens Basin to Los Angeles. Ground water, which 

provides water to isolated springs and springs that are the headwaters of streams in the 

Owens Basin, and surface water are also used extensively for agriculture and municipal 

purposes within the Owens Basin. These man-made changes to aquatic habitat in the 

Owens Basin dramatically reduced suitable aquatic habitat for the Owens tui chub. They 

reduced the occurrence of the Owens tui chub from a common, wide-ranging species in the 

Owens Basin to a rare species occurring at a few sites, representing less than 1 percent of 

the fish’s historical range (USDI Fish and Wildlife Service 1985).

In addition to the increasing water demands for the greater Los Angeles area, areas adjacent 

to the Owens Valley (such as Round, Chalfant, and Hammil Valleys) are growing, and the 

demand for water is growing. This increased demand has resulted in an increased 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

406

withdrawal of ground and surface water from the Owens Valley Groundwater Basin, which 

affects springs and other surface waters in the Owens Basin (Pinter and Keller 1991).

Habitat requirements for the Owens tui chub include aquatic submerged vegetation but not 

large amounts of emergent vegetation. At the Little Hot Creek Pond, invasive emergent 

plants (such as cattail) have altered the aquatic habitat. Cattail proliferation results in 

deposition of large amounts of organic biomass, eventually converting aquatic habitat to 

upland habitat (Potter 2004) which can result in a loss of habitat. In addition, dense 

emergent vegetation provides cover for nonnative predators, such as bullfrogs and crayfish. 

The area around Little Hot Creek pond was evaluated along with the California Department 

of Fish and Wildlife for management options for the emergent vegetation but the specific 

equipment needed wasn’t available and no project has been initiated to date.

• Disease or predation: Predation by introduced nonnative fish, specifically brown trout, has 

been a major threat to the Owens tui chub. Predation by nonnative largemouth bass and 

brown trout, both abundant in the Owens River system, has been identified as a factor 

eliminating Owens tui chubs from much of their historical range in the Owens River (Chen 

and May 2003). Much of the recreation-based economy of the Owens Basin depends on 

recreational fishing, primarily for trout and largemouth bass. Because of the miles of 

riverine habitat and the historical and current practice of angling in the Owens Basin, it is 

unlikely that it feasible nor desirable to eliminate them from the Owens Basin, nor would 

simply curtailing future stocking of these species eliminate them from the Basin.

Mosquitofish are abundant at Little Hot Creek Pond. It is known that mosquitofish will 

prey on small individuals of Mohave tui chub (Archdeacon and Bonar 2010), a similar 

species, but data are not available regarding mosquitofish interaction with the Owens tui 

chub. Observations over time suggest that the tui chub population at Little Hot Creek Pond 

appears to continue to reproduce and thrive in the presence of mosquitofish in this location.

Rainbow trout and brown trout exist within Sotcher Lake and continue to be stocked in that 

lake by the California Department of Fish and Wildlife (ICF Jones & Stokes 2010).

• Other natural or manmade factors: The introduction of Lahontan tui chub and 

subsequent hybridization and competition are major threats to the Owens tui chub. 

Although not discussed in the listing rule, stochasticity (random events), catastrophic 

events, and climate change are also potential threats given the limited distribution of 

remaining populations.

♦ Hybridization: Until recently, the Owens tui chub and the closely related Lahontan tui 

chub were isolated from each other. Lahontan tui chubs were introduced as baitfish into 

many of the streams in the Owens Basin. This was first observed at Crowley Lake in 

1973, where fishermen illegally introduced the Lahontan tui chub (Miller 1973). Since 

that time, hybridization between the Owens tui chub and Lahontan tui chub has been 

documented for several populations. At the time of listing, only three populations of 

genetically pure Owens tui chubs existed, while at the present time, there are six 

genetically pure populations.

Using Lahontan tui chubs in the Owens Basin as baitfish is not allowed under fishing 

regulations set by the State of California. However, Lahontan tui chubs and hybrids are 

already present in the Owens Basin including Crowley Lake, Hot Creek and tributaries, 

including Little Hot Creek, and the lower portion of the Owens Gorge. If man-made 

barriers isolating the Owens tui chub populations at these sites are degraded or 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

407

removed, this degradation/removal could result in the loss of the pure populations of 

Owens tui chubs. Currently, the only viable locations for establishing the Owens tui 

chub are isolated springs or the headwaters of streams with downstream barriers to 

upstream movement of Lahontan tui chubs or hybrids. Since the Little Hot Creek Pond 

is close to the national forest boundary, the barriers on Little Hot Creek are primarily 

water diversion for irrigation off the National Forest System lands that keep the natural 

creek from connecting with the Owens River.

♦ Competition: Competition with nonnative fish species is a threat to the Owens tui 

chub. However, little specific information on the impact of competition on the Owens 

tui chub is available in the literature. Nonnative insectivorous mosquitofish occur at the 

Little Hot Creek Pond. A major part of the diets for these nonnative species is the same 

aquatic insects consumed by Owens tui chubs. Although information is not available 

for rainbow trout completion and predation on this species, mosquitofish are known to 

affect some southwestern native fishes through competition and predation (Archdeacon 

and Bonar 2010).

♦ Stochasticity: The creation and maintenance of small, often intensively managed 

populations have prevented extinction of the Owens tui chub. Species consisting of 

small populations, such as the Owens tui chub with six isolated populations, are 

recognized as being vulnerable to extinction from stochastic (random) threats, such as 

demographic, genetic, and environmental stochasticity and catastrophic events.

Demographic stochasticity includes random variability in survival and/or reproduction 

among individuals within a population. Currently Owens tui chub populations are 

small; therefore, random events that may cause high mortality or decreased 

reproduction may have a significant effect on the viability of Owens tui chub 

populations. In small populations, such as the Owens tui chub, loss of individuals may 

reduce the amount of genetic diversity retained within populations and may increase 

the chance that deleterious recessive genes are expressed. Loss of diversity could limit 

the species’ ability to adapt to environmental changes and contributes to inbreeding 

depression (loss of reproductive fitness and vigor) and reduce the viability and 

reproductive success of individuals. Environmental stochasticity is the variation in birth 

and death rates from one season to the next in response to weather, disease, 

competition, predation, or other factors external to the population. Although they 

generally occur infrequently, catastrophic events, such as severe floods or prolonged 

drought, can have disastrous effects on small populations and can directly result in 

extinction. Multiple factors may also act in combination. One possible scenario of how 

these factors in combination could increase the risk of extinction for the Owens tui 

chub would be the loss of one or two populations during a drought period at the same 

time a predator is introduced to one of the remaining populations. Although one or two 

of the populations may survive and be a source for future reintroductions, the resulting 

loss of genetic diversity would further increase the risk of extinction.

♦ Climate Change: Impacts to the Owens tui chub under predicted future climate change 

are unclear. However, a trend of warming in the Sierra Nevada and Inyo Mountains is 

expected to increase winter rainfall, decrease snowpack, hasten spring runoff, reduce 

summer stream flows, and reduce ground water recharge. Increased summer heat may 

increase the frequency and intensity of wildfires. Loss of upland and riparian 

vegetation leads to soil erosion, increased sedimentation, downcutting of waterways, 

loss of bank stabilization, and decreased ability of soils to hold moisture and slowly 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

408

release it into nearby waterways, all of which would negatively affect Owens tui chub 

habitat. While northward and/or higher elevation habitats could be important factors in 

the future conservation of this species, currently the isolated populations of the Owens 

tui chub are unable to access these habitats because of other threats, including a lack of 

connectivity of habitats caused by physical barriers (dams and diversion structures); 

habitat destruction and alteration; and predation, competition, and hybridization with 

introduced species.

Aquatic Vertebrate Species of Conservation Concern

Fish and Amphibians

The key ecological conditions and key risk factors for these potential species of conservation 

concern center around aquatic or riparian habitats, even for the terrestrial species. For the one 

truly aquatic species, California golden trout, the key risk factor is related to sufficient water 

quantity in occupied streams. The other species are dependent on ponds, springs, seeps, streams 

or creeks and associated riparian habitats. Severe wildfire and trends in climate change generally

have a negative influence on water quantity and quality, and can change the distribution of these 

limited aquatic and riparian habitats. In addition, they can change where suitable habitats for 

these species exist on Inyo National Forest. Large changes in habitat can occur due to large areas 

burned by moderate or high severity fire, or by warming and drying conditions associated with 

climate change. Low and moderate severity fire effects likely benefit these species by improving 

vegetation condition and diversity without significantly affecting logs and riparian habitat. 

Changes can also occur at the local scale such as streambank impacts from livestock, recreation 

activities, roads, or trails, which can be important for these species with limited populations or 

limited habitat. For the more terrestrial salamander species ground-based disturbance from a 

variety of sources could directly impact individuals on the surface or under rocks, logs or forest 

litter. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

409

Table 65. Aquatic vertebrate species of conservation concern, ecological conditions, and primary stressors and threats to persistence on the Inyo 

National Forest

Species

Primary Ecosystem 

Assessment or Habitat 

Type (s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under 

Forest Service Control

Primary Stressors not under Forest 

Service Control

Inyo Mountains 

slender

salamander

Riparian Conservation 

Areas (Springs and Seeps); 

Sagebrush, Desert Riparian 

Habitats

Non pool forming seeps. Moist 

substrates (for egg laying) with 

riparian vegetation; canyons, 

solid-rock cliffs, areas where 

outcrops or talus are in contact 

with surface flow.

Fire suppression (use of 

drafting pumps); Grazing/feral 

burros; and water 

impoundments (reduction of 

water flow and increased 

sedimentation).

Disturbance of permanent seeps/springs 

associated with stochastic events 

(drought/flash floods) and climate change; 

high levels of endemism and naturally 

limited dispersal ability. Municipal water 

diversions and alteration of hydrological 

flow; mining.

Kern Plateau 

salamander

Riparian Conservation 

Areas (Springs and Seeps,

Perennial Streams, Wet 

meadows surrounded by 

mixed conifer (red 

fir/lodgepole pine) between 

4,690 to 9,190 feet

Perennially wet and moist habitat, 

usually associated with rocky 

outcrops or rock substrate, along 

the eastern escarpment of the 

Sierra Nevada Mountains.

Activities that disrupt water 

flow (Timber harvest, Fire 

suppression (use of drafting 

pumps); Grazing/feral livestock 

(reduction of water flow and 

increased sedimentation).

Disturbance of permanent seeps/springs 

associated with stochastic events 

(drought/flash floods) and climate change; 

high levels of endemism and naturally 

limited dispersal ability. Municipal water 

diversions and alteration of hydrological 

flow.

Black toad Sagebrush and Pinyon 

juniper, Riparian 

Conservation Areas 

(Springs and SeepsAntelope spring).

Short plant cover providing 

shaded/cooler environments; 

unobstructed access to still or 

slowly flowing water, rodent 

burrows in winter and shallow 

marsh and pond waters for 

breeding. 

Vegetation encroachment; 

Activities that disrupt water 

flow (Fire suppression-use of 

drafting pumps); Grazing/feral 

livestock (reduction of water 

flow and increased 

sedimentation).

High endemism, stochastic events (e.g. 

wildland fire, flash-flooding) that cause 

changes in timing and flow of water and 

water availability resulting from climate 

change and/or municipal water diversions.

California golden 

trout

Rivers and Streams Cold clean water with pooling 

habitat/undercut banks and 

emergent vegetation. Golden 

Trout Wilderness (South Fork of 

Kern River and Golden Trout 

Creek) 

Any activities that alter water 

flow and hydrologic regime 

(grazing and water 

impoundments).

Restricted distribution, genetic 

introgression and competition from 

nonnative fish species, 

endemism/localized extinctions, and 

stochastic events and drying conditions. 

Climate change (increased water 

temperatures and susceptibility to 

wildlife/sedimentation, reduced snow 

melt/precipitation).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

410

Black Toad

Status: The black toad is a restricted endemic, limited to several isolated populations in Deep 

Springs Valley in Inyo County within close proximity to the Inyo National Forest. The 

predominant population area is located on adjacent, private land. However, the Inyo will continue 

to provide additional (ephemeral) fringe habitat for dispersing adults. While the ecological 

conditions the black toad depends on appear generally stable and or trending in a positive 

direction based on current management, there is still substantial concern for the species 

persistence by simple virtue of its rarity and uncertain climate change related effects. As a result 

of this rarity and its limited distribution, this species is highly susceptible to stochastic events and 

drying conditions resulting from increasing temperatures and climate change. Its limited dispersal 

ability and isolated populations put it at further risk for localized extinctions and susceptibility to 

stochastic events.

Threats: Water flow disruption and climate change are threats to the black toad on the Inyo 

National Forest. Although these threats are largely outside of the control of the Inyo National 

Forest, the Inyo may contribute to the maintenance of spring sources within Deep Springs Valley, 

such as Sam’s Spring, which has historic artesian wells that maintain the existing habitat. Drying 

of springs and any activities or processes that disrupt water flow (such as water diversions and 

dams, in-stream mining, stream capping, feral livestock (burros and cattle), upstream water 

pumping) would lead to direct mortality (desiccation) and loss of habitat. (Wright et al. 2013) list 

the black toad as one of the ten most likely species to be affected by climate change. Under their 

modeling, the black toad could see a reduction in suitable habitat by up to 80% during the 

forecast period. Additional threats may include disease and geologic action.

Inyo Mountains Slender Salamander

Status: The Inyo Mountain slender salamander is a restricted endemic, limited to several isolated 

populations scattered throughout a small portion of the Inyo National Forest. It is known from 

fewer than 20 sites in the Inyo Mountains east of the Sierra Nevada range and there are relatively 

few recorded observations. Occupied sites are highly localized, springs surrounded by expanses 

of desert, and apparently isolated from each other. This distributional pattern results in a high 

potential for extirpations at the site level from stochastic events. Most known populations appear 

to be stable, although populations may have declined or been extirpated at a few sites due to 

habitat modification.

Threats: As a result of its rarity and its limited distribution, this species is highly susceptible to 

stochastic events such as drying conditions which may become more frequent with climate 

change. The Inyo salamander’s limited dispersal ability and isolated populations put it at risk for 

localized extinctions. The Inyo Mountains salamander is restricted to spring habitats so any 

impact that influences stream flow (including duration and quantity) would likely threaten 

population persistence. Past impacts to stream flow and riparian areas include the capping of 

springs, diversion of stream flow, in-stream mining, and disturbances to riparian areas from feral 

livestock (burros and cattle). This species is also vulnerable to climate change and any changes in 

precipitation patterns that influence spring discharge would likely result in a decrease in available 

habitat. (Wright et al. 2013) modeled that up to 50 percent of the suitable habitat could be reduced 

by 2050 as a result of anticipated changes to climate.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

411

Kern Plateau Salamander

Status: The Kern Plateau salamander is highly endemic and is largely restricted to the Kern 

Plateau and western portions of Owens Valley. This species occurs in perennially wet and moist 

habitat, usually associated with rocky outcrops or rock substrate, along the eastern escarpment. In 

the drier portions of its range, the spring and riparian habitats it occupies are fragile and 

vulnerable to damage.

Threats: The Kern Plateau salamander occurs in areas of permanent or seasonal surface 

moisture. Any activities that limit these microsite conditions could negatively affect the species. 

This includes management activities such as road construction, timber harvesting, fire 

suppression and habitat degradation through capping of springs or alterations of spring water or 

habitat. Habitat on the Inyo National Forest may be naturally limited and increased wildland fire 

events coupled with subsequent flash-floods that scour habitat are also potential risk factors. 

Persistence of the salamander populations may be closely tied to climate variations that affect 

their habitat, especially if they experience extreme drying trends, or stochastic events such as 

flash floods.

California Golden Trout 

Status: The California golden trout is an endemic fish species, limited to a small portion of 

suitable habitat on the Inyo National Forest. The California golden trout is native to Golden Trout 

Creek and the South Fork Kern River in the upper Kern River basin (Moyle 2002). Because the 

range of the trout has been severely reduced and is limited to two watersheds, this distribution 

makes the California golden trout vulnerable to stochastic events that can lead to localized 

extirpations or reductions in population size. Smaller populations are subsequently vulnerable to 

inbreeding which can influence long-term adaptability to changing environmental conditions.

Threats: Hybridization with rainbow trout, competition and predation from nonnative trout, 

grazing, recreation, limited distribution, and climate change.

The primary threats to California golden trout are hybridization with rainbow trout and 

competition and predation by brown trout (Moyle 2002) (Stephens, McGuire, and Sims 2004). 

Hybridization undermines the unique genetic integrity of the golden trout which may result in a 

loss of locally adapted genes to the species (Stephens, McGuire, and Sims 2004). Brown trout 

compete and prey upon the golden trout, even to the point of local extirpations. The California 

Department of Fish & Wildlife and the Forest Service have worked cooperatively to improve 

conditions for golden trout including removal of obviously hybrid fish, the establishment of 

barriers to prevent the upstream movement of fish other than golden trout, and the planting of 

sterile rainbow trout in popular recreational fisheries in close proximity to occupied golden trout 

waters (Stephens, McGuire, and Sims 2004). Grazing is another primary threat to the continued 

existence of golden trout (Moyle 2002) (Knapp and Vredenburg 1996) (Stephens, McGuire, and 

Sims 2004). Overgrazing may cause impacts to riparian and bank structure thereby affecting the 

instream habitats the trout rely upon. Climate change has the potential to further reduce the range 

of the California golden trout, primarily through increased water temperatures. The impact of 

recreation on the California golden trout is relatively minor; however, human activities can result 

in impacts to stream and riparian features and result in the reintroduction of undesirable fish 

species into occupied golden trout waters.

Aquatic Invertebrate Species of Conservation Concern
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

412

Table 66. Aquatic invertebrate species of conservation concern ecological conditions, and primary stressors or threats to persistence on the Inyo 

National Forest

Species

Primary Ecosystem 

Assessment or Habitat 

Type (s)

Special Habitat Needs/Key 

Ecological Conditions

Primary Stressors under 

Forest Service Control

Primary Stressors not under Forest 

Service Control

Western Pearl shell Rivers and Streams South Fork-Kern River; cold, 

clean water where sea-run 

salmon or native trout persist 

(documented host fish 

species critical to life cycle).

Activities such as grazing, water 

impoundments, dredging, and 

road construction that affect in 

stream flow hydrology and 

increase sedimentation.

Climate change (increasing water 

temperatures) is primary environmental 

stress. Anthropogenic stressors include 

municipal water diversions and related 

actions that reduce/alter hydrologic regimes 

including mining operations and suction 

dredge activities (regionally relevant, no 

mining or suction dredging within Inyo NF 

Pearl shell habitat).

Wong’s springsnail Springs and Seeps Uses escarpments of the 

White and Inyo mountains on 

the east side of the Owens 

Valley. Cold spring water 

sources with perennial flow.

Activities such as grazing, water 

impoundments, dredging, and 

road construction that affect in 

stream flow hydrology and 

increase sedimentation.

High endemism/restricted distributions and 

limited dispersal ability; stochastic events 

(e.g. wildland fire, flash-flooding) that cause 

changes in timing and flow of water and 

limited water availability resulting from 

climate change and/or municipal water 

diversions and ground water withdrawals.

Owen’s Valley 

Springsnail

Springs and Seeps Cold spring water sources 

with perennial flow.

Activities such as grazing, water 

impoundments, dredging, and 

road construction that affect in 

stream flow hydrology and 

increase sedimentation.

High endemism/restricted distributions and 

limited dispersal ability; stochastic events 

(e.g. wildland fire, flash-flooding) that cause 

changes in timing and flow of water and 

limited water availability resulting from 

climate change and/or municipal water 

diversions and ground water withdrawals.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

413

Springsnails require undisturbed springs. Even small water developments or disturbances can 

limit the ability of these species to use the area. Climate change is a substantial risk factor for 

many of these species because they have very limited distributions, and frequently disjunct 

populations. Springsnails are dependent on seeps and springs which can be affected by changed 

precipitation patterns. 

Western Pearlshell Mussel

Status: The western pearlshell has a broad distribution; however, it is in decline in most of its 

range and has been extirpated from many known localities. The causes for these declines, 

although not completely clear, are associated with anthropogenic changes to habitats that either 

influence physical habitat features or the fish hosts that the mussels rely upon for successful 

reproduction. Despite the broad distribution of this species throughout the western states, its 

decline has led to limited localities on the Inyo National Forest. On the Inyo National Forest, the

ecological conditions necessary for western pearlshell can be found in the South Fork Kern River 

and similar river systems, especially where the host fish species occur. Many western pearlshell 

populations are no longer recruiting new individuals or the recruitment levels are very low and, in 

some cases, die offs have been observed (Howard and Cuffey 2006; Hastie and Toy 2008; 

Howard 2008; Jepsen, LaBar, and Arnock 2012). 

Threats: River or stream impoundments probably have had the greatest impact on western 

pearlshell populations because hydropeaking water releases interrupt streamflow patterns 

(including timing, volume, and temperature), channel morphology, and influence the presence 

and density of host fish species. Many types of channel alteration can affect the stability of the 

streambed where mussels occur including suction dredge mining, gravel extraction, and channel 

dredging. If these activities occur in or in close proximity to pearlshell beds, the streambed may 

become unstable and detrimental changes to the channel can occur with effects to water velocity, 

water depth, and protection from increased shear stress. Because clear, cold water is a key habitat 

element required by the pearlshell, climatological changes that result in reduced streamflow, 

increased water temperatures, or both, may result in a further reduction in suitable habitat for the 

mussel or appropriate fish hosts. (Vannote and Minshall 1982) and Howard and Cuffey (2006)

attributed increased sediment with declines in M. falcata, implicating in-channel dredging, 

logging, and livestock use in the affected watersheds.

Wong’s and Owens Valley Springsnails

Status: The springsnails of conservation concern are restricted endemics with few known 

locations on the Inyo National Forest. Each population of springsnail is endemic to the spring it 

inhabits, and since these snails are obligatory aquatic throughout their entire life, they cannot 

disperse to other springs, nor can springs where snails have been extirpated be recolonized. Both 

species occur at Batchelder Springs. There is substantial concern for the species persistence due 

to its rarity and restriction to cold perennial springs and seeps. As a result of this rarity and its 

limited distribution, these species are highly susceptible to stochastic events and drying 

conditions resulting from increasing temperatures and weather events related to climate change. 

Threats: Threats include any activities that alter microsite conditions at perennial water sources. 

Activities such as overgrazing or water diversion projects may degrade or eliminate springsnail

habitat. Excessive sedimentation from a variety of activities such as logging, mining, road and 

railroad grade construction, and overgrazing may smother substrates causing death by preventing 

feeding and movement, and obstructing gills (Vannote and Minshall 1982, Hovingh 2004, Webb, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

414

Craft, and Elswick 2008, Bettaso and Goodman 2010). Additionally, water quality (temperature) 

and climate change are considered key risk factors.

Environmental Consequences to At-risk Aquatic Species

Consequences Common to all Alternatives

All alternatives contain protective measures, both through plan language and compliance with 

Endangered Species Act requirements that will generally protect aquatic species from direct 

effects of national forest management activities. 

All alternatives would retain riparian conservation areas with direction that protects aquatic 

habitats by providing guidance for protecting aquatic and riparian species during grounddisturbing management activities in riparian areas. Projects, guided by desired conditions, would 

implement standards and guidelines, including equipment limitations close to water and riparian 

vegetation. Established best management practices to protect water quality would be applied to all 

ground-disturbing projects (USDA Forest Service 2011d, 2013a). Best management practices are 

expected to benefit aquatic species habitat on a forestwide scale. The Inyo National Forest would

continue to follow agency direction to implement an annual best management practices 

evaluation and adaptive management program, following established agency monitoring 

protocols.

All alternatives would promote priority watershed restoration focused on maintaining or 

improving watershed conditions using the national Watershed Condition Framework as funding 

permits. Additionally, restoration of aquatic ecosystems is a regional priority as outlined in the 

“Ecological Restoration Leadership Intent” established by the Regional Forester (USDA Forest 

Service 2015g). The Inyo National Forest, with help from partners, is actively implementing 

restoration actions to reduce erosion on roads, trails, dispersed camping areas, grazed areas, and 

other developed and dispersed recreation sites. These efforts are expected to continue under all

alternatives, resulting in improved water quality and improved aquatic habitat conditions by 

reducing erosion and improving and restoring degraded areas.

Effect to aquatic species from livestock grazing will not vary by alternative, because the 

alternatives would have the same livestock management approach as under the current plan. 

Under all alternatives, grazing will be managed specifically to avoid negative effects to aquatic 

species through trampling standards, range readiness standards, utilization standards, and other 

protective measures. All permits contain language that livestock will not enter the allotment prior 

to range readiness. Within the plan area, California golden trout and the Mountain and Sierra 

yellow legged frog overlap with active allotments. Typically, spawning and egg-laying timing 

coincides with spring melt-off in suitable habitats and is a consideration addressed in determining 

the timing of “range readiness,” for grazing (see “Production Livestock Grazing” section).

Operations of dams, water diversions and groundwater extraction would continue under all 

alternatives, and there would be no difference in management of these water uses by alternatives. 

Therefore, effects to at-risk aquatic species would not vary by alternative. Under all alternatives, 

the Inyo National Forest would continue to work with partners such as the Federal Energy 

Regulation Commission and water users to minimize effects of these activities on species. 

However, many of these effects are largely outside the control of the Forest Service, and therefore 

dams and diversions will continue to have major effects to aquatic habitat and species on the 

Inyo, through affecting stream and spring flow. Effects to many of the at-risk species, such as 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

415

Yosemite toads and yellow-legged frogs, are largely unaffected by these activities because their 

habitat is upstream of almost all diversions and dams on the national forest.

Although on-the-ground vegetation treatments are expected to have a variety of long-term 

benefits, there is potential for short-term effects during and immediately following project 

implementation. In general, alternatives that manipulate more habitat would translate into more 

potential for disturbance to aquatic species and temporary disturbance to aquatic habitat 

conditions from the use of equipment or fire, until the habitat recovers. Treatments to improve 

fire resilience in both upland and riparian ecosystems over the long term would mitigate the 

short-term impacts to water temperature, riparian vegetation and other components that provide 

quality habitat for aquatic species. Alternatives that treat more areas would provide greater longterm benefits by restoring ecosystem integrity more aligned towards the natural range of variation 

that would be expected to provide greater resilience and greater sustainability of ecosystem 

functions of aquatic systems.

General Consequences of Alternative A

The aquatic management strategy would continue to be used to manage riparian habitats 

according to the riparian conservation objectives to maintain the ecology of riparian areas to 

buffer sediment from entering aquatic habitats. Standards and guidelines in the current plans 

emphasize protecting water quality and protecting riparian conservation areas by limiting active 

management within a variable buffer distance around riparian features. There is some ability to 

restore riparian vegetation structure and composition in alternative A but it is limited by 

restrictions on mechanical treatments within riparian conservation areas. The number of critical 

aquatic refuges would remain unchanged, so some watersheds containing refugia or 

concentrations of rare species would remain outside of a critical aquatic refuge. Because riparian 

conservation areas include most primary habitat for these species, their habitat has the same 

protections as critical aquatic refuges, but over a smaller area. The existing direction is sufficient 

to protect these species from direct project impacts, but does not protect against indirect impacts 

of future large fires as well as the plan revision alternatives.

Direction under this alternative has allowed for improvements to stream habitats by reducing 

erosion risk with actions such as decreasing trail and road density in riparian areas and meadows 

and removing or mitigating effects of dispersed camping from the edges of meadows and streams. 

Alternative A proposes the fewest number of meadows maintained, enhanced or improved and 

has some of the most restrictive constraints on use of restoration tools. Few areas would have 

conifers removed to restore more open meadow habitats. This alternative leaves meadow, seep, 

and spring habitats more vulnerable to wildfire outside the range of natural variability.

All alternatives allow removal of vegetation through hand thinning, mechanical treatments, 

prescribed fire, and wildfire managed to meet resource objectives as a means to improve the 

resilience of vegetation to stressors and move vegetation and ecosystem functions toward the 

natural range of variation. However, alternative A has the smallest acreage for prescribed and 

managed fire, and does not focus on reducing uncharacteristically large fires on a landscape scale. 

Therefore, the Forest will likely continue to have increased sediment from these fires, such as 

occurred after the O’Harrel fire in Lahontan cutthroat trout habitat. 

The desired conditions under the current management approach do not specifically consider 

climate change or climate-related stressors. Without addressing climate change stressors and the 

influence of various adjacent ecosystems on a larger landscape scale, this alternative makes it 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

416

more difficult for projects to strategically protect and improve the condition of riparian habitat 

than the other alternatives.

Alternative A includes some treatment restrictions within riparian conservation areas and critical 

aquatic refuges, which limits the extent of aquatic and riparian habitat restoration by preventing 

lighting of prescribed fires within riparian conservation areas or critical aquatic refuges. 

Improvement of aquatic habitat conditions is primarily related to mitigating the effects of 

sediment from roads, and addressing hydrologic connectivity from road culverts and stream 

crossings. While hydrologic connectivity is addressed generally under this alternative, 

maintenance of aquatic habitat connectivity was only emphasized for some aquatic species, 

primarily trout. Restoration of aquatic habitat connectivity by improving road crossings or 

mitigating water diversions would be expected to occur at a slow pace. Under this alternative, the 

limited implementation of restoration is expected to leave many areas containing native at-risk 

aquatic species untreated and vulnerable to increased sediment input from uncharacteristically 

large fires. 

Restrictions on mechanical treatments also limit the ability to adequately reduce fuel volumes in 

riparian conservation areas to safely incorporate prescribed fire and reduce the threat of wildfire 

spread in riparian habitats. Additionally, prescribed fire restrictions in riparian areas limit direct 

fire ignitions, which reduce the ability of fire managers to create a patchy mosaic within riparian 

areas to lower the risk of riparian vegetation burning at high intensity during wildfires. There is 

less control of fire intensity and spatial burn patterns when fire is only allowed to back down into 

riparian areas compared to fire managers using direct ignition methods to more closely control the 

fire burn patterns and fire behavior. Lack of managed fire ignitions in this habitat restricts the 

ability of fire managers to control how the fire behaves and create a patchy mosaic of low and 

moderate-severity fire effects. Although managed wildfire is considered a tool under this 

alternative, the unnaturally dense vegetation conditions of many riparian habitats and mechanical 

treatment restrictions make the use of this tool for the benefit of riparian habitat improvement 

unlikely in most situations, except in the higher elevation areas.

Given the limited amounts of fuel reduction treatment, this alternative does not substantially 

improve the resilience of the overall landscape to wildfire. The burned area under this alternative 

is predicted to increase two to four times compared to alternatives B, B-modified and D, and 

much of the change would be in increasingly larger fires that are predicted to have large patches 

of high-intensity and high-severity fire (see the “Fire Trends” section), which is more likely to 

remove large areas of riparian vegetation (Elliot, Miller, and Audin 2010). High-severity fire can 

dramatically increase overland water flow and peak flows, triggering severe flooding and erosion 

(DeBano et al. 1998, Neary et al. 2005). High-severity wildfires increase runoff and erosion rates 

by two or more orders of magnitude (Elliot, Miller, and Audin 2010). Therefore, under this 

alternative, more acres of aquatic habitat remain at risk of being adversely affected by the 

increasing trend in large, high-intensity wildfire and the resulting increases in surface erosion and 

sediment delivery to aquatic habitats.

General Consequences Common to Alternatives B, B-modified, C, and D

Current forest plan direction for invasive species is focused primarily on invasive plants and does 

not explicitly address other invasive species. For alternatives B, B-modified, C, and D, direction 

is expanded to include terrestrial and aquatic invasive species through forestwide guidance to 

control, or eradicate when possible, and prevent establishment of new populations of aquatic 

invasive species. Riparian conservation area desired conditions include direction to work with 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

417

State and Federal wildlife agencies to reduce impacts of invasive species to native aquatic species

populations. All plan revision alternatives include forestwide direction to clean equipment when 

moving from waterbodies with known aquatic invasive species thus reducing risk of invasive 

species becoming established (INV-FW-STD-01).

All plan revision alternatives provide direction for aquatic ecological restoration and attempt to 

mitigate effects of climate change at varying scales. They include goals to mitigate climate effects 

through riparian vegetation and aquatic system restoration to maintain or reduce water

temperatures and prevent erosion for the benefit of at-risk aquatic species.

General Consequences of Alternative B

Alternative B is anticipated to improve aquatic habitat conditions at the landscape scale. The 

increased pace and scale of restoration treatments under this alternative, along with a focus on 

landscape-level improvements and an emphasis on prescribed fire and wildfire managed to meet 

resource objectives is predicted to result in forest landscapes with a stronger resilience to large, 

high-intensity fires. The ability to use more mechanical treatments and natural fire tools under 

this alternative translates into a greater ability to adapt to climate change than alternative A. The 

focus on a landscape treatment approach, combined with riparian conservation area direction, is 

designed to reduce the negative effects of wildfire on aquatic habitats more effectively than the 

scattered treatment approach of alternative A and the limited treatment approach of alternative C.

Alternative B proposes to designate one additional critical aquatic refuge to protect additional atrisk aquatic species habitats. The direction for managing critical aquatic refuges is similar to 

alternative A. Although additional designation may be a benefit, more critical aquatic refuges do 

not necessarily translate into improved aquatic habitat conditions within the designations. 

Restrictions on treatment options and constraints on the use of restoration tools would continue to 

limit some restoration opportunities which could reduce the potential to build adaptive capacity to 

climate change for some at-risk species.

The additional critical aquatic refuge identified surrounds a population of black toads. This 

additional critical aquatic refuge would add some minor protections for the toad relative to 

alternative A. Additionally, strengthened direction for management of at-risk species and upland 

portions of watersheds is strengthened forestwide, and applies to all watersheds would improve 

protection for black toad habitat.

Alternative B proposes to maintain, enhance or improve more meadows than alternative A, a 

similar number of meadows as alternative D, and fewer meadows than alternative C. Riparian and 

meadow vegetation restoration under this alternative would be for the purpose of moving 

vegetation toward desired conditions and would be intended primarily to restore native species 

composition, heterogeneity, resilience, and reduce the ingrowth of conifers and shrubs. Removal 

of conifer species in meadow habitats, particularly lodgepole pine, can increase the water table 

and provide better wet meadow, seep and spring habitat conditions. Increased standing water in 

meadow habitats would improve the vegetation structure and complexity, thereby improving 

habitats for at-risk aquatic species. The end result of the treatments under this alternative would 

generally be improved riparian hardwood composition and structure, increased herbaceous 

density, vigor and structural complexity, and increased amounts of surface water.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

418

Alternative B includes an increased emphasis on partnerships to accomplish meadow restoration. 

Under this alternative there is also greater potential for stewardship funding to address meadow 

and riparian restoration work.

This alternative manages the same riparian conservation areas as alternative A and uses the full 

suite of plan components (desired conditions, standards and guidelines, goals) to better move 

riparian ecosystems toward resilience to fire and climate change. The management approach 

under alternative B proposes to maintain, enhance, or improve more acres of riparian habitat than 

alternative A and with a greater variety of restoration tools including mechanical thinning, 

prescribed fire, and wildfire managed to meet resource objectives.

Alternative B modifies direction in alternative A by allowing more flexibility to use prescribed 

burning and more mechanical and hand treatments to improve riparian resilience to fire, drought 

and climate change. Although mechanical equipment use in riparian habitat could occur under 

this alternative, these treatments would be for the purpose of reducing high fuel loads to prepare 

riparian areas to be treated by prescribed fire methods. Overall, over the long term, these 

restoration actions are anticipated to result in providing more productive site conditions, which 

would result in improved aquatic habitat conditions.

Alternative B also allows for direct ignition of prescribed fire in riparian areas which is predicted 

to greatly improve the resilience of riparian habitats because fire is introduced back onto the 

landscape in a controlled and purposeful way. All restoration that results in a reduction of upland 

conifers in riparian areas would restore riparian vegetation composition and structure. This would 

increase sunlight for riparian hardwoods and shrubs that are often shaded out by upland trees and 

shrubs. Prescribed fire and wildfire managed to meet resource objectives would improve the 

condition, vigor and health of most native riparian plants that support a variety of riparian system 

functions. Increased structural diversity of these habitats would enhance use by a variety of 

species strongly associated with complex understory and overstory. Increased fire would result in 

increased sprouting of native vegetation, and improved health, condition, and vigor of hardwood 

and understory plants, including host plants for a variety of invertebrates. The trend in 

composition and structural heterogeneity of native species would increase under this alternative.

General Consequences of Alternative B-modified

In alternative B-modified, critical aquatic refuges are not identified. All existing critical aquatic 

refuges would be eliminated. Elimination of critical aquatic refuges would not result in fewer 

protections for at-risk aquatic species. Plan components addressing specific at-risk species, and 

forestwide upland components that would apply to all watersheds, along with riparian 

conservation area direction that is the same under all alternatives, would maintain or increase 

protection of these species relative to alternative B. 

Conservation watersheds are associated with several populations of at-risk species and areas that 

are priorities for aquatic and riparian restoration. They were designed to address landscape-scale 

processes, to maintain functionality of watersheds, and not just focus on a small species-specific 

area. The effects should be a more widespread improvement to habitat conditions, providing 

greater resilience to the effects of stochastic events by allowing for greater species dispersal and 

more areas providing refugia to these species. When coupled to forestwide watershed, riparian 

conservation area, and stronger species plan components, each operating at different scales, it is 

expected that the overall approach will have positive effects on species viability and persistence.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

419

The consequences of differences in managing for critical aquatic refuges in alternatives A, B, C, 

and D and conservation watersheds in alternative B-modified is described in the species-specific 

sections below and discussed in the Conservation Watershed white paper in the project record. 

General Consequences of Alternative C

Alternative C proposes to reduce high-intensity fire risk by increasing the use of prescribed fire 

and wildfire managed to meet resource objectives, instead of mechanical treatments. The pace 

and scale of treatments are not sufficient to reduce the long-term negative effects from highintensity wildfire across the landscape. Since climate change is likely to increase the risk of highintensity wildfire, overall watershed function would decline under alternative C (see “Fire 

Trends” section).

Alternative C proposes to designate 8 additional critical aquatic refuges on the Inyo National 

Forest. Therefore, there would be protection of more aquatic habitat in these designated areas 

than under alternatives A and B. Overall this is viewed as a positive improvement over 

alternatives A and B but not without potential negative short-term consequences. As described 

under alternative B, restrictions on treatments in these areas could unintentionally prevent needed 

restoration work that removes or mitigates stressors within these systems.

Riparian and aquatic restoration work to help offset impacts of climate change on stream 

temperatures and availability of water would likely be limited to existing and new priority 

watersheds and to completing essential projects within those watersheds. The riparian element 

would not likely change in the short term but would decline over the long term due to the limited 

pace and scale of ecological restoration of adjacent uplands, except where restoration of riparian 

structure and native species occurs.

Since alternative C does not limit watershed restoration and could use additional sources of 

funding and assistance through partnerships to address aquatic habitat conditions, the pace and 

scale of meadow restoration may increase relative to alternative A.

This alternative proposes to maintain, improve, or enhance the most meadows. More restoration 

is proposed because hand equipment, prescribed fire, and wildfire managed to meet resource 

objectives may more rapidly treat smaller meadows with less severe conifer encroachment, 

invasive species, and issues related to water retention. In contrast, alternative B may treat larger 

meadows with more complex issues because mechanical treatments can be used as a precursor to 

burning. Alternative C emphasizes the use of prescribed fire and wildfire managed to meet 

resource objectives to accomplish restoration and proposes to use more prescribed fire and 

managed wildfire than alternative A. Therefore, the treatments under this alternative have a 

greater potential than alternative A, but less than B to restore or improve meadow habitat 

conditions. This could provide slightly greater improvements to habitat conditions for at-risk 

species dependent on shallow groundwater than alternative A.

Although there is less potential for short-term, implementation-related impacts under this 

alternative because of fewer mechanical treatments, there could be long-term negative impacts on 

habitat conditions because of the treatment limitations compared to the other plan revision 

alternatives.

Alternative C does not modify direction to allow flexibility to use more prescribed burning, 

mechanical treatments, or hand treatments for riparian resilience to fire, drought, and climate 

change. Under this alternative, the use of prescribed fire to treat riparian areas would be 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

420

constrained because of species-specific protections (not a landscape approach) and excessive fuel 

loading in riparian areas that could not be treated with mechanical treatments before using 

prescribed fire. This alternative has the most area with a passive management approach with 

potential for repeated prescribed fire treatments in riparian areas. This alternative does not treat at 

the landscape scale, making habitat patches more vulnerable to a variety of stressors adjacent to 

riparian zones, including loss from wildfire, ingrowth of conifers from adjacent upland units, and 

spread of invasive species. This alternative has a lower ability than alternative B to move the 

landscape toward resilience to climate change and continues to have a low resiliency to large 

high-intensity wildfire. As a result, aquatic habitat under this alternative would be at a greater risk 

to degradation from untreated stressors and large-scale disturbances.

Similar to alternative A, this alternative does not substantially improve the resilience of the 

overall landscape to wildfire given the limited amounts of fuel reduction treatment. This 

alternative treats only a small proportion of the lands needing treatment to substantially reduce 

the risk of large-scale high-intensity wildfires. The burned area under this alternative is predicted 

to increase and result in increasingly larger fires with large patches of high-intensity and highseverity fire (see “Fire Trends” section). This is more likely to remove large areas of riparian 

vegetation (Elliot et al. 2010), dramatically increase overland water flow and peak flows, and 

potentially trigger severe flooding and erosion. Therefore, under alternative C, more acres of 

aquatic habitat and the condition of that habitat is anticipated to be adversely affected by the 

increasing trend in large, high-intensity wildfire and the resulting increases in surface erosion and 

sediment delivery to aquatic habitats.

General Consequences of Alternative D

Under this alternative, the critical aquatic refuges and plan direction and effects would be the 

same as in alternative B. More opportunities exist for implementing watershed restoration 

projects than in any other alternative, which results in increase in overall long-term ecological 

restoration. More treatment within watersheds should reduce the acreage that wildfire burns at 

high severity, would make the landscape more resilient to climate change, and in the long term, 

achieve the greatest improvements to aquatic habitats than any other alternative.

The emphasis on low- and medium-intensity fires across the landscape including within the 

riparian areas limits the accumulation of fuels, and encourages healthy functioning aquatic 

habitats and therefore, the long-term potential for indirect impacts of sediment flows to streams 

from wildfire is lower than all other alternatives considered in detail (See “Fire Management” 

section). 

Under alternative D, water quality and aquatic habitats would be improved where restoration of 

watersheds occurs, especially in meadows and associated riparian areas. This alternative would 

provide the most improvements to groundwater storage, base flows, and surface water due to 

slightly higher infiltration rates across the landscape. This in turn would result in lower water 

temperatures during the dry season. Encouraging shallow groundwater storage potentially 

mitigates some of the impacts from climate change by increasing aquatic ecosystem resilience, 

providing more stable stream flows, and benefitting aquatic species dependent on springs. 

Alternative D would maintain, enhance, or improve more meadows than alternative A and would 

be the same as alternatives B and B-modified. Restoration of meadows and aquatic systems and 

protection of aquatic habitat would improve resilience as in alternatives B, B-modified, and C but 

on an increased number of acres under alternative D. Alternative D would allow increased use of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

421

mechanical equipment in the riparian conservation areas to improve conditions. By treating more 

areas, alternative D would reduce the risk of uncharacteristically large wildfires more than the 

other alternatives, thus reducing the risk of undesirable short-term impacts to aquatic habitats 

from high-intensity wildfire while still allowing for the historically beneficial role of fire to be 

expressed. Increased fire resilience would result in long-term benefits to watersheds and riparian 

areas more than all other alternatives.

An increase in ecosystem restoration could have short-term negative consequences to aquatic 

species, particularly where mechanized treatments are used to restore riparian vegetation. This 

alternative may have short term impacts for aquatic species habitats from ground-disturbing 

activities. These short-term consequences on riparian species diversity are balanced favorably 

against the long-term benefits of creating more sustainable landscapes that have more resilience 

to changes from wildfire, climate change, and other stressors.

Species-specific Consequences

Sierra Nevada and Mountain Yellow-legged Frogs (Endangered)

Consequences Common to All Alternatives

The majority of the designated critical habitat for the mountain yellow-legged frog and Sierra 

Nevada yellow-legged frog in the Inyo National Forest plan area is within designated wilderness 

areas. Within designated wilderness, active, ground-disturbing management, such as direct 

vegetation management, prescribed burning, and habitat restoration, generally would not occur. 

However, habitat restoration specifically designed for frogs may occur and could occur using the 

same methods and in the same areas under all alternatives. Within designated wilderness, since 

direct restoration of habitat involving ground-disturbing action will be limited, the primary means 

of achieving restoration of aquatic habitats will be passive managing actions or small-scale 

restoration such as moving trails away from breeding habitat.

Livestock occurs in only one area currently occupied by Sierra Nevada yellow-legged frog and 

mountain yellow-legged frog on the Inyo, in the Mulkey Allotment in the area around Mulkey 

Meadows, which could affect the mountain yellow-legged frog. There is current livestock grazing 

in designated critical habitat. 

None of the alternatives directly change the status or use on individual allotments, nor do they

substantively change current direction for livestock grazing. As described elsewhere, in the plan 

revision alternatives, process-related language is removed from the forest plan and is issued as 

supplemental implementation guidance so it can be kept more current as protocols improve with 

better knowledge. This change for administrative purposes is not expected to change any on-theground action or activity related to livestock grazing and would not differ by alternative. These 

guidelines should continue to protect habitat for both yellow-legged frog species under all 

alternatives.

Other than fire management, habitat within critical habitat areas, largely within wilderness, will 

remain essentially undisturbed by management activity, but meadows and streams used by these 

species may be exposed to periodic, low-level, recreational use by individuals, small groups of 

hikers and recreational pack stock. Current use levels collected during wilderness permit issuance 

show that use is low to moderate and has decreased over past historic levels. Under all 

alternatives, within designated wilderness, if the level of recreation use were found to be 

adversely impacting these species, the plan provides guidance to mitigate the effects. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

422

Within the small areas outside of wilderness in the Evolution/Le Conte critical habitat subunit for 

Sierra Nevada yellow-legged frog, recreation activities are expected to continue because of the 

road access. There are no known conflicts with recreation at these sites.

There are no effects from roads and other infrastructure that would affect the northern distinct 

population segement of the mountain yellow-legged frog because all occupied habitats and 

critical habitats are located within designated wilderness. Within the portion of the Evolution/Le 

Conte critical habitat unit for the Sierra Nevada yellow-legged frog, road maintenance would 

occur as needed along the existing roads. However, any road maintenance activities in this area 

would be designed to avoid, mitigate, or minimize effects to the Sierra Nevada yellow-legged 

frog and consultation would occur if any project may affect the species or its habitat. Because of 

the proximity to Baker Creek and other streams in the area, additional direction to protect riparian 

conservation areas would also apply to many road related activities that might be proposed.

Consequences Specific to Alternative A

Alternative A does not define specific forest plan direction regarding fire management strategies 

outside of the wildland-urban interface that address at-risk species. However, national forest staff 

can evaluate naturally ignited wildfires on a case-by-case basis to determine if they could be 

managed to meet resource objectives. Because the emphasis is not on landscape-scale natural fire 

regimes, habitat, alternative A is the least likely to return natural fire to the landscape within 

yellow-legged frog habitat, and long-term effects of fire suppression will likely continue, 

including increased risk of uncharacteristically large fires and subsequent increase in sediment 

input into habitat. 

Consequences Common to Alternative B, B-modified, C, and D

In designated wilderness, the desired condition for the two yellow-legged frog species will 

primarily be attained through managing wildfires by considering the expected fire effects on 

habitats and striving to maintain and restore fire as an ecological process. While managing 

wildfires to meet resource objectives is also allowed under alternative A, resource objectives in 

the forest plan would be more clearly defined in alternatives B, B-modified, C and D, thus 

making it simpler to evaluate and manage selected wildfires that are appropriate for this strategy.

Effects to yellow-legged frog species will be considered when determining whether to manage 

wildfires for resource protection, and improve overall watershed resilience to stochastic events, 

therefore improving the long-term habitat condition for the frogs.

Only a small portion of critical habitat for the Sierra Nevada yellow-legged frog occurs outside of 

the John Muir Wilderness on the Evolution/Le Conte critical habitat unit in the Coyote Flat area. 

This area has mostly shrub or sparse subalpine conifers, and would not likely have mechanical 

vegetation treatment. Therefore, though there could be more mechanical treatment throughout the 

Forest, it is unlikely to lead to a difference in effects to either yellow-legged frog species between 

the plan revision alternatives.

Consequences Specific to Alternative B-modified

Alternative B-modified could have slightly different effects to yellow-legged frog species due to 

conservation watersheds being used, and no designation of critical aquatic refuges. This could 

slightly improve overall watershed condition due to a holistic management direction for the 

conservation watershed allowing for greater resilience to climate change and stochastic events. 

However, because almost all critical habitat for these species is within designated wilderness, the 

management within critical habitat will have few, if any, differences. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

423

Yosemite Toad (Threatened)

Consequences Common to All Alternatives

The majority of the designated critical habitat for the Yosemite toad on the Inyo National Forest is

within designated wilderness areas. In these areas, active, ground-disturbing management, such as 

direct vegetation management or prescribed burning would occur in very limited situations, if at 

all. In designated wilderness, the desired condition for Yosemite toad will primarily be attained 

through guiding decisions related to managing wildfires by considering the expected fire effects 

on habitats to provide benefits for resources and striving to maintain and restore fire as an 

ecological process. While this primary approach is common across the alternatives, there are 

some differences in the plan direction for how and where fires are managed and this will be 

evaluated more specifically by alternative.

Other than fire management, habitat within wilderness areas will remain essentially undisturbed by 

management activity, but meadows and streams used by these species may be exposed to periodic, 

low-level, dispersed wilderness travel, by individuals and small groups of hikers primarily on trails.

Recreationists are often attracted to meadows and viewing and photographing wildlife is a substantial 

attraction. If recreation disturbances were found to be causing an adverse effect, under all 

alternatives, the Inyo staff would work with the California Department of Fish and Wildlife and the 

U.S. Fish and Wildlife Service to determine what mitigations might be needed.

Recreational pack stock use could impact individuals or habitats if it occurs in breeding and rearing 

habitat prior to metamorphosis. Current pack stock use levels across the national forest, collected 

during wilderness permit issuance, show that use is low to moderate and has decreased over past 

historic levels. Commercial pack stock use is prohibited by a court order that restricts pack-stock 

grazing in occupied Yosemite toad breeding and rearing habitat through the time of toad 

metamorphosis. This is not expected to change, and if there were changes, there would be 

required subsequent environmental analysis and would not vary by plan alternative. These 

restrictions are consistent with the forestwide plan direction to consider project timing for 

projects that may affect occupied habitats for at-risk species.

The risk of adverse effects to critical habitat occurs primarily in the small portion of critical 

habitat located outside of designated wilderness around Lake Mary. In this area, active 

suppression of wildfires might occur to protect life and property, and this is unlikely to vary by 

alternative in this area heavily used for recreation. Active fire suppression could result in some 

risk of adverse effects but would be subject to emergency consultation to minimize effects. 

Similarly, there could be a need and opportunities for vegetation and fuels management to reduce 

fire risks and to provide for public safety given the heavy recreation use that occurs in this area; 

however, this would not be likely to adversely affect critical habitat as there is plan direction that 

provides for riparian conservation areas that would apply to meadows and projects that occur in 

critical habitat or that could affect Yosemite toads would require consultation with the U.S. Fish 

and Wildlife Service. Restoring fire to the ecosystem would benefit critical habitat by reducing the risk 

of post-fire sediment affecting aquatic habitats.

If restoration or other project activities are proposed around meadows and ponds occupied by 

Yosemite toads, they would be guided by direction for riparian conservation areas to maintain or 

improve the ecological conditions that contribute to the recovery of threatened and endangered 

species and would be designed to include design features, mitigation, and project timing 

considerations that would avoid, minimize, or mitigate effects to occupied habitats. The Inyo 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

424

National Forest would continue to consult with U.S. Fish and Wildlife Service on all site-specific 

projects under all alternatives.

The use of pesticides within critical habitat and occupied habitat would continue to be limited for 

treatment of invasive plant species, and possible treatment within campgrounds for vector control 

of disease from rodents. In all cases, plan direction requires that any pesticide application within 

500 feet of known occupied Yosemite toad sites would avoid adverse effects to individuals or 

their habitats and future projects would require compliance with section 7 of the Endangered 

Species Act and consultation with the U.S. Fish and Wildlife Service as needed.

Outside of designated wilderness there are existing roads around Lake Mary but no roads around 

the other occupied sites (Crystal Lake and T.J. Lake). Since the area around Lake Mary has 

heavily used existing developed recreation facilities, roads will likely be maintained to a standard 

that supports the higher use levels, similar to the current condition. Although alternative Bmodified identifies this area as a destination recreation area where management of impacts from 

recreation would be greater than other areas on Inyo National Forest, that designation would not 

change on-the-ground conditions relative to the current situation. Currently, recreational activities 

are not known to be negatively affecting current Yosemite toad populations, and that will continue 

under all alternatives. All alternatives would manage sites and activities to avoid, mitigate, or 

minimize effects to federally listed species and to contribute to the recovery of the species. Thus, 

consequences of road use on Yosemite toad is not expected to vary by alternative, especially since 

use of these roads are not known to be a current mortality factor.

Consequences Specific to Alternative A

Alternative A does not define specific forest plan direction regarding fire management strategies 

outside of the wildland-urban interface that address at-risk species. The Inyo would evaluate 

naturally ignited wildfires on a case-by-case basis to determine if they could be managed to meet 

resource objectives. This would occur in the majority of occupied habitats and critical habitat 

located within designated wilderness. To the extent that fire is restored to these higher elevation 

landscapes, it will reduce the likelihood of future wildfires burning outside of the natural range of 

variation which will reduce the potential for post-fire sediment impacts. 

The portion of critical habitat outside of designated wilderness near Lake Mary is within the WUI 

defense and threat zones where fuels treatments and fire suppression are expected to protect 

human assets. However, because of the high recreation values of this area, the extent and 

locations of fuel treatments would likely be mitigated by the need to provide the scenic values 

expected by the recreating public. This could result in less effective fuels treatments compared to 

the other alternatives that emphasize the need for effective strategic treatments.

Consequences Specific to Alternative B

Alternative B replaces the distance-based Wildland-urban Intermix Defense and Threat Zones with 

strategic fire management zones. The majority of the critical habitat for Yosemite toad is located in the 

Wildfire Maintenance Zone and Wildfire Restoration Zone, which have desired conditions to be 

resilient to the range of fire effects and where wildland fire has predominantly positive benefits. Within 

these two strategic fire management zones, fires from lightning would be evaluated to determine if they 

could be managed with less than a full fire suppression response considering safety to firefighters and 

the public and potential positive and negative effects from expected fire behavior to various resources. 

To aid in determining the appropriate wildfire management strategy, spatial support tools are used to 

identify the locations of special habitats and key habitat areas, including critical habitat areas, so they 

can be considered. The direction will increase the likelihood that more wildfires will be managed in the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

425

future to restore the ecological role of fire and to improve ecosystem integrity and lessen future adverse 

effects of wildfires. Therefore, there would be a long-term improvement in Yosemite Toad habitat 

relative to alternative A.

Vegetation and fuels management could occur within the portion of critical habitat unit outside of 

wilderness near Lake Mary, especially within the community and general wildfire protection 

zones. Fuels treatments could use hand treatments, mechanical treatments, or prescribed burning 

or some combination of those methods. Within the riparian conservation areas surrounding 

occupied habitats, plan direction would limit the ground disturbing impacts to protect Yosemite 

toad habitat. Plan direction would also guide the design of treatments to meet the scenery needs 

of recreation in this heavily used area. Vegetation treatments that improve the resilience of the 

vegetation near occupied sites and fuels reduction treatments that lessen the risk of high severity 

wildfire outside the natural range of variation would benefit the Yosemite toad by providing more 

stability to the habitat conditions of occupied sites.

Consequences Specific to Alternative B-modified

Although the fire management zones are slightly different under alternatives B and B-modified, 

the effects to the toad from fire management would be the same. That is because within their 

habitat, the differences in fire management zones are so small that in effect, within Yosemite toad

habitat, effects would not differ.

Consequences Specific to Alternative C

Although the strategic fire management zones in alternative C are different than those in the other 

alternatives, the effects to Yosemite toad are expected to be the same as B and B-modified. Most 

wildfires near Lake Mary would likely continue to be suppressed because of the risks to 

communities and assets.

In alternative C, there could be vegetation and fuels treatments planned in the Wildland-urban 

Intermix Defense Zone around Lake Mary, but the emphasis will be on hand treatments and the 

use of prescribed burning instead of on the use of mechanical equipment. There would likely be 

no difference in effect to Yosemite toads and there habitat, however, because mechanical 

treatments in Yosemite toad habitat would be designed to protect the species and its habitat. There 

could be slightly fewer short-term effects to habitat from mechanical treatment, but slightly 

greater potential negative effects from uncharacteristically large wildfires because alternative C 

would not be able to treat as many acres of fuels as alternatives B and B-modified.

Consequences Specific to Alternative D

The strategic fire management zones would be the same as alternative B-modified and the effects 

to Yosemite toad would be expected to be the same. 

Since alternative D would have the highest amount of vegetation and fuels treatments of all 

alternative, there is a higher potential for fuels treatments to occur in or surrounding the 

community and general wildfire protection zones around Lake Mary than any of the other 

alternatives. To the extent this happens, it would reduce the risk of future wildfires burning with a 

higher severity than the natural range of variation which could affect the habitat used by Yosemite 

toads.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

426

Lahontan Cutthroat Trout (Threatened)

Consequences Common to All Alternatives

All occupied habitat around O’Harrel Creek is fenced and excluded from domestic livestock 

grazing to protect the Lahontan cutthroat trout. Any future proposals to discontinue the fencing or 

to consider additional fencing would be guided by the plan direction to manage essential habitat 

for the species according to the recovery plan and to limit streambank disturbance.

Roads exist in the area of the lower portion of O’Harrel Creek; however, the fencing around all 

occupied portions of the creek limit impacts such as sedimentation from road associated uses. In 

all alternatives, road maintenance will implement best management practices and projects would 

be designed to avoid, minimize, or mitigate potential impacts to occupied habitat and would 

require consultation with the U.S. Fish and Wildlife Service if the projects may affect the species. 

Most of the roads exist downstream of the occupied habitat, which is in an inventoried roadless 

area, limiting the potential for road-related impacts.

Restoration activities, particularly the installation of instream structures to benefit Lahontan 

cutthroat trout have occurred in the past and could occur in the future, including installation of 

new structures or maintenance of existing structures. If in-stream activities are planned they could 

adversely affect Lahontan cutthroat trout in the short term but would be designed to improve 

ecological conditions in the long term. As stated in the existing conditions section, this population 

is out-of-basin and habitat suitability is marginal.

If additional restoration activities are needed, such as restoration if wildfires burn within the 

watershed, the Inyo National Forest would coordinate with California Department of Fish and 

Wildlife and U.S. Fish and Wildlife Service to insure protection of habitat. While this would 

occur under alternative A without specific plan direction, it is addressed as a plan goal in

alternatives B, B-modified, C, and D to document the Inyo’s intent to coordinate to improve 

conditions for federally listed species.

Consequences Specific to Alternative A

As described in the section on “Aquatic and Riparian Ecosystems,” alternative A includes an 

aquatic and riparian conservation strategy focused on riparian conservation areas and critical 

aquatic refuges. The O’Harrel critical aquatic refuge was identified in 2001 to be managed for 

recovery of Lahontan cutthroat trout (USDA Forest Service 2001b). Projects proposed within the 

critical aquatic refuge would be guided by direction to provide habitat for Lahontan cutthroat 

trout and to restrict or minimize activities that would impact riparian habitats or stream 

conditions. As the occupied habitat is currently fenced and expected to be maintained through the 

life of the forest plan, no substantial consequences to Lahontan cutthroat trout habitat are 

anticipated.

O’Harrel Creek does not contain any Wildland-urban Intermix Defense or Threat Zones so there 

is no specific fire management direction; however, because of the general proximity to nonnational forest lands near Benton Crossing and Lake Crowley, it is likely that most wildfires will 

have some fire suppression actions taken. The occupied portions of O’Harrel Creek are identified 

as terrestrial aerial retardant avoidance areas on maps used when suppressing wildfires (USDA 

Forest Service 2011c). This will reduce the risk of aerial retardants entering the occupied portions 

of O’Harrel Creek and affecting fish, but reduced use of retardants could also result in wildfires 

burning at higher intensities or across larger areas which could cause higher risks of post-fire 

sedimentation. Although sedimentation could occur that impacts the occupied stream segment 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

427

given the generally sparse vegetation in this area, the risks of substantial high-severity fire effects 

would likely be low to moderate.

Consequences Specific to Alternative B, B-modified, C, and D

As described in the section on “Aquatic and Riparian Ecosystems,” all plan revision alternatives

include an aquatic and riparian conservation strategy that provides a comprehensive and multiscale management framework for watershed, riparian and stream conservation. The aquatic and 

riparian conservation strategy is similar to alternative A retaining the essential elements of the 

existing management direction for riparian conservation areas. There are many specific desired 

conditions for watersheds forestwide and for riparian conservation areas that would shape the 

purpose and need and project design outcomes of future projects. Desired conditions for the 

riparian conservation areas and watersheds provide beneficial functions such as cold, clean water; 

stream shading; aquatic/riparian habitat; and nutrients. There are also many specific standards and 

guidelines that avoid, mitigate, or minimize certain types of activities or intensities or magnitudes 

of effects within riparian conservation areas and to riparian resources. These plan components 

collectively help assure stream and riparian habitats are conserved and restored for long-term 

sustainability and resilience of the ecological conditions that contribute to species recovery. The 

plan revision alternatives vary in management of critical aquatic refuges or conservation 

watersheds, which will be discussed for each alternative below.

For the Lahontan cutthroat trout, the entire segment of O’Harrel Canyon Creek (Stream ID 1.141) 

was evaluated and has been found to meet the eligibility requirements to be considered for 

inclusion in the National Wild and Scenic Rivers System. The assigned preliminary classification 

is “recreational river.” Eligible wild and scenic rivers are managed by applying interim protection 

measures that protect them sufficiently to maintain free flow and outstandingly remarkable 

values. Fisheries, because of the presence of Lahontan cutthroat trout, are identified as one of the 

outstandingly remarkable values. Future in-stream habitat restoration projects, such as, 

construction of structures and vegetation management to protect and enhance wildlife and fish 

habitat, can occur within recreational rivers as long as they fully protect identified river values 

and do not affect the river’s free-flowing character. Vegetation and fuels management projects 

would be evaluated for consistency with the eligible wild and scenic river status. Any planned 

vegetation or fuels management projects would likely be designed to be of low intensity in order 

to maintain the scenic characteristics of a recreational class wild and scenic river.

Additional plan direction further limits the potential for impacts to riparian resources when 

prescribed fires are planned. When water drafting is needed on projects, screening devices are

required to minimize removal of aquatic species from aquatic habitats, including juvenile fish, 

amphibian egg masses and tadpoles. However, prior to determining if water drafting would be 

suitable for occupied habitats, the proposed sites would be evaluated for effects to Lahontan 

cutthroat trout and in some cases, water drafting may be prohibited. Efforts to manage the 

impacts of wildfires and to implement vegetation and fuels management to lessen the risk of 

habitat loss or the potential for sediment from adjacent burned areas from impacting occupied 

habitats would contribute towards recovery of this species by better protecting this out-of-basin 

population. The potential for proposing mechanical vegetation and fuels treatments is limited in 

the upper portions of O’Harrel Creek being within inventoried roadless areas where access is 

limited.

While the Inyo National Forest does not manage activities that occur on private lands, including 

the recreation that occurs on the private land parcel along O’Harrel Creek, these alternatives 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

428

would include a goal to cooperate with partners and private landowners to encourage resource 

protection and restoration across ownership boundaries. An additional goal for sustainable 

recreation is to manage dispersed recreation activities when evidence of impacts to natural 

resources emerge or are causing damage. Together these goals would facilitate working with 

private landowners and managing recreation on the Inyo National Forest to minimize impacts to 

occupied habitats where possible.

Consequences Specific to Alternative B

The O’Harrel critical aquatic refuge would be managed the same as alternative A and would have 

the same consequences. The O’Harrel Creek area is predominately within the Wildfire 

Restoration Zone in the upper portions within the inventoried roadless area and General Wildfire 

Protection Zone in the lower portion. In the Wildfire Restoration Zone, when naturally caused 

wildfires occur, they will be evaluated to determine if they could be managed to restore fire to the 

landscape with acceptable effects to highly valued resources, such as the Lahontan cutthroat 

habitat. In the General Wildfire Protection Zone, many wildfires will likely continue to have some 

fire suppression actions taken because of the higher risk of threats to communities and highly 

valued resources and assets. This would be similar to alternative A where most wildfires would 

have some fire suppression actions taken. Fires would be managed whenever possible to reduce 

the potential future sediment inputs from large wildfires that burn outside the natural range of 

variation. There could be greater long-term reduction in sediment input to O’Harrel Creek, and 

therefore greater protection of Lahontan cutthroat trout habitat, with this reduction in large 

wildfires.

Consequences Specific to Alternative B-modified

With the forestwide direction for animal and plant species coupled with the multi-scale aquatic 

and riparian conservation strategy approach, alternative B-modified is functionally equivalent to 

alternatives A and B. Any proposed activities that would affect the area around the occupied 

portions of O’Harrel Creek would be guided by forestwide direction for at-risk species and 

watersheds. This provides desired conditions and guidance in project design to maintain, 

improve, or protect ecological conditions needed to contribute to the recovery of Lahontan 

cutthroat trout. The removal of the O’Harrel Creek critical aquatic refuge would likely cause no 

difference to the trout’s habitat because protections would still exist under the riparian 

conservation area direction, Endangered Species Act, and general watershed protections. 

The strategic fire zones in the area around O’Harrel Creek is very similar to alternative B. 

Because the differences are minor, the consequences are expected to be the same as those 

described for alternative B.

Consequences Specific to Alternative C

The O’Harrel critical aquatic refuge would be managed the same and have the same 

consequences as alternative A. Alternative C does not differentiate between the General Wildfire 

Protection Zone and Wildfire Restoration Zone like the other plan revision alternatives, instead 

categorizing the area around O’Harrel Creek as the general wildfire zone. Regardless, the 

direction for managing fire be the same as t the other plan revision alternatives by having 

guidance to manage wildfires to meet resources objectives when it is safe to do so and manage 

and mitigate the impacts of fire suppression activities to the extent possible. Thus, even though 

the mapped fire zones would be different between the alternatives in the area that could affect 

Lahontan cutthroat trout, the consequences would be similar to those described for alternative B, 

B-modified, and D because fire management decisions would be guided by protection of life and 

property and managing wildfires to meet resource objectives, which would restore fire as an 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

429

ecological process, when it is safe to do so. Alternative C would limit mechanical treatments to 

restore vegetation or treat fuels, but since little vegetation treatment or fuels reduction is likely 

due to the inventoried roadless area and eligible wild and scenic river status, there would be little 

difference between the plan revision alternatives and the consequences would be similar to that 

described for alternatives B and B-modified. There could be a slightly higher chance of increased 

sediment input from large wildfires with less overall fuels treatment across the Forest, but in this 

watershed, the difference between alternatives would be very small because this is not an area 

where landscape scale fuels treatments are likely.

Consequences Specific to Alternative D

The O’Harrel critical aquatic refuge would be managed the same and have the same 

consequences as described for alternative A. The direction and consequences for managing fire 

would be the same as described for alternative B-modified.

Paiute Cutthroat Trout (Threatened)

Consequences Common to All Alternatives

All alternatives include an aquatic and riparian conservation strategy that provides a multi-scale 

management framework for watershed, riparian and stream conservation and management. This

will provide for Paiute cutthroat trout habitat conservation to sustain their viability to the extent 

that activities occur within the occupied portions of Leidy Creek watershed (Cabin Creek 

population) and the Cottonwood Creek watershed (North Fork of Cottonwood Creek population). 

The aquatic and riparian conservation strategy in all alternatives retains the essential elements of 

the existing management direction for riparian conservation areas, which were designed to protect 

riparian and aquatic habitat. The plan revision alternatives vary in management of critical aquatic 

refuges or conservation watersheds, which will be discussed for each alternative below.

Since occupied habitat areas for both populations are located within the designated White 

Mountains Wilderness, there are expected to be no effects from vegetation management. The 

primary risk of habitat effects is related to wildfire impacts from suppression activities or from 

how fire is managed as an ecosystem function. Within wilderness, fire suppression activities 

would employ minimum impact suppression techniques wherever feasible in all alternatives. The 

occupied portions of Cabin Creek and North Fork of Cottonwood Creek are identified as 

terrestrial aerial retardant avoidance areas on maps used when suppressing wildfires (USDA 

Forest Service 2011c). Use of aerial retardants is minimized within designated wilderness areas 

unless needed to protect life or property. When needed, water drops from helicopters is preferred 

to minimize impacts to wilderness character and if needed near occupied habitat, to limit the risk 

of adverse fire effects to federally listed species. The effect of these actions would minimize the 

risks of direct impacts from fire suppression activities and fire-related sediment to occupied 

habitats.

In the area around the North Fork of Cottonwood Creek, the Cottonwood Creek and Tres Plumas 

Allotments are in non-use status which is allowing passive restoration of the riparian systems, 

contributing to a reduction in sediment and the improvement of habitat conditions for the Paiute 

cutthroat trout. In the future, if stream and riparian conditions improve, future livestock use of the 

allotments could be considered. Any proposals to authorize livestock grazing in these areas would 

be guided by plan direction that land management activities be designed to maintain or enhance 

self-sustaining populations of at-risk species within the inherent capabilities of the plan area by 

considering the relationship of threats (including site-specific threats) and activities to species 

survival and reproduction. The Cabin Creek area has not been grazed since 2005. However, if 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

430

livestock grazing occurs there in the future, it would be managed by a grazing permit guided by a 

project-level biological opinion from the U.S. Fish and Wildlife Service. In both cases, livestock 

grazing would be mitigated by plan direction that limits streambank disturbance from livestock to 

10 percent of the occupied or essential habitat stream reach identified in the Paiute cutthroat trout 

recovery plan. Livestock grazing management would not vary by alternative, and therefore these 

effects would be the same under all alternatives.

In order to avoid the risk of hybridization, it is important to maintain the existing barriers that 

isolate occupied habitats from downstream populations of rainbow trout. The plan revision 

alternatives include a desired condition that recognizes that while generally the desire for stream 

ecosystems is to exhibit full connectivity where feasible to maintain aquatic species diversity, in 

some cases barriers need to be maintained to protect native aquatic species. If a change were to 

occur to the barriers at these two sites that threaten their effectiveness, projects would be 

considered to meet the desired condition to manage for ecological conditions that contribute to 

the survival, recovery, and delisting of species under the Endangered Species Act and the goal to 

coordinate with the U.S. Fish and Wildlife Service and with California Department of Fish and

Wildlife to restore and maintain essential habitat for at-risk species and implement other recovery 

actions consistent with species recovery plans. Maintaining a functional barrier would contribute 

towards the recovery plan by protecting and enhancing occupied Paiute cutthroat trout habitat.

Consequences Specific to Alternative A

As described in the section on “Aquatic and Riparian Ecosystems,” alternative A includes an 

aquatic and riparian conservation strategy focused on riparian conservation areas and critical 

aquatic refuges. The Cottonwood Creek critical aquatic refuge was identified in 2001 to be 

managed for recovery of Paiute cutthroat trout (USDA Forest Service 2001b). Projects proposed 

within the critical aquatic refuge would be guided by direction to provide habitat for Paiute

cutthroat trout and to restrict or minimize activities that would impact riparian habitats or stream 

conditions. The occupied habitat is located within the White Mountains Wilderness, no active 

vegetation or fuels activities are expected and therefore no effects to Paiute cutthroat trout habitat 

are anticipated.

Neither Cabin Creek nor the North Fork of Cottonwood Creek is near any Wildland-urban 

Intermix Defense or Threat Zones so there is no specific fire management direction. Since both 

locations are within the White Mountains Wilderness, it is likely that most wildfires will have 

limited fire suppression actions taken if they can be managed to meet resource objectives. The 

occupied portions of Cabin Creek and the North Fork of Cottonwood Creek are identified as 

terrestrial aerial retardant avoidance areas on maps used when suppressing wildfires (USDA 

Forest Service 2011c). This will reduce the risk of aerial retardants entering the occupied portions 

of these creeks and affecting fish, but reduced use of retardants could also result in wildfires 

burning at higher intensities or across larger areas which could cause higher risks of post-fire 

sedimentation. Sedimentation could occur that impacts the occupied stream segment given the 

generally sparse vegetation in this area though, the risks would likely be low to moderate of 

substantial high-severity fire effects.

Consequences Specific to Alternative B, B-modified, C, and D

The direction for watersheds and riparian conservation areas would build resilience into

watershed systems and habitats to better enable them to adapt to drought and climate change and 

enable stream systems and associated habitats to adapt to altered flow regimes and disturbances.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

431

For the Paiute cutthroat trout, an additional 1.66 miles of the North Fork of Cottonwood Creek 

(Stream ID 1.028) was evaluated and has been found to meet the eligibility requirements to be 

considered for inclusion in the National Wild and Scenic Rivers System. This additional section 

includes the headwaters of the North Fork of Cottonwood Creek above the occupied area. The 

assigned preliminary classification is “wild river.” Eligible wild and scenic rivers are managed by 

applying interim protection measures that protect them sufficiently to maintain free flow and 

outstandingly remarkable values unless a determination of ineligibility or non-suitability is made. 

Fisheries, because of the presence of Paiute cutthroat trout, are identified as one of the 

outstandingly remarkable values. Future in-stream habitat restoration projects, such as, 

construction of structures and vegetation management to protect and enhance wildlife and fish 

habitat, can occur within wild rivers as long as they fully protect identified river values and do not 

affect the river’s free-flowing character. Cutting of trees or vegetation in eligible wild and scenic 

rivers would not occur with a few exceptions, for example, maintaining trails or suppressing fires 

or to protect outstanding remarkable values. Prescribed burning projects are allowed if they are 

designed to maintain or restore at-risk species habitats or to restore the natural range of 

variability. Since the occupied habitat is within the White Mountains Wilderness, cutting of trees 

or prescribed burning is not expected to occur, except trees may be cut during fire suppression. 

The plan revision alternatives include plan direction to improve the delivery of public information 

regarding management of natural resources and at-risk species management through conservation 

education which contributes to a recovery plan action.

The recovery plan calls for developing a long term conservation plan and conservation agreement 

for managing the Paiute cutthroat trout. For the two out-of-basin populations of Paiute cutthroat 

trout that occur on the Inyo National Forest, a goal describes the intent of the Inyo to work with 

the State and Federal wildlife agencies to restore and maintain essential habitat for at-risk species 

and implement other recovery actions consistent with species recovery plans. If conservation 

strategies are developed or a conservation agreement is approved, actions to implement 

conservation actions would be provided by plan direction that habitat management objectives or 

goals from approved conservation strategies or agreements should be incorporated, if appropriate, 

in the design of projects that will occur within at-risk species habitat. This would serve to ensure 

actions are contributing to the recovery of the species.

Consequences Specific to Alternative B

The Cottonwood Creek critical aquatic refuge would be managed the same as alternative A and 

would have the same consequences.

Since Cabin Creek is within the wildfire maintenance zone, when naturally caused wildfires 

occur, they will be evaluated to determine if they could be managed to restore fire to the 

landscape while having acceptable effects to highly valued resources, such as habitats for at-risk 

species. The occupied habitat in the North Fork of Cottonwood Creek is within the general 

wildfire protection zone due to its proximity to the Ancient Bristlecone Pine Forest. In this zone, 

many wildfires are expected to continue to have some fire suppression actions taken because of 

the higher risk of threats to highly valued resources and assets. As a result, it may be more 

difficult to restore fire as a landscape element than in alternatives A, B-modified, or C. 

Consequences Specific to Alternative B-modified

This alternative does not identify Cottonwood Creek critical aquatic refuge as a management area

for Paiute cutthroat trout. In this alternative, the area would instead be managed as part of the 

larger Cottonwood-Crooked Creek Headwaters Conservation Watershed. The desired condition 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

432

for conservation watersheds emphasizes their importance for habitats for the recovery of federally 

listed species. Additionally, restoration projects and actions within Conservation Watersheds 

would be a high priority for implementation and monitoring. Since the occupied portion of 

Cottonwood Creek is within designated wilderness, it is not likely that active, ground-disturbing 

restoration would be proposed or would occur. Instead, passive restoration and non-grounddisturbing actions that improve Watershed Condition Framework indicators would be given 

priority.

This alternative includes forestwide direction for riparian conservation areas, upland areas, and 

animal and plant species which coupled with the conservation watershed, would provide the same 

or better protection to the Paiute cutthroat trout as that provided by the critical aquatic refuge 

under the other alternatives. The plan provides desired conditions and guidance in project design 

to maintain, improve, or protect ecological conditions needed to contribute to the recovery of 

Paiute cutthroat trout (see SPEC-PCTR-STD and RCA plan components)

The strategic approach to wildfire management identifies the Cabin Creek area and North Fork of 

Cottonwood Creek area as part of the wildfire maintenance zone. In the area around the North 

Fork of Cottonwood Creek fire risks to the Ancient Bristlecone Pine Forest were offset by the 

benefits of restoring fire to the landscape and most fires were not likely to pose such a threat that 

suppression actions were likely to be the predominate action needed. In the wildfire maintenance 

zone, the desired condition is that ecosystems are resilient to the impacts of wildfire and wildland 

fire has predominantly positive benefits to ecosystems and resources. Within this zone, when 

natural ignitions occur, efforts would be made to manage wildfires to meet resource objectives 

and restore and maintain fire as an ecological process. To the extent that fire can be restored to the 

landscape, this would benefit Paiute cutthroat trout by reducing the overall risk of fires burning 

outside of the natural range of variation which would lessen the risk of post-fire sediment 

impacts.

Consequences Specific to Alternative C

The Cottonwood Creek critical aquatic refuge would be managed the same and have the same 

consequences as alternative A. Alternative C would manage both the Cabin Creek occupied 

habitat and the North Fork of Cottonwood Creek occupied habitat as the wildlife maintenance 

zone as described for alternative B-modified and would be expected to have the same 

consequences.

Consequences Specific to Alternative D

The Cottonwood Creek critical aquatic refuge would be managed the same and have the same 

consequences as alternative A. Alternative D would use the same strategic wildfire zones as 

alternative B-modified and would have the same consequences.

Owens Tui Chub (Endangered)

Consequences Common to All Alternatives

All alternatives include an aquatic and riparian conservation strategy that provides a 

comprehensive and multi-scale management framework for watershed, riparian and stream 

conservation and management in the plan area, which will indirectly provide for Owens tui chub 

habitat conservation to sustain their viability to the extent that activities occur within the occupied 

portions of the Hot Creek watershed and in the upper portion of the Middle Fork of the San 

Joaquin River watershed near Sotcher Lake.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

433

The aquatic and riparian conservation strategy in the plan revision alternatives retains the 

essential elements of the existing management direction for riparian conservation areas, a variable 

distance buffer area surrounding streams and bodies of water. Desired conditions for the riparian 

conservation areas provide ecologically appropriate and resilient riparian vegetation and

functioning aquatic systems. There are specific standards and guidelines that would avoid, 

mitigate, or minimize certain types of activities or intensities or magnitudes of effects within 

riparian conservation areas and to riparian resources. Although many of the specific plan 

components change in wording or plan component or plan content type between alternative A and 

the plan revision alternatives, the functional intent is retained overall in the forest plan or by other 

applicable laws, regulations, or policies of the agency. These plan components collectively help 

assure stream and riparian habitats are conserved and restored for long-term sustainability and 

resilience, and contribute to species long-term viability.

While the Forest Service regulates surface activities on National Forest System lands, regulating 

water rights and water withdrawals is under the authority of the State of California and is outside 

the authority of the Forest Service. Water withdrawal affecting Little Hot Creek Pond is not 

expected because the majority of the headwaters area affecting the pond is National Forest 

System lands and there are no known or expected withdrawal proposals on the national forest. 

Water withdrawals or changes from activities that might affect the seeps and springs that feed the 

hydrology of the ponds are unlikely given direction in desired conditions that water developments 

that might dewater aquatic habitat for at-risk species should be avoided. In additions, desired 

conditions describe adequate quantity and timing of water flows to support aquatic species and 

that there are sufficient in-stream flows to support aquatic biota. There is concern about impacts 

to water at the Little Hot Creek Pond from the Casa Diablo IV geothermal energy development 

projects located in the Mammoth Lakes area. Effects to springs from the Casa Diablo project are 

monitored by the US Geological Survey, and no effects have been found over decades of 

monitoring. Effects will continue to monitored and if any effects are found, management changes 

will be made in conjunction with U.S. Fish and Wildlife Service direction, and the BLM, which 

has jurisdiction over geothermal development.

The Little Hot Creek Pond may be buffered slightly from environmental stochasticity related to 

drought and annual weather variability because of the spring fed nature of the hydrologic system 

that feeds it. The dry grassland and shrublands that surround this area reduce the magnitude and 

risk of substantial impacts from wildfire, if it were to occur. The effects of climate change may be 

expressed in many ways, such as changes in precipitation patterns and runoff patterns that could 

affect streamflows and groundwater systems that feed the springs and seeps that supply the Little 

Hot Creek Pond. Changes in water withdrawals that feed the ponds are not expected during the 

life of the forest plan and projects would be designed to consider watershed resilience to climate 

change and if projects proposed changes in instream flows, they would consider the effects on 

Little Hot Creek Pond.

Demographic and genetic stochasticity are outside the authority of the Forest Service to directly 

address other than the Inyo would cooperate and coordinate with the U.S. Fish and Wildlife 

Service or California Department of Fish and Wildlife if recovery actions to augment or establish 

additional populations were determined to be necessary to contribute to the recovery of the 

Owens tui chub.

The management of livestock grazing is not expected to affect this species because the areas 

around the Little Hot Creek Ponds are fenced and not subject to livestock grazing and no 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

434

livestock grazing occurs around Sotcher Lake. Following a project level consultation with the U.S. 

Fish and Wildlife Service, the Little Hot Creek Pond is currently fenced to exclude livestock and to 

discourage other uses. It is expected that this fence will be maintained through the life of the forest plan 

to avoid impacts to Owens tui chub habitat from domestic livestock grazing and incidental public uses, 

including recreation uses.

Roads are not expected to affect this species because the road adjacent to the Little Hot Creek 

Pond is maintained as a gravel road to minimize dust and erosion risks to the pond and routine 

maintenance along this section is not expected to impact the pond. There are no roads 

immediately adjacent to Sotcher Lake. The main access road to Reds Meadow has a small 

parking area near the road for the Sotcher Lake Picnic area but continued use and management of 

the road and picnic area infrastructure would not affect Sotcher Lake.

All alternatives recognize that it is desirable for some barriers to be maintained in good condition 

to protect native aquatic species. As described above, the Little Hot Creek Pond is currently 

isolated from nonnative aquatic predators like largemouth bass and brown trout and hybridization 

with Lahontan tui chub by downstream diversions that prevent connection with the Owens River. 

It is not anticipated that bass or trout will become introduced or established in the Little Hot 

Creek Pond because it does not provide suitable habitat and is small in size. If a change were to 

occur to these barriers to threaten their effectiveness, projects would be considered to avoid 

hybridization in order to contribute to the survival, recovery, and delisting of species under the 

Endangered Species Act. This would contribute to recovery of the species by using barriers to 

separate occupied habitat from deleterious nonnative species.

The area around Little Hot Creek Pond was evaluated along with the California Department of 

Fish and Wildlife for management options for the emergent vegetation growing within the pond. 

While there is some vegetation encroachment, the population of Owens tui chub appears to be 

stable. The Inyo would continue to coordinate with the U.S. Fish and Wildlife Service and 

California Department of Fish and Wildlife to evaluate habitat conditions at Little Hot Creek 

Pond under all alternatives. If it’s determined that vegetation control is needed and the specific 

equipment needed is available, the Inyo would develop a site-specific project with sufficient 

design features and mitigations to contribute to recovery of the species.

Although mosquitofish are abundant at Little Hot Creek Pond, the tui chub population at Little 

Hot Creek Pond appears to continue to reproduce and thrive in the presence of mosquitofish in 

this location. At this time, control of mosquitofish is not planned, but the Inyo would consider 

action, if feasible, if recommended by the U.S. Fish and Wildlife Service or California 

Department of Fish and Wildlife in order to contribute to the recovery of the Owens tui chub.

Consequences Specific to Alternative A

The current forest plan does not include species-specific plan direction for Owens tui chub so 

relevant direction is primarily found in direction for riparian conservation areas and critical 

aquatic refuges. The direction for riparian conservation areas would provide project direction to 

limit activities that would adversely affect riparian vegetation and protect habitat conditions for 

Owens tui chub in Little Hot Creek Pond. When projects are proposed within the Little Hot Creek 

critical aquatic refuge, they would be designed to contribute to the recovery of the Owens tui 

chub. Since the area surrounding the pond is already fenced to eliminate livestock grazing and to 

reduce other incidental public uses, no additional protective actions are expected to occur over the 

life of the forest plan.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

435

Because of the existing sparse vegetation conditions around Little Hot Creek, no fuels 

management is likely to be needed or occur during the life of the forest plan and the risk of 

adverse effects from fire suppression or potential post-fire erosion impacts is low. The area 

around Sotcher Lake is within the Wildland-urban Intermix Threat Zone where fuels reduction 

projects could be planned to reduce the levels of fuels that could lead to larger or higher severity 

wildfires that could threaten the Wildland-urban Intermix Defense Zone around Reds Meadow or 

the nearby communities around Mammoth Lake. If fuels management projects are proposed, they 

would be guided by direction for riparian conservation areas to have the ecological conditions 

that contribute to the recovery of threatened and endangered species. Fuels management activities 

would typically occur in the upland areas and not immediately affect the lakeshore or riparian 

habitats that might affect habitat conditions for the Owens tui chub.

It is unknown if there are any habitat restoration needs for Sotcher Lake to benefit Owens tui 

chub. While recreation occurs around Sotcher Lake, it is unknown if activities on the shoreline 

are affecting the aquatic habitats used by this species; however, if shoreline impacts are causing 

impacts they could be mitigated by direction for riparian conservation areas to limit shoreline 

disturbance.

Consequences Common to Alternatives B, B-modified, C, and D

For the Owens tui chub, the entire segment of Little Hot Creek (Stream ID 1.084) was evaluated 

and found to meet the eligibility requirements to be considered for inclusion in the National Wild 

and Scenic Rivers System. The assigned preliminary classification is “recreational river.” Any 

future proposed projects would be guided by direction that applies interim protection measures to 

ensure they are protected sufficiently to maintain free flow and outstandingly remarkable values.

Future in-stream habitat restoration projects, such as, construction of structures and vegetation 

management to protect and enhance wildlife and fish habitat, can occur within recreational rivers 

as long as they fully protect identified river values and do not affect the river’s free-flowing 

character.

The forestwide direction for watersheds and direction for riparian conservation areas would build

resilience into watershed systems and habitats by guiding projects to better enable watersheds to 

adapt to drought and climate change and enable stream systems and associated habitats to adapt to 

altered flow regimes and disturbances.

There is a risk of fire effects for the Sotcher Lake population because it is in a forested 

environment where fire risks are generally high. The area around Sotcher Lake is in the 

Community Wildfire Protection Zone where a high priority is on protecting assets from wildfire 

impacts and where, due to risks, most wildfires are expected to be fully suppressed under all 

alternatives. In order to reduce the risk of negative wildfire impacts, projects could be proposed 

around Sotcher Lake to meet a forest plan goal for the Community Wildfire Protection Zone to 

reduce the impacts of wildfire by creating fire-adapted communities through fuel reduction 

treatments, prescribed fire, and managing wildfires that can benefit natural resources while 

reducing risk. If fuels management projects are proposed, they would be guided by direction for 

riparian conservation areas to have the ecological conditions that contribute to the recovery of 

threatened and endangered species. Fuels management activities would typically occur in the 

upland areas and not immediately affect the lakeshore or riparian habitats that might provide 

direct habitat for the Owens tui chub. These projects would also be guided by a forestwide 

direction for watersheds to use best management practices to mitigate adverse impacts to soil and 

water resources.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

436

Recreation around Sotcher Lake would be continue to be managed and the consequences would 

be similar to alternative A. In alternatives B and D there is an emphasis on providing sustainable 

recreation which would emphasize addressing and mitigating impacts from recreation to at-risk 

species; however, as described for alternative A, there are no known conflicts.

Consequences Specific to Alternative B-modified

The Little Hot Creek critical aquatic refuge would no longer be designated under Alternative Bmodified. The forestwide direction for riparian conservation areas requires protection of aquatic 

and riparian species habitat, as well as the focus on protecting watershed function, will protect tui 

chub and their habitat by preventing major disturbances and attempting to improve resilience to 

climate change and other stochastic events. As a result, there are no substantial changes expected 

from the change in management approach that eliminates the Little Hot Creek critical aquatic 

refuge.

Sotcher Lake is within the Mammoth Lakes Destination Recreation Area where desired 

conditions provide for higher levels of development to manage the concentrated recreation uses 

within a natural appearing landscape. This lake is a popular location for fishing and there is a 

designated picnic area that receives heavy use. Given that information about the specific habitats 

and areas of occupancy in Sotcher Lake is not known, it is difficult to assess the potential for 

impacts from recreation uses. Within Destination Recreation Management Areas, direction to 

limit streambank and shoreline disturbance for riparian conservation areas may not currently be 

met in all cases, but projects would be designed and managed to reduce the percent of impact to 

the extent feasible. These activities are found to affect Owens tui chub, then consultation with the 

U.S. Fish and Wildlife Service would occur at the project-level. As explained for alternative A, 

there are no known restoration needs at Sotcher Lake and there would continue to be no known 

impacts from recreation.

The effects of vegetation management on this species is expected to be the same as described for 

alternative B. It is expected that fuels management would be planned within this area during the 

life of the forest plan. Direction for fuels management around Sotcher Lake would be guided by 

the same direction for riparian conservation areas as alternative B.

Fire management can affect Owens tui chub and its habitat primarily in terms of fire suppression 

impacts and potential post-fire erosion impacts. The low risk would be the same as described for 

alternative A for the Little Hot Creek Ponds population because of the sparse vegetation 

surrounding this area. The risk is higher for the Sotcher Lake population because it is in a forested 

environment where fire risks are higher and would be the same as described for alternative B 

since it would have the same Community Wildfire Protection Zone where most wildfires are 

expected to be fully suppressed.

Consequences Specific to Alternative C

Alternative C would continue to manage the Little Hot Creek critical aquatic refuge the same as

alternatives B and D and would have the same consequences. Alternative C would manage the 

area around Sotcher Lake as part of the General Wildfire Zone. Since it is in close proximity to an 

area identified as Wildland-urban Intermix Defense Zone around Reds Meadow, it is expected 

that wildfires would be managed similarly to the other alternatives, likely with full suppression. 

There may be less vegetation treatment under alternative C due to the emphasis on prescribed fire 

instead of mechanical treatment. Because prescribed fire would be difficult to implement on a 

large scale in this highly used, dense forest area without previous mechanical thinning, there 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

437

could be a greater potential for large wildfires that may increase sediment input into Sotcher Lake 

and affect tui chub habitat.

Recreation around Sotcher Lake would be managed the same as alternative A. There would not be 

specific direction for the area but if recreation impacts along the shoreline were occurring to 

Owens tui chub habitat, direction for riparian conservation areas would guide developing future 

site-specific actions to mitigate the impact.

Amphibians: (Black Toad, Inyo Mountains Slender Salamander, Kern Plateau 

Salamander)

These three species have been grouped here based on riparian ecosystems they depend on and the 

similarities in the consequences from the alternatives. The Inyo Mountains slender salamander 

occurs exclusively in isolated springs in largely desert ecosystems comprised of desert scrub. The 

Kern Plateau salamander occurs in perennially wet and moist habitat, usually in rocky outcrops or 

rock substrate. On the national forest, these conditions can be found largely on the Kern Plateau. 

Black toad is an aquatic species restricted to wet areas near permanent springs with 

subpopulations separated by arid desert scrub at least 1.5 km apart. Short plant cover which 

provides shaded/cooler environments and unobstructed access to still or slowly flowing water, 

rodent burrows in winter and shallow marsh and pond waters for breeding are all important 

habitat elements.

The black toad and Inyo Mountains slender salamander are Pacific Southwest Region sensitive 

species. Projects that may impact these species would complete a biological evaluation and 

ensure the continued viability of the species on Inyo National Forest. The Kern Plateau 

salamander is not identified as a sensitive species. 

Alternatives B, B-modified, C, and D propose all three species as species of conservation concern

(see chapter 2 under “Features Common to Alternatives B, B-modified, C, and D, Species of 

Conservation Concern.”) By doing so, forestwide watershed and forestwide at-risk species 

direction will be strengthened. 

Under current plan direction (alternative A), there are no critical aquatic refuges designated for 

black toad. However, existing critical aquatic refuges do exist that benefit the Inyo Mountains

slender salamander (Lead Canyon and Barrel Springs critical aquatic refuges) and Kern Plateau 

salamander (Olancha and Haiwee critical aquatic refuges). For both species of salamanders, the 

same critical aquatic refuges proposed under alternative A are proposed under alternatives B, C, 

and D. Birch Creek Critical Aquatic Refuge is proposed under alternatives B, C, and D that will 

benefit black toad. Alternative B-modified does not propose critical aquatic refuges, but proposes 

conservation watersheds instead. None of the three species occur within any of the proposed 

conservation watersheds under B-modified. Where additional critical aquatic refuges are 

proposed, such designation will strengthen forestwide direction in comparison to alternative A. 

Direction to protect species of conservation concern, as well as riparian conservation area 

direction, will be included in alternative B-modified, and will apply to riparian areas occupied by 

these species. The effects therefore will not change with the elimination of critical aquatic 

refuges.

Proposed recommended wilderness under alternatives B, B-modified, and C will result in Haiwee 

(alternatives B and B-modified) and portions of Olancha (alternative C) critical aquatic refuges

being incorporated into the wilderness areas. Both the Lead Canyon and Barrel Springs critical 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

438

aquatic refuges (Inyo Mountains slender salamander) are located within current wilderness areas. 

Alternative D proposes no recommended wilderness areas. Proposed recommended wilderness 

areas (Deep Springs North) under alternative C could limit restoration activities to nonmechanical methods. Nevertheless, threats to these species are primarily outside the control and 

authority of the Forest Service. 

The black toad is an endemic species, limited to several isolated populations in Deep Springs 

Valley in Inyo County within close proximity to and or on the Inyo National Forest. Individuals 

have been documented on the Inyo, but the majority of the habitat and population is located on 

adjacent, private land. The Inyo National Forest will continue to provide additional (ephemeral) 

fringe habitat for dispersing adults. While the ecological conditions the black toad depends on 

appear generally stable and or trending in a positive direction based on current management, there 

is still substantial concern for the species persistence by simple virtue of its rarity and uncertain 

climate change related effects. As a result of this rarity and its limited distribution, this species is 

highly susceptible to stochastic events (such as flash floods) and drying conditions resulting from 

increasing temperatures and precipitation events. Its limited dispersal ability and isolated 

populations put it at further risk for localized extinctions and susceptibility to disease outbreaks. 

The preferred alternative includes ecosystem plan components and species specific plan 

components to maintain the necessary ecological conditions for a viable population of black toad 

on the Inyo. The Inyo’s ability to maintain a viable population is limited, however, because the 

species primary range occurs outside of the national forest boundary and primary threats to the 

species are not within Forest Service control. Appendix F in volume 2 includes a more detailed

discussion of black toad persistence.

Although the Kern Plateau salamander is largely restricted to the Kern Plateau and western 

portions of Owens Valley, it appears to be well distributed throughout its range. Most populations 

are not imperiled by ongoing threats or known to be declining. However, habitat on the Inyo 

National Forest may be naturally limited and increased wildland fire events coupled with 

subsequent flash floods that scour habitat are potential risk factors. Springs are sensitive water 

features due to their relative rarity, their small area, and their ecological importance relative to 

their size. Any activities that disrupt water flow puts spring ecosystems at risk. In addition, 

persistence of the salamander populations may be closely tied to climate variations that affect 

their habitat, especially if they experience extreme drying trends, or stochastic events such as 

flash floods. Given its endemism, restricted range and susceptibility to these environmental 

events, there is substantial concern for this species ability to persist on the planning unit. The Inyo 

National Forest has a number of ecosystem-level and species-specific plan components in place 

to mitigate risks within its management authority, but cannot mitigate all threats for persistence. 

Based upon this evaluation, the final set of ecosystem plan components and the additional 

species-specific plan components would provide the necessary ecological conditions to maintain 

a viable population of Kern Plateau Salamander within its range. However, key risk factors 

including climate change, ground water pumping and water diversions that occur off forest that 

are not within Forest Service control could affect spring habitat making it difficult to maintain 

viability in the plan area.

The Inyo Mountains slender salamander is an endemic species, limited to several isolated 

populations scattered throughout a small portion of the Inyo National Forest. While the ecological 

conditions the salamander depends on appear generally stable and or trending in a positive 

direction based on current management, there is still substantial concern for the species 

persistence by simple virtue of its rarity and uncertainty regarding climate change-related effects 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

439

and losses in spring habitat. As a result of this rarity and its limited distribution, this species is 

highly susceptible to stochastic events such as flash floods, and drying conditions which may 

become more frequent with climate change. The Inyo Mountains slender salamander’s limited 

dispersal ability and isolated populations put it at further risk for localized extinctions from these 

types of events. Further, the watershed is not wholly contained within the national forest and the 

Inyo has little control over water management outside national forest boundaries. For this reason, 

it will be difficult for the Inyo to fully restore this habitat to reference conditions. 

Species viability of Inyo Mountains slender salamander on the Inyo is currently uncertain;

however, proposed plan components are designed to move habitat conditions to a more desired 

ecological state than what currently exists. The Inyo National Forest has a number of ecosystemlevel and species-specific plan components in place to mitigate risks within its management 

authority, but cannot mitigate all threats for persistence. Based upon this evaluation, the final set 

of ecosystem plan components and the additional species-specific plan components would 

provide the necessary ecological conditions to maintain a viable population of Inyo Mountains 

slender salamander within its range. However, key risk factors including climate change, ground 

water pumping and water diversions that occur off the national forest and are not within Forest 

Service management authority will continue to impact spring habitat making it difficult to 

maintain viability in the plan area.

California Golden Trout

Effects to California golden trout should vary only slightly between alternatives, because multiple 

layers of existing protections already apply to this species. Most of its habitat is within designated 

wilderness, where few ground-disturbing activities take place. Potential threats are all addressed 

by the Conservation Assessment and Strategy for the California Golden Trout (Stephens, 

McGuire, and Sims 2004), which will continue to be followed under all alternatives. Additionally, 

a Comprehensive Management Plan for the North Fork and South Forks of the Kern Wild and 

Scenic River (USDA Forest Service 1994) provides overall management direction for the wild 

and scenic river. The wild and scenic river designation for the North and South Forks of the Kern 

River would continue under all alternatives.

Under alternatives B, B-modified, C, and D, Golden Trout Creek is proposed as an eligible wild 

and scenic river. The Inyo National Forest would therefore be required to maintain free flowing 

condition and the values that make it eligible as a wild and scenic river. This would provide 

another layer of protection for California golden trout, as it would prevent activities that would 

cause major changes to the stream. 

Alternative A would continue to provide direction (for riparian habitat and sensitive species) 

through its forest plan components to guide management for the continued conservation of the 

California golden trout. California golden trout is a Pacific Southwest Region sensitive species. 

Any projects that may impact this species would be required to complete a biological evaluation

and ensure the continued viability of the species on the national forest. Alternatives A, B, C, and 

D would continue providing direction for this species within the Golden Trout/Volcano Creeks 

critical aquatic refuge. Under B-modified, the South Fork of the Kern River and its headwaters 

would be designated a conservation watershed. This change would likely make little difference to 

habitat conditions, viability and persistence of this species. The designation of the conservation 

watershed may slightly improve habitat compared to existing conditions, because it would focus 

restoration activities on improving the entire watershed function. This could drive watershed 

improvements that could help improve resilience to climate change, fire, or other stochastic 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

440

events. However, the difference is likely to be very slight, because most of the California golden 

trout habitat is within wilderness, and other than varying wildfire management strategies, there 

would be little difference in management of wilderness areas by alternative.

Alternatives B, B-modified, C, and D propose golden trout as a species of conservation concern. 

This designation will ensure that the Inyo implements management actions to improve persistence 

of the species. This is unlikely to, by itself, lead to any change in effects to the California golden 

trout, because the Inyo is already managing it under a conservation assessment and strategy.

Livestock grazing overlaps with golden trout habitat, and would continue under the same 

management direction under all alternatives. Grazing has been reduced over time, and many 

legacy impacts to streams within the Kern Plateau have improved and continue to improve. Under 

all alternatives, it would be expected that effects from grazing on stream habitat would continue 

to improve under plan direction, and would not vary by alternative.

The plan revision alternatives all have an emphasis on managing wildfire to return to a more 

natural fire regime and reduce the size and severity of wildfire. In golden trout habitat, the plan 

revision alternatives may therefore reduce negative effects from large fires relative to 

alternative A. 

Aquatic Invertebrates

(Owens Valley Springsnail, Western Pearlshell, Wong’s Springsnail)

These species have been grouped due to their dependence on aquatic and/or riparian habitat and 

ecological similarities as aquatic invertebrates. Both species of springsnails are identified on the 

Pacific Southwest Region sensitive species list. Biological evaluations are required for proposed 

projects that may impact sensitive species and would continue under alternative A. The current 

forest plan provides standards and guidelines that generally limit disturbance and impacts within 

riparian conservation areas and critical aquatic refuges and call for consideration of impacts to 

aquatic and riparian systems and resources. The western pearlshell is currently not a Pacific 

Southwest Region sensitive species, and under alternative A, it would not be specifically

considered in project planning.

All three species are proposed species of conservation concern in the plan revision alternatives

(see chapter 2, under “Features Common to Alternatives B, B-modified, C, and D, Species of 

Conservation Concern”). This designation will ensure that the Inyo implements management 

actions to improve persistence of the species. Since western pearlshell would have no special 

status under alternative A, this designation could improve habitat for this species better under the 

plan revision alternatives. It would be specifically analyzed and management actions would 

specifically consider effects to this species.

Alternatives B, B-modified, and D would provide management more options and flexibility than 

alternatives A and C for restoring watersheds and habitat using fire (prescribed fire and managing 

fire for resource benefit) through the designation of four strategic fire management zones. In 

addition, more flexibility is provided to management for managing and restoring habitat within

riparian systems using fire, and hand and mechanical treatments. More flexible management 

options and larger proposed acreage for treatment will be beneficial to these species if the 

restoration either directly or indirectly improves or restores habitat for these species found in 

riparian and aquatic systems. For example, if the headwaters of a river or creek are treated to 

reduce the density of trees and minimize the risks of a catastrophic wildfire in the future, the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

441

potential and amount of sedimentation into the aquatic system down below would be reduced. 

Aquatic species would be expected to benefit from improved water quality and substrate such as 

cobbles and stones in the water important for these aquatic invertebrates. However, for these three 

species, their habitat is not in areas that are likely to have much active vegetation management. 

They are more likely to benefit from fire management allowing a return to more natural fire 

intervals.

Alternative C would allow prescribed fire in riparian areas where it was historically prevalent to 

restore desired fuel conditions, to the extent it could occur with limited or no mechanical 

preparation. For these species, the effects would not be different than under the other plan 

revision alternatives because their habitat is not in areas where mechanical preparation is likely to 

occur, due to topography, vegetation types, and remote locations of many of the populations.

Under alternative B-modified, a total of three recreation management zones would be designated 

as a means to manage recreation and support sustainable use. The risks to these species are not 

originating from recreation activity so there would be no effects from these designations. 

Livestock grazing will not vary by alternative; therefore effects will remain the same as under the 

existing condition.

Alternative C contains the southernmost population of pearlshell within recommended 

wilderness. Although recommended wilderness areas are proposed under alternatives B, Bmodified, and C (not D), the benefits to these species is contingent on whether habitat exist for 

these species (or whether species they are present), condition and self-sustainability of the habitat 

over time, and limited management options for treating or restoring habitat, if needed, due to 

restrictions. 

The Inyo National Forest has a number of ecosystem level and species specific plan components 

in place to mitigate risks within its management authority, but cannot mitigate all threats for 

persistence. Based upon this evaluation, the final set of ecosystem plan components and the 

additional species-specific plan components, when carried out, would provide the necessary 

ecological conditions to maintain a viable population of Western Pearlshell, Owen’s Valley 

springsnail, and Wong’s springsnail within its range. 

Due to uncertainty about the species current viability, the potential for host species loss, general 

population loss or collapse, the limited amount of habitat on the Inyo National Forest, and 

potential future threats associated with climate change and ground water use, the Inyo’s ability to 

maintain a viable population is limited. 

Cumulative Effects 

The analysis area is part of the greater southern Sierra Nevada ecosystem and is the vast majority 

of lands are administered or owned by the several Federal agencies, the State of California, water 

and power utilities, several Native American Tribes, and private landowners. The present and 

foreseeable actions of these public land management agencies and private landowners will 

determine the cumulative consequences to aquatic habitat conditions.

The majority of the land within the analysis area that is managed by Federal land management 

agencies have individual resource management plans or shared, collaborative programs in place 

to guide the protection of natural resources, particularly in the management of wildfires. The 

focus of the 2012 Planning Rule on ecosystem integrity, resilience, and diversity is in close 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

442

alignment with new direction for the National Park Service, which is to build ecosystem 

resilience for coping with changing climates. The “Strategic Framework for Science in Support of 

Management in the South Sierra Nevada Ecoregion” was developed collaboratively by Federal 

land managers in the Southern Sierra Nevada ecoregion (including the Sierra and Sequoia 

National Forests and Giant Sequoia National Monument) to help mitigate impacts from, and 

adapt to, climate change (Nydick and Sydoriak 2011a, b). Cumulatively, the strategic 

collaborations developed by the federal agencies, combined with plan components and the plan’s 

similar focus on increasing landscape resilience, should improve region-wide habitat for at-risk 

aquatic species. Land management activities across jurisdictions containing the same at-risk 

species, should be complementary and work together to improve viability and persistence of 

species.

The Forest Service will continue to work with the States in developing total maximum daily load

strategic action plans for the 303(d) listed streams. If sources of impairment are identified related 

to Forest Service management, the total maximum daily loads plans may identify mitigation 

strategies including implementation of best management practices, maintenance or 

decommissioning of facilities, roads, and trails, implementation of currently planned restoration 

projects, and removal of existing stressors. The operators of the various dams associated with 

rivers in the analysis area adapt their operations to meet Federal Energy Regulatory Commission 

relicensing requirements and to address effects of climate change on runoff and baseflows. All 

alternatives minimize the effects of stream diversions or other flow modifications on at-risk 

species for Federal Energy Regulatory Commission, State and other authorized water use 

planning, water rights, and relicensing on the national forest. The Federal Energy Regulatory 

Commission and the power companies in conjunction with the Forest Service will continue 

working collaboratively to address issues as they arise in the future. These collaborations will 

help maximize improvement to at-risk species habitat, within the constraints of existing 

infrastructure.

The proposed management approaches under each of the plan revision alternatives are generally 

consistent with management of other public lands within the cumulative effects analysis area. 

Although the alternatives vary in their ability and pace to achieve the desired conditions and some 

alternatives present more risk of short-term impacts to aquatic habitats than others, it is not 

expected that the management approach under any alternative would have an adverse cumulative 

effect on aquatic habitats on other lands within the analysis area. Therefore, given that the 

majority of the land in the analysis area is managed by Federal agencies and guided by individual 

resource management plans as well as stronger, more relevant multi-agency partnerships, these 

strong consistencies in management direction are expected to provide for landscape-level 

resilience.

Analytical Conclusions

The alternatives considered in detail outline different approaches to achieving the same overall set 

of goals for maintaining and enhancing aquatic habitats and watershed health. This section 

summarizes how well these alternatives are expected to achieve these goals expressed in terms of 

the quality and quantity of aquatic habitats as they relate to effects to aquatic at-risk species.

For most species, plan components describe broad desired conditions that would provide for the 

ecosystem fabric to support a sufficient distribution of individuals of species of conservation 

concern and their habitat so that species are resilient to stressors and are likely to persist into the 

future. Species distribution is partially provided for by the fact that plan components aim to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

443

maintain or restore the diversity and connectivity of ecosystems and habitat types throughout the 

plan area. Fine-filter (special habitat-specific) plan components complement that direction by 

maintaining individuals of species that rely on smaller scale habitats or have very limited 

distribution. Finally, when necessary, project-level protections are an option. As a result, each 

threat in each ecosystem for each species of conservation concern identified has been addressed 

or mitigated in at least one plan component in each alternative, so that the persistence of each 

species is provided for.

If, during the life of a plan, it is found that plan components are not sufficient to ensure the 

persistence of species of conservation concern, the monitoring program developed for the plan 

should detect this and changes to the plan components would be considered to address the issue.

Federally Listed Endangered and Threatened Aquatic Species Determinations

The forest plan provides a programmatic framework for future site-specific projects and actions 

but does not prescribe specific projects or assign project locations. Plan components exist to 

ensure proposed actions avoid, mitigate or minimize impacts to threatened and endangered 

species. All future project-level activities that may affect federally listed species will require 

project-specific assessments and consultation under section 7 of the Endangered Species Act.

For aquatic threatened and endangered species, the biological assessment determined that plan 

components and plan content that would serve to avoid, mitigate, or minimize effects to federally 

listed species, yet actions and activities may disturb and displace individuals and habitat could be 

affected by restoration activities. Since the forest plan is at a programmatic level, it cannot ensure 

that projects developed under it would have no effect or that all actions would be discountable, 

insignificant or beneficial to federally listed species. Therefore, the biological assessment 

determined that adoption of the revised forest plan under all alternatives may affect and is likely 

to adversely affect the northern distinct population segment of the mountain yellow-legged frog,

Sierra Nevada yellow-legged frog, Yosemite toad, Lahontan cutthroat trout, Paiute cutthroat trout, 

and Owens tui chub. We believe that because of the conservation measures of the alternatives, the 

U.S. Fish and Wildlife Service will determine that adopting any of the alternatives would not 

jeopardize the continued existence of these species when they issue a biological opinion.

Critical habitat on the Inyo National Forest has been designated for the northern distinct 

population segment of the mountain yellow-legged frog, Sierra Nevada yellow-legged frog, and

the Yosemite toad. For the purpose of consultation under the Endangered Species Act, we 

determined that although all alternatives are designed to conserve critical habitat, because some 

restoration actions, such as meadow or stream restoration may have short-term adverse effects to 

critical habitat, adoption of the revised forest plan under all alternatives may affect and is likely to 

adversely affect critical habitat for these species. Due to the conservation approach of the 

alternatives, we believe that the U.S. Fish and Wildlife Service will determine that at the 

programmatic level, all of the alternatives are not likely to result in destruction or adverse 

modification of critical habitat.

For the purpose of revising the forest plan, we determined that all plan revision alternatives have 

developed adequate plan components (ecosystem and species-specific) to provide for ecological 

conditions that contribute to the recovery of aquatic federally-listed species within the plan area.

Aquatic Species of Conservation Concern Outcomes

This determination is summarized from the persistence analysis in appendix F of this document. 

The persistence analysis found that for all six aquatic species of conservation concern, “it is 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

444

beyond the authority of the Forest Service to maintain or restore the ecological conditions to 

maintain a viable population of the species in the plan area. Nonetheless, the plan components 

should maintain or restore ecological conditions within the plan area to contribute to maintaining 

a viable population of the species within its range.” The persistence analysis based these 

conclusions on the plan components ability to protect water flows, manage invasive species, 

improve ecosystem resilience to climate change and other events outside the control of the Forest 

Service, and collaborate with other agencies and organizations to restore and maintain at-risk 

species and their habitat.

At-risk Plant Species

Background

Similar to other at-risk species sections, we evaluate and disclose the potential environmental 

consequences of the forest plan alternatives on at-risk plant species and habitat; evaluating the 

effectiveness of the alternatives to provide direction to create the ecological conditions to 

conserve candidate species and maintain a viable population of species of conservation concern 

within the plan area. As previously discussed, the need for plan revisions is guided by three 

primary topics, including ecological integrity which addresses the need to restore the resilience of 

vegetation and aquatic and riparian ecosystems to fire, drought, and climate impacts; restore plant 

habitat and diversity; and reduce the risk of wildfire impacts to species habitat. The alternatives 

present a range of approaches that address the revision topics and issues, including the issues 

related to at-risk plant species and habitat.

The sections on “Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” cover the 

ecological integrity of the ecosystems upon which at-risk plant species depend and evaluate the 

consequences of implementing the alternatives on various taxa35 by integrating an analysis of 

wildlife, aquatic, invertebrate, and plant species. In this section, the evaluation was completed by 

examining conditions of and threats to individual at-risk plant species, and also by examining the 

collective distribution patterns of at-risk flora within the plan area, by biogeographic region and 

by ecosystem. This approach assists in understanding the broad relationship between a 

programmatic land management plan and the desired conditions identified for at-risk species.

Analysis and Methods

The analysis area includes all National Forest System lands within the Inyo National Forest. In 

some cases, the best available scientific information for at-risk species’ ecological relationships 

originated outside the analysis area. However, we used indicator measures and threat information 

from within the analysis area in making conclusions. Because of differences in available 

biological and threat information for federally listed species versus species of conservation 

concern, and because the Forest Service Handbook outlines different procedures to identify plan 

components necessary to provide for the two groups of species, we used different approaches in 

their analyses.

Indicators and Measures

For all at-risk plant species, we identified the extent and condition of habitat as indicators, which

are direct measures of ecological conditions needed to provide for persistent populations. 

Furthermore, for most species, extent and condition of habitat typically constitute the best 

 35 Groups or ranks in a biological classification into which related organisms are classified.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

445

available scientific information indicating whether such populations will continue to persist with 

sufficient distribution in the plan area (36 CFR Sec. 219.19). Finally, we selected extent and 

condition of habitat as indicators because relative differences among alternatives could be readily 

compared.

We made qualitative rather than quantitative comparisons because the known distribution of 

many species is not spatially mapped and the programmatic nature of a forest plan does not direct 

activities in particular locations. To evaluate extent and condition of habitat, we relied strongly 

upon the findings for environmental consequences in the “Terrestrial Ecosystems” and “Aquatic 

and Riparian Ecosystems” sections. In other words, the extent and condition of each ecosystem or 

special ecosystem type served as the habitat indicator for individual species, and for assemblages 

of at-risk species and overall floristic diversity. However, the ecosystem types outlined in the 

“Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” sections are roughly, but not 

exactly aligned with floristic geographic subdivisions (Baldwin et al. 2012), to which at-risk plant 

populations are often associated. Therefore, the extent and condition of floristic geographic 

subdivisions themselves are also discussed to reflect the habitat indicators.

Whitebark pine is a candidate species for federal listing under the Endangered Species Act, and

an additional indicator of population trend was evaluated. For this species, some trend 

information related to management activities has been documented in the plan area and

quantitative, species-specific information was available for analysis.

Determinations for each species of conservation concern consist of a persistence analysis, which 

examines whether plan components provide ecological conditions necessary to provide for the 

persistence of each species in the plan area. This information is found in the “Analytical 

Conclusions” section. It is important to note most of the species of conservation concern have 

small occurrence numbers and/or limited distribution. For these species, associated threats can 

cause substantial concern for persistence in the plan area. Threats in combination with a 

stochastic event could affect a substantial proportion of species of low occurrence or limited 

distribution on the national forest.

As described at the beginning of this “Wildlife, Fish and Plants” section, the primary context for 

the evaluation of at-risk species, including species of conservation concern, is that forest plan 

direction for ecological conditions provide for ecosystem integrity and ecosystem diversity. The 

2012 Planning Rule requires that forest plan direction be integrated across resources and that the 

forest plan needs to provide for the ecological conditions that will provide for the persistence of 

at-risk species within the inherent capabilities of the forest plan area (36 CFR Sec. 219.5 and 

219.8-219.9). The evaluation of forest plan direction that provides for species persistence is done 

first by examining the ecosystem level plan direction, conducted using habitat extent and 

condition as indicators. Where needed, individual species-specific plan direction is added.

For the ecosystem level approach, species were grouped by ecosystems described in the 

“Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” sections and discussed in this 

section. The environmental consequence findings of those sections also compared existing and 

foreseeable future conditions of ecosystems to desired conditions, and this comparison was used 

as the basis of the coarse filter evaluation. This ecosystem approach assumes that persistence of 

species of conservation concern is broadly dependent upon the integrity of the ecosystems where 

they currently occur.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

446

Because integrity of whole ecosystems does not necessarily ensure persistence of all species of 

conservation concern, particularly those with very limited distribution, we conducted additional 

analyses by special habitat and/or species-specific direction to ensure that persistence is provided 

for all plant species of conservation concern. The fine filter evaluation was conducted by analysis 

of (1) special habitats that support suites of some species of conservation concern, and (2) known 

threats to each individual species of conservation concern. Species were grouped by fine-scale 

habitats where possible, to enable a fine filter look at ecological conditions that affect 

populations. Documented threats that influence species trends in distribution and persistence were 

also evaluated. The plant rationale document (USDA Forest Service 2018b) lists each species’ 

ecosystem, NatureServe rank, threats, and the occurrence information. Known threats to species 

of conservation concern were compared qualitatively by alternative.

For species that were previously listed as Forest Service Pacific Southwest Region sensitive 

species, but which were not identified as at-risk species under the 2012 Planning Rule, the 

rationale for this determination and an overview of those species are presented in the plant 

rationale document (USDA Forest Service 2018b) and briefly summarized above in the 

introduction section for this “Wildlife, Fish and Plants.”

Analysis Area

In general, the analysis area for indirect effects includes all National Forest System lands 

managed by the Inyo National Forest.

Assumptions

• Land management plans do not have direct effects. They do not authorize or mandate any 

site-specific projects or activities (including ground-disturbing actions). However, there 

may be implications, or longer term environmental consequences, of managing the national 

forest under this programmatic framework. As a result, all effects discussed in this section 

are considered indirect effects or cumulative effects.

• The planning timeframe for the effects analysis is 10 to 15 years; other timeframes may be 

specifically analyzed depending on the resource and potential consequences.

• Monitoring identified in the plan monitoring program and any broader-scale monitoring 

will occur, and the land management plan will be amended, as needed during the life of the 

plan.

• Relevant considerations to the analysis that are common to all alternatives include: existing 

wilderness will continue to be managed as such; there will be a general increase in 

recreational demand as the human population size increases; weeds and weed seeds will 

continue to be deposited and spread onto and within the plan area; and climate change 

trends will continue as projected, with warming temperatures and reduced snowpack.

• Funding will be available to implement restoration measures, including nonnative invasive 

plant treatments identified as priorities because they pose substantial threats to the 

persistence of at-risk plant species.

Species Evaluated

A total of 106 at-risk plant species were identified on the Inyo National Forest; this includes one 

federally designated candidate species, whitebark pine, and 105 plant species of conservation 

concern.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

447

Federally Listed and Candidate Plant Species

There are currently no federally listed plant species occurring in the plan area; there is one 

candidate species, whitebark pine (table 67). Candidate species are plants and animals for which 

the U.S. Fish and Wildlife Service has sufficient information on their biological status and threats 

to propose them as endangered or threatened under the Endangered Species Act, but for which 

development of a proposed listing regulation is precluded by other higher priority listing 

activities. Candidate species do not have formal protection under the Endangered Species Act but 

the 2012 Planning Rule requires that forest plans are developed to conserve candidate species (36 

CFR 219.9).

Ramshaw meadows abronia (Abronia alpina) was a candidate species during the assessment 

phase for plan development and revision but has since been removed from consideration as a 

candidate species by the U.S. Fish and Wildlife Service36 and was added to the list of species of 

conservation concern on the Inyo National Forest due to concern for its persistence in the plan 

area.

Table 67. Federally designated plant species and critical habitat

Scientific Name Common Name Status Critical Habitat Principal Habitat

Pinus albicaulis Whitebark pine Candidate Not applicable Subalpine, alpine

Plant Species of Conservation Concern

The Inyo National Forest has 105 plant species of conservation concern on, comprising 97 

flowering plants; 5 ferns, 2 mosses and lichen. Over 200 botanical species were considered for 

species of conservation status (FSH 1909.12, section 12.52c-d), as documented in the Rationales 

for Plant Species Considered for Species of Conservation Concern, Inyo National Forest (USDA 

Forest Service 2018b). The list of plant species of conservation concern37 is presented in table 70, 

in the “Affected Environment” section.

Under the current forest plan, rare plants are provided for according to the direction for Region 5 

sensitive species. Of the 67 sensitive plant species that occur in the Inyo National Forest plan 

area, 46 were carried forward as species of conservation concern. In addition, 59 species not 

previously categorized as Pacific Southwest Region sensitive species were added as species of 

conservation concern. The species of conservation concern lists are specific to each national 

forest, and species must be known to occur with the plan area. For that reason, some sensitive 

species may be identified as species of conservation concern on one national forest, while not on 

the neighboring national forest. The specific reasons a sensitive species was determined to meet 

or not meet the established criteria as a species of conservation concern are provided in the

species rationales found in the plant rationale document (USDA Forest Service 2018b). A 

summary is provided in table 56.

Affected Environment

Although some concentrations of species can be identified on the Inyo National Forest (such as in

alpine ecosystems of the White Mountains), at-risk plant species can be found in all floristic 

geographic subdivisions, and in all ecosystem types. The special habitats, or ecosystem types 

 36 Federal Register: 80 FR 60834, Oct. 8, 2015

37 Pacific Southwest Regional Forester signed list on January 2018.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

448

called out in the “Terrestrial Ecosystems” and “Aquatic and Riparian Ecosystems” sections can 

sometimes host a number of at-risk plant species.

Floristic Diversity

The flora of the Inyo National Forest is notably diverse, reflecting the area’s complex geology, 

topography, and climate. The close juxtaposition of such variable habitats has created 

opportunities for genetic isolation and subsequent evolution. As a result, the area has an 

exceptionally high level of endemic species (unique to a place or region) relative to other regions 

of the United States (California Native Plant Society 2015). Inyo National Forest is situated at the 

intersection of California’s three major floristic provinces (Baldwin et al. 2012): California 

Floristic Province, Great Basin, and Desert.

Because many species of conservation concern have a greater affinity for floristic geographic 

subdivisions (like provinces) than for ecosystems, some detail is provided here on the 

subdivisions, which assisted in the evaluation of habitat condition and extent. The three major 

provinces and their respective regions that occur in the plan area host relatively distinct floras, 

although the transitions are not necessarily abrupt, resulting in some overlap, particularly where 

mountain passes or drainages support connectivity. 

Figure 31 show the floristic geographic subdivisions represented in the plan area and table 68

displays the number of plant species tracked by the California Natural Diversity Database to show 

the relative diversity of plants in these provinces (Baldwin et al. 2012).

Table 68. Plant species diversity by floristic geographic province, region, and subdivisions1

Province Region Subregion1

No. Plant 

Species in 

CNDDB2

Area (acres)

California 

Floristic 

Province

Sierra Nevada High Sierra Nevada (Central 

and Southern districts) 76 823,746

Great Basin Eastern Sierra 

Nevada White and Inyo Mountains 75 471,698

Great Basin Eastern Sierra 

Nevada

Other Eastern Sierra 

Nevada (Mono Basin, Glass 

Mts., Eastern escarpment)

60 667,251

Desert Mojave Desert Mojave Desert (exc. Desert 

Mts.) 4 14,019

1. Spatial dataset used with permission from the Jepson Herbarium (Jepson Flora Project 2015).

2. CNDDB is the California Natural Diversity Database (California Department of Fish and Wildlife 2017b). Note many 

plants occur in more than one province.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

449

Figure 31. Floristic geographic subdivisions
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

450

The Sierra Nevada region, which occupies the majority of the plan area, is characterized primarily 

by igneous geology. The High Sierra Nevada subregion (central and southern districts) is 

topographically complex, spanning nearly 10,000 feet in elevation. Vegetation may be dominated 

by ponderosa pine, mixed conifer, Jeffrey pine, red fir, lodgepole pine, mountain hemlock, 

whitebark pine, foxtail pine, or western white pine. Treeless alpine areas, meadows, and riparian 

areas, are also common. The southern High Sierra Nevada subregion supports some pinyon pine 

and sagebrush. Although this region is the largest in size and supports about one-third of at-risk 

plant species on Inyo National Forest, the density of at-risk populations is not high in comparison 

to the Mojave Desert or White and Inyo Mountains subregions.

In the Eastern Sierra Nevada Region, the 10,000-foot elevation gradient is abrupt, creating rapid 

transitions from desert and sagebrush vegetation at the lowest elevations, to pinyon pine 

woodlands, coniferous forests, and alpine areas. The region includes most conifers found on the 

west side of the Sierra Nevada, but mixed conifer is relatively uncommon. This region is 

geologically complex, with significant volcanic, sedimentary, and metamorphic bedrock and soils 

represented. The White and Inyo Mountains subregion is situated in the rain shadow of the Sierra 

Nevada, and receives less precipitation, as evident in the arid-adapted vegetation, including 

pinyon-juniper, mountain mahogany, sagebrush, bristlecone and limber pine, and large expanses 

of high alpine areas.

Ecosystem Types

The floristic geographic subdivisions give an overview of the distribution of diversity in the plan 

area and assist with a broad, qualitative analysis. For further detailed analysis, plant species are 

aligned with ecosystem types classified in the “Terrestrial Ecosystems” and “Aquatic and 

Riparian Ecosystems” sections. The ecological habitat types that host particularly high numbers 

of at-risk plant species are subalpine, sagebrush, alpine, and pinyon-juniper habitats. As discussed 

in the “Terrestrial Ecosystems” section, special habitats are limited, uncommon habitats that are 

important in providing unique conditions and may support concentrations of plant species of 

conservation concern. Examples of special habitats on the Inyo National Forest include alkali 

flats, caliche-covered clay soil mounds, pumice flats, and stabilized dunes. The ecosystem type 

associated with each plant species of conservation concern is included in table 70.

Status and Threats for At-risk Plant Species

Federally Listed and Candidate Plant Species

Whitebark pine is a candidate species for listing. There are no other federally listed plant species 

analyzed on the Inyo National Forest. A brief species summary is given here; a full species 

account with literature citations was provided during the assessment phase for forest plan revision 

and is included in the project record (USDA Forest Service 2013a). Although candidate species 

do not have formal protection under the Endangered Species Act, we included an analysis of 

whitebark pine in the biological assessment prepared for this project (USDA Forest Service

2017a). The information is briefly summarized below.

Whitebark pine is known to occur in the western mountains of the United States and Canada. In 

California, it occurs in the Klamath Range, Cascade Range, Warner Mountains, and Sierra 

Nevada. It is a slow-growing, long-lived conifer that tolerates poor soils, steep slopes, and windy 

exposures and is found at treeline and subalpine elevations throughout its range. On the Inyo 

National Forest, approximately 140,000 acres contain whitebark pine stands (table 69); about 37

percent of the extent of whitebark pine in California (Slaton, Gross, and Meyer 2014). 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

451

Approximately 86 percent of the whitebark pine on the Inyo National Forest occurs within 

wilderness. The remaining acres occur primarily either within ski areas, near high elevation 

reservoirs where day use activities are popular (such as Lake Sabrina, Saddlebag Lake, and South 

Lake), or at the lower elevations of the whitebark pine zone, where campgrounds and trailheads 

are often found (Onion Valley, Bishop Creek, and Rock Creek developed recreation sites). Some 

whitebark pine stands occur in the Glass Mountains.

Table 69. Distribution of whitebark pine on the Inyo National Forest and in 

California

Location Acres

Inyo National Forest 139,922

In Wilderness on Inyo National Forest 120,137

Other National Forests in California 123,089

National Parks in California 107,438

California Total 372,035

Whitebark pine serves a number of important ecological functions, including snow retention, 

runoff regulation, soil temperature moderation, early colonization of disturbed sites, and forage 

and habitat for birds and mammals (Meyer 2013b). There are several major threats to whitebark 

pine, including attack by native bark beetles, climate change, fire suppression, and the introduced 

pathogen white pine blister rust (United States Department of the Interior 2011, 2016b). White 

pine blister rust is uncommon on the east side of the Sierra Nevada crest, including in whitebark 

pine in the plan area (Meyer 2013b). Whitebark pine of all age classes are adversely affected by 

high intensity fire, but burned areas provide a seedbed and are used by Clark’s nutcrackers as

seed cache sites and can serve as regeneration sites. A climate-related threat is impacts to 

individuals from snow avalanches which will be influenced by climate change to the extent that 

patterns of snowfall and conditions that trigger avalanches change over time. Although each 

threat individually is problematic, the combined impacts pose a significant threat to species 

viability. 

Whitebark pine population trend information from surveys conducted in the vicinities of June 

Mountain and Rock Creek indicate bark beetle attacks result in high mortality among medium- to 

large-diameter trees, with high survivorship in small trees (Meyer et al. 2014b). While there has 

been a trend of changing stand structure in some whitebark pine stands, there has been no clear

evidence of range retraction or expansion. Mountain pine beetle mortality in stands of whitebark 

pine functioned to release saplings that were seed cached by Clark’s nutcrackers where saplings 

were many decades old and suppressed in growth by the overstory trees. These stands some 

showed signs of increased growth following release (MacKenzie 2014, Perkins 2015).

Plant Species of Conservation Concern

For each species of conservation concern, important information that contributes to the judgement 

of whether a substantial concern exists for the persistence of a given species includes the 

occurrences within the plan area, extent of habitat (broad ecosystems or ecosystem types as 

defined in the forest plan), and known threats. Table 70 displays the list of plant species of 

conservation concern with species grouped by known threats to persistence and principal 

ecological habitats on Inyo National Forest. This information is used in the analysis to evaluate 

how plan components provide for the ecological conditions needed by habitat type and addresses 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

452

threats associated with those habitats. Within the threat column, we include identifying species 

with small occurrences and/or limited distribution.

No set number was used as a threshold for population size, but rather the context in which each 

species occurs was considered. Fundamental principles of conservation biology related to 

minimum population sizes to maintain viable populations and on causes of rarity were considered 

in these determinations (Rabinowitz 1981, Shaffer 1981), and (Wiens and Slaton 2012). Species 

carried forward to the list of species of conservation concern are those for which the identified 

threats were considered to at least in part affect local population persistence, thus contributing to 

the substantial concern for species persistence. 

Table 70. Inyo National Forest plant species of conservation concern and threats by principal habitat 

type

Scientific Name Common Name Known Threats to Persistence Principal habitats

Abronia alpina Ramshaw 

Meadows abronia

Conifer encroachment; hydrologic 

alteration; climate change; small 

occurrence numbers 

Subalpine; dry forb 

Agrostis humilis Alpine bentgrass

Climate change and related 

hydrologic alteration; social trails in 

meadows; packstock; small 

occurrence numbers

Alpine

Allium atrorubens var.

atrorubens

Great Basin 

onion

Grazing; mining; small occurrence 

numbers

Mountain mahogany; 

subalpine; pinyon-juniper

Astragalus cimae var.

sufflatus

Inflated Cima 

milk-vetch

Invasive species; small occurrence 

numbers Pinyon-juniper

Astragalus inyoensis Inyo milk-vetch Mining; vehicles; restricted 

geographic range Pinyon-juniper

Astragalus johannishowelliiLong Valley milkvetch Grazing; small occurrence numbers Sagebrush; alkali flat 

Astragalus kentrophyta 

var. elatus

Spiny-leaved 

milk-vetch

Climate change; recreation; small 

occurrence numbers; soil 

degradation

Subalpine

Astragalus lemmonii Lemmon's milkvetch

Grazing; hydrologic alteration; few 

occurrence numbers Sagebrush; alkali flat 

Astragalus lentiginosus 

var. kernensis

Kern Plateau 

milk-vetch

Vehicles; climate change; drought; 

grazing

Subalpine; dry forb; 

lodgepole

Astragalus monoensis Mono milk-vetch Unauthorized OHV travel; drought; 

grazing; limited distribution

Jeffrey pine; sagebrush; 

dry forb; pumice flats

Astragalus ravenii Raven's milkvetch

Climate change; very small 

occurrence numbers; fragile habitat Alpine; subalpine

Astragalus serenoi var.

shockleyi

Shockley's milkvetchMining; grazing; invasive species; 

small occurrence numbers

Pinyon-juniper; xeric 

shrub/blackbrush

Astragalus subvestitus Kern County 

milk-vetch

Grazing; unauthorized OHV travel; 

very few occurrences Subalpine; dry forb

Boechera bodiensis 

(Arabis b.)

Bodie Hills 

rockcress Climate change; few occurrences Pinyon-juniper; sagebrush 

Boechera pendulina Rabbit-ear 

rockcress Climate change; few occurrences Alpine

Boechera pinzliae Pinzl's rockcress Climate change; few occurrence 

numbers Alpine; subalpine

Boechera shockleyi 

(Arabis s.)

Shockley's 

rockcress

Mining; vehicles; small occurrence 

numbers Xeric shrub/blackbrush
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

453

Scientific Name Common Name Known Threats to Persistence Principal habitats

Boechera tiehmii (Arabis 

t.)

Tiehm's 

rockcress

Climate change; small occurrence 

numbers Alpine

Boechera tularensis Tulare rockcress Grazing; climate change; very few 

occurrence numbers Subalpine; meadow

Botrychium ascendens Upswept 

moonwort

Hydrologic alteration; trampling; 

unauthorized OHV travel; severe soil 

disturbance; small occurrence 

numbers

Subalpine; meadow

Botrychium crenulatum Scalloped 

moonwort

Hydrologic alteration; trampling;

unauthorized OHV travel; severe soil 

disturbance

Subalpine; meadow

Botrychium lineare Slender

moonwort

Hydrologic alteration; trampling; 

unauthorized OHV travel; severe soil 

disturbance; one occurrence of a 

single plant

Subalpine; meadow

Botrychium minganense Mingan 

moonwort

Hydrologic alteration; trampling; 

unauthorized OHV travel; severe soil 

disturbance; small occurrence 

numbers

Subalpine; meadow

Bruchia bolanderi Bolander's 

bruchia

Hydrologic alteration; recreation 

impacts in meadow; few occurrences Alpine; subalpine 

Calochortus excavatus Inyo County startulip

Grazing; hydrologic alteration; small 

occurrence numbers

Sagebrush; xeric 

shrub/blackbrush; 

meadow 

Calyptridium pygmaeum Pygmy 

pussypaws

Climate change; trampling; small 

occurrence numbers Alpine; subalpine

Carex davyi Davy's sedge Hydrologic alteration; grazing; small 

occurrence numbers Subalpine; meadow

Carex duriuscula Spikerush sedge Grazing; hydrologic alteration; small 

occurrence numbers

Sagebrush; subalpine; 

meadow

Carex idahoa Idaho sedge Grazing; climate change; small 

occurrence numbers

Sagebrush; subalpine; 

meadow

Carex petasata Liddon's sedge Grazing; climate change; small 

occurrence numbers 

Pinyon-juniper; subalpine; 

meadow

Carex praticola Northern 

meadow sedge

Grazing; climate change; small 

occurrence numbers Subalpine; meadow

Carex scirpoidea ssp. 

pseudoscirpoidea

Western singlespiked sedgeGrazing; climate change; small 

occurrence numbers Sagebrush; subalpine

Carex stevenii Steven's sedge Climate change; small occurrence 

numbers; hydrologic alterations Alpine

Carex tiogana Tioga Pass 

sedge

Climate change; recreation; small 

occurrence numbers Alpine; subalpine 

Carex vallicola Western valley 

sedge

Hydrologic alteration; climate 

change; small occurrence numbers Sagebrush; subalpine

Chaetadelpha wheeleri Wheeler's dunebroom

Extremely restricted; soil degradation 

from vehicles and solar energy 

development. Possibly threatened by 

nonnative plants. small occurrence 

numbers 

Sagebrush; sand dune

Claytonia megarhiza Fell-fields 

claytonia

Climate change; small occurrence 

numbers Alpine

Cordylanthus eremicus 

ssp. kernensis

Kern Plateau 

bird's-beak

Grazing; recreation; climate change;

small occurrence numbers Alpine; subalpine 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

454

Scientific Name Common Name Known Threats to Persistence Principal habitats

Crepis runcinata ssp. 

hallii

Hall's meadow 

hawksbeard

Grazing; unauthorized OHV travel; 

hydrologic alteration; small 

occurrence numbers and restricted 

habitat

Sagebrush; alkali flat

Cuniculotinus gramineus 

(Chrysothamnus g.)

Panamint rockgoldenrodMining; invasive species; small 

occurrence numbers 

Mountain mahogany; 

subalpine; carbonate

Cymopterus globosus Globose 

cymopterus

Grazing; hydrologic alteration; Very 

few occurrence numbers Sagebrush

Dedeckera eurekensis July gold

Mining; recreation; invasive species; 

small occurrence numbers and 

limited distribution

Xeric shrub/blackbrush; 

carbonate

Draba californica California draba Climate change; limited distribution Sagebrush; alpine

Draba monoensis White Mountains 

draba Climate change; few occurrences Alpine 

Draba sharsmithii Mt. Whitney 

draba

Climate change; small occurrence 

numbers; trail construction and 

maintenance; trampling by hikers 

Alpine

Dryopteris filix-mas Male fern

Climate change; possible hydrologic 

concerns (drying of springs); few 

occurrences

Subalpine

Ericameria gilmanii Gilman's 

goldenbush

Invasive species; mining; Very few 

populations Pinyon-juniper; subalpine

Erigeron compactus Compact daisy

Invasive species; climate change; 

small occurrence numbers and 

limited habitat

Sagebrush; pinyonjuniper; carbonate; alkali 

flat

Erigeron uncialis var.

uncialis Limestone daisy Very few occurrences and limited distribution Sagebrush; carbonate

Eriogonum alexandrae 

(E. ochrocephalum var.

ochrocephalum)

Alexander’s 

buckwheat

Invasive species; trampling (wild 

horses/cattle); unauthorized OHV 

travel; few occurrences

Sagebrush; pinyonjuniper; caliche-covered 

clay soil mounds

Eriogonum mensicola Pinyon Mesa 

buckwheat

Mining; recreation; invasive species; 

small occurrences numbers Pinyon-juniper

Eriogonum wrightii var.

olanchense

Olancha Peak 

buckwheat

Climate change; small occurrence 

numbers Alpine; subalpine

Goodmania luteola Yellow spinecape Grazing; small occurrence numbers Sagebrush

Greeneocharis 

circumscissa var.

rosulata

Rosette cushion 

cryptantha

Grazing; trampling; climate change; 

small occurrence numbers Alpine; dry forb; subalpine 

Grusonia pulchella Beautiful cholla Grazing; few occurrence numbers Sagebrush; xeric 

shrub/blackbrush

Hackelia brevicula Poison Canyon 

stickseed

Grazing; climate change; small 

occurrence numbers Sagebrush; subalpine

Hackelia sharsmithii Sharsmith's 

stickseed

Recreation impacts along trails; 

small occurrences Sagebrush; subalpine

Helodium blandowii Blandow's bog 

moss

Hydrologic alteration; grazing; small 

occurrence numbers Subalpine; meadow

Hesperidanthus jaegeri Jaeger's 

hesperidanthus

Climate change; invasive species; 

few occurrences and limited habitat 

Pinyon-juniper; subalpine; 

carbonate

Horkelia hispidula White Mountains 

horkelia

Grazing; climate change; limited 

distribution Sagebrush 

Hulsea brevifolia Short-leaved 

hulsea

Trampling; altered fire regime; small 

occurrence numbers Subalpine; mixed conifer
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

455

Scientific Name Common Name Known Threats to Persistence Principal habitats

Hulsea vestita ssp. 

inyoensis Inyo hulsea Mining; small occurrence numbers Pinyon-juniper; sagebrush

Ivesia campestris Field ivesia Grazing Subalpine; meadow

Ivesia kingii var. kingii Alkali ivesia

Grazing; unauthorized OHV travel; 

hydrologic alteration; small 

occurrence numbers

Sagebrush; alkali flat 

Jamesia americana var.

rosea

Fivepetal 

cliffbush

Climate change; recreation 

trampling; small occurrence numbers Alpine; subalpine

Kobresia myosuroides 

(K. bellardii) Seep kobresia Small occurrence numbers Subalpine; meadow

Ladeania lanceolata 

(Psoralidium 

lanceolatum)

Lance-leaved 

scurf-pea

Wild horse; grazing; limited 

occurrence Sagebrush; sand dunes

Lomatium foeniculaceum 

ssp. inyoense Inyo biscuitroot Soil degradation; climate change Sagebrush; subalpine

Lupinus duranii Mono Lake lupine Unauthorized OHV travel; grazing; 

invasive species; road maintenance

Jeffrey pine; sagebrush; 

dry forb; pumice flats

Lupinus padre-crowleyi Father Crowley's 

lupine

Livestock trampling; altered fire 

regime; limited occurrence numbers Sagebrush; Jeffrey pine

Mentzelia inyoensis Inyo blazing star Invasives; very small occurrence 

numbers and limited distribution.

Pinyon-juniper; sagebrush 

(calcareous pumice)

Mentzelia torreyi Torrey’s blazing 

star

Invasives; vehicles; grazing and 

trampling and limited distribution

Sagebrush; pinyonjuniper; caliche-covered 

clay soil mounds

Monardella beneolens Sweet-smelling 

monardella

climate change; small occurrence 

numbers Alpine; subalpine 

Oreocarya roosiorum 

(Cryptantha roosiorum)

Bristlecone 

cryptantha

Climate change; small occurrence 

numbers Subalpine 

Oxytropis deflexa var.

sericea

Blue pendant-pod 

oxytrope Grazing; small occurrence numbers Subalpine; meadow

Penstemon calcareus Limestone 

beardtongue

Invasive species; burros; very small 

occurrence numbe

Xeric shrub/blackbrush; 

carbonate

Petrophyton 

caespitosum ssp. 

acuminatum (P. 

acuminatum) 

Marble rockmat Very small occurrence numbers; 

competition by invasives 

Mountain mahogany; 

subalpine; pinyon-juniper 

Phacelia inyoensis Inyo phacelia Grazing; vehicle use; very few 

occurrences Sagebrush; meadow

Phacelia monoensis Mono phacelia Restrictive habitat and limited 

distribution Pinyon-juniper 

Phacelia nashiana Charlotte's 

phacelia Invasives: small occurrences Xeric shrub/blackbrush 

Physaria ludoviciana Silver bladderpod Wild horses; only one occurrence 

recorded

Sagebrush; calichecovered clay soil mounds

Physocarpus alternans Nevada ninebark Very small occurrence numbers; 

invasive species; climate change Pinyon-juniper; carbonate

Plagiobothrys parishii Parish's 

popcornflower

Climate change; hydrological 

alteration; grazing; very small 

occurrence numbers and limited 

distribution

Xeric shrub/blackbrush; 

Polemonium chartaceum Mason's sky pilot Climate change; grazing; recreation; 

small occurrence numbers Alpine
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

456

Scientific Name Common Name Known Threats to Persistence Principal habitats

Polyctenium williamsiae Williams' 

combleaf

Climate change; limited habitat; 

grazing; unauthorized OHV travel; 

small occurrence numbers 

Sagebrush

Populus angustifolia Narrow-leaved 

cottonwood

Hydrologic alteration, altered fire 

regime; one occurrence of all male 

plants

Pinyon-juniper; sagebrush

Potentilla morefieldii Morefield's 

cinquefoil Climate change; grazing; recreation Alpine; carbonate

Potentilla pulcherrima Beautiful 

cinquefoil

Grazing; erosion; small occurrence 

numbers Sagebrush; alpine 

Ranunculus 

hydrocharoides

Frog's-bit 

buttercup

Hydrologic alteration; drought and 

horse trampling identified as possible 

threats; small occurrence numbers 

Pinyon-juniper 

Sclerocactus 

polyancistrus

Redspined 

fishhook cactus

Horticultural collection; vehicles; 

grazing; insect herbivory

Sagebrush; xeric 

shrub/blackbrush

Solorina spongiosa

Fringed 

chocolate chip 

lichen

Limited occurrence on INF; single 

occurrence along roadside in 

recreation area; recreation trampling 

Subalpine 

Sphaeromeria 

potentilloides var.

nitrophila

Fivefinger 

chickensage Unauthorized OHV travel; grazing Sagebrush; alkali flat; meadow 

Sphenopholis obtusata Prairie wedge 

grass

Grazing; hydrologic alteration; small 

occurrence numbers Sagebrush; pinyon-juniper 

Stipa divaricata Small-flowered 

rice grass

Grazing; climate change; very small 

occurrences numbers Sagebrush

Streptanthus gracilis Alpine 

jewelflower

Hydrologic alteration; climate 

change; recreational trampling; 

limited distribution

Alpine 

Streptanthus oliganthus

Masonic 

mountain 

jewelflower

Grazing; mining; erosion; small 

occurrence numbers Pinyon-juniper 

Taraxacum 

ceratophorum Horned dandelion Grazing; hydrologic alteration; small 

occurrence numbers & distribution Subalpine 

Tetradymia tetrameres Dune horsebrush

Invasive species; unauthorized OHV 

travel; climate change; small 

occurrence numbers and limited 

distribution

Sand dune; xeric 

shrub/blackbrush

Thelypodium 

integrifolium ssp. 

complanatum

Foxtail 

thelypodium

Very few occurrence numbers; 

grazing; hydrologic alteration Pinyon-juniper; sagebrush

Thelypodium milleflorum Many-flowered 

thelypodium

Invasive species; wild horse 

browsing; unauthorized OHV travel; 

vegetation management; climate 

change; small occurrences 

Sagebrush; xeric 

shrub/blackbrush; calichecovered clay soil mounds

Townsendia leptotes Slender 

townsendia Climate change; limited distribution Alpine

Transberingia bursifolia 

ssp. virgata

Virgate 

halimolobos

Grazing; hydrologic alteration; small 

occurrence numbers

Pinyon-juniper; subalpine; 

meadow

Trichophorum pumilum Little bulrush Hydrologic alteration; grazing; small 

occurrence numbers Subalpine

Trifolium dedeckerae (T. 

kingii ssp. dedeckerae)

Dedecker's 

clover

Grazing; road maintenance; climate 

change; invasive species 

Alpine; subalpine; 

sagebrush; 

Viola purpurea ssp. 

aurea 

Golden violet Grazing; vehicles; small occurrence 

numbers Sagebrush
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

457

As previously discussed, the at-risk species specific, or fine filter, evaluation was conducted by 

analysis of (1) special habitats that support suites of some species of conservation concern on the 

Inyo National Forest, and (2) known threats to each individual species of conservation concern. In 

table 70, special habitats that support some species of conservation concern are included in the 

principal habitat column. The major threat groups and numbers of species documented to be 

affected by the threat are displayed in table 71. Threats to plant species of conservation concern 

from recreation activities include trampling, ground disturbance, plant harvesting, and 

introduction of weeds, including by hikers, stock, and unauthorized off-highway vehicle travel. 

Areas with developed facilities, like campgrounds, make areas more accessible and concentrate 

use that can impact plant habitat. Dispersed camping has similar impacts. Soil disturbance also 

occurs during vegetation management treatments and prescribed burning activities, including 

during associated road building or maintenance, or line construction. Roads used for vegetation 

management treatments may also provide an avenue for invasive plant species. Nonnative

invasive plant species can displace native plant communities through resource competition, which

could result in the loss of native at-risk species habitat, loss of pollinators, decreased plant 

diversity, and decreased rare plant species viability. Invasive species management activities may 

include herbicide spraying and mechanical ground disturbance that could impact native species.

Table 71. Known threats to plant species of conservation concern, as documented 

in best available scientific information*

Threat

Number of Species Documented to 

be Affected by Threat

Altered fire regime 3

Climate change 45

Conifer encroachment 1

Drought 4

Erosion/soil degradation 9

Few occurrences and/or limited distribution** 94

Fragile habitat 1

Grazing 46

Horticultural collection 1

Hydrologic alteration 27

Insect herbivory 2

Invasive species 19

Livestock trampling 3

Mining 10

Recreation (trails, trampling) 20

Road maintenance 2

Unauthorized OHV travel 14

Wild horses, burros 4

* Most species of conservation concern on the Inyo National Forest are affected by more than one 

threat.

** All species of conservation concern are considered rare to some degree; occurrence numbers or 

restricted ranges are considered with various factors that threaten persistence in the plan area.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

458

Environmental Consequences to At-risk Plant Species

Consequences to Whitebark Pine (Candidate Species)

Consequences Common to All Alternatives

Whitebark pine are periodically monitored by the Regional Ecology Program and it is recognized 

as a species highly susceptible to climate change (USDI Fish and Wildlife Service 2016b). 

Whitebark pine will continue to be evaluated by the Forest Health Protection program and by 

forest pathologists for tree mortality and susceptibility to bark beetle attack and to monitor for 

white pine blister rust. As needed, Forest Health Protection staff may recommend management or 

restoration projects which may be considered and implemented by the Inyo when feasible.

The extent of impacts of recreation management on whitebark pine is not known but they occur 

within and near several popular campgrounds and recreation sites, ski areas, and trails. Whitebark 

pine trees may be affected by incidental damage by recreationists within campgrounds and during 

campground maintenance, including pruning or removal when they create safety hazards. 

Whitebark pine can also be affected by collection and use of whitebark pine branches and downed 

wood for campfires by recreationists. However, since 2002, the Inyo has implemented elevationbased campfire restrictions in wilderness areas in part to reduce the impacts of depletion of 

downed wood and ground litter in the elevations where whitebark pine occurs.

Where whitebark pine occurs along roads, trails, within utility corridors, and near facilities, they 

may be pruned or removed where they contribute to safety hazards and cannot be avoided. In 

general, efforts are made to protect mature trees and the plan revision alternatives include a 

specific desired condition to protect mature cone-bearing trees where possible.

Consequences Specific to Alternative A

Alternative A has general direction to protect the diversity of plant communities and seral stages, 

but has no direction specific to whitebark pine. Projects and activities would be guided by agency 

direction for managing candidate species and direction to manage Regional Forester’s sensitive 

species. As a sensitive species, project proposals would be evaluated at the project level to ensure 

they do not lead to a trend towards federal listing. Short-term effects would be minimal to 

whitebark pine, because small-scale restoration projects and species monitoring would continue 

to occur under this alternative and projects that could affect whitebark pine would be evaluated to 

ensure it would contribute to the conservation of the species. Where whitebark pine occurs in 

recreation sites, including ski resorts under special use permit, and near roads and other 

infrastructure, they will continue to be pruned or removed where needed to provide for public 

safety. Where possible, projects would continue to be designed to reduce competing vegetation to 

increase resilience and create suitable seedbeds to support natural regeneration as has occurred in 

recent projects in the June Lakes area.

The current forest plan only defines fire management zones around communities. No specific 

forest plan direction exists to guide fire management related to whitebark pine in the majority of 

the areas where whitebark pine occurs, which is primarily located in designated wilderness and 

remote alpine and subalpine habitats away from communities. When fires occur in these areas 

away from communities, fire management decisions are guided by agency policies and 

procedures where naturally ignited wildfires are considered for management to meet resource 

objectives on a case-by-case basis. Since forest plan resource objectives for wildfire management 

are only general in nature, many wildfires continue to be suppressed, slowing the restoration of 

fire as an ecosystem function to many forest landscapes. Continuing to suppress wildfires allows 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

459

vegetation to continue to become denser which can increase competition by encroaching trees and 

shrubs and increase water stress to whitebark pine. Burned areas that create exposed mineral soil 

are also important for seed caching by animals, particularly the Clark’s nutcracker, which is an 

important mechanism for whitebark pine regeneration.

Because it lacks an emphasis on whitebark pine conservation and many wildfires that burn in 

whitebark pine habitats will likely continue to be suppressed, alternative A would protect and 

restore the least amount of whitebark pine habitats but would still provide the ecological 

conditions necessary to conserve candidate species and would maintain or restore their habitats in 

the plan area to contribute to preventing them from being federally listed.

Consequences Common to Alternatives B, B-modified, C, and D

Desired conditions for the alpine and subalpine zone provide for healthy whitebark pine, 

including resilience to moisture stress, drought, and bark beetles, and resistance to white pine 

blister rust. The desired condition for the alpine and subalpine vegetation zone provides for 

protection and conservation of genetic diversity through the maintenance of mature cone-bearing 

trees. This is important to ensure sufficient seeds for caching by Clark’s nutcrackers to aid in 

natural regeneration and to maintain genetic diversity.

Since most of the whitebark pine occurs within wilderness, no direct active management other 

than restoring fire as an ecosystem process will likely occur to move towards the vegetation

desired conditions that would benefit whitebark pine. Compared to alternative A, the plan 

revision alternatives would better reduce the threat of high-intensity fire, and to some degree 

other threats, because of the emphasis on ecosystem restoration through the use of prescribed fire 

and wildfire managed to meet resource objectives. The latter is especially beneficial for whitebark 

pine because this is the primary restoration treatment in designated wilderness areas, where much 

of the whitebark pine occurs. As a result, there would be a positive effect to whitebark pine 

habitat quality and population trend to the extent that fire is restored within the natural range of 

variation.

In general, limited vegetation management to reduce stand densities is expected to occur in stands 

with whitebark pine. Outside of wilderness, vegetation projects could be designed to reduce stand 

density of trees to lessen competition and increase the resilience of whitebark pine. This type of 

active management is generally limited because of difficult access by equipment and the higher 

costs of vegetation management due to limited vegetation management infrastructure. When

projects are designed in the alpine and subalpine ecological zone, desired conditions will function 

to guide them to consider the seral stages of whitebark pine and ensure that regeneration is likely 

to continue to occur which will increase the likelihood of climate adaptation (Brautigam et al. 

2013). Thinning of mature trees has been observed to improve whitebark pine regeneration in the 

June Mountain area (MacKenzie 2014) where suppressed sapling sized trees were released to 

grow, even though they were fairly old.

The forest plan includes a goal to collaboratively develop a regional whitebark pine conservation 

and restoration strategy. This strategy is envisioned as a regional approach to the rangewide 

restoration strategy developed in 2012 (Keane et al. 2012) and would cover whitebark pine across 

its range in California. It would likely identify habitat management objectives or habitat goals and 

tactical practices that could be implemented to conserve whitebark pine. If such habitat 

management objectives or habitat goals were developed, they would be considered in the design 

of projects as appropriate. Any tactical practices could be considered and implemented in future 

projects unless they are inconsistent with an existing standard or guideline, in which case an 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

460

amendment to the forest plan may be considered. This would provide additional assurances that 

whitebark pine are conserved on Inyo National Forest. Although the need to develop a regional 

conservation strategy is currently recognized, there is no specific plan direction in alternative A

and it may be less likely to occur without the added recognition and emphasis in the forest plan.

Therefore, under alternatives B, B-modified, C, and D, greater acreage of wildfire managed to 

meet resource objectives may potentially result in improved resilience and regeneration of 

whitebark pine. This factor is expected to result in a moderate, but site-specific upward trend in 

whitebark pine vigor and reproduction. As a result, these alternatives would have some positive 

short- and long-term effects to whitebark pine habitat extent and condition.

Consequences Specific to Alternative B

Alternative B would allow for vegetation management in whitebark pine stands to improve 

habitat quality and stand structure, providing improved resilience to bark beetles and reducing 

drought susceptibility, especially to mature trees. Compared to alternative C, greater potential for 

mechanical pre-treatment could allow for more acreage to be treated and restored. These areas are 

still relatively limited, but include some whitebark stands in the vicinity of ski areas and other 

nonwilderness, high-elevation sites. As a result, there would be some beneficial effects for habitat 

condition and population trend under this alternative.

The majority of the wilderness areas and remote areas where whitebark pine occurs are in the 

Wildfire Maintenance Zone and the Wildfire Restoration Zone where the desired conditions are to 

manage conditions such that wildland fire predominately has a positive benefit to ecosystems and 

resources. Using the full range of wildfire management strategies and tactics encouraged by the 

desired conditions, it is expected that more wildfires will be managed within these zones to meet 

resource objectives than is currently occurring. The desired conditions support developing 

resource objectives that will identify the risks and benefits to whitebark pine from wildfire which 

will allow more adaptive and responsive wildfire management decisions, including when 

managing wildfires can restore ecological conditions favorable to whitebark pines. As more 

wildfires are managed and more areas have burned, future fires are expected to burn more similar 

to the natural range of variation, with a more varied mix of fire severities more responsive to the 

scattered and more heterogeneous upper elevation forest conditions. This should lessen the risks 

of large high severity wildfires that could affect large areas of whitebark pine to a greater extent 

than would occur under alternative A.

Consequences Specific to Alternative B-modified

Effects to whitebark pine would be very similar to alternatives B. The strategic fire management 

zones where whitebark pine occurs are similar to alternative B but with slightly more areas 

identified as wildfire restoration zone instead of wildfire maintenance zone. This recognizes that 

some wildfires may still burn under conditions that may need suppression actions because they 

would not be able to meet resource objectives or may need additional fuels management or 

strategic fire treatments to reduce the risks of managing wildfires to meet resource benefits. The 

expected result however is that wildfires that burn near areas with whitebark pine would be 

managed similarly to alternative B because fire management decisions would be based upon the 

ability to safely manage naturally ignited wildfires that would burn under conditions similar to 

those expected under the natural range of variation. Since there would be no difference between 

alternatives for the amount of active fuels management within wilderness or remote areas with 

little access, the consequences would be similar to alternative B.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

461

Consequences Specific to Alternative C

Effects to whitebark pine would be very similar to alternatives B. Under alternative C, there may 

be slightly fewer opportunities for whitebark pine restoration using prescribed fire, because 

greater restrictions for mechanical pre-treatment may preclude the introduction of fire that would 

be safe and of low to moderate severity. This would only affect places outside of wilderness 

where mechanical treatment could occur. Under alternative C, hand treatments would be favored 

in lieu of mechanical treatments and may be sufficient to rearrange fuels to reduce the risk of 

damage to mature whitebark pines in some situations, but may be at higher costs of 

implementation limiting the extent of restoration completed with available funding. As a result, 

there could be fewer positive effects for whitebark pine habitat condition and population trend 

compared to alternatives B, B-modified, or D.

Alternative C uses the same wildfire maintenance zone as alternative B-modified where much of 

the whitebark pine occurs. Most of the remaining forest where whitebark pine occurs would be in 

the general wildfire zone where wildfire risk is more variable and there are less clear resource 

objectives. However, the intent of fire management within this zone is similar to alternative Bmodified, to restore fire as an ecosystem function, so opportunities and outcomes for managing 

naturally ignited wildfires in the occupied portions of this zone would likely be similar to 

alternative B-modified.

Consequences Specific to Alternative D

Effects to whitebark pine would be very similar to alternatives B, with greater potential for 

whitebark pine restoration projects that require mechanical pre-treatment than the other 

alternatives. There would be slightly greater opportunity for proactive restoration for whitebark 

pine than the other alternatives, at least in the 14 percent of that ecosystem type that occurs 

outside wilderness.

The strategic wildfire management zones would be the same as alternative B-modified and 

consequences for management wildfire would be similar for the whitebark pine that occur in the 

wildfire maintenance zone. Where the whitebark pine occurs in the wildfire restoration zone 

outside of designated wilderness there may be more opportunity to manage wildfires to meet 

resource objectives to the extent that additional strategic vegetation and fuels treatments occur 

and to the extent that more wildfires are managed over time. This would benefit whitebark pine 

by restoring fire to the landscape which would reduce vegetation density and increase stand 

resilience and also create more suitable seedbeds for natural regeneration.

Consequences to Plant Species of Conservation Concern

Consequences Common to all Alternatives

All alternatives would incorporate at-risk species information from the California Natural 

Diversity Database, the California Department of Fish and Wildlife and the U.S. Fish and 

Wildlife Service.

All alternatives include fuels reduction and vegetation treatments designed to contribute to the 

restoration of a more resilient landscape. The amount of potential treatment, method of treatment, 

and priority locations for treatment, varies by alternative as discussed by alternative below.

Travel management and the authorized motorized route system will be the same under all 

alternatives. If substantial impacts to plant species of conservation concern from use of the 

authorized motorized route system are discovered, they would be addressed through developing 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

462

site specific mitigations and, if needed, through site-specific changes in the authorized motorized 

route system following procedures of the Travel Management Rule.

Utilization of special forest products and personal-use fuelwood would generally remain similar 

to current conditions, with minimal increases expected due to population trends. The impacts to 

plant species of conservation concern are difficult to assess for dispersed personal firewood 

collection by individuals; this is assessed and managed when planning vegetation and fuels 

projects that will create piles or collection sites open to public gathering. The potential impacts to 

plant species of conservation concern would be considered during site-specific planning for those 

projects with mitigations to minimize or avoid impacts incorporated into project design.

There will be no changes to the current direction for mining. The impacts of authorized mining 

activities to plant species of conservation concern would be considered and mitigations required 

as part of decisions to authorize permits for activities and uses.

Consequences from grazing would be similar for all alternatives. All alternatives provide for 

mitigating effects to at risk plants from grazing and no alternative is expected to change the 

amount of permitted livestock use. Similarly, all alternatives include taking an approach to 

controlling invasive species and preventing their introduction. 

Ramshaw Meadows Abronia

There is additional management guidance for Ramshaw Meadows abronia. A conservation 

agreement between the Inyo National Forest and the Sacramento Office of the U.S. Fish and 

Wildlife Service was signed in 2015 for this species (USDA Forest Service and USDI Fish and 

Wildlife Service 2015), and that agreement is currently in place and applies to all alternatives. 

Among the management actions in the agreement designed to protect the species are:

1. protection of the Ramshaw Meadow ecosystem 

2. management of adverse effects of camping and hiker and packstock trampling 

3. management of past and potential future livestock grazing (at the present date, livestock 

grazing is not permitted in the area) 

4. management of conifer encroachment 

5. study of climate change effects

Regular species monitoring is an essential component of the agreement. As a result, all 

alternatives would have positive short- and long-term effects to Ramshaw Meadows abronia 

habitat extent and quality.

Since 1985, species monitoring of Ramshaw Meadows abronia has occurred at least every 3 

years, with total population estimates ranging from about 50,000 to 160,000 (USDA Forest 

Service and USDI Fish and Wildlife Service 2015). Although approximate 10-year cycles in peak 

population numbers are evident during this time period, no significant correlation has been 

detected between population trend and precipitation, or potential threats identified to the species. 

As a result, under all alternatives there is not expected to be a change in population trend.

Consequences to Floristic Geographic Subdivisions

Though none of the alternatives authorize specific actions that may affect individual species, this

analysis includes an integrated look at potential effects to floristic biogeographic subregions and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

463

diversity that might be most affected by the alternatives. In addition, we analyze differences 

between alternatives in their effects to special habitats that host at-risk plants.

Compared to alternative A, alternatives B, B-modified, C, and D increase the pace and scale of 

restoration using fire. This may affect Sierra Nevada montane forests composed of dry mixed 

conifer, Jeffrey pine, red fir, lodgepole pine, and mountain mahogany vegetation types more

strongly than other ecosystems because forests there are more strongly departed from desired 

conditions (table 24 and table 25). These ecosystems occur in the High Sierra Nevada floristic 

biogeographic subregion, and host about 35 percent of at-risk plant species (table 68). Some 

species, like Hulsea brevifolia, have been impacted by altered fire regimes and will benefit from 

restoration treatments using fire. 

Particularly high densities of at-risk plant species occur in the subalpine and alpine zones of the 

High Sierra Nevada and White, Inyo, and Glass Mountains in the Great Basin, as well as

sagebrush, pinyon-juniper ecosystem types and special habitats. Among the threats identified to 

species in these ecosystems is climate change. Alternatives B, B-modified, C, and D include plan 

direction aimed at increasing ecosystem resilience to climate change which will lessen the risks to 

species persistence slightly better than alternative A, which does not include specific direction to 

consider climate change.

Dispersed and developed recreation is expected to increase to some degree under all alternatives 

due to increasing human populations and recreation demand in the future. Some habitats like 

meadows, riparian areas, and rock outcrops are often places where recreation is more frequent or 

intense. Increased recreation activities can have direct negative effects to at-risk plant habitat 

extent or quality, due to trampling or habitat alterations; or can have indirect negative effects 

through the introduction or increases of invasive plants. Because these habitats may host clusters 

of at risk-plants, and because these areas may have especially high concentrations of recreational 

activities, forest plan direction and guidance under alternatives B, B-modified, C, and D, would

provide for the continued persistence of at-risk species that occur there. For example, plan 

direction to mitigate these threats would include avoiding fire management activities in riparian 

conservation areas and meadows except when necessary to protect life and property. This 

includes avoiding activities such as line construction and staging areas and taking extra measures 

to avoid spread of invasive plants. In addition, direction in the plan revision alternatives for 

sustainable recreation recognizes the need for mitigation of some recreational activities where 

they adversely impact and jeopardize the persistence of at-risk species. Plan direction guides 

projects to consider a wide range of management responses to minimize impacts and does not 

solely require avoidance. Under alternative A, similar efforts and consequences described above 

are guided by direction focused on Pacific Southwest Region sensitive species.

Consequences Specific to Alternative A

Under alternative A, the Inyo National Forest would continue to manage a total of 67 Forest 

Service plant sensitive species, some of which have no known occurrence in the plan area. This 

alternative would consider fewer rare plants in the project planning process compared to the 105 

plant species of conservation concern considered by the other alternatives. At the programmatic 

level, species management guides are developed for Forest Service sensitive species with 

recommendations for management and monitoring. In general, avoidance, rather than restoration, 

of Forest Service sensitive species at the project level is emphasized. Alternative A requires 

project level assessment of effects to sensitive species compared to alternatives B, B-modified, C, 

and D that rely more strongly on the achievement of desired conditions at the ecosystem scale and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

464

within special habitats to provide for species persistence, with project-level protections applied 

when necessary.

Since the existing management direction under alternative A would not direct the Inyo to 

adequately manage recreation opportunities and settings, there is more uncertainty in how 

recreation would adaptively manage new and emerging uses. For example, there would be 

uncertainty when and how to respond to changing or emerging unmanaged recreation uses that

have potential ecological effects, since it would likely be addressed through analysis of effects on 

a project-by-project basis.

Alternative A would provide forestwide direction and guidance to address noxious weeds, 

including those that affect at-risk plant species. Forest plan direction requires individual projects 

to have a noxious weed risk assessment and direction to minimize and mitigate the risk of weed 

spread and control new infestations. Treatment efforts for noxious weeds are localized and limited 

by available funding.

Consequences Common to Alternatives B, B-modified, C, and D

A total of 105 plant species of conservation concern were identified in the plan area (table 70) for

alternatives B, B-modified, C, and D. The list of plant species of conservation concern differs 

from the current (alternative A) list of Regional Forester’s plant sensitive species for the Inyo 

National Forest. As previously discussed, the plant species of conservation concern list includes 

46 of the 67 plant sensitive species that are included in alternative A. The 105 plant species of 

conservation concern, known threats to the persistence of each plant species of conservation 

concern, and primary habitat is included in (table 70) and a summary of the number of species 

affected by a known threat is provided in (table 71).

The plan revision alternatives are designed to maintain key ecosystem characteristics and 

ecosystem functions in order to maintain biodiversity of Inyo National Forest, thus providing for 

habitat needs of diverse native animal and plant species. This ecosystem, or course filter, 

approach focuses on managing for conditions consistent with the natural range of variation at the 

landscape scale, with the expectation that the needs and functional capacity of most organisms 

would be fulfilled. Ecosystem direction in combination with at-risk species, or fine filter, 

direction and direction for other resources is designed to promote resilient intact ecosystems, 

balance the needs of at-risk species with other resource uses and ecological processes, and 

mitigate risk to persistence from land management activities and other disturbance, including 

activities that increase spread of invasive species or impacts from management and recreational 

activities. The list of primary ecosystem and at-risk species specific plan components that 

contribute to providing for the habitat needs and protection of plant species of conservation 

concern is displayed in appendix F of volume 2. Plan direction would provide for ecosystems and 

habitat conditions resilient to disturbance (both natural and human caused) and the interrelated 

effects of climate change, and to mitigate site specific effects that might occur during projects or 

forest management activities.

Plan components related to plant species of conservation concern are similar for all the plan 

revision alternatives. For some plan direction, there are slight differences in category of plan 

component between some plan revision alternatives. For example, a guideline for alternatives B, 

C and D has become a standard in alternative B-modified. Differences are described in individual 

alternative sections.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

465

For the plan revision alternatives, forestwide “Terrestrial Ecosystems and Vegetation” plan 

direction is course filter direction that covers all ecosystem types. Direction for all plant species 

includes direction to provide vegetation structure and composition that is resilient to climate 

change and other stressors, including altered fire regimes, drought, and flooding in riparian 

systems; ecosystems retain their essential components, processes and functions; the landscape 

contains a mosaic of vegetation types and structures; fire occurs within an ecologically 

appropriate regime of frequency, extent, and severity, and enhances ecosystem heterogeneity and 

habitat and species diversity; composition, density, structure, and condition of vegetation help 

reduce the threat of undesirable wildfires; and ecological conditions in untrammeled landscapes 

(such as wilderness and recommended wilderness areas) are primarily the result of natural 

ecological processes, which occur with little direct human influence across the larger landscape.

A forestwide desired condition for animal and plant species includes course level direction to

provide sustainable populations of plant and animal species supported by healthy ecosystems, 

ecological processes, and land stewardship activities ecosystems, which would be resilient to 

uncharacteristic fire, climate change, and other stressors. Alternative A has no direction specific 

to climate adaptation or resilience. There is some ecological restoration aimed at reducing forest 

density but it is more limited in intensity and extent.

Desired conditions for ecosystem type-specific plan direction for the plan revision alternatives

would provide for the composition, structure, and function of vegetation that is within the natural 

range of variation for the ecosystem type, and is resilient to fire, drought, insects, pathogens, and 

climate change, and fire frequency is within the natural range of variation for the ecosystem type. 

For many ecosystems, fire is a key ecological process to restore and maintain proper conditions, 

and to increase heterogeneity and understory plant vigor. Other plan direction for some terrestrial 

ecosystem types under the plan revision alternatives would include design measures that benefit 

plant species of conservation concern. For example, restoration projects following large-scale 

changes in structure or species composition (like type conversion to cheatgrass) from wildfires, or 

other disturbances, should consider restoring habitat, including restoring connectivity, and longterm maintenance of regional biodiversity in disturbed and adjacent undisturbed landscapes. In 

addition, there is direction for xeric shrub/blackbrush that projects must include design measures 

to minimize damage to biological soil crusts, with the intent is to maintain areas resistant to 

nonnative plant invasions, and to include islands of untreated vegetation in project design to 

speed native species regeneration. Alternative A would not emphasize forest heterogeneity 

approaches to promote resilience to the same degree as the plan revision alternatives.

Plan direction for the plan revision alternatives would include that riparian conservation areas 

have ecological conditions that support aquatic and riparian-dependent plant and animal species, 

including plant species of conservation concern occurring in riparian systems. Direction would 

also: limit impacts to water quality or habitat for aquatic and riparian-dependent species, 

including from livestock grazing; support stable herbaceous and woody vegetative communities 

that are resilient to drought, climate change, and other stressors; and insure natural hydrologic, 

hydraulic, and geomorphic processes sustain their unique functions and biological diversity. The 

latter is particularly important to the 27 plant species of conservation concern that are affected by 

hydrologic alteration. Alternative A direction and best management practices would reduce the 

impacts of management actions locally but do not by themselves address the biodiversity, 

sustainability, or persistence of aquatic and riparian associates. Plan direction is primarily 

prescriptive and restrictive to limit management activities that would restore forest vegetation and 

improve habitats that support the persistence of all life stages of aquatic or riparian species. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

466

Resilience of riparian composition and structural heterogeneity to climate change and increased 

risk of wildfires would not be improved in alternative A except on the occasional basis. 

There are several plan components for the plan revision alternatives in the “Animal and Plant 

Species” section and other resource areas that would provide direction specific to at-risk species, 

providing fine filter direction that would add additional emphasis to key ecological conditions for 

many at-risk plant species. For example, there is a forestwide terrestrial ecosystem and vegetation 

desired condition reinforcing ecological conditions support the persistence of at-risk species and 

direction in the forestwide components for animal and plant species that ecological conditions 

provide habitat to improve conditions for at-risk species and support self-sustaining populations 

within the inherent capabilities of the plan area. Other at-risk species specific direction includes

ecosystems are resilient to uncharacteristic fire, climate change, and other stressors, and this 

resilience supports the long-term sustainability of plant communities; that land management 

activities are designed to maintain or enhance self-sustaining populations of at-risk species by 

considering the relationship of threats and activities to species survival and reproduction; that the 

structure and function of vegetation, aquatic and riparian systems, and associated microclimate 

and smaller scale elements (carbonate rock outcrops, fens, or pumice flats) exist in adequate 

quantities to provide habitat and refugia for at-risk species; that there would be collaboration with 

other partners to maximize opportunities to improve conditions in the plan area for at-risk 

species; that design features, mitigation, and project timing considerations are incorporated into 

projects that may affect occupied habitat for at-risk species; and that habitat management 

objectives or goals from approved conservation strategies or agreements are incorporated, as 

appropriate, in the design of projects that will occur within at-risk species habitat. Alternative A 

would continue plant sensitive species direction to emphasize the development and 

implementation of a consistent, systematic, biologically sound program for sensitive plant species 

and their habitat so that federal listing does not occur. The plan revision alternatives include this 

as plan guidance in the form of a potential management approach. Plan direction for alternative A 

would also include inventories of project sites, a sensitive plant program management plan for the 

Forest, species management guides, and scientific studies where there are known detrimental 

effects on sensitive species. 

The plan revision alternatives direction would provide for persistence of plant species of 

conservation concern that occur in special habitats and address identified threats to special 

habitats. Examples of special habitats for at-risk plants include alkali flats, pumice flats, calichecovered clay soil mounds, and rock outcrops which may support several at-risk plant species.

Principal habitats, including special habitats, for each at-risk plant species are listed in (table 70).

For alternative A, there is no specific direction for special habitats with limited distribution; plant

sensitive species occurring in these areas would be included in plan direction for developing 

species management guides. 

For the plan revision alternatives, desired conditions for special habitats include maintaining or 

improving the composition, diversity, and structure of these habitats, including where there are 

multiple uses such as recreation and grazing; providing habitat and refugia for species with a 

specific geographic or restricted distribution; and that conditions would remain suitable for longterm sustainability of the suite of native plants adapted to special habitats and their associated 

insect pollinators. These are especially important for species with extremely limited distributions 

like Thelypodium milleflorum and a few other plant species of conservation concern found in 

caliche-covered clay mounds in eastern Mono Basin. This species faces increasing threats from 

invasive species, wild horse browsing, unauthorized off-highway vehicle travel, vegetation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

467

management, and climate change. Other plan direction would include working cooperatively with 

researchers and interested parties to study and monitor, and assist in appropriate restoration 

measures of special habitats; incorporate the location of special habitats in the corporate 

geographic information system; evaluate and incorporate maintenance and enhancement needs for 

special habitats into project design and implementation; and avoid fire management activities in 

special habitats. 

The plan revision alternatives would also include plan components to alleviate or eliminate 

threats to species of conservation concern from activities associated with wildfire management, 

sustainable recreation, designated wilderness, tribal relations and uses, and other land 

management activities. For example, plan direction would reduce the impacts of wildfire on plant 

species of conservation concern through fuel reduction treatments, prescribed fire, and managing 

wildfires that can benefit natural resources while reducing wildfire risk. There is desired 

condition direction that fire occurs as a key ecological process in fire-adapted ecosystems where 

it does not pose an unacceptable risk to life and property, and that fire occurs within an 

ecologically appropriate regime of frequency, extent, and severity, and enhances ecosystem 

heterogeneity, and habitat and species diversity. 

Overall, alternatives B, B-modified, C, and D have greater potential short-term negative effects to 

species of conservation concern compared to alternative A, due to the increased pace and scale of 

restoration, but they also have more potential for long-term positive effects due to restoration of 

resilience to ecosystems. Ecological restoration is expected to be focused in the mixed conifer 

and Jeffrey pine in the High Sierra Nevada region. The potential increased short-term effects are 

primarily related to the increase in mechanical treatments, which could increase soil erosion, soil 

compaction, or trampling of plants. These site-specific negative effects to at-risk plant habitat 

extent and quality would be mitigated through project design features, but mitigations may not 

eliminate effects altogether. Long-term landscape restoration of forested ecosystems, including 

restoring fire regimes within the natural range of variation, would have positive effects to at-risk 

plant habitat and quality, including for short-leaved hulsea (Hulsea brevifolia) and Father 

Crowley’s lupine (Lupinus padre-crowleyi). Since there are some differences between alternatives 

in the amount and methods of achieving restoration, this aspect is further discussed by alternative 

below.

The increased vegetation management activity and increase in the restoration of fire, while 

beneficial overall to improve ecosystem diversity and ecosystem integrity, creates habitat for 

several invasive species, including cheatgrass (Bromus tectorum) and yellow starthistle 

(Centaurea solstitialis). At least 19 plant species of conservation concern are known to be 

threatened or potentially threatened by invasive species. Although the increased vegetation 

management activities would likely result in both short-term and long-term increases in invasive 

plant species, these increases would be offset to some extent by treatment actions proposed under 

each alternative. The plan revision alternatives include similar plan direction compared to 

alternative A, to guide projects to minimize the risk of invasive species spread associated with 

project activities and to monitor and treat infestations when they occur. The plan revision 

alternatives include desired conditions limiting invasive plant invasion and spread, and 

management approaches, standards, and guidelines to reduce invasion and spread during 

management activities using an early detection and rapid response strategy. The amount of 

invasive species treatment and eradication could be increased by the emphasis on more 

cooperation and collaboration with other agencies and partners, and emphasis to coordinate with 

research to evaluate the potential effects of climate change on the spread of invasive and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

468

nonnative species. Invasive plant species compete with native plant species, and can change the 

fire regime in an area, leading to negative effects to some species of conservation concern. 

Direction includes an objective to take action to eradicate at least three species of high priority 

nonnative invasive plants from the Inyo National Forest within 10 years of plan approval.

Although restoring the fire regime to the natural range of variation is generally beneficial to 

species of conservation concern, there is no historic proxy for a fire regime under the current 

condition of nonnative invasive plant species infestation. Thus, it is unknown if restoring the fire 

regime would result in less impact to native species from invasive species. Adaptive management 

would be essential to ensure that the increased use of fire does not result in negative effects to 

species of conservation concern from the indirect effects of invasive plant species introduction 

and spread.

Eighteen plant species of conservation concern occur in meadows and the plan revision 

alternatives would increase the amount of meadow restoration compared to alternative A. 

Restoration efforts in meadows and other herb-dominated communities and riparian areas, would 

likely have positive, long-term effects for the many at-risk plant species dependent upon these 

systems. This would provide benefit to species dependent upon those habitats, especially those 

that have been negatively affected by hydrologic changes like Lemmon's milk-vetch (Astragalus 

lemmonii), which occupies moist alkaline meadows in the Long Valley area. 

Climate change is a major threat of many high elevation at-risk species (45 species) that have 

extremely low occurrences, and climate change and the potential related drought effects will 

likely continue to exert pressure on the key ecological conditions that these species depend. The 

Inyo National Forest cannot directly control climate change, but ecosystem plan components in 

the plan revision alternatives would provide conditions resilient to ecosystem stressors and the 

interrelated effects of climate change and support the long-term sustainability of at-risk plant 

communities. Direction includes that fire management and reforestation is responsive and 

adaptable to rapidly changing conditions. And reforestation treatments are emphasized in riparian 

areas that face the most risk from large-scale events associated with climate change. There is also 

an emphasis interpretation and conservation education to convey up-to-date and clear messages 

about natural resources and climate change, and could include information on impacts to plant 

species of conservation concern. Alternative A would include direction that will somewhat reduce 

the impacts of climate change on plant species of conservation concern, but the rates are 

relatively low to moderate rates of restoration treatment compared to the plan revision 

alternatives.

Forestwide direction under the plan revision alternatives for sustainable recreation and wilderness 

include support for at-risk species. For example, forestwide direction for sustainable recreation 

would include desired conditions to provide a variety of recreation activities with minimal impact 

on sensitive environments and resources; dispersed recreation does not adversely impact natural 

resources; permitted recreation special events protect natural resources, and trails are compatible 

with other resources, like plant species of conservation concern. Other direction would include 

managing dispersed recreation activities when evidence of impacts to natural resources emerge; 

not locating new recreation facilities within at-risk plant species habitat; and to address impacts to 

at-risk species habitat and changing conditions in recreation settings during project design.

Desired conditions and guidelines for wilderness mitigate threats from recreation, fire and 

livestock and ensure watersheds are functioning properly and that impacts to at-risk species are 

minimized. Management direction under alternative A would not include managing recreation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

469

activities with minimal adverse impacts to sensitive environments and natural resources, 

including at-risk plant species.

The plan revision alternatives’ direction related to at-risk plants and Tribes would include that 

Native Americans have access to traditional and cultural practices for plant gathering and that 

their traditional ecological knowledge is valued in the process of developing and implementing 

restoration projects.

Consequences Specific to Alternative B

In addition to the short- and long-term consequences for plant species of conservation concern 

habitat extent and condition as described in the “Common to Alternatives B, B-modified, C, and 

D” section, there are some additional consequences to alternative B. The moderate restoration 

treatment rates of alternative B would reduce the combined impacts of climate change, fire, 

insects, and pathogens in more areas than in Alternative A. Treatments in sagebrush and pinyon 

juniper ecosystems will have enhanced capacity to resist the interactive effects of multiple 

stressors. Alternatives B incorporates four strategic fire management zones to better align 

expectations of where fire suppression may be more favored, like areas with highly valued 

resources and assets, or areas where fire risks are lower and there is greater potential to restore 

fire as an ecosystem function. Alternatives B would prioritize fuel reduction and restoration 

treatment in the two protection zones and on strategic ridges and along key roads; this can 

facilitate larger landscape prescribed burns or increase opportunities to manage wildfires when it 

is determined they have the potential to meet resource objectives. At least 20 percent of the 

landscape is anticipated to be restored through various management activities, including 

vegetation management, fuels reduction, and timber harvest. Alternative B would have a larger

area potentially treated to reduce fire risks and restore ecosystem conditions compared to 

alternatives A, and alternative B encourages designing larger, landscape-scale ecological 

restoration projects in order to better restore ecosystem functions such as fire regimes and 

improving watershed conditions. There is more potential for mechanical treatments to be used for 

alternative B than for alternative A, which could result in more potential for the spread of 

invasive species. However, additional plan direction increases emphasis on mitigating and 

controlling invasive species when planning ground disturbing projects which may slow the spread 

of invasive species. Vegetation treatment rates in riparian ecosystems and meadows would also 

likely be higher in alternative B, resulting in potential short-term impacts from treatment and 

potential long-term benefits like resilience to climate change and other threats compared to 

alternative A. Although alternative B would map portions of the sagebrush habitats as Wildfire 

Restoration Zone, due to known sensitivity of sagebrush habitats to fire and invasive species 

following fire, most wildfires would continue to be suppressed.

Recommended wilderness areas under alternative B could serve to benefit plant species of 

conservation concern by precluding management activities, like mechanical treatments that might 

allow increases in invasive species, and by limiting mechanized and motorized activities such as 

mountain biking and unauthorized off-highway vehicle travel that could cause soil disturbance. 

The recommended wilderness in alternatives B would provide benefit to some plant species of 

conservation concern that occupy these areas, such as species that occupy xeric shrub and 

blackbrush habitats (like Charlotte’s phacelia), or the special carbonate habitat type (such as 

Nevada ninebark).

Consequences Specific to Alternative B-modified

Alternative B-modified would strengthen some plan direction for plant species of conservation 

concern, for example, by elevating an “Animal and Plant Species” guideline to a standard, so that 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

470

design features, mitigation, and project timing considerations are incorporated into projects that 

may affect occupied habitat for at-risk species. 

Alternative B-modified makes some procedural changes to the plan direction regarding 

production livestock grazing in alternative B without making substantive changes in the range 

program overall from the current condition. This is not expected to directly result in any changes 

to the current livestock grazing program in and of itself and would not cause any immediate 

change in range management. Permitted livestock grazing would continue as determined by sitespecific allotment management plan decisions and in accordance with annual operating 

instructions. Forestwide direction for at-risk species would ensure that the ecological conditions 

needed for at-risk species is considered when livestock grazing permits are issued.

Alternative B-modified is the only alternative that would provide direction to manage recreation 

settings through a zoned approach, including the use of direct management techniques in the 

general recreation area zone to respond when necessary to protect resources like habitat for plant 

species of conservation. For example, Astragalus subvestitus is a species that occurs in the 

general recreation area, and trampling by unauthorized off-highway vehicle travel has been 

observed as a threat to this species in the Monache Meadows area. Destination recreation areas 

have concentrated recreation use, and alternative B-modified includes guidance that 

infrastructure, maintenance, or more controls such as setting capacity limits may be needed to 

protect resources. 

Alternative B-modified replaces many smaller critical aquatic refuges with a few larger 

conservation watersheds. Critical aquatic refuges in the other alternatives are largely delineated 

around aquatic wildlife species and it is largely unknown to what extent they also provide habitat 

for plant species of conservation concern. However, conservation watersheds, because of the 

large subwatershed scales, did consider the location of plant species of conservation concern in 

identifying which watersheds should be selected. Because most conservation watersheds are large 

and are focused on high elevation headwaters watersheds, they include many locations of species 

associated with alpine, subalpine, and meadow ecosystem types. However, since many of these 

same occurrences are in designated wilderness areas, there is little additional species specific 

benefit from being in conservation watersheds. Some of the species in the lower elevation 

portions of the Mono Lake Headwaters and Cottonwood-Crooked Creek Headwaters 

conservation watersheds may include species using other ecosystem types. In all cases, the 

forestwide direction for at-risk species provides the primary project level guidance that would 

ensure that projects are designed to provide for the persistence of plant species of conservation 

concern. Therefore, while it is known that several plant species of conservation concern occur in 

the conservation watersheds and several could also occur in some of the critical aquatic refuges of 

the other alternatives, it is not likely there is a substantial difference in risk or benefit to these

species between alternatives because of this forestwide direction for at-risk species in alternatives 

B, B-modified, C, and D, and the direction to evaluate project level effects to sensitive species in 

alternative A.

Alternative B-modified makes some changes in the locations of the alternative B strategic fire 

management zones, primarily to adjust areas dominated by the sagebrush vegetation types to be 

reclassified from wildfire restoration zone or wildfire maintenance zone to the general wildfire 

protection zone. This recognizes that sagebrush ecosystem are sensitive to fire with invasive 

species such as cheatgrass often significantly type converting and degrading burned areas. The 

classification of general wildfire protection zone indicates that most wildfires will likely have 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

471

some fire suppression actions taken. While there could be some additional ground disturbance 

from fire suppression actions, much as currently occurs, extra efforts are taken during fire 

incident management and in post-fire restoration to reduce the risk of invasive species spread. 

Since the sensitivity of sagebrush ecosystems to wildfire is known, it is likely that would be little 

functional difference between the plan revision alternatives in terms of where and when wildfires 

would have suppression actions taken since in all alternatives fire management decisions consider 

factors such as safety, impacts to resources and assets, and overall manageability of the fire. 

However, the overall intent to manage sagebrush ecosystems through restoration actions other 

than increasing the amount of fire restored to the landscape is clearer in alternative B-modified

than the other alternatives. This would potentially benefit the 44 plant species of conservation 

concern associated with the sagebrush ecosystem.

Effects to plant species of conservation concern for recommended wilderness areas under 

alternative B-modified are the same as alternative B.

Consequences Specific to Alternative C

Due to less intensive vegetation management favoring prescribed burning and minimizing 

mechanical treatments, alternative C would likely have the fewest short-term negative effects to 

plant species of conservation concern, particularly those dependent on mixed conifer and Jeffrey 

pine ecosystems. Acres with mechanical treatment under alternative C would be one-quarter of 

the current plan; this is the fewest acres of mechanical treatment of all alternatives. To the extent 

that mechanical ground disturbance increases the risk of invasive species spread, risk of new 

invasive plant species infestations and spread and negative effects on plant species of 

conservation habitat would likely be less than other alternatives. However, alternative C would 

have a larger focus on restoration of sagebrush and pinyon-juniper ecosystems, with much of the 

work completed with mechanical or hand work to remove conifers. So there is a risk of increased 

spread in these areas. It would still be likely that alternative C results in the fewest negative 

effects to plant species of conservation concern habitat quality of all alternatives. Recreation site 

improvements are likely to be less under this alternative compared to alternatives B, B-modified,

and D, resulting in few impacts to habitat; however, a continuation of existing recreation impacts 

would likely continue under C.

The greater area of recommended wilderness under alternative C may provide benefit to some 

plant species of conservation concern that occupy these areas, such as species that occupy xeric 

shrub and blackbrush habitats or the special carbonate habitat type, or populations of Raven’s 

milk-vetch in the Glass Mountains, which have been impacted by unauthorized off-highway 

vehicle travel (assuming enforcement and signage aimed at preventing unauthorized motorized 

vehicle travel would be increased because of the recommended wilderness status). However, the 

recommended wilderness status would allow some non-conforming activities including

mechanized restoration of the sagebrush in the Glass Mountains, although it might be more 

limited than in the other alternatives. 

Consequences Specific to Alternative D

Alternative D proposes more intensive vegetation management, especially within the mixed 

conifer and Jeffrey pine ecosystems. The potential timber harvest activity for alternative D is 

estimated to be the greatest of all alternatives due to greater flexibility in achieving desired 

conditions and encouragement of larger, landscape-level projects. Although these activities result 

in a higher risk for new invasive plant species infestations, through the disturbance of soils and 

removal of vegetation cover, the absolute level of harvest activities is still low, significantly less 

than historic levels, and methods and equipment used have less ground-disturbing impact. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

472

Restoration activities would strive to maintain native species composition and by inference, 

exclude or control nonnative species. 

Project design features would minimize invasive plant species introduction and spread, but the 

risk of invasions as the result of soil disturbance and loss of vegetation cover would be greater 

than under the other alternatives because the risk of introductions cannot be eliminated altogether. 

The section above on “Consequences Common to Alternatives B, B-modified, C, and D” provides 

an overview of potential negative and positive effects of both vegetation management to species 

of conservation concern. The 11 species identified in table 70 as potentially threatened by fuels 

treatment and the 51 species potentially affected by recreational activities, may have greater 

short-term negative effects to habitat extent and condition under this alternative.

However, the greater acreage of restoration proposed under this alternative would benefit some 

species, especially those that are threatened by altered fire regimes, such as short-leaved hulsea, 

Father Crowley's lupine, and narrow-leaved cottonwood.

Cumulative Effects

At-risk plant species are affected by management activities that occur both within the plan area and

on adjacent land under Federal, State, local agency, or private management. The consequences of 

these actions are cumulative across boundaries. These cumulative actions could produce positive 

results, such as increased at-risk plant habitat extent or improved condition as restoration 

measures are taken, particularly those that reduce the risk or extent of invasive species. Similarly, 

there may be negative impacts, such as habitat loss, or degradation, primarily by the introduction 

or spread of invasive plant species.

Many restoration activities and project design features aimed at protecting at-risk species are 

shared by adjacent public land agencies, in particular the National Park Service and Bureau of 

Land Management. For example, efforts to use weed free and weed seed-free plant material for 

animal feed or bedding, soil stabilization and land rehabilitation complements similar efforts in 

the adjacent Yosemite and Sequoia and Kings Canyon National Parks. Combined and coordinated

efforts in these areas would improve ecological conditions that provide for the persistence of atrisk species. Similarly, fire management strategies and approaches are similar across the federal 

land management agencies and interagency coordination occurs with federal, state, and local 

agencies and Tribes when wildfires cross or threaten adjacent lands. Similar approaches to restore 

fire to wilderness areas and remote areas are likely to result in more acres where wildfires are 

managed to meet resource objectives in the future on federal lands which would benefit species in 

the long run by restoring fire regimes similar to the natural range of variation.

Other reasonably foreseeable vegetation management activities that may occur on private, State, 

or other Federal land would be similar in effects to those performed on the national forest—

prescribed burning to restore fire disturbance regimes or the thinning or removal trees to reduce 

the risk of high-severity wildfire. These activities would be expected to have similar short-term

impacts and long-term benefits similar to those described above, although activities on private 

lands would have less emphasis or protection for species that do not have state or federal 

designations such as state or federal endangered species status or state species of concern status.

Road management will continue to occur on state and county roads and roads will remain as 

potential sources of invasive plants. Vehicles traveling on roads with invasive species or that have 

been used off-road on other lands with invasive species could spread those invasive species onto 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

473

the national forest. The plan revision alternatives include direction described above to work with 

other partners such as the counties to address invasive species which could reduce the extent and 

risk of invasive species spread or coordinated treatment that is more effective and efficient. This 

would benefit at-risk plant species overall.

Analytical Conclusions

Candidate Plant Species Determination

Key conclusions:

• The forest plan provides a programmatic framework for future site-specific projects and 

actions but does not prescribe specific projects or assign project locations. Plan components 

exist to ensure proposed actions avoid, mitigate or minimize impacts to candidate species. 

All future project level activities that may affect this species will require project-specific 

assessments to evaluate the extent that projects may accelerate the trend toward federal 

listing and projects may seek technical assistance from the U.S. Fish and Wildlife Service

on additional conservation recommendations to consider or incorporate to avoid, minimize, 

or mitigate potential effects.

• All alternatives recognize the need to develop a regional whitebark pine conservation and 

restoration strategy relevant to whitebark pine in California national forests which could 

identify additional actions to better conserve the species on the Inyo National Forest.

For whitebark pine, we determined that despite plan components and plan content that would 

serve to avoid, mitigate, or minimize effects, some actions and activities may disturb or remove

individuals and whitebark pine stands or habitat could be affected by restoration activities and 

management actions along roads and near facilities. Since the forest plan is at a programmatic 

level, it cannot ensure that projects developed under it would have no effect or that all actions 

would be discountable, insignificant or beneficial. Therefore, we determined that adoption of the 

revised forest plan under all alternatives may affect individuals, but is not likely to jeopardize the 

continued existence of the whitebark pine on the Inyo National Forest.

For the purpose of revising the forest plan, we determined that all plan revision alternatives have 

developed adequate plan components (ecosystem and species-specific) to provide for ecological 

conditions that contribute to the conservation of whitebark pine within the plan area.

Plant Species of Conservation Concern Determinations and Plan Evaluation Outcomes

In general, alternative A would provide the necessary ecological conditions to maintain viable 

populations of at-risk plant species by relying primarily on project-level surveys and mitigations 

of adverse effects for Regional Forester sensitive species. Although there are 59 plant species of 

conservation concern that are not Regional Forester’s sensitive species, in general they occur in 

similar habitats and ecological conditions are expected to be provided. However, since alternative 

A would likely result in lower restoration treatment rates than other alternatives, vegetation would 

likely remain dissimilar to the desired condition in structure, composition and resilience across 

many arid landscapes. 

The Inyo National Forest has 105 botanical species of conservation concern. Many of these 

species have very low number of occurrences and/or very limited distribution, however, the 

relative rarity of a species alone does not constitute vulnerability. In analyzing persistence of 

plant species of conservation concern, rarity is a factor that is included along with ecological 

conditions of habitat and the identified threats in the plan area. Because botanical species are non-
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

474

mobile, identified threats to species with very low numbers of occurrences and/or very limited 

distribution need to be managed at sites where they exist in order to improve resilience to 

stochastic events (such as wildfire, flooding, and climate change) and provide for persistence over 

the long term. 

During the persistence analysis of plant species of conservation concern for the plan revision 

alternatives, each species was evaluated individually (see appendix F in volume 2) and grouped 

into one of these three determinations:

• For species having one or two occurrences in the plan area, with identified threats to 

persistence, and the species also occurs elsewhere: It is beyond the authority of the Forest 

Service or not within the inherent capability of the plan area to maintain or restore the 

ecological conditions to maintain a viable population of these botanical species in the plan 

area. Nonetheless, the plan components should maintain or restore ecological conditions 

within the plan area to contribute to maintaining a viable population of the species within 

its range. There are twenty-two plant species of conservation concern in this group. 

• For species that have low to very low numbers of occurrences, limited distribution, and 

identified threats to persistence in the plan area (although some species are endemic to the 

plan area, many occur elsewhere but have more than two occurrences in the plan area): The 

ecosystem plan components may not provide the ecological conditions necessary to 

maintain a viable population of these botanical species of conservation concern in the plan 

area. Therefore, additional species-specific plan components have been provided. The 

combination of ecosystem and species-specific plan components should provide the 

ecological conditions necessary to maintain a viable population of these botanical species 

in the plan area. There are seventy-three plant species of conservation concern in this 

group.

• For species that have sufficient numbers and distribution of occurrences, and individuals 

within occurrences, such that inadvertent loss of individuals or occurrences will not 

threaten population persistence and viability: The ecosystem plan components should 

provide the ecological conditions necessary to maintain a viable population of these 

species of conservation concern in the plan area. Nonetheless, additional species-specific 

plan components have been provided for added clarity and/or measures of protection.

There are 10 plant species of conservation concern in this group.

All three determinations provide both ecosystem and at-risk species-specific forest plan direction

for persistence. The outcome for each plant species of conservation concern is displayed in 

appendix F. The emerging plan components under alternatives B, B-modified, C, and D when 

carried out, would provide the necessary ecological conditions to maintain viable populations of 

plant species of conservation concern. These alternatives include ecosystem coarse filter plan 

components aimed at protecting the broad habitats upon which these species depend and at-risk 

species-specific and ecosystem type-specific plan components, especially those for special 

habitats, to ensure species persistence. 

To the extent possible, the broad ecosystem desired conditions provide for the broad ecosystem 

fabric that supports sufficient distribution of a minimum number of reproductive individuals of 

species of conservation concern and their habitat so that species would remain viable. Species 

distribution is partially provided for by plan components that aim to maintain or restore the 

diversity and connectivity of ecosystems and habitat types throughout the plan area (FSH 

1909.12.20.13). Forest-wide ecosystem plan components support natural ecological processes, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

475

functions, and biodiversity, and promote ecological conditions that are resilient to climate change 

and other stressors. Additional ecosystem plan components provide area-specific desired 

conditions and management direction, and are tailored to specific ecosystem types or 

management areas, including providing ecological conditions that support persistence of species 

of conservation concern in riparian conservation areas; habitat types that host many botanical 

species of conservation concern. Forestwide plan direction includes the intent to protect habitats 

as the ecological fabric to maintain persistence of a large group of at-risk plant species, and it is 

expected that alternatives B, B-modified, C, and D would have minimal short-term negative 

effects to habitat extent and quality for those at-risk species that depend on them. Disturbance 

processes (such as fire) and management activities (such as grazing and recreation) are addressed 

by ecosystem and other plan components that consider effects to plant communities and/or 

species diversity.

At-risk species-specific plan components provide additional forest-wide guidance for at-risk 

species: to promote healthy, resilient ecosystems that support functional plant and animal 

communities and self-sustaining populations of at-risk species. These plan components are 

particularly important to botanical species of conservation concern because they address sitespecific threats in occupied habitat. Species-specific plan components, including for special 

habitats, mitigate risk to persistence from land management activities, and provide guidance for 

addressing existing site-specific threats not related to project activities, while balancing the needs 

of at-risk species with other resource uses and ecological processes. In addition, at-risk speciesspecific potential management approaches suggest development of systematic and programmatic 

approaches to achieve conservation of these botanical species.

When necessary, project-level protections are an option. As a result, each threat in each 

ecosystem for each species of conservation concern identified has been addressed or mitigated in 

at least one plan component in the forest plan, to provide for the persistence of each species.

For the purpose of revising the forest plan, we determined that all plan revision alternatives have 

developed adequate plan components (ecosystem and at-risk species-specific) to provide for 

ecological conditions that contribute to the persistence of plant species of conservation concern in 

the plan area, or, for those species described above and in appendix F, contribute to maintaining a 

viable population of the species within its range.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

476

Revision Topic 3:

Sustainable Recreation and Designated Areas

The following section provides the analysis for recreation and scenery, heritage, wilderness, wild 

and scenic rivers, and the Pacific Crest National Scenic Trail. Wilderness and the Pacific Crest 

National Scenic Trail are discussed with the recreation and scenery resource because of their key 

roles within the larger context of sustainable recreation. Maps showing the recreation opportunity 

spectrum, recreation places and scenic integrity objectives are located in appendix A of the draft 

forest plans.

Sustainable Recreation and Scenery

Sustainable Recreation

The need to provide sustainable recreation was a key topic of interest at public meetings and 

during public engagement. Sustainable recreation is the recreation settings and opportunities on 

National Forest System lands that are ecologically, economically, and socially sustainable for 

present and future generations.

Analysis and Methods

Indicators and Measures

• Percentage of recreation opportunity spectrum class by alternative

• Change in miles of system trails that allow mechanized transport within areas 

recommended as wilderness

• Change in miles of motorized routes within areas recommended as wilderness or Eligible 

Wild and Scenic Rivers

• Effectively manages recreation development to respond to recreation demand and uses

Methods

The recreational opportunity spectrum is the Forest Service’s method of defining recreation 

settings. These settings are categorized into six classes: primitive, semi-primitive nonmotorized, 

semi primitive motorized, roaded natural, rural and urban. The level of development in roads and 

facilities is directly tied to these settings. The amount of land in each of the classes indicates the 

expected level of development, type of settings, and access that can be expected. Providing a 

range of settings that vary in level of development, access insures recreation al experiences for a 

wide range of activities. 

The Inyo niche is an important aspect in characterizing the existing condition and assessing the 

approaches to recreation management in the alternatives. The Inyo’s niche statement developed 

during the 2007 recreational facilities analysis process describes a forest that attracts visitors from 

all parts of the state, country and world to enjoy and experience the stunning scenery and high 

quality diversity of recreation. Iconic destinations such as Mt. Whitney, Mono Lake and the 

Ancient Bristle cone Pine forest, as well as outstanding designated wilderness characterize this 

forest. 

Types of recreation activities visitors participate in are measured through the National Visitor Use 

Monitoring program in the Forest Service which provides a consistent national approach to data 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

477

collection. Under the National Visitor Use Monitoring program, national forests conduct studies 

every 5 years, and each national forest monitors visitor use through exit surveys. The program 

provides science-based estimates of the volume and characteristics of recreation visitation to 

national forests. The Inyo National Forest last collected data in 2016; however the most recent 

years for which study results are available are 2006 and 2011. Results from those recent surveys 

are discussed in more detail in the “Visitor Use” section.

Assumptions

In the analysis for this resource, we made the following assumptions:

• Partnerships and volunteer opportunities are viable options to maintain and possibly

increase forest capacity. However, attempts to increase partnerships beyond certain levels 

may be constrained by agency capacity.

• Conservation education and interpretative services can play a key role in fostering a greater 

connection between people and nature and helping to create an understanding of sense of 

place.

• Recreation demand is increasing across Inyo National Forest.

• Deferred maintenance on developed recreation sites and infrastructure is continuing to 

outpace budgets.

• Funding and agency recreation staffing are anticipated to decline throughout the planning 

cycle.

• Effective interpretive techniques and public information services can help to inform and 

motivate the public into becoming stewards of the national forest (California Outdoor 

Recreation Planning Program 2002, National Association of Recreation Resource Planners 

2009).

• Climate change is predicted to produce warmer temperatures and drier conditions 

influencing snowpack, drought, and hydrologic flow. Activities dependent on snow and 

snow melt would be affected. Warmer temperatures could cause recreationists to shift their 

activities to higher elevations during the summer months (Morris and Walls 2009).

Affected Environment

Background

Outdoor recreation contributes to human health and well-being by offering a variety of physical 

and mental health benefits. Eighty-four percent of the Californians polled in the most recent 

Comprehensive Outdoor Recreation Plan statewide survey said outdoor recreation was an 

“important” or “very important” contributor to their quality of life (Roberts et al. 2009).

Areas adjacent and within the national forest boundaries are projected to continue to increase in 

population. This growth is expected to increase recreation demand in these national forests, and 

increase the numbers of visitors in the future (English, Froemke, and Hawkos 2014). With 

projected growth, increase in use levels can potentially increase conflicts, such as crowding, 

which can lead to unmet visitor expectations for recreation experiences and can influence public 

satisfaction at recreation sites.

In addition to growth, increases in culturally diverse populations will likely be reflected in 

outdoor recreation (Winter et al. 2014). Two groups whose growth is expected to have the most 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

478

influence on outdoor recreational styles and participation patterns in the future are Latinos and 

Asian Americans (Roberts et al. 2009). Current recreation infrastructure may not meet the needs 

of these two groups which include larger developed group sites with picnic tables, grills, trash 

cans and flush toilets picnicking that support day-long activities, hiking and walking, and 

opportunity to be with family (Roberts et al. 2009).

Increase in recreational use, particularly unmanaged recreation, impacts ecosystems by causing 

changes in habitat through vegetation trampling as well as the spread of noxious or invasive plant 

species to new locations. Unmanaged recreation can include areas that are difficult to manage, 

areas where inappropriate dispersed recreation is occurring or areas that have unmonitored 

nontraditional recreation activities (Pond 2007). Impacts from unmanaged recreation are often 

found in riparian areas, areas adjacent to the urban interface, areas of intense recreation use, and 

areas just outside of developed recreation sites. Examples of unmanaged recreation include usercreated trails to access rock climbing routes at newly discovered climbing areas, user-created 

mountain bike trails, dispersed camping in sensitive ecosystems such as riparian areas, and 

motorized vehicle use outside of designated travel routes. Unmanaged recreation can also 

adversely affect visitor experiences as a result of conflicting or competing uses and 

overcrowding. Ecosystem impacts may ultimately have a negative effect on recreation if the

impacts create conditions where recreation use can no longer be supported.

To ensure sustainable recreation on the Inyo National Forest, adaptive management will be 

necessary. This is particularly true for unmanaged recreation, where timely response to new uses 

that have potential ecological effects will be necessary. Given the expected increase in population 

and recreation demand, tradeoffs will need to be made to ensure that resources are managed 

sustainably.

People choose a specific setting for recreation activities to achieve a desired set of experiences. 

For example, camping in a large undeveloped area with few facilities offers a sense of solitude, 

challenge, and self-reliance. In contrast, camping in a setting having easy access and developed 

facilities such as restrooms and tables offers more comfort, convenience, security, and 

opportunities for social interaction. The Inyo National Forest provides opportunities for 

recreationists to obtain satisfying recreation experiences through choices in both the types of 

settings and use (levels and types of use), and conditions provided by management 

(developments, roads, regulations).

Recreation Settings and Opportunities 

Recreation opportunities are the opportunities to participate in a specific activity in a particular 

recreation setting to enjoy a desired recreation experience. Recreation settings allow a range of 

experiences to be achieved, from remote and challenging to easily navigated and supported by 

tourism services in surrounding communities. The “recreation opportunity spectrum” offers a 

framework for understanding these settings and experiences. It is aligned with scenic character 

and scenery settings that support the value of recreation opportunities and the ability to connect 

people with nature. 

The recreation opportunity spectrum has six distinct classes in a continuum to describe settings 

that range from highly modified and developed to primitive and undeveloped (Clark and Stankey 

1979). The six classes are described below.

• Primitive (P) – An unmodified natural environment with very high probability of 

experiencing solitude. Motorized use within the area is generally not permitted.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

479

• Semi-primitive nonmotorized (SPNM) – A predominantly natural or natural-appearing 

environment with high probability of experiencing solitude. Motorized use is generally not 

permitted.

• Semi-primitive motorized (SPM) – A predominantly natural or natural-appearing 

environment with moderate probability of experiencing solitude. Motorized use is generally 

permitted.

• Roaded natural (RN) – A predominantly natural-appearing environment with moderate 

evidence of the sights and sounds of other humans. Motorized use is provided for in 

construction standards and design of facilities.

♦ Roaded modified (subclass of roaded natural) – A substantially modified natural 

environment except for campsites. Motorized use is provided for in construction 

standards and design of facilities.

• Rural (R) – A substantially modified natural environment. Sights and sounds of people are 

readily evident, and the interaction between users is often moderate to high.

• Urban (U) – A substantially urbanized environment, although the background may have 

natural-appearing elements. Sights and sounds of people onsite are predominant. Large 

numbers of users can be expected, both onsite and in nearby areas.

The existing recreation opportunity spectrum map (volume 3) was updated to correct for 

unintended data errors from data migration and technology improvements over time, and to 

reflect changes adopted by forest plan amendments that had not yet been updated in the recreation 

opportunity spectrum data system.

Table 72 shows the allocation of the existing recreation opportunity spectrum classes on the Inyo 

National Forest. The largest four recreation opportunity spectrum classes are primitive (53

percent), roaded natural (15 percent), semi-primitive motorized (14 percent), and semi-primitive 

nonmotorized (12 percent). The nonmotorized setting accounts for 65 percent of the national 

forest; this is primarily due to designated wilderness areas (46 percent of the national forest) and 

large amounts of inventoried roadless areas (836,583 acres). The motorized setting occurs on 31 

percent of the national forest.

Table 72. Existing recreation opportunity spectrum classes

Recreation Opportunity 

Spectrum Class Acres Percent Total Acres

Primitive 1,061,318 53

Semi-primitive 

nonmotorized 241,504 12

Semi-primitive motorized 286,784 14

Roaded natural 291,980 15

Roaded modified 49,011 2

Rural 13,853 1

Urban 0 0

No assigned class 41,342 2

Some lands were transferred to the Inyo National Forest after the release of the forest plan in 

1988 as a result of the National Forest and Public Lands of Nevada Enhancement Act, and a 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

480

decision was made to wait until the next round of planning to do recreation opportunity spectrum 

mapping. Those areas are shown as “not assigned.”

The primitive recreation opportunity spectrum setting on the Inyo National Forest provides large, 

remote, and predominately unmodified landscapes where there is no motorized activity while 

providing for solitude with few facilities or developments. Most of these primitive settings are in 

wilderness areas. Semi-primitive nonmotorized recreation opportunity spectrum settings include 

areas of the Inyo managed for nonmotorized use although mountain bikes and other mechanized 

equipment can be present. Rustic facilities (like wooden bridges over wet areas) are present for 

the primary purpose of protecting the natural resources of the area. Semi-primitive nonmotorized

settings offer opportunities for exploration, challenge, and self-reliance.

Sixteen percent of the Inyo National Forest consists of semi-primitive motorized recreation 

opportunity spectrum settings, which are managed for backcountry motorized use on designated 

routes. Routes are designed for off-highway vehicles and other high-clearance vehicles. This 

setting offers visitors motorized opportunities for exploration, challenge, and self-reliance. 

Mountain bikes and other mechanized equipment are also sometimes present. Rustic facilities are 

present for the primary purpose of protecting the natural resources of the area or providing portals 

to adjacent areas of primitive, or semi-primitive, nonmotorized areas.

The roaded natural setting, on 16 percent of the Inyo National Forest, is managed as natural 

appearing with corridors and destinations that support developments and concentrated use, user 

comfort, and social interaction. Corridors include roads such as the Ancient Bristlecone Scenic 

Byway, Horseshoe Meadow road, and Eureka Valley road. Destinations can include trailheads 

such as Bloody Canyon, Pine Creek, or Baxter Pass or campgrounds such as Hartley Springs or 

Inyo Craters. The road system is generally well defined in this setting and can typically 

accommodate sedan travel. National Forest System roads also provide access to other recreation 

opportunity spectrum settings of semi-primitive motorized, semi-primitive nonmotorized and 

primitive areas.

The smallest recreation opportunity spectrum setting on the Inyo is rural (1 percent). The rural 

setting represents the most developed recreation sites and modified natural settings. Facilities like 

picnic areas and campgrounds are designed primarily for user comfort and convenience. The rural 

setting is characterized by a substantially developed environment although the background may 

have natural appealing elements. There is no urban recreation opportunity setting on the Inyo 

National Forest.

Access

Recreation access consists of trails, roads, and other transportation that connect people to 

recreation settings and opportunities. Recreation access to and within the Inyo National Forest is 

provided by state highways, county roads, and a designated system of National Forest System 

roads and trails. Roads and trails not only provide access to recreation opportunities, but are 

themselves a recreation experience as driving for pleasure increases in popularity. Access to the 

Inyo National Forest is also provided by partners, agencies that manage adjoining public lands, 

and private land owners.

The transportation system on the Inyo National Forest has evolved over time, with many roads 

and motorized trails beginning as user-created wagon roads from the California gold rush period 

of the mid-to-late 1800s. As the use of roads expanded and modes of transportation changed, 

many of the user-created roads were reconstructed to higher standards. Routes which were 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

481

created for the sole purpose of permitted resource extraction, such as mining or timber roads, 

were considered “temporary” roads, which would be unneeded after the permitted use ceased. 

Accordingly, these were generally not added to the Forest Transportation System. Increasing and 

unmanaged off-highway vehicle usage in the past few decades also led to significantly more usercreated routes that were not part of the official Inyo National Forest transportation system.

The 2009 Inyo National Forest Motorized Travel Management Environmental Impact Statement 

(USDA Forest Service 2009b) analyzed the temporary and user-created routes in existence that 

were not part of the Forest Transportation System and considered non-system routes. The analysis 

considered the contribution of the routes to the administration and use of the Forest and their 

respective environmental concerns. The Record of Decision added over 800 miles of maintenance 

level 2 roads and approximately 157 miles of motorized trails to the Forest Transportation System 

while closing others to motorized vehicle use (USDA Forest Service 2009b).

The transportation system on the Inyo National Forest is very important to the public and tourism 

in the Eastern Sierra’s as it is the primary means for access to the national forest. The public uses 

the transportation system to access recreation interests such as camping, picnicking, fishing, 

hunting, hiking, backpacking, mountain biking, rock climbing, sight-seeing, skiing and 

snowboarding, snowmobiling, driving off highway with off-highway vehicles, and visiting 

historic and natural interest areas. The transportation system is also used by the public for 

personal and commercial fuel wood gathering, mining, geothermal exploration, range uses, pine 

nut gathering, and traditional Native American uses. In addition to facilitating the above uses, the 

transportation system is also used in an administrative capacity by Forest Service staff for fire 

suppression, fuels management, and forest health management. 

The Inyo National Forest provides motorized access through conventional two-wheel-drive roads, 

four-wheel-drive roads, motorized trails, and over-snow travel routes. Roads referred to as 

“maintenance level 1” are closed to motorized use and are maintained in storage and for future 

access needs. Maintenance level 2 roads are managed to accommodate travel by off-highway and 

high-clearance vehicles. Maintenance level 3, 4 and 5 roads are managed to accommodate 

passenger cars and other licensed vehicles (these are closed to unlicensed off-highway vehicles, 

unless specifically designated). The Inyo National Forest has approximately 1,950 miles of 

national forest transportation system roads (see table 73).

Table 73. Miles of system roads by maintenance level

System Roads by Maintenance Level Miles

Roads designated for passenger cars

(maintenance level 3, 4 & 5)

119

Roads designated for high clearance & fourwheel drive vehicles (maintenance level 2)1,824

Total roads open to motor vehicles 

(maintenance level 2-5)

1,950

The Inyo National Forest presently offers many miles of trails for nonmotorized access. Out of 

the 1,669 miles of designated trails on the Inyo, 1,105 miles are standard nonmotorized trails, and 

32 miles are nonmotorized snow trails. The Inyo National Forest currently manages an average of 

approximately 969 miles of trails per year, to a level where their maintenance and condition meet 

Forest Service standards. Nonmotorized trails are open to nonmotorized uses including 

mechanized transport outside of wilderness unless otherwise closed by a Forest Service closure 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

482

order. Mountain bikes are allowed on 573 miles of trails. There are 339 miles of motorized trails, 

and 221 miles of trails designated as motorized snow trails open to over-snow vehicles (see table 

74).

Table 74. Miles of trails by designated and allowed uses 

Trails by Designated and Allowed Uses Miles

Trails designated as nonmotorized 1,105

Trails designated as nonmotorized snow trails 32

Trails open to mountain bike use 573

Trails designated as motorized trails 339

Trails designated as motorized snow trails 221

Total # miles of trails 1,669

In this analysis, the term “mechanized transport” is defined as transport powered by a living or 

non-living power source and includes such things as bicycles and game carts. The term bicycle is 

used to represent mechanized transport in the discussion below. Bicycle use is allowed on 

designated motorized trails in addition to designated nonmotorized trails except within wilderness 

areas as described below. The Pacific Crest National Scenic Trail is closed by a regional closure 

order to mechanized transport. Electric bicycles are considered motorized vehicles and are 

allowed on designated motorized routes. Seventy-five percent of the system trails on the Inyo 

National Forest are located in designated wilderness. The Wilderness Act prohibits motorized use 

and mechanized transport such as mountain bikes, are not allowed, only primitive means of travel 

is permitted, such as hiking, horseback, ski mountaineering or snowshoeing; The remaining 25 

percent of the trails offer a wider variety of nonmotorized travel options, such as mountain 

biking, and bicycling or roller blading on paved paths. Approximately 33 percent of the snow 

trails are groomed by permit holders as an authorized special use. All of the nonmotorized system 

snow trails are located outside of wilderness, and have a variety of nonmotorized activities, 

including Nordic skiing, snowshoeing, or walking. Nonmotorized use such as Nordic skiing or 

backcountry skiing is acceptable in designated wilderness.

The Inyo National Forest is open to motorized and nonmotorized winter recreation activities. 

Over-snow vehicles are allowed on routes and open areas outside of designated wilderness. 

Existing over-snow-vehicle use is not suitable in recommended wilderness areas. After sitespecific analysis through subpart C of the Travel Management Rule is completed, over-snow 

motorized use would be prohibited by future Forest Service orders inside recommended 

wilderness areas. These open areas and routes are or will be shown on over-snow vehicle use 

maps as winter travel management analyses are completed in the future. Designated winter routes 

can be groomed, and open areas, which are not groomed, consist of natural snowpack that ranges 

from powder to spring freeze conditions.

The Inyo National Forest system of authorized motorized routes was designated in 2009 under 

Travel Management Planning - Travel Management Rule (36 CFR Part 212, Subpart B). There 

are a total of 339 miles of motorized trails open to motorized travel on the national forest in 

addition to 1,950 miles of National Forest System roads open to motorized travel. Management of 

motorized routes would remain the same between all the alternatives since the number of 

motorized routes does not change between alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

483

Facilities and Level of Development

Developed recreation sites provide much of the infrastructure necessary for the enjoyment of a 

wide variety of recreation activities in the analysis area. The current level of development of a 

recreation facility depends upon the assigned recreation opportunity spectrum class and the need

for managing recreation uses. 

The Inyo National Forest has a total of 247 developed recreation sites, the majority of which are 

found in the roaded modified and rural recreation opportunity spectrum classes. They include 

recreation sites such as campgrounds, group camping areas, horse camps, picnic or day use areas, 

boating sites, and swimming sites which provide recreation opportunities and access. Table 75

identifies the number of developed recreation sites that are development scale 2 or higher on the 

national forest by site type. Development scales are used to define the level of development at a 

recreation site from minimum site modifications, which would typically exist in primitive 

recreation opportunity spectrum settings (Development scale 1) to a high degree of site 

modification, which would typically exist in rural recreation opportunity spectrum settings 

(Development scale 5).

Table 75. Developed recreation sites 

Developed Recreation Site Type Total Sites 

Boating Site 9

Campground 79

Horse Camp 2

Campground Group 16

Interpretive Site 15

Information Site 5

Observation Site 14

Picnic Site 20

Ski Area Nordic 1

Alpine Ski Area 2

Visitor Center 5

Swimming Site 1

Trailhead 78

Total number of recreation sites 247

Recreation sites, and facilities within those sites require operations and maintenance. The 

deferred maintenance backlog in 2013 for recreation site buildings as reported in the Forest 

Service database of record for recreation sites (INFRA) was $3.7 million. Due to lack of staff to 

regularly perform condition surveys of these buildings, the actual deferred maintenance cost is 

likely much higher. Additionally, this figure does not include deferred maintenance of recreational 

water systems or wastewater systems as no data exists. Deferred maintenance for other recreation 

site amenities, such as campsites, food storage lockers, and picnic tables, is $3.2 million as 

reported in INFRA.

The majority of the campgrounds on the Inyo National Forest are run by concessionaires under 

special use permit. The permits are awarded on a competitive basis for a period of 5 years, with 

an option to extend for an additional 5 years based on satisfactory performance. The Forest 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

484

Service has Granger-Thye authority under these special use permits, which allows a fee offset to 

occur, where the permittee returns a percentage of their proceeds back to the Federal Government 

for the purpose of maintaining the recreation sites under that permit. This fee-offset helps to 

address deferred maintenance needs at recreation sites.

There are also privately owned recreation sites and facilities on the Inyo National Forest operated 

under special use permit. These privately-owned developed recreation facilities such as ski areas 

and resorts provide recreation opportunities and access on National Forest System lands.

Visitor Use

The Inyo National Forest offers a full suite of outdoor recreation activities, in all seasons, for 

those who enjoy either motorized or nonmotorized pursuits on land, water, or in the air. The list of 

recreation activities is long, and includes activities such as, but not limited to: cross-country and 

downhill skiing or snowboarding, snowmobiling, rock or ice climbing and mountaineering, 

hiking or backpacking, equestrian riding or packing, mountain biking, camping, hunting or 

fishing, off-highway vehicle driving or riding, picnicking, swimming, boating, paddle boarding, 

hang-gliding, wildlife watching, fall foliage viewing, visiting historic sites or scenic areas, 

participating in interpretive programs or tours, resort use, and more.

Despite differences in recreation preferences across demographic groups and changes that have 

occurred over time, the core set of activities preferred by the majority of people have generally 

been nonmotorized activities like walking, picnicking, swimming, riding bicycles, and viewing 

and learning about nature. These activities are some of the easiest and least expensive to provide 

and address the needs of a broad group of people (Watts Jr and Fisher 2010).

The National Visitor Use Monitoring program monitors recreation use every five years through 

exit surveys on national forests. The data collected during National Visitor Use Monitoring 

surveys provides estimates of the volume and characteristics of recreation visitation. The Inyo 

National Forest last collected data in 2016; however, the most recent years for which data results 

are available are 2006 and 2011.

Nonmotorized activities such as hiking/walking and skiing are popular on the Inyo NF, and have 

maintained some of the highest participation rates according to most recent NVUM surveys

(NVUM 2011). Motorized activities and use of motor vehicles to travel to and engage in 

nonmotorized activities are also important and are discussed in the context of access below.

Table 76 lists visitor participation on the Inyo National Forest by recreation activity during 2011 

National Visitor Use Monitoring surveys. Visitor participation is listed in the table by main 

activity and by activity participation. Because most national forest visitors participate in several 

recreation activities during each visit, it is more than likely that other visitors also participated in 

this activity, but did not identify it as their main activity. For example, on one national forest 63 

percent of visitors identified viewing wildlife as a recreational activity that they participated in 

during this visit, however only 3 percent identified that activity as their main recreational activity

(NVUM 2011).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

485

Table 76. Visitor participation in recreation activities on the Inyo NF in 2011 National Visitor Use 

Monitoring surveys

Activity Percentage Participation* Percentage Main Activity**

Viewing Natural Features 59.2 21.2 

Relaxing 54.6 6.2

Hiking / Walking 43.8 12.6

Downhill Skiing 39.4 38.1

Viewing Wildlife 34.5 2.0

Driving for Pleasure 29.0 1.8

Nature Center Activities 21.8 0.3

Picnicking 18.8 0.3

Developed Camping 14.7 2.1

Resort Use 14.7 0.0

Fishing 14.6 6.2

Visiting Historic Sites 14.1 10.2

Nature Study 11.0 0.2

Other Non-motorized 6.8 0.4

Cross-country Skiing 6.7 1.9

Bicycling 6.6 1.4

No Activity Reported 3.8 3.9

Gathering Forest Products 3.8 0.0

Primitive Camping 3.5 0.0

Non-motorized Water 2.7 0.9

Backpacking 24 1.2

OHV Use 2.2 0.0

Motorized Water Activities 1.6 0.0

Some Other Activity 1.3 0.1

Motorized Trail Activity 1.2 0.2

Snowmobiling 1.1 0.1

Horseback Riding 0.9 0.1

Other Motorized Activity 0.9 0.0

Hunting 0.2 0.0

* Survey respondents could select multiple activities so this column may total more than 100%.

**Survey respondents were asked to select just one of their activities as their main reason for the national forest visit. 

Some respondents selected more than one, so this column may total more than 100%.

According to 2006 and 2011 National Visitor Use Monitoring data results, the top 10 most 

popular activities in terms of visitor participation on the Inyo National Forest stayed relatively 

constant between 2006 and 2011, though rankings have changed over time. The most frequently 

reported primary activity in the 2011 survey was downhill skiing (38 percent), followed by 

viewing natural features (21 percent), and hiking (13 percent). Over 55 percent of the visits report 

participating in relaxing and viewing scenery (USDA Forest Service 2011b and 2006). The 10

most popular recreation activities on the Inyo National Forest in 2006 and 2011 are listed below.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

486

• viewing natural features

• relaxing

• downhill skiing

• hiking/walking

• )viewing wildlife

• driving for pleasure

• nature center activities

• developed camping

• picnicking (in 2011)

• resort use (in 2011)

• fishing (in 2006)

• visiting historic sites (in 2006)

In addition to the most popular recreation activities listed above, dispersed recreation activities 

occur throughout the national forest in undeveloped or general forest areas where there are few or 

no facilities. Dispersed recreation includes a wide range of outdoor motorized and nonmotorized 

recreation opportunities that are available throughout the year. Activities may include but are not 

limited to activities such as camping, hiking, horseback riding, off-highway-vehicle driving or 

riding, rock climbing, mountain biking, wildlife viewing, fishing, hunting, cross-country skiing, 

snowmobiling, visiting historic sites and scenic areas, and exploring the national forest. Dispersed 

recreation opportunities can be found in all recreation opportunity spectrum classes.

Table 77 shows the total estimated forest visitation on the Inyo National Forest based upon the 

most recent NVUM data available from 2006 and 2011. There was an estimated 2.5 million 

national forest visits to the Inyo NF in 2011. Key recreation access road closures on the national 

forest during 2011 may account for the drop in total forest visits from 2006 to 2011. The total 

estimated recreation site visits increased to 5.5 million on the national forest in 2011, which was 

more than double the estimated recreation site visits in 2006. Another notable increase in 

visitation was the increase in wilderness visits which nearly doubled from 2006 to 2011 (USDA 

Forest Service 2011b, 2006). 

Table 77. Forest visitation numbers (in thousands)

Visit Type 2006 2011

Total estimated national forest visits to Inyo* 2,862 2,530

Total estimated site visits** 2,738 5,495

General forest area estimated visits 748 978

Day use developed estimated site visits 2,738 2,524

Overnight developed site estimated visits 907 1,741

Designated wilderness estimated visits 138 252

*A national forest visit is defined as the entry of one person upon a national forest to participate in recreation activities for 

an unspecified period of time. A national forest visit can be composed of multiple site visits

** A site visit is the entry of one person onto a national forest site or area to participate in recreation activities for an 

unspecified period of time. Sites and areas were divided into four site types as listed here

Demographic results from the 2011 National Visitor Use Monitoring survey data results available 

show that very little visitation on the Inyo National Forest is local; more than three-quarters of 

visits come from people who live more than 200 miles away from the national forest. Among 

racial and ethnic minorities, the most commonly encountered are Hispanic/Latino (10 percent) 

and Asian (5 percent). The age distribution shows that the Inyo has a very high proportion of 

children in the visiting population. About 30 percent of visits are under the age of 16. People over 

the age of 60 account for about 15 percent of visits (USDA Forest Service 2011b).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

487

The Inyo National Forest has recreation sites under special use permit, which are more 

commercial in nature, and for a fee offer a variety of services. Included are resorts, downhill ski 

resorts, recreation residences, improved cross-country ski trails, recreation events, marinas, and 

organizational camps. Recreation special uses can provide for recreation access and recreation 

experiences that the Forest Service doesn’t typically provide. 

The Inyo National Forest currently manages a total of 534 recreation special use authorizations; 

of those, there are 350 recreation residence permits, 82 outfitter and guide permits, 32 resort 

permits, 19 recreation events permits, 5 permits for marinas, and several other types of recreation 

special use permits.

Key recreation sites or areas on the Inyo National Forest include Mount Whitney, Mammoth 

Mountain and June Mountain Ski Areas, Mammoth Lakes Basin, Mono Lake, June Lake, Coyote 

Flat, Bishop Creek, Whitney Portal, Papoose Flat, the Ancient Bristlecone Pine Forest, Reds 

Meadow, Buttermilk climbing area, the Kern Plateau, Ansel Adams and John Muir Wilderness 

Areas, and Rock Creek. Many of these key recreation sites or areas receive high amounts of 

concentrated recreation use.

Environmental Consequences to Sustainable Recreation

Consequences Specific to Alternative A 

Existing plan direction is based on recreation uses and demand in the late 1970s and 1980s, prior 

to the current plan being developed. The current plan focuses on improving recreation 

opportunities by concentrating on the maintenance, development, adaptation, or alteration of 

recreation sites consistent with the recreation opportunity spectrum class where each site is 

located. Partnerships and volunteer opportunities are referenced to increase the amount of trails 

and facilities managed to desired standards.

Recreation Settings and Opportunities 

The recreation opportunity spectrum is the primary management tool of recreation settings in the 

existing plan. The primary difference in management of recreation settings between this 

alternative and alternatives B, C, and D is the slight change of recreation opportunity spectrum 

classes (primarily primitive and semi-primitive nonmotorized) based on acres of recommended 

wilderness per alternative. There is no recommended wilderness in alternative A.

Table 78 shows the recreation opportunity spectrum classes for the existing forest plan 

(alternative A) and for alternatives B, B-modified, C, and D, which present variations of the 

desired recreation opportunity spectrum in acres and percent. Maps of the recreation opportunity 

spectrum classes for the Inyo National Forest can be found in volume 3.

In the current plan, the largest recreation opportunity spectrum class on Inyo National Forest is 

primitive at 53 percent followed by roaded natural (15 percent) and semi-primitive motorized (14 

percent). When the two nonmotorized settings are combined (primitive and semi-primitive 

nonmotorized), this alternative provides 65 percent of the national forest in a nonmotorized 

setting. Combining the motorized setting (semi-primitive motorized, roaded natural, roaded 

modified and rural), this alternatives provides 32 percent of the national forest in a motorized 

setting. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

488

Table 78. Existing (alternative A) and desired (alternatives B and B-modified, C, D) recreation 

opportunity spectrum classes in acres and percentage of national forest by alternative

Class Alternative A Alternative B 

Alternative Bmodified Alternative C Alternative D

Primitive 1,061,318

53 percent

1,092,748

55 percent

1,092,340

55 percent

1,334,083

67 percent

1,084,095

55 percent

Semi-primitive 

nonmotorized

241,504

12 percent

221,532

11 percent

227,093

11 percent

97,763

5 percent

229,442

12 percent

Semi-primitive 

motorized

286,784

14 percent

365,264

18 percent

366,899

18 percent

264,209

13 percent

365,861

18 percent

Roaded 

Natural

291,980

15 percent

239,287

12 percent

233,632

12 percent

223,688

11 percent

239,432

12 percent

Roaded 

Modified

49,011

2 percent

47,645

2 percent

46,562

2 percent

47,078

2 percent

47,645

2 percent

Rural 13,853

1 percent

19,300

1 percent

19,300

1 percent

19,011

1 percent

19,300

1 percent

Urban 0 0 0 0 0

Unassigned 41,342

2 percent 0 0 0 0

Existing management direction under alternative A would not direct the Inyo to adequately 

manage recreation opportunities and settings, since the current forest plan was developed almost 

30 years ago. The current plan does not account for changing uses, emerging uses, or changing 

demographics. A good example of a changing use not adequately reflected under alternative A is 

that the technology advancements for motorized over-snow vehicles since the last forest plan was 

written increased their ability to access different areas. This change also has implications with 

nonmotorized opportunities, as over-snow vehicles can be used to access remote backcountry 

areas for winter nonmotorized activities. Outdated recreation opportunity spectrum classifications 

currently exist as a result of changes in management and land status since the plan was written.

The current recreation opportunity spectrum under alternative A would not adequately capture 

valued recreation settings and opportunities.

Management direction in the existing plan does not provide a range of year-round developed and 

dispersed recreation settings that offer a variety of motorized and nonmotorized opportunities and 

recreation experiences.

The existing plan also does not recognize decreasing budgets, which could affect the ability to 

effectively manage recreation settings across the recreation opportunity spectrum. As a result of 

decreasing budgets, alternative A would not provide adequate management direction on the need 

for partnerships and volunteers to help manage recreation opportunities and settings across the 

recreation opportunity spectrum.

The existing plan would not ensure a sustainable recreation program on Inyo National Forest, this 

is particularly true for unmanaged recreation, where timely response to new uses that have 

potential ecological effects would be necessary into the future. The current forest plan also lacks 

the direction to adaptively manage new and emerging uses.

Without a change in current trends of forest conditions that could adversely affect recreation 

settings (such as stand replacing wildfire, disease, and mortality) there would potential for 

adverse effects on recreation settings. These recreation settings are what provides for the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

489

recreational opportunities such as hiking, wildlife viewing, and fishing. There would likely be 

short-term impacts on recreation settings which could displace recreational visitors to unaffected 

areas. There would also be long-term impacts without restoration activities and overall limited 

treatment rates due to a decline in quality of the recreation settings without restoration activities 

identified in plan revision alternatives.

Under the existing plan, 17 critical aquatic refuges will be retained instead of conservation 

watersheds developed under B-modified. Critical aquatic refuges are intended to provide 

protection to aquatic species; however, they are not intended to prohibit recreation uses. In the 

event recreation uses would have negative impacts on critical aquatic refuges, changes to the 

physical recreation setting may be necessary such as hardening a creek crossing or a necessary 

trail re-route, but the recreation activity would likely not become prohibited. Alternative A has a 

slightly less number of critical aquatic refuges than alternatives B and D, and alternative C has 

the highest number of critical aquatic refuges.

Access

Existing recreation opportunity spectrum settings would not change under alternative A;

therefore, there would be no impact to nonmotorized, motorized or mechanized transport access 

under this alternative. The number of miles of access roads and trails would remain the same 

under alternative A. The average number of miles per year of trails that meet Forest Service 

standards under alternative A would remain the same (969 miles), which is roughly 58 percent of 

the trail system.

There is no recommended wilderness in this alternative; therefore, there would be no impact to 

mechanized access (mountain bike use) since there would be no change in the miles of system 

trails that allow mountain bike use. The number of miles of motorized trails and roads available 

would not be impacted since there would be no change.

Although there is no change to the number of miles of roads and trails available under alternative 

A, management direction under alternative A would not provide direction for motorized and 

nonmotorized trail systems that meet current demands, uses; as well as managing conflicting 

uses. This would likely have negative impacts on future trail management without relevant 

direction to meet current demands and uses. There is also no current direction provided for trail 

connectivity, linkages to local communities, or access to destinations, all of which are a critical 

component of trail access. 

Alternative A does not provide direction to adequately manage motorized and nonmotorized trails

given that budgets are expected to decline. There is limited emphasis in the existing plan on using

volunteers and partnerships to help manage trails with fewer federally appropriate funds 

available. Without adequate management direction for using volunteers and partnerships, there 

would be likely be adverse effects to trails since they would not be maintained to Forest Service 

standards. 

Without a change in current trends of forest conditions (such as stand-replacing wildfire, disease, 

and mortality), there would be potential for negative effects to recreation access. These impacts 

would likely be short term in nature as roads and trails could be closed due to catastrophic 

wildfires or hazardous conditions along roads and trails from hazard trees.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

490

Facilities and Level of Development

Management direction under the current forest plan would not provide a framework for how the 

Inyo will improve, manage, or limit existing recreation sites along with a potential management 

approach that speaks to redesigning, restoring and rehabilitating sites if unacceptable resource 

impacts are occurring. A lack of direction on managing these recreation sites into the future would 

have negative impacts on managing existing recreation facilities and could result in closures of 

recreation sites or an absence of creating new recreation facilities where demand and use warrant 

additional infrastructure. 

The current plan also does not provide direction to manage the condition, function, and 

accessibility of recreation facilities to accommodate a diverse public. A lack of clear management 

direction would likely have negative impacts on maintenance, condition, and accessibility of 

recreation facilities. This could also result in the Inyo’s failure to provide an adequate number of 

facilities to meet the demands of the public.

Current management direction under alternative A also does not provide integrated direction for 

managing and operating recreation facilities in a changing environment, and does not respond to 

changes in visitor demands and uses (or environmental conditions) that may be needed to make 

changes to facilities or possibly alter access to recreation facilities. Without an integrated and 

responsive approach to managing these facilities, recreation development and facilities would 

likely be negatively impacted and could result in closure or under-utilization.

Visitor Use 

The existing plan does not provide direction for managing visitor use. The current plans’s 

recreation management approach is more concentrated and emphasizes improving recreation 

opportunities by focusing on recreation sites rather than managing visitor use. Without direction 

on managing visitor use, visitor experiences could be negatively impacted without responding to 

visitor conflict, crowding, or under-represented uses.

The existing plan does not provide a framework for informing management decisions on current 

and future activities and visitor expectations. This would have negative outcomes on the 

availability of a broad range of visitor activities and the national forest would likely fail to meet 

visitor expectations.

There is no direction under the existing plan to adapt to changes in visitor use levels, patterns of 

use, or the necessity to protect resources where over-use or incompatible uses occur. Without 

clear management direction on managing visitor uses, visitor experiences could be negatively 

impacted if crowding is perceived where it is not expected or unintended resource damage could 

cause closure of recreation sites or areas. 

The existing plan lacks management direction on when and where it is appropriate to emphasize 

recreation special use authorizations. As a result, special uses would likely be issued where they 

may not be appropriate and could cause over-crowding in areas, or the use could exceed the 

sustainability of the natural and cultural resources that support these activities. Visitor 

experiences would likely be negatively impacted under this alternative if visitors experience 

crowding or conflict.

Consequences Common to Alternatives B, B-modified, C, and D

There would be an increase in restoration activities in all plan revision alternatives; therefore, all 

of these alternatives provide greater potential to improve the long-term sustainability of recreation 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

491

opportunities and settings in comparison to alternative A, which maintains current restoration 

activity levels.

The plan revision alternatives do have the potential for short-term adverse effects to recreation 

settings and opportunities by displacing visitors during restoration activities, but this is negligible 

given that it is short term in nature and recreation sites and settings would be protected in the long

term.

Consequences Specific to Alternative B

Recreation Settings and Opportunities 

Alternative B’s recreation management strategy stems from the recreation opportunity spectrum 

and the concept of place-based management areas (referred to as recreation places), which are 

characterized by their distinctive roles and contributions within the broader landscape. There are 

16 recreation places spanning the entire Inyo National Forest under alternative B. Each is 

centered on a central theme and consists of one broad desired condition that provides limited, 

general direction for management of the area related to scenery, recreation settings, recreation 

opportunities, and recreation sites and infrastructure. Each recreation place is categorized as one 

of six types: destination, dispersed use, high country, high-use overnight, scenic drive, or 

wildlands. 

Though the recreation opportunity spectrum is the primary management tool of recreation settings 

in alternative B, this alternative does not contain descriptions of the characteristics of each 

recreation opportunity spectrum setting or associated plan components to achieve each desired 

recreation opportunity spectrum class. This alternative also provides little direction on integrating 

recreation settings with other resources which could cause unintended negative impacts to 

resources or recreation experiences if resource conditions degrade under this alternative.

Alternative B only provides direction for managing summer recreation settings; it does not 

provide the management for both summer and winter recreation opportunity spectrum settings.

This alternative also contains unsuitable desired conditions for over-snow, winter recreation 

because they are specific to summer recreation opportunity spectrum settings. Because alternative 

B does not manage for winter recreation settings, this alternative is not responsive to the change 

in winter recreation opportunities. Recent advances in over-snow vehicle technologies have 

increased the range and demand for access to backcountry skiing, snowboarding, and 

snowshoeing. There is no direction provided for a range of winter recreation opportunities under 

alternative B, which would likely have negative consequences on winter recreation opportunities. 

Under alternative B, 18 critical aquatic refuges would be maintained instead of conservation 

watersheds developed under B-modified. Critical aquatic refuges are intended to provide 

protection to aquatic species; however, they are not intended to prohibit recreation uses. In the 

event recreation uses would have negative impacts on critical aquatic refuges, changes to the

physical recreation setting may be necessary such as hardening a creek crossing or a necessary 

trail reroute, but the recreation activity would likely not become prohibited. Alternatives B and D 

have the same number of designated critical aquatic refuges, alternative A has slightly fewer, and 

alternative C has the highest number.

In alternative B, the largest recreation opportunity spectrum class on the Inyo National Forest 

would be primitive class at 55 percent of the national forest followed by semi-primitive motorized 

(18 percent), and then by roaded natural (12 percent). When the two nonmotorized settings are 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

492

combined, these alternative would result in 66 percent of the Inyo in a nonmotorized setting. 

Combining the motorized settings, these alternatives would provide a motorized setting on 33 

percent of the national forest. The amount of nonmotorized setting in this alternative would be the 

similar to alternatives B-modified and D, and less than alternative C. Like alternative B-modified, 

a slight increase in nonmotorized recreation opportunity spectrum settings would be beneficial to 

nonmotorized recreation opportunities as it increases opportunities for wilderness-based 

opportunities that require solitude and quiet recreation activities. A slight decrease in motorized 

settings available would be a negligible impact to motorized opportunities considering there 

would be no motorized route closures as a result of the recommended wilderness areas.

Recreation opportunities are the opportunities to participate in a specific activity in a particular 

recreation setting to enjoy a desired recreation experience. The recreation opportunity spectrum 

provides the primary guidance for recreation opportunities in alternative B (similar to alternatives 

C and D). The primary difference in management of recreation opportunities between these 

alternatives is the slight change in access due to differences in recommended wilderness 

alternatives B and D compared with alternative C. 

Like alternative B-modified, alternative B provides a framework to inform management decisions 

on current and future activities and visitor expectations that is not present under the current plan. 

This is particularly important given that visitor use is expected to increase with potential for 

changing and new uses. Although alternative B does not have the integrated and adaptive 

management approach under the sustainable recreation zones of alternative B-modified, its 

management framework would still improve recreation opportunities and experiences on the 

national forest to meet the demands and expectations of visitors, and it is responsive to the 

changing and emerging uses not present under the current plan.

This alternative, like alternative B-modified, provides direction to ensure recreation opportunities 

provide a high level of visitor satisfaction and that the range of recreation activities provide social 

and economic sustainability. This would be a beneficial impact to recreation opportunities.

Access

Under alternative B (like alternative B-modified) there are four recommended wilderness areas, 

none of which contain any system trails that allow bicycle use; therefore, there would be no 

change in miles of system trails that allow mechanized transport. Within the four recommended 

wilderness areas there are no existing system motor vehicle routes or open areas; therefore there 

would be no impact to the miles of motorized or nonmotorized system trails, roads, or open areas 

allowing motorized use. 

Like alternative B-modified, this alternative provides direction to increase transportation systems 

to connect people to nature, improve personal health, and increase access for underserved 

communities, minorities and urban youth. This would be a beneficial effect to recreation access. It 

also provides 

Management direction under alternative B (like B-modified) provides for motorized and 

nonmotorized trail systems that meet current demands and uses; as well as managing conflicting 

uses which would be a beneficial impact to trail access as compared to alternative A. The 

alternative (like B-modified) also emphasizes trail connectivity, linkages to local communities, 

and access to destinations which is a beneficial impact to trails, and social and economic stability. 

Management direction related to recreation access under alternative B does not offer a different 

focus across different recreation zones and assigned recreation opportunity spectrum settings, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

493

direction is based solely upon the assigned settings. Without a focus on different emphasis zones, 

the Inyo lacks direction on where to prioritize trail management. 

Alternative B (like alternative B-modified) provides a framework to manage motorized and 

nonmotorized trails into the future given that budgets are expected to decline. There is emphasis 

placed upon using volunteers and partnerships to help manage trails with less federally 

appropriate funds available. Under this alternative, 75 percent of the national forest designated 

trail system would be maintained to standard and 25 percent of the deferred maintenance on trails 

would be addressed through partnerships. This would be a beneficial impact to public’s access to 

motorized and nonmotorized trails. However, without clear direction on how that access will be 

managed and prioritized across the national forest, utilizing partnerships under this alternative 

would not be as beneficial as under alternative B-modified.

With the restoration activities that will occur under alternative B (as under B-modified, C, and D) 

there would be potential for short-term negative effects to recreation access if roads or trails are 

closed during restoration activities, but this is negligible given that it is short-term in nature. 

Restoration activities would have beneficial impacts to access in the long-term because as 

ecosystems are restored over time, it would be less likely that roads and trails would be closed 

due to catastrophic wildfires or hazardous conditions along roads and trails from tree mortality or 

fires.

Facilities and Level of Development

Alternative B (similar to alternative B-modified) provides direction to manage recreation 

facilities and ensure they are place based, integrated, and responsive to changes that may limit or 

alter access. This integrated approach provides for facilities to meet user demands while ensuring 

resources are protected. This would benefit developed recreation because it allows for 

redesigning, restoring, or rehabilitating recreation sites where recreation activities have caused 

unacceptable natural or cultural resource damage. Like alternative B-modified, one of the tradeoffs when compared with the alternative A is that it provides the framework to restore recreation 

facilities that are underutilized or causing resource damage, but ultimately this would benefit 

developed recreation because it allows the Inyo to focus managing only recreation sites that are 

needed while protecting resources. This would help meet desired conditions and ensure that 

recreation facilities are maintained to desired conditions.

Under alternative B (like alternative B-modified) there is a focus on partnerships and community 

stewardship to help the Inyo operate and maintain recreation facilities with opportunities such as 

the establishment of “adopt a facility” programs. This would be a benefit to the condition of 

recreation facilities across the national forest and help the Inyo meet desired conditions.

Under alternative B, there is no specific framework provided to ensure recreation development is 

suitable across the different areas of the national forest, there is only the recreation opportunity 

spectrum settings that guide management of facilities under this alternative. A lack of specific 

direction on when and where additional development would be appropriate across different areas 

and recreation opportunity spectrum settings on the Inyo would likely cause adverse impacts if 

facilities do align with user demands and uses. This alternative does not direct the Inyo to focus 

developed recreation management in areas where the highest use is occurring and greatest 

demand. This would likely cause negative impacts to the condition of facilities as the Inyo could 

end up with more facilities than they can manage.

Alternative B does not provide integrated and adaptive direction for managing and operating 

sustainable recreation facilities in a changing environment. Unlike alternative A, this alternative 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

494

recognizes there will be new and changing uses, but without an adaptive and integrated approach 

to designing and managing recreation infrastructure, the Inyo could end up with unnecessary 

facilities, facilities that impact sensitive resources, or recreation facilities that conflict with user 

expectations or uses. Without an integrated and responsive approach to development and 

management of these facilities, recreation facilities would likely be negatively impacted and 

could result in closure or under-utilization of these facilities. 

Visitor Use

Alternative B recognizes that visitor use and demand will continue to increase, which alternative 

A does not do, but since direction is based solely upon the recreation opportunity spectrum, it 

does not provide for an adaptive and integrated approach to managing visitor use. Without an 

adaptive and integrated approach to managing visitor use, visitor experiences would be negatively 

impacted without responding to visitor conflict, crowding, or under-represented uses.

There is also no direction under alternative B to adapt to changing patterns of use, or the necessity 

to protect resources where over-use or incompatible uses occur. Without adaptive management 

direction on managing changing patterns of use across different settings on the national forest, 

visitor experiences could be negatively impacted if crowding is perceived where it is not expected 

or unintended resource damage could cause closure of recreation sites or areas. This would 

negatively impact visitor expectations. 

Like alternative A, alternative B lacks specific management direction on when and where it is 

appropriate to emphasize recreation special use authorizations, it only ensures that they are 

consistent with recreation settings. As a result, special uses could likely be issued where they may 

not be appropriate and could cause over-crowding in areas, or the use could exceed the 

sustainability of the natural and cultural resources that support these activities. Visitor experiences 

would be negatively impacted under this alternative if visitors experience crowding or conflict 

where it is not expected.

Consequences Specific to Alternative B-modified

Recreation Settings and Opportunities 

Table 78 shows that in alternative B-modified, the largest recreation opportunity spectrum class 

would be primitive at 55 percent of the national forest followed by semi-primitive motorized (18 

percent), and then by roaded natural (12 percent). When the two nonmotorized settings are 

combined, this alternative would result in 66 percent of the Inyo in a nonmotorized setting. 

Combining the motorized settings, these alternatives would provide a motorized setting on 33 

percent of the national forest. This slight increase in nonmotorized recreation opportunity 

spectrum settings would be beneficial to nonmotorized recreation opportunities since it has the 

biggest increase in wilderness-based opportunities that require solicitude and a remote setting.

There would be a slight decrease in motorized recreation settings from the current plan 

(alternative A) due to the recommended wilderness areas; however, this impact is considered 

negligible since it would not result in any closures of motorized routes.

The amount of nonmotorized settings in alternative B-modified is similar to alternatives B and D, 

but less than alternative C. The amount of motorized settings under alternative B-modified in 

these alternatives would be similar to alternatives B and D, but higher than alternative C.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

495

Alternative B-modified is the only alternative that provides direction to manage recreation 

settings through a zoned approach. The sustainable recreation zones provide direction for the Inyo

to offer a variety of recreation opportunities, integrating the different recreation opportunity 

spectrum settings under each of the three zones. The three recreation management zones under 

alternative B-modified manage for a continuum of recreation user densities across the three 

zones: from a high-concentration of recreation activities to a low-density of recreation activities, 

providing for a full spectrum of recreation opportunities and experiences. The zone management 

approach would be beneficial to recreation settings because it supports a diversity of settings 

across the recreation opportunity spectrum, including the level of facility development allowed in 

each setting. Recreation opportunity spectrum is incorporated into each of the recreation 

management zones and is a clear descriptor in the desired condition of each area, which would 

ensure that recreation facilities and activities match the setting and zone.

Alternative B-modified recognizes there are gradations of recreation use levels and types within 

the same recreation opportunity spectrum class and polygon. Table 79 and figure 32 show the 

different recreation opportunity spectrum settings and how they would be managed across the 

three different recreation zones.

Table 79. Recreation opportunity spectrum settings of recreation zones in alternative B-modified

(acres and percentage of forest)

Sustainable 

Recreation Zone Primitive

SemiPrimitive 

Nonmotorized

SemiPrimitive 

Motorized

Roaded

Natural

Roaded 

Modified Rural

Destination 

Recreation Area

(High use)

990

0 percent

6,118

3 percent

1,069

0 percent

128

0 percent

23,662

51 percent

11,397

59 percent

General Forest 

Recreation Area 

(Mixed/Moderate 

Use)

5,551

1 percent

49,130

22 percent

71,751

20 percent

172,565

74 percent

19,147

41 percent

7,762

40 percent

Challenging 

Backroad Area 

(Low Use)

82,301

8 percent

149,140

66 percent

263,360

72 percent

48,488

21 percent

52

0 percent

0

0 percent

As shown in table 79 and figure 32, the Destination Recreation Zone would provide the least 

amount of primitive and semi-primitive settings, but this would be appropriate in the high use 

areas of this zone type where the rural and roaded modified settings are suitable for high use. The 

Challenging Backroad Area would provide the most nonmotorized settings, which would also be 

appropriate for this type of zone where minimal facilities and management would be needed. The 

zoned approach would have beneficial impacts to recreation settings and opportunities as it would 

ensure that a broad range of visitor experiences are provided across the different zones and 

recreation opportunity spectrum settings. Rather than recreation opportunity spectrum providing 

the sole direction for recreation opportunities under alternative B, alternative B-modified 

integrates components of recreation opportunity spectrum classes, both summer and winter, to 

provide a framework to adaptively manage recreation.

The zoned management approach to recreation management under alternative B-modified would 

provide for expansion of recreational opportunities under the General Recreation Area if 

warranted by visitor use and demands. This would be a beneficial consequence to recreation 

opportunities as it would increase opportunities available. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

496

Figure 32. Recreation opportunity spectrum (ROS) categories within sustainable recreation 

zones in alternative B-modified
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

497

Alternative B-modified, like alternative B, provides a framework to inform management 

decisions on current and future activities and visitor expectations. This is particularly important 

given that visitor use is expected to increase with potential for changing and new uses. The 

management framework under alternative B-modified would be beneficial to ensuring recreation 

opportunities and experiences on Inyo National Forest meet the demands and expectations of 

visitors and is responsive to the changing and emerging uses. 

This alternative, like alternative B, provides direction to ensure recreation opportunities provide a 

high level of visitor satisfaction and that the range of recreation activities provide social and 

economic sustainability. This would be a beneficial impact to recreation opportunities. 

Alternative B-modified is the only alternative which provides direction to manage both summer 

and winter recreation opportunity spectrum settings. A winter recreation opportunity spectrum 

map is included in appendix A of the final revised plan, which depicts the location, mix and 

distribution of setting attributes, access, and associated winter opportunities (both motorized and 

nonmotorized). Distinct seasonal changes in the recreation settings and opportunities are 

integrated with relevant multiple uses, resource values, and management objectives. Future 

planning efforts, such as for subpart C of the Travel Management Rule (over-snow vehicle travel 

designations) could further modify recreation opportunity spectrum boundaries for either 

motorized or nonmotorized winter characteristics. The addition of the winter recreation 

opportunity spectrum settings in alternative B-modified sets a basis for managing winter 

recreation opportunity spectrum settings and as a result would be a positive effect to winter 

recreation opportunities, both motorized and nonmotorized.

Under alternative B-modified, direction is provided for an integrated approach to managing 

recreation settings that have been impacted by declining ecosystem health, wildfire, and 

unsuitable uses. This would improve affected recreation settings by ensuring these settings would 

eventually be protected or restored to sustain the quality of outdoor experiences.

Under Alternative B-modified, conservation watersheds would be designated instead of critical 

aquatic refuges under the other alternatives. Conservation watersheds, although covering more 

acreage than critical aquatic refuges in alternatives A, B, C, and D, do not include any plan 

language that prohibits, or restricts recreation use or activities. Recreation direction within 

conservation watersheds specifies that any site-specific activities that occur within the 

Destination or General Recreation Areas will continue to promote the maintenance or restoration 

of the Watershed Condition Framework indicators (MA-CW-STD-01). As long as recreation uses 

within conservation watersheds continue to maintain functioning aquatic systems, recreation 

opportunities and settings would not be impacted under alternative B-modified. In the event 

recreation uses would have resource impacts on conservation watersheds, changes to the physical 

recreation setting may be necessary such as hardening a creek crossing or a necessary trail reroute, but the recreation activity would likely not become prohibited. Recreation opportunities 

such as fishing and other downstream recreation opportunities would likely be enhanced from 

watershed improvements done in conservation watersheds as the health of watersheds is 

improved.

Alternative B-modified is responsive to changing uses, new uses, and a diverse public and 

ensures management focuses on settings that enhance Inyo National Forest recreation program 

niche. This alternative would benefit recreation opportunities by ensuring that a variety a broad 

range of year-round recreation opportunities would be provided to the public and that the Inyo

has direction to respond to changing uses and new uses. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

498

Access

Under alternative B-modified, there are four recommended wilderness areas, none of which 

contain any system trails that allow bicycle use; therefore, there would be no change in miles of 

system trails that allow mechanized transport. Within the four recommended wilderness areas 

there are no existing system motor vehicle routes or open areas; therefore there would be no 

impact to the miles of motorized or nonmotorized system trails, roads, or open areas allowing 

motorized use.

Alternative B-modified seeks to increase transportation systems to connect people to nature, 

improve personal health, and increase access for underserved communities, minorities, and urban 

youth. This would be a beneficial effect to recreation access. The average number of miles per 

year of trails that meet Forest Service standards would increase to 1,100-1,300 miles under 

alternative B-modified (66 to 78 percent of the trails would meet standard) as opposed to 58 

percent of the trails meeting standard under alternative A, the current plan. This would be a 

benefit to access, since a higher percentage of trails would meet standard.

Management direction under alternative B-modified provides for motorized and nonmotorized 

trail systems that meet current demands and uses; as well as managing conflicting uses, which 

would be a beneficial impact to management of trails as compared to the existing plan. This 

alternative also emphasizes trail connectivity, linkages to local communities, and access to 

destinations, which is a beneficial impact to trails, and social and economic stability. 

Proposed wilderness recommended additions under B-modified would not reduce motorized or 

mechanized (mountain bikes) access to the national forest or adjacent lands since there are no 

motorized routes or mechanized routes proposed for closure due to the recommended wilderness 

additions or eligible wild and scenic rivers in alternative B-modified. Management of the Pacific 

Crest Trail under this alternative would not affect any existing mechanized or motorized access 

routes.

Under alternative B-modified access, opportunities for pack stock would not be affected. There 

are two existing horse camps on the Inyo National Forest, both of which are outside of wilderness 

areas and would not be negatively impacted. Furthermore, wilderness designation generally 

allows customary nonmotorized and nonmechanized use which usually includes use of pack and 

saddle stock. This would not change under alternative B-modified (or any of the alternatives), 

thus a sustainable level of pack and saddle stock access would continue to be retained.

The key difference between B-modified and the other alternatives in terms of user access is that 

alternative B-modified uses the zone management approach, which offers a different focus on 

roads and trails across the different recreation zones and assigned recreation opportunity spectrum 

settings. This allows the Inyo to place a management emphasis on managing road and trail 

systems, particularly in the Destination Recreation Areas, which will provide roads and trails for 

relatively easy access for users. This management framework would be beneficial to management 

of trails because it would allow the Inyo staff to focus more on ensuring trails within those areas 

would be maintained to standard. Within the General Recreation Areas, recreation opportunities 

have room to expand, therefore new trails could be built to provide additional opportunities 

resulting in a beneficial impact to access. 

Alternative B-modified provides a framework to adequately manage motorized and nonmotorized 

trails into the future given that budgets are expected to decline. Alternative B-modified places an 

emphasis upon volunteers and partnerships to help manage trails with less federally appropriate 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

499

funds available. Under this alternative, 75 percent of the national forest designated trail system 

would be maintained to standard and 25 percent of the deferred maintenance on trails would be 

addressed through partnerships. This would be a beneficial impact to public access to motorized 

and nonmotorized trails. 

With the restoration activities that would occur under alternative B-modified (along with 

alternatives B, C, and D) there is potential for negligible short-term negative effects to recreation 

access if roads or trails are closed during restoration activities. In general, restoration activities 

would have beneficial impacts to access in the long term because as ecosystems are restored over 

time, it would be less likely that roads and trails would be closed due to catastrophic wildfires or 

hazardous conditions along roads and trails from tree mortality or fires. 

Facilities and Level of Development

Alternative B-modified provides direction to manage recreation facilities and ensure they are 

place based, integrated, and responsive to changes that may limit or alter access. This integrated 

approach provides for facilities to meet user demands while ensuring resources are protected. 

This would benefit developed recreation because it allows for redesigning, restoring, or 

rehabilitating recreation sites where recreation activities have caused unacceptable natural or 

cultural resource damage. One of the trade-offs in this alternative when compared with alternative 

A is that it provides the framework to restore recreation facilities that are underutilized or causing 

resource damage, but ultimately this would benefit developed recreation because it allows the 

Inyo staff to focus managing only recreation sites that are needed while protecting resources. This 

would help meet desired conditions and ensure that recreation facilities are maintained to desired 

conditions.

Under alternative B-modified there is a large focus on partnerships and community stewardship 

to help the Inyo operate and maintain recreation facilities with opportunities such as the 

establishment of “adopt a facility” programs as an example.

Under alternative B-modified, the zoned management approach provides direction on the 

management of recreation facilities across the different zones and settings. This is the only 

alternative that provides the framework to ensure recreation development fits within the three 

zones and recreation opportunity spectrum settings. This would be a benefit to recreation facilities 

and the level of development because it provides direction on when and where additional 

development is appropriate across the zones and recreation opportunity spectrum settings, as long 

as partnerships are available to assist with the management and maintenance of any new 

infrastructure. This alternative would allow the Inyo staff to focus management on the High 

Density Recreation zones where there are the highest number of visitors, and where the greatest 

user demand for highly developed facilities. The General Recreation Areas would be where the 

Inyo could also consider additional facilities to provide access to dispersed recreational activities. 

Visitor Use

Recreation use patterns, amount, and types vary across a landscape and change with time. 

Alternative B-modified recognizes visitor use and demand will continue to increase, making 

appropriate, adaptive management a critical component to achieving sustainable recreation. This 

alternative also provides a framework to adapt to changing uses and new uses that may emerge.

Alternative B-modified acknowledges that tradeoffs may be necessary to ensure resources are 

managed sustainably, but overall, this management approach would be beneficial to ensuring 

visitor use is adequately managed, resources are protected, and visitors have a quality recreation 

experience. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

500

Partnerships and volunteer opportunities are considered necessary to continue to meet visitor 

needs. Recreation uses would be managed adaptively to prevent impacts to other resources and 

recreation settings. Plan components emphasize partnership opportunities to provide stewardship 

and interpretive services that educate forest visitors, enhance responsible behaviors, and improve 

etiquette. Alternative B-modified recognizes that user conflicts exist and that expanding 

recreation activities creates more opportunities for visitors, but also more opportunities for 

conflict. Plan components direct the Inyo to seek collaborative input on sustainable recreation 

opportunities to address potential conflicts between activities and any resource impacts that may 

be of concern. This approach to management would be beneficial, because it would likely help 

ensure the visitor expectations are met by reducing conflicts. 

Alternative B-modified provides direction to encourage recreation special use permits such as 

recreation special events or guided activities when they are consistent with recreation zones and 

settings, protect natural and cultural resources, and contribute to the economic sustainability of 

local communities. This would be a beneficial consequence to visitor experiences, as it provides 

more recreation opportunities for visitors to have quality outdoor experiences within the 

appropriate zone or setting. The trade-off is that some recreation special uses may not be 

appropriate for allowing under this alternative if the use doesn’t fit within the goals and settings 

for that zone.

The recreation zone approach under alternative B-modified provides the Inyo flexibility to 

manage activities differently from one location to another and to manage uses over time. This 

approach focuses management where it is most intensely needed, as well as the ability to manage 

recreation differently from one place to another, based on resource needs. In the General 

Recreation Zones and Challenging, Backroad Recreation Areas, it ensures visitor expectations for 

a more challenging and remote experience are met. This management approach would be 

beneficial to visitor experiences as it ensures visitor expectations are in line with settings across 

the different zones. 

Alternative B-modified contains direction specific to the challenges of managing intensive 

recreation developments within the natural setting of the national forest, particularly those that are 

highly popular and iconic. These areas receive high levels of visitation and have a focus on 

managing high use levels and the accompanying support facilities. Overall this would be a 

beneficial impact to providing quality visitor experiences. Tradeoffs may include implementing 

management actions such as setting capacity limits or setting more management controls within 

the Destination Recreation Zones.

Alternative B-modified provides direction that protects the environment and cultural resources 

and manages for natural settings while still accommodating recreation use. It also directs the Inyo

to manage recreation uses adaptively to prevent impacts to other resources and also speak to 

restrictions and restoration when negative impacts occur from recreation. The recreation zone 

approach provides the flexibility to be responsive to resource needs from one location to another. 

For example, destination recreation areas are high-use areas that would be managed more 

intensively in this alternative. Resource impacts would be concentrated and limited to hardened 

sites and conservation education and interpretation programs would focus on developing a land 

ethic as part of the recreation experience in these areas. Low-use density recreation areas would 

be focused on resource conservation.

Direction under alternative B-modified would be the most responsive out of all the alternatives at 

addressing resource impacts from a variety of recreation uses such as trail impacts from mountain 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

501

bike use, off-highway vehicle use, equestrian use, and foot traffic. This alternative provides an 

adaptive approach that would help protect resources from impacts that may occur from increased 

use or inappropriate user behaviors. There is plan direction within the final revised plan that 

addresses recreational use impacts, such as impacts from trampling in riparian conservation areas 

(MA-RCA-STD-07 and -08). 

Consequences Specific to Alternative C

Recreation Settings and Opportunities

Environmental consequences to recreation settings in alternative C are similar to alternative B 

except for the following.

Recreation opportunities under alternative C shift to larger areas of primitive and semi-primitive 

nonmotorized settings due to the recommendation of additional wilderness areas. Under this 

alternative, the largest recreation opportunity spectrum class on would be primitive at 67 percent,

followed by semi-primitive motorized (13 percent), and then by roaded natural (11 percent). 

When the two nonmotorized settings are combined, this alternative would result in 72 percent of 

the Inyo in a nonmotorized setting. Combining the motorized setting, this alternative would 

provide a motorized setting on 27 percent of the national forest. The amount of nonmotorized

setting in this alternative would be the highest of all alternatives. Conversely, the amount of 

motorized setting in this alternative would be the lowest of all alternatives.

The change in recreation opportunity spectrum settings in alternative C is due largely to the 

increase in recommended wilderness in this alternative over alternatives A, B, and B-modified, 

and D; which would increase nonmotorized settings to 72 percent under alternative C. This would 

be a beneficial consequence to nonmotorized opportunities because there would be an increase in 

wilderness-based opportunities that provide quiet solitude in a remote setting, and reduce 

probabilities of seeing or hearing motorized vehicles and other people in remote and 

predominately unmodified landscapes.

Motorized settings would decrease to 27 percent of the national forest under alternative C,

providing less opportunity in settings that are more developed and in roaded areas that allow 

motorized activities. This would be a negative effect to the amount of acres of motorized 

opportunities provided, but this effect is considered somewhat negligible since no motorized 

routes would be impacted as a result of this alternative. 

Under alternative C, 25 critical aquatic refuges would be designated instead of conservation 

watersheds developed under B-modified. Alternative C has a higher number of critical aquatic 

refuges compared to alternatives A, B, and D. Critical aquatic refuges are intended to provide 

protection to aquatic species; however, they are not intended to prohibit recreation uses. In the 

event recreation uses would have negative impacts on critical aquatic refuges, changes to the 

physical recreation setting may be necessary such as hardening a creek crossing or a necessary 

trail re-route, but the recreation activity would likely not become prohibited.

Access

Environmental consequences to access under alternative C are similar to alternative B except for 

the following.

Alternative C has the greatest impact on mechanized access (mountain bikes) out of all the 

alternatives because of the additional recommended wilderness areas. There are six recommended 

wilderness areas in this alternative that contain 43 miles of system trails which currently allow 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

502

mountain bike use. A plan component (MA-WILD-SUIT-04) makes mechanized transport 

unsuitable in recommended wilderness areas; therefore, trail access by mountain bikes would be 

decreased by 43 miles on system trails, which is a 9 percent reduction in nonmotorized trails open 

to mountain bikes compared to A, B, B-modified, and D. Given the topography and sandy soils of 

where these trails are located, only a minor impact to mechanized access would be expected 

under this alternative. 

If site-specific decisions were made to prohibit mountain bike use on these trails within the 

recommend wilderness areas, mountain bike access on system trails could decrease by 43 miles 

within recommended wilderness areas and mechanized transport would be allowed on 432 miles 

of nonmotorized system trails across the entire Inyo National Forest. A site-specific decision to 

close trails within recommended wilderness areas would need to be completed before an 

enforceable closure could be made to prohibit bicycle use. The trails would allow for mechanized 

use until a project-level decision was completed.

Facilities and Level of Development

Environmental consequences to facilities and development would be the same as alternative B.

Visitor Use

Environmental consequences to visitor use in alternative C is the same as alternative B. 

Consequences Specific to Alternative D

Recreation Settings and Opportunities

Environmental consequences to recreation settings and opportunities in alternative D would be

the same as alternative B except for the following.

In alternative D, the largest recreation opportunity spectrum class would be primitive at 55 

percent of the Inyo National Forest, followed by semi-primitive motorized (18 percent), and then 

by roaded natural and semi-primitive nonmotorized (both 12 percent). When the two 

nonmotorized settings are combined, this alternative would result in 67 percent of the Inyo in a 

nonmotorized setting. Combining the motorized settings, this alternative would provide a 

motorized setting on 33 percent of the national forest. The amount of nonmotorized setting in this 

alternative would be higher alternatives A, B, and B-modified, but less than alternative C. 

Conversely, the amount of motorized setting in this alternative would be the same as alternatives

B and B-modified, but higher than alternative C (see table 78 on page 488).

The primary difference in management of recreation settings between alternative D and the other 

alternatives is the slight change of recreation opportunity spectrum classes (primarily primitive 

and semi-primitive nonmotorized) based on the fact that there are no recommended wilderness 

areas in this alternative. However, despite the fact that there are no recommended wilderness 

areas, this alternative would provide the highest percentage of nonmotorized recreation 

opportunity spectrum settings resulting in a beneficial impact to nonmotorized recreation 

opportunities. 

Access

Environmental consequences to recreation access in alternative D would be the same as 

alternative B.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

503

Facilities and Level of Development

Environmental consequences to facilities and level of development in alternative D would be the 

same as alternative B except for the following.

This alternative provides the greatest benefit to protecting recreation facilities and infrastructure 

from catastrophic fires and tree mortality because of the direction it provides for the increased 

pace and scale of restoration and fuels treatments.

Visitor Use

Environmental consequences to visitor use in alternative D is the same as alternative B.

Cumulative Effects

Cumulative effects to sustainable recreation considered in this section are through the next 

planning period (estimated at 10 to 15 years).

Since it is assumed that population growth will increase recreation demands and visitation will 

continue to increase, there will be increasing demands on recreation that could result in higher 

concentrations of use at existing recreation areas and increased conflicts. This includes increasing 

demands on adjacent county lands. This could have negative cumulative impacts on the quality of 

recreation settings, including impacts to nearby county lands. All plan revision alternatives

include direction that is responsive to increasing recreation demands, but alternative B-modified 

would be the most responsive to meeting recreation demands and ensuring the quality of 

recreation settings is retained and resources are protected across the different recreation zones. 

Continuing changes in equipment technology used for recreational purposes on the Inyo National 

Forest may have effects on recreation opportunities and access, as new or existing uses may 

change the way visitors access the national forest or where they recreate. These changes in uses 

may alter the recreational experiences in some areas if uses are not compatible with one another 

or new uses create a sense of crowding where it is not expected. Changes to access and settings 

has the greatest potential to cumulatively impact the nonmotorized recreation opportunity 

settings, such as hiking or back-country skiing, where many visitors seek remote settings. 

Although all plan revision alternatives have some direction to respond to changing uses, 

alternative B-modified would be the most responsive to retaining the quality of recreation settings 

due to the adaptive manner in which this alternative responds to changing uses across the 

recreation zones. 

Recreation in and surrounding the national forest, national parks as well as state and local lands 

does not follow administrative boundaries, and therefore changes in management of recreation on 

all of these lands together affects recreation use that would occur on the Inyo as well as adjacent

lands. These cumulative changes may positively impact recreation settings and access, or they 

also have the potential to negatively impact settings and access if changes are not managed 

properly. Since the Eastern Sierra continues to have ever increasing visitation across all land 

jurisdictions, higher visitation could lead to increased resource impacts and crime, if use is not 

managed across all lands. Alternative B-modified provides the most adequate direction to adapt to 

changes that would have the potential to impact National Forest lands as well as adjacent lands.

Lands that were designated by Congress as wilderness in 2009 had no recreational facilities and 

little to no motorized route access, so there was minimal effect on access as a result of recent 

wilderness designations. The 2005 Travel Management rule, subpart B, required the Forest 

Service to designate roads, trails, and areas open to motor vehicle use. Designations were made 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

504

by class of vehicle and, if appropriate, by time of year. The final rule prohibited the use of motor 

vehicles off the designated system, as well as use of motor vehicles on routes and in areas that is 

not consistent with the designations.

38 The Travel Management rule resulted in a reduction in the 

amount of motorized opportunities on National Forest System lands on the Inyo National Forest. 

The 2009 Travel Management Record of Decision on the Inyo National Forest designated more 

than 800 miles of routes that were previously not system roads, as maintenance level 2 roads, and 

approximately 157 miles of previously unauthorized motorized trails were added to the Forest 

Transportation System (USDA Forest Service 2009a). However, none of the plan revision 

alternatives in this planning effort affect any authorized system motorized routes; therefore, past 

wilderness designations in combination with proposed recommended wilderness in alternatives B, 

B-modified, and C would have minimal cumulative effects on motorized access, either on 

national forest lands or adjacent lands. 

Since climate change is predicted to produce warmer temperatures and drier conditions 

influencing snowpack, drought, and hydrologic flow, activities dependent on snow and snow melt 

would be affected. Warmer temperatures could cause recreationists to shift their activities to 

higher elevations during the summer months (Morris and Walls 2009).These changes resulting 

from climate change could have the potential to alter the timing of summer recreational 

opportunities such as causing fishing opportunities to occur earlier and for a shorter season. This 

could also shift the timing of motorized and nonmotorized summer activities to occur earlier and 

for a longer season. Alternative D would provide direction for increased management activities to 

protect the physical settings where recreation activities occur; however, alternative B-modified 

provides the most effective management direction to be responsive to changes in recreation 

settings due to climate change. Alternatives B and C would provide adequate management 

direction that would be responsive to cumulative impacts from climate change. 

Analytical Conclusions

Table 80 below provides a relative comparison of how the alternatives respond to indicators. 

Comparison of recreation opportunity spectrum for the nonmotorized setting. Alternative A 

has the lowest amount of nonmotorized setting, but this is partly due to the recreation opportunity 

spectrum not being formally assigned to acquired lands. Alternatives B, B-modified, and D would 

have an increased motorized setting compared to alternative A, but less than alternative C. 

Alternative C would have the highest amount of nonmotorized setting due to the recommended 

wilderness areas and would be the most beneficial to the nonmotorized recreation setting. 

Alternative A would be the least beneficial to the nonmotorized recreation opportunity setting.

Comparison of motorized recreation opportunity spectrum setting. Alternative C has the 

lowest amount of motorized recreation opportunity setting with alternative A having the second 

lowest amount of motorized recreation opportunity spectrum setting. Alternatives B, B-modified, 

and D would have the highest amount of motorized setting with alternative D having slightly 

more due to not having any recommended wilderness areas. Alternative D would be the most 

beneficial impacts to the motorized recreation opportunity setting, but it is only slightly higher 

than alternatives B and B-modified.

 38 36 CFR 212; Code of Federal Regulations, Title 36: Parks, Forests, and Public Property, Part 212: Travel 

Management
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

505

Change in miles of mechanized transport (mountain bike use). Alternative C has the biggest 

change in miles of mechanized transport due to the additional recommended wilderness areas 

with a decrease in 43 miles of trails available to mountain bikes. Alternative A has no change to 

the number of miles available to mechanized transport, and even though both alternatives B and 

B-modified have recommended wilderness, there is no change to the number of miles of trails 

available for mechanized transport. Alternative C would be the least beneficial at providing for 

mountain bike opportunities.

Change in miles of motorized routes. Proposed wilderness recommended additions under Bmodified would not reduce access to the national forest or adjacent lands since there are no 

motorized routes proposed for closure due to the recommended wilderness additions or eligible 

wild and scenic rivers in alternatives B-modified, B, or C. 

Effectively manages recreation development to respond to recreation demand and uses. 

Alternative A does not adequately manage recreation development because it does not recognize 

there will be new and changing uses; it also is not an adaptive and integrated approach that 

protects sensitive resources. Alternatives B, C, and D are only somewhat effective at managing 

recreation development because they do not provide integrated and adaptive direction for 

managing and operating sustainable recreation facilities in a changing environment while 

ensuring resources are protected. Alternative B-modified is the most beneficial to managing 

recreation development because it recognizes there will be new and changing uses and uses an 

adaptive and integrated approach to designing and managing recreation infrastructure.

Table 80. Comparison of indicators by alternatives

Indicator Alternative A

Alternative 

B

Alternative BmodifiedAlternative 

C

Alternative 

D

Comparison of 

amount of 

nonmotorized

recreation opportunity 

spectrum setting

Lowest 

amount

Moderate 

amount

Moderate 

amount

Highest 

amount 

Moderate 

amount

Comparison of 

motorized recreation 

opportunity spectrum 

setting

Second 

highest 

amount

Highest 

amount 

along with 

alternatives 

B-modified 

and D

Highest 

amount along 

with 

alternatives B

and D

Lowest 

amount 

Highest 

amount 

along with 

alternatives

B and Bmodified

Change in miles of 

mechanized transport 

(mountain bike)

No change No change No change Decrease of 

43 miles

No change

Effectively manages 

recreation 

development to 

respond to recreation 

demand and uses

Not adequate Somewhat Yes Somewhat Somewhat

Alternative A neither adequately manages recreation opportunities and settings in a changing 

environment nor provides a range of year-round developed and dispersed recreation settings that 

offer a variety of experiences. This would have negative impacts to ensuring quality summer and 

winter recreation opportunity spectrum settings are provided. There is also a lack of direction

overall for access, facilities and development, and visitor use, because current direction does not 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

506

recognize new and changing uses, nor is it an adaptive and integrated approach that protects 

sensitive resources. Its approach to managing visitor use is more concentrated and emphasizes 

improving recreation opportunities by focusing on recreation sites rather than managing visitor 

use. This alternative would be the least beneficial of all alternatives to recreation settings and 

opportunities, access, recreation facilities, and visitor use because of the lack of direction to

adaptively managing recreation resources in a changing environment with changing uses and 

increased demands on recreation.

Alternative B provides direction that informs management decisions on current and future 

activities and visitor expectations that is not present under the existing plan, but it is not 

integrated and adaptive to respond to changing uses, environmental conditions, and demands. 

Like all plan revision alternatives, alternative B provides direction on using partnerships to help 

manage facilities, wilderness, and trails which is a benefit to managing these resources to desired 

conditions. However, overall, this alternative would result in less benefits to recreation settings 

and opportunities, access, facilities, and visitor use than alternative B-modified because it lacks 

an adaptive management approach across the different recreation zones in the face of changing 

demands and uses placed upon recreation resources. This alternative also only provides direction 

for managing summer recreation settings; which could negatively impact the quality of winter 

recreation opportunity spectrum settings.

Alternative B-modified provides management direction that is adaptive and responds to changes 

in both environmental conditions, uses, and visitor demands; utilizing partnerships and volunteers 

to help manage trails, facilities, and wilderness. It also provides direction to manage both summer 

and winter recreation opportunity spectrum settings. This alternative would be the most beneficial 

to recreation settings and opportunities, access, visitor use, and recreation development because 

of its adaptive management approach across the three different recreation zones and recreation 

opportunity spectrum settings, and recognition of changing demands and uses placed upon 

recreation settings, facilities and access. Alternative B-modified also strikes a balance between 

providing for restoration treatments, while still providing for areas recommended for wilderness 

designation. Alternative B-modified provides management direction that would result in the 

greatest overall benefit to recreation resources, while ensuring resource protection in a changing 

environment with increasing recreation demands.

Alternative C would result in the greatest benefit to nonmotorized recreation opportunities that 

provide quiet solitude in a remote setting because of the additional recommended wilderness 

areas. Conversely, this alternative would also result in the greatest negative impacts to motorized 

recreation settings because of the reduction in acres of motorized settings. Alternative C would 

also have the greatest negative impact on mechanized access (mountain bikes) out of all the 

alternatives because of the additional recommended wilderness areas. In all other aspects of 

recreation settings and opportunities, access, recreation facilities, and visitor use, alternative C 

would result in similar benefits as alternatives B and D to recreation settings and opportunities, 

access, facilities, and visitor use as because it also lacks an adaptive management approach in the 

face of changing demands and uses placed upon recreation resources.

Alternative D would have the greatest benefit to protecting recreation facilities and development 

from catastrophic fires and tree mortality because of the direction it provides for the increased 

pace and scale of restoration and fuels treatments. In other aspects of recreation settings and 

opportunities, access, recreation facilities, and visitor use, alternative C would result in similar 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

507

benefits as alternatives B and C because it also lacks an adaptive management approach in the 

face of changing demands and uses placed upon recreation resources.

Scenery

Analysis and Methods

Indicators and Measures

• Acres and kind of fuel treatment to reach the desired vegetation condition that reflects the 

natural range of variation which leads to scenic stability and relative protection of scenic 

character.

• Percentage of scenic integrity objectives on each forest by scenic integrity objectives.

Methods

For comparative purposes, we mapped the desired scenic integrity objectives for alternatives B, 

B-modified, C, and D. The geographic information system was used to calculate the number of 

acres in each scenic integrity objective class. For scenic stability, we compared the amount and 

kind of fuel treatment needed to reach the desired vegetation condition that reflects the natural 

range of variation (which leads to scenic stability).

Assumptions

In the analysis for this resource, we made the following assumptions:

• Scenic integrity is maintained in places people visit and view.

• Restoration treatment of fuels (prescribed fire, mechanical treatment, wildfires managed to 

meet resource objectives) that moves vegetative condition toward the natural range of 

variation has a long-term positive effect to scenic stability ultimately sustaining scenic 

character, even though some short-term impacts of scenic character may occur. Mechanical 

treatment of fuels moves vegetative condition toward the natural range of variation faster 

than prescribed fire or management of wildfires to meet resource objectives and can better 

manage short-term impacts to scenic character. However, when combined, mechanical and 

fire restoration activities can move vegetation conditions towards the natural range of 

variation at a faster rate than either treatment type alone.

• Climate change may increase the frequency of large high-intensity wildfires or areas with 

high levels of insect or disease tree mortality that most likely would impact scenic 

character.

Affected Environment

The scenic character of the Inyo National Forest is diverse and is representative of the three major 

biological provinces within this area: the Sierra Nevada, the Great Basin, and the Mojave Desert. 

With elevations ranging from 3,800 to 14,495 feet, this shapes the scenic character of this area. 

The topographic relief is extreme, and 10,000 foot vertical gradients are found in the Sierra 

Nevada, White and Inyo Mountains. Opportunities for scenic overlooks are found throughout the 

area and allow visitors to experience the large expanses of undeveloped land; rare geologic 

formations like the Mono Craters and Obsidian Dome; wilderness areas such as the Ansel Adams 

and John Muir Wildernesses; and diverse ecosystems from alpine, mixed-conifer, Jeffrey pine, 

sagebrush steppe, to desert. Some of the most outstanding visual attractions include Mono Lake 

with geologic formations like tufa, and Mount Whitney, the highest peak in the continental United 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

508

States at 14,494 feet in elevation. These are areas where visitors are expected to have a high 

concern for scenic values and changes to scenery.

The most common developments on the Inyo National Forest that alter scenic integrity include 

powerlines, communication sites, substations, propane tanks, geothermal development, ski areas, 

hydropower facilities, reservoirs, recreation facilities, resorts, and temporary conditions like dust 

and smoke.

On the Inyo, many of the valued vegetation scenery attributes are at high risk of being impaired 

or seriously threatened due to dense vegetation conditions, ecosystem stressors such as insect and 

disease outbreaks, and fire return interval conditions that render landscapes susceptible to severe 

wildfire (see “Terrestrial Vegetation Ecology” and “Fire Trends” sections). Forest landscapes 

characterized by these conditions are considered to have low scenic stability. The majority of the 

landscapes on the Inyo includes wilderness areas and areas have high to very high scenic integrity

and can be found adjacent to developed areas, such as the Town of Mammoth Lakes.

Scenery Resources

Scenic integrity plays a key role in sustainable recreation by contributing to the identity and sense 

of place of an area. The scenery of each national forest is a significant attraction to residents and 

visitors alike, creating a sense of place and a connection to the land. The magnificent vistas, 

meandering rivers, and forested settings are often featured by state and local tourism and 

marketing efforts which contributes to the economic and social sustainability of local 

communities. The scenic character of a national forest is a combination of physical, biological, 

and cultural images that give an area a visual and cultural identity. Scenic character provides a 

frame of reference from which to determine scenic attractiveness and to measure scenic integrity.

To evaluate scenery resources, the current forest plan used the Visual Management System, which 

was a systematic approach to inventory, analyze, and monitor scenic resources, but did not 

recognize or incorporate natural disturbance processes such as fire, insects, and disease. The 

Forest Service has been transitioning from the Visual Management System to the newer Scenery 

Management System, which uses different scenery evaluation terminology. A cross-walk between 

the two systems terminology is shown in table 81.

Table 81. Cross-walk between visual management system and scenery 

management system terminology

Visual Management System 

Terminology

(Visual Quality Objectives)

Scenery Management System 

Terminology

(Scenic Integrity Objectives)

Preservation Very High

Retention High

Partial retention Moderate

Modification Low

Maximum modification Very Low

Scenic Character

Scenic character is defined as the combination of the physical, biological, and cultural images that 

give an area its scenic identity and contribute to its sense of place. Scenic character provides a 

frame of reference from which to determine scenic attractiveness and to measure scenic integrity. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

509

All landscapes have definable scenic character attributes. In most national forest settings, scenic 

character attributes are positive natural elements such as landform, vegetative patterns, and water 

characteristics. In pastoral or rural settings, positive cultural elements may include historic 

elements such as split rail fences, stone walls, barns, orchards, hedgerows, and cabins. In urban 

settings, scenic character attributes may include a fabric of architectural styles. A combination of 

these attributes define scenic character. The concept of scenic character is embodied in the “image 

of an area.”

Descriptions of different types of scenic character include:

• Naturally Evolving – Scenic character expressing the natural evolution of biophysical 

features and processes, with very limited human intervention. These landscapes are largely 

associated with wilderness areas.

• Natural Appearing – Scenic character that expresses predominantly natural evolution, but 

also human intervention including cultural features and processes. 

• Cultural – Scenic character expressing built structures and landscape features that display 

the dominant attitudes and beliefs of specific human cultures. These landscapes are largely 

associated with areas containing recreation site development, administrative sites, or public 

uses under special use permits.

• Pastoral – Scenic character expressing dominant human-created pastures, meadows and 

associated structures, reflecting valued historic land uses and lifestyles. Pastoral lands also 

occur on private lands outside of the national forest administrative boundary, where they 

may be viewed while traveling on forest roads or trails.

• Agricultural – Scenic character expressing dominant human agricultural lands uses 

producing food crops and domestic products. These landscapes generally occur on private 

lands that are outside of the National Forest System administrative boundary, but may be 

visible while traveling on national forest roads or trails.

• Historic – Scenic character expressing valued historic features that represent events and 

period of human activity in the landscape. 

• Urban – Scenic character expressing concentrations of human activity, primarily of 

commercial, cultural, education, residential, transportation structures, and supporting 

infrastructure. These landscapes generally occur on private lands, but may be visible while 

visiting a national forest.

Scenic Integrity

Scenic integrity measures the degree to which a landscape is free from visible disturbances that 

detract from the natural or socially valued appearance, including any visible disturbances from 

human activities or extreme natural events outside of the natural range of variation. Scenic 

integrity measures these disturbance effects in degrees of consistency, harmony, dominance and 

contrast with the valued scenic character.

Scenic integrity uses a graduated scale of five levels ranging from very high integrity to low 

integrity. It is emphasized within view of travelways, use areas, and special places. These levels 

include:

• Very High Integrity – The valued scenery appears natural or unaltered. Only minute visual 

disturbances to the valued scenery, if any, are present.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

510

• High Integrity – The valued scenery appears natural or unaltered, yet visual disturbances 

are present; however, they remain unnoticed because they repeat the form, line, color, 

texture, pattern and scale of the valued scenery

• Moderate Integrity – The valued scenery appears slightly altered. Noticeable disturbances 

are minor and visually subordinate to the valued scenery because they repeat its form, line, 

color, texture, pattern and scale. 

• Low Integrity – The valued scenery appears moderately altered. Visual disturbances are 

co-dominant with the valued scenery, and may create a focal point of moderate contrast. 

Disturbances may reflect, introduce or “borrow” valued scenery attributes from outside the 

landscape being viewed. 

• Very Low Integrity – The valued scenery appears heavily altered. Disturbances dominate 

the valued scenery being viewed; and they may only slightly borrow from, or reflect, 

valued scenery attributes within or beyond the viewed landscape.

Many of the landscapes that include wilderness areas and areas within the primitive nonmotorized 

and semi-primitive nonmotorized recreation opportunity spectrum classes have high to very high 

scenic integrity. Common developments that alter scenic integrity include but are not limited to 

powerlines, communication sites, substations, propane tanks, geothermal developments, ski areas, 

hydropower facilities, reservoirs, recreation facilities, resorts, and temporary conditions like dust 

and smoke.

Scenic integrity objectives are developed in coordination with recreational settings, management 

direction and scenic classes. Scenic classes represent the relative landscape value by combining 

visibility mapping inventories and scenic attractiveness inventories. Generally, scenic classes 1 

and 2 have high public value; classes 3, 4, and 5 have moderate value; and classes 6 and 7 have 

low value.

Scenic Stability

Scenic stability measures the degree to which the scenic character and its scenery attributes can 

be sustained through time and ecological progression. In other words, it looks at the ecological 

sustainability of the valued scenic character and its scenery attributes. Because attributes such as 

rock outcroppings and landforms change relatively little over time, scenic stability focuses on the 

dominant vegetation scenery attributes. Scenic stability recognizes major changes to the 

landscape that are outside of the natural range of variation, such as large wildfires and land 

clearing for developments, but it also includes subtle, incremental changes that can severely 

diminish or eliminate scenic character.

The natural range of variation can be used to assess the scenic stability of forest landscapes. This 

can be measured in terms of the landscape’s departure from the natural range of variation. 

Insufficient fire or too much fire on the landscape can determine the level of departure from the 

natural range of variation. Departures in fire regime, insect outbreaks, and other disturbances 

from the natural range of variation help assess scenic stability.

Environmental Consequences to Scenery Resources

Alternatives B, B-modified, C, and D would add specific plan components relevant to scenery in 

the form of desired conditions, objectives and guidelines. All alternatives would help move 

vegetation conditions toward the natural range of variation but the amount and scheduling of 

restoration to move toward the natural range of variation would vary between alternatives. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

511

Mechanical treatments for restoration may have short-term impacts to scenic integrity compared 

to hand treatments or prescribed fire, but over the long term, scenic character would benefit 

through increased scenic stability. There would be short-term scenic integrity losses with fire, but 

long-term potential increases in scenic integrity, especially with the reestablishment of the role of 

fire on the landscape. High-severity fires could cause a short-term change in scenic character and 

recreational value due to the fact that vegetation plays a major role in establishing and 

maintaining scenic character and sense of place in national forest recreation settings. Recreation 

settings with ecologically sound landscapes possessing diverse attributes, particularly vegetation 

with a composition containing a variety of species, area distribution and canopy height, have the 

greatest potential for high scenic value and maintaining a sense of place. High-severity fire, while 

providing benefits to other resources, can have a negative effect on scenic character if the result 

reduces the heterogeneity of the vegetation type, distribution and structural composition.

Scenic Stability and Character

Embedded within the restoration treatment discussed for each alternative is the objective SCENFW-OBJ-01, which focuses some fuel treatment restoration activities on recreation sites that are 

in areas with a high risk of large, high-intensity wildfire. This plan component helps focus 

restoration treatment at high-risk recreation sites to become more resilient to large, high-intensity 

fires, thus increasing scenic stability.

High-severity fire causes a short-term change in scenic character and recreational value due to the 

fact that vegetation plays a major role in establishing and maintaining scenic character and sense 

of place in national forest recreation settings. Recreation settings with ecologically sound 

landscapes possessing diverse attributes, particularly vegetation with a composition containing a 

variety of species, area distribution and canopy height, have the greatest potential for high scenic 

value and maintaining a sense of place. High-severity fire, while providing benefits to other 

resources, can have a negative effect on scenic character if the result reduces the heterogeneity of 

the vegetation type, distribution and structural composition. Scenic integrity and character would 

be at the greatest risk to impacts from high-severity fires under alternative A, followed by 

alternative C. Alternatives B, B-modified, and D provide the greatest potential to protect scenic 

integrity and character from high-severity fires, with D being the highest. 

Consequences Specific to Alternative A

Under the existing plan, this alternative would increase scenic stability across the Inyo National 

Forest, which in turn improves scenic character; however it would be less than alternatives B, Bmodified, C, and D. Despite some short-term impacts to scenic character, mechanical treatment 

achieves the natural range of variation quicker and with more precision, lessening the short-term 

visual impacts of treatment compared to prescribed fire or wildfire managed to meet resource 

objectives. This alternative has slightly less mechanical treatment than alternatives B, Bmodified, and D but slightly more than alternative C. This alternative would trend vegetation 

toward achieving the natural range of variation but at a substantially slower rate than alternatives 

B, B-modified, C, and D, thus providing the lowest protection for scenic character.

Consequences Specific to Alternative B

Restoration of vegetation would occur within the montane and sagebrush systems, with the 

emphasis of returning these landscapes to the natural range of variation and to reduce fuels 

around communities and other infrastructure. These ecosystems are found within areas that have 

moderate to very high scenic integrity. Restoration in these areas would include slightly more 

mechanical treatments than alternative A, similar to alternative B-modified, more than alternative 

C, and just slightly less than alternative D. Prescribed fire would also be used in these areas, at a 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

512

level similar to alternatives B-modified and D (estimated range overlaps completely with

alternative C). Wildfires managed to meet resource objectives would also be used at a higher rate 

under this alternative than alternatives A and C, slightly lower than alternative B-modified, and 

approximately half the rate of alternative D. This activity would occur in the very high scenic 

integrity areas located in wilderness and would increase scenic stability by lessening the 

consequences of large high-intensity wildfire. 

This alternative would help trend vegetation toward achieving the natural range of variation 

which would increase scenic stability across the landscape, and improve scenic character more 

than alternatives A and C, and less than alternative D. 

Consequences Specific to Alternative B-modified

Consequences to scenic stability and character would be the same as in alternative B, above.

Consequences Specific to Alternative C

Under this alternative there are more acres of potentially recommended wilderness, which would 

increase the amount of scenic integrity in the very high and high classes. However, within these 

areas, management direction would be for managed wildfire to meet resource objectives, which 

would have a slower rate of the vegetation returning to the natural range of variability. The area 

may also be at risk from wildfires that burn outside of the natural range of variation or have 

impacts from insects and disease which may affect scenery stability over larger areas of the 

landscape. This increased acreage also reduces the amount of mechanical treatments that could 

occur, as compared to alternatives A, B, B-modified, and D. Treatment rates for prescribed fire in 

alternative C are highly variable (lowest level is less than anticipated under alternative A and 

highest level exceeds all other alternatives) but broadly similar to alternatives B, B-modified, and 

D. Wildfires managed for resource objectives are substantially lower than alternatives B, Bmodified, and D, but higher than alternative A. Although this alternative would increase scenic 

stability it would be less than alternatives B, B-modified, and D. 

Consequences Specific to Alternative D

In this alternative, the objective to restore vegetation conditions to the natural range of variation 

using mechanical treatments is slightly higher than alternatives B and B-modified. This would 

increase scenic stability across the landscape, particularly within the montane and sagebrush 

systems, at a faster rate than alternatives B, B-modified, and C, which in turn would improve 

scenic character. Restoration activities also include a higher use of wildfires managed to meet 

resource objectives, which although can restore areas to the natural range of variation, would 

have greater longer-term impacts to scenic integrity and take longer to achieve scenic stability 

than alternatives B, B-modified, and C. The use of prescribed fire would be the same as 

alternatives B and B-modified, therefore restoration of scenic stability would be at the same rate 

as those alternatives using this method of treatment. 

Scenic Integrity Objectives

Future developments that have the potential to affect scenic integrity on the Inyo National Forest 

include powerline development and replacement, geothermal and alternative energy development, 

and periodic smoke and dust events. In addition, there may be potential negative short-term 

impacts to scenic integrity from fuel reduction restoration projects, especially those that are 

accomplished by mechanical means. This is primarily due to the more open vegetation on much 

of the Inyo National Forest and the greater visibility from high points. Short-term negative 

impacts would be off-set by long-term benefits where vegetation conditions are moving toward 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

513

the natural range of variation to reduce impacts to scenic character from high-intensity fires and 

increased vegetation density caused by fire suppression.

Table 82 shows the acres and percent of the Inyo National Forest for each scenic integrity 

objective by alternative. The visual quality objectives for alternative A were converted to scenic 

integrity objectives as shown in the cross-walk in table 81. Because alternative A does not include 

approximately 44,600 acres of lands that were added to the Inyo National Forest from the 

National Forest and Public Lands of Nevada Enhancement Act of 1988, caution should be used 

when comparing alternative A to the other alternatives.

The table shows that alternative C would have the highest percentage of very high scenic integrity 

objective compared to all alternatives, mainly due to the higher acreage of recommended 

wilderness and increase in the Pacific Crest Trail width in this alternative. Alternative B would 

have a slightly higher percentage of very high scenic integrity objective compared to alternative 

D, mainly due to the acreage of recommended wilderness. In alternative D, those areas would be 

managed to meet mostly high and very high desired scenic integrity objectives. Alternative A 

would have the highest amount of low scenic integrity objective of all alternatives, primarily 

because of the difference in approaches to mapping the older visual quality objectives.

Table 82. Desired scenic integrity objectives in acres and percentage of national forest by alternative

Scenic Integrity 

Objective Alternative A

Alternatives B

and B-modified Alternative C Alternative D

Very high 751,860

37 percent

1,001,596

50 percent

1,289,968

65 percent

964,564

49 percent

High 537,540

26 percent

669,697

34 percent

450,366

23 percent

701,920

35 percent

Moderate 716,375

35 percent

301,603

16 percent

237,259

12 percent

309,412

15 percent

Low 35,470

2 percent

11,661

1 percent

9,964

less than

1 percent

11,661

1 percent

Very Low* 

5

less than 

1 percent

0 0 0

* Although the maximum modification objective was used in the visual management system, the current scenery 

management system tends to not have desired objectives for very low scenic integrity. Thus, the maximum 

modification/very low objective will not be compared to alternatives B, B-modified, C, and D.

Cumulative Effects for the Inyo National Forest

Areas modified by vegetation treatments, powerlines and other infrastructure would continue to 

appear highly managed over the next 10 to 15 years in all alternatives and scenic integrity would 

remain moderate to very low in those areas. Vegetation treatments and infrastructure 

development on adjacent private, State and Federal lands may influence overall scenic integrity. 

Restoration treatments across the landscape would trend vegetation toward the natural range of 

variation and protection of the scenic character. Driving for pleasure and other scenery dependent 

activities on the Inyo National Forest could be affected slightly by human disturbance to areas 

under other administrations. Wildfire and other disturbance processes, if large in scale and 

intensity, may result in lowered scenic character in those areas affected by the disturbance.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

514

Analytical Conclusions

Change in Protection of Scenic Character based on Pace and Scale of Restoration

Alternatives B and B-modified provide the greatest protection of scenic character through the use 

of mechanical treatments, which are greater than alternatives A and C. Although alternative D has 

the greater use of mechanical treatment over these alternatives, the use of wildfires managed for 

resource benefit is greater, which may have longer-term effects to scenic integrity and take longer 

to reach scenic stability compared to alternatives B and B-modified. Alternative C would have the 

lowest amount of protection of scenic character as it would have the lowest amount of mechanical 

treatment.

Partnerships

Partnerships and volunteerism are key components of managing public lands, particularly under 

sustainable recreation, and they enable the Forest Service to forge valuable relationships that help 

to provide a means of leveraging the agency’s financial investment in recreation and management 

of other resources, while connecting people to the natural environment. It is generally through 

outdoor recreation activities, partnerships, and volunteerism that visitors interact with nature and 

experience the intrinsic values of the national forest. Since 1972, the Forest Service has brought 

in over 2.8 million volunteers, who have provided more than 123 million hours of service that is 

valued at about $1.4 billion.

Partnerships are an important component of sustainable recreation that management relies upon to 

deliver services and aid in the stewardship of the trails, recreation sites and wilderness areas, as 

well as other resources located on the Inyo National Forest. This section describes current 

partnerships on Inyo and effects to partnerships from the different alternatives. 

Analysis and Methods

The analysis area for effects to partnerships includes all lands within the boundary of the Inyo 

National Forest. The timeframe for the environmental consequences related to partnerships is the 

expected life of the forest plan, or 10 to 15 years

Indicators and Measures

Indicators and measures for this analysis consist of change in partnerships and volunteer 

opportunities.

Affected Environment

Partnerships, volunteerism, and new management strategies have played an increasing role in 

maintaining and improving developed recreation facilities and trails, and restoring and 

rehabilitating landscapes on the Inyo National Forest. Nonprofit organizations help remove 

graffiti and trash, and provide visitor information and interpretive programs along river corridors, 

popular dispersed recreation sites, and developed recreation sites. These partnerships and 

agreements are often made possible with funding from sources such as off-highway vehicle green 

sticker funds, resource advisory council grants, the Federal Lands Recreation Enhancement Act, 

stewardship councils, and other sources that supplements appropriated dollars. These partnerships 

are critical to helping the Inyo meet current and future public demands for high quality recreation 

experiences. Partnerships and volunteer programs help mitigate many of the negative impacts of 

unmanaged recreation and improve the Inyo’s ability to deliver high-quality sustainable 

recreation.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

515

Concessionaires (private businesses that operate and maintain government recreation facilities 

under a special use permit) operate approximately 70 developed family campgrounds, as well as 

group campgrounds, day use facilities, and cabin rentals. The Federal Lands Recreation 

Enhancement Act has increased the funds available for some recreation facilities and 

opportunities that the Forest Service manages. Under this Act, the Forest Service collects use fees 

at 10 campgrounds and 3 day-use sites on the national forest. The fees collected at these sites help 

provide services and make improvements that benefit the visitors who pay these fees. 

Under the current forest plan, partnerships, volunteers, grants, and agreements help maintain and 

improve developed recreation facilities and trails on the Inyo National Forest. Most developed 

campgrounds and fee day-use sites are managed under a concessionaire contract. Some sites and 

facilities not under concessionaire management have partnership agreements with local non-profit 

organizations and user groups. These partnerships, volunteers, and agreements assist with 

maintenance on motorized and nonmotorized trails, wilderness patrols, and facilities operation 

and maintenance. Non-profit organizations help remove graffiti and trash, and provide visitor 

information and interpretive programs along river corridors, popular dispersed recreation sites, 

and developed recreation sites. These partnerships and agreements are often made possible with 

funding (such as green sticker funds, resource advisory council grants, the Federal Lands 

Recreation Enhancement Act, stewardship council, and other sources) that supplements 

appropriated dollars.

The Inyo National Forest has outfitters and guides, organizational camps, and special recreation 

events that operate under special use permits to provide recreation opportunities to the public. 

The level of facilities and programs currently available to the public are dependent on these 

partnerships with commercial and private operators. Under the Recreation Enhancement Act, 90 

percent of the fees collected from outfitters and guides and for special recreation events are 

returned to the Inyo National Forest to provide and improve the recreation experience of visitors.

Partnerships and volunteerism also play an important role in maintaining and restoring trails, and 

rehabilitating landscapes and watersheds on the Inyo National Forest. Between 2010 and 2015, 

Inyo National Forest partners and volunteers contributed 203,787 hours; of those, 94,119 were 

wilderness and nonwilderness trail maintenance, and 4,479 hours were trail restoration and 

rehabilitation. Partners and volunteers play an important role in maintaining trails as well; with 

the assistance of partners and volunteers, the Inyo National Forest was able to maintain 

approximately 579 miles of trails in 2015. 

Environmental Consequences to Partnerships

Consequences Specific to Alternative A

Under the current forest plan, partnerships, volunteers, grants, and agreements would continue to 

help maintain and improve developed recreation facilities and trails on the Inyo National Forest. 

Existing partnerships and volunteers would be expected to continue at current levels under 

alternative A. New partnerships would be created as staffing to manage volunteers would allow.

Consequences Common to Alternatives B, B-modified, C, and D

A significant emphasis was placed on volunteers and partnerships in the revised plan. The revised 

plan alternatives contain components in the form of desired conditions and goals to provide 

direction on partnerships and volunteers.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

516

Given the increased emphasis on creating and maintaining successful partnerships in the revised 

plan, all plan revision alternatives would have an overall increase in partnership opportunities 

over alternative A. The Inyo National Forest would also have a greater staffing capacity to create 

and foster successful partnerships which would likely create additional partnership opportunities.

Partnerships, volunteerism, and grants and agreements that help maintain or improve developed 

recreation facilities would likely increase in all plan revision alternatives due to the increased 

management emphasis focused on partnerships and volunteers. 

Consequences Specific to Alternatives B and B-modified

Under alternatives B and B-modified, there would be four new recommended wilderness areas. 

The wilderness polygons do not include any system motorized roads or trails; therefore, existing 

partnerships centered on motorized use would likely not be affected and even increase over 

alternative A. There would be an increased opportunity for partnerships and volunteerism focused 

on wilderness stewardship and trails in the new recommended wilderness areas, but less than 

alternative C with 24 recommended wilderness areas. 

Specific to alternative B-modified, under this alternative conservation watersheds would likely 

provide an increase in partnerships opportunities with fish and wildlife groups. 

Consequences Specific to Alternative C

There are 24 new recommended wildernesses areas in alternative C, which could likely increase 

partnership opportunities focused on wilderness stewardship and nonmotorized opportunities to a 

greater extent than B and B-modified because it has the greatest number of recommended 

wilderness areas. The wilderness polygons do not include any system roads or trails similar to 

alternatives B and B-modified; however, with the greatest decrease in motorized settings, it is 

possible motorized partnerships could decrease in this alternative. Mechanized transport 

(mountain bike use) would not be suitable on 43 miles of trails that currently allow bicycles in 

this alternative, which could potentially cause a decrease in existing and future partnerships by 

groups focused on mechanized use. However, it is also possible that partnerships with 

mechanized groups and volunteers could shift to other locations on the Inyo National Forest, 

thereby not causing a decrease in mechanized partnerships. 

Consequences Specific to Alternative D

This alternative would likely have similar levels of partnership opportunities to alternatives B and 

B-modified, except without any recommended wilderness areas, the partnership opportunities 

with wilderness based groups would have less potential to increase than alternatives B, Bmodified, and much less than alternative C. The pace and scale of ecologic restoration may have 

potential to decrease partnerships and volunteerism in the short term depending on location and 

type of treatment, but there would still be an overall increase in long term partnership 

opportunities so this is considered a negligible .

Analytical Conclusions

Table 83 shows a comparison of changes in partnership and volunteer opportunities across all 

alternatives. Under alternative A there would be no change in partnerships or volunteerism. 

Existing partnerships would likely continue and new partnerships would be considered as staffing 

and resources allow. Partnership and volunteer opportunities related to wilderness stewardship 

would increase under alternatives B and B-modified, and to the greatest extent in alternative C. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

517

However, under alternative C, there is less potential for an increase in mountain bike and 

motorized related partnerships than alternatives B, B-modified, and D because of the decrease in 

motorized settings and mechanized trails. There would be an overall increase in partnership and 

volunteer opportunities in all plan revision alternatives over alternative A, but it is likely that the 

greatest increase in partnership opportunities would occur under alternative B-modified because 

of the partnership opportunities within new recommended wilderness areas and conservation 

watersheds. 

Table 83. Comparison of indicator by alternative

Indicator Alternative A Alternative B

Alternative Bmodified Alternative C Alternative D

Change in 

partnerships 

and volunteer

opportunities 

No change. 

Existing 

partnerships 

expected to 

continue at 

current levels 

with new new 

partnerships 

considered as 

staffing and 

resources 

allow

Partnership

opportunities 

expected to 

increase; higher 

potential

increase in 

wilderness-based 

partnerships than 

alternative D, but 

less than 

alternative C

Similar to

alternative B, 

except 

conservation 

watersheds in 

B-modified

would provide

highest level of 

partnership 

opportunities 

with fish and 

wildlife groups

Partnership 

opportunities 

expected to 

increase; highest 

potential for 

increase in 

wilderness-based 

partnerships, but 

less potential 

increase in 

mountain bike 

and motorized 

related 

partnerships than 

alternatives B, Bmodified and D

Partnership 

opportunities 

expected to 

increase; less 

potential for an 

increase in 

wildernessbased 

partnerships 

than 

alternatives B, 

B-modified, or 

C

Heritage Resources

Background

This section summarizes the current heritage resources environment on the Inyo National Forest 

and the potential consequences to heritage resources from the draft forest plan and alternatives.

Heritage resources (also sometimes referred to as “cultural resources”) are an object or definite 

location of human activity, occupation, or use identifiable through field survey, historical 

documentation, or oral evidence. Heritage resources are prehistoric, historic, archaeological, or 

architectural sites, structures, places, or objects and traditional cultural properties. Heritage 

resources include the entire spectrum of resources for which the Forest Service is responsible,

from artifacts to cultural landscapes without regard to eligibility for listing on the National 

Register of Historic Places. These resources represent past human activities or uses and, by their 

nature, are considered an irreplaceable and nonrenewable resource if not managed for 

preservation over the long term.

Because heritage resources represent important cultural values, they are of special concern to the 

public. Interest in our heritage and concern over the destruction of archaeological sites has 

prompted the passage of national, state, and local levels of legislation that are designed to 

promote and protect these examples of our Nation’s historical and traditional legacy. As a result, a 

variety of laws, regulations, and policies provide direction for managing and protecting heritage 

resources on National Forest System lands. This guidance is independent from forest plan 

direction and does not change across alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

518

Every endeavor that results in ground disturbance or brings an increase of public or agency use 

has the potential to affect heritage resources. Activities that disturb the ground include such things 

as digging postholes for sign placement, timber harvest, constructing a new bathroom, enhancing 

a campground, laying fiber optic cable, large scale vegetation management, or fire prevention and 

suppression activities. In addition, projects may have indirect effects on areas of the landscape 

that are important for cultural and tribal values. The consequences to Tribes and tribal resources 

are discussed separately in the “Tribal Relations and Uses” section.

The Forest Service Heritage program has operated under the premise of “flag and avoid” heritage 

resources during project implementation for years. A flag-and-avoid strategy works for protection 

of heritage resources on “small foot-print” types of projects because scheduling and heritage staff 

can be made available to accomplish compliance with section 106 of the National Historic 

Preservation Act. It is difficult and costly to implement for large landscape scale projects and has 

led to the conundrum the Inyo National Forest now faces regarding heritage resources and project 

implementation. Sites that have been “flagged and avoided” usually have not been evaluated; thus 

until evaluated, they must be treated as if they are historic properties eligible for listing on the 

National Register of Historic Places. This presents a major management challenge given the 

number of sites already known and the increased numbers that will be discovered during surveys 

as larger landscape areas are being evaluated for restoration projects. Having to manage resources 

that may not be eligible for listing on the National Register of Historic Places, takes away 

valuable staff time which could be better spent on managing and monitoring those resources that 

are listed or eligible for listing, inventorying areas that have not been previously surveyed for 

heritage resources and providing recordation and evaluation for newly identified heritage assets.

Analysis and Methods

It is not possible to evaluate the impacts of the alternatives on specific heritage sites because a 

high percentage of known sites have not been evaluated and because the draft forest plan is

programmatic in nature. Instead, the analysis is based on considering the amount of potential 

ground disturbance as a proxy for the potential for impacts to heritage resources.

Indicators and Measures

The amount of ground disturbance that might occur under each alternative is used as an indicator 

because of the potential for ground disturbance to adversely affect heritage resources. This is 

complicated by the fact that the total occurrences of cultural sites are unknown due to the lack of

complete survey and inventory on the Inyo National Forest. 

Affected Environment

Heritage resources on the Inyo represent a diversity of cultures and their uses of the landscapes, 

including native people, colonial California, late 19th and 20th century state history (such as the

Gold Rush) and American history, Civilian Conservation Corps history, and Forest Service 

history.

The plan area has at least a span of 9,000 years of human occupation and use. People arrived in 

California more than 13,000 years ago (Johnson et al. 2002). The exact date of Native American 

arrival is unknown. Occupation of the lower southern Sierra Nevada foothills began prior to 9,000 

years ago and would have been limited in many locations due to high-elevation glaciation. As the 

climate and resource availability changed so did the people as they adapted to changing 

environmental conditions and the distribution of plants and animals used for sustenance and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

519

shelter. Archaeological research within the national forest is limited but a chronological sequence 

of cultural transitions in adjacent areas is applicable as described below from McGuire and 

Garfinkle (1980).

Prehistoric and Historic Periods

Paleoindian Period (9,000 to 6,000 years ago)

Most prehistoric sites on the national forest from this time period would have been associated 

with trans-Sierran travel and trade or seasonal big game hunting. Most prehistoric use of the land 

within the plan area during this period appears to have been pass-through travel or seasonal 

resource extraction. Generally, the Inyo was only used sporadically by nomadic groups during the 

Paleoindian period.

Lamont Phase or Little Lake Period (6,000 to 3,200 years ago) 

This was a dry time with sites located on ridges, saddles, and along meadow margins. Visits to the 

plan area were sporadic and associated with plant collecting and big game hunting. During the 

warm dry time, it is postulated that the stands of pinyon pine shifted and expanded providing 

additional plant foods for foraging peoples. Obsidian and other stone tool materials are common 

to this period.

Canebrake Phase or Newberry Period (3,200 to 1,400 years ago) 

This time period saw a tremendous increase in Native American use of the pinyon pine stands and 

other plant foods. Milling equipment increased in both quantity and variety. Obsidian quarrying 

in the eastern Sierras intensified. Stone tool point styles were more varied and diverse. The spear 

and atlatl were the primary hunting weapons, as they were during the Paleoindian period. While 

populations remained highly mobile, a pattern of returning use began to emerge with suggestions 

of a more permanent settlement pattern becoming established throughout the lower western Sierra 

foothills. The first signs of intensive occupation are found in ecological boundary areas rich in 

plant and animal resources, such as the Kern River Valley.

Sawtooth Phase or Haiwee Period (1,400 to 700 years ago) 

During this time there was a tremendous increase in the number and diversity of archaeological 

sites over the entire landscape. The number of people living and traveling through the national 

forest increased exponentially as the bow and arrow, a much superior weapon, replaced the spear 

as the hunting tool of choice. Large mammals such as mule deer, pronghorn and bighorn sheep 

were hunted, as were smaller mammals such as rabbits, hares and rodents. The development of 

the ubiquitous bedrock mortar and pestle, and milling and grinding slabs across the landscape 

indicate the importance of plant foods such as acorns, seeds, pine nuts, grasses and forbs. 

Wetlands and waterfowl were also important. Populations appeared less mobile, with favored 

food processing locations revisited again and again over many millennia, resulting in the 

development of deeply stratified archaeological sites. The appearance of Olivella beads at sites 

east of the Sierra suggest the beginning of trade networks stretching to the California coast, and 

there is some discussion of a possible major emigration of people into the Great Basin from 

southeastern California.

Chimney Phase or Marana Period (700 years ago; the historic period)

Subsistence strategies during this period were diverse and intensive, with resources from a large 

number of ecological zones used, including wetlands, desert sage communities, upland and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

520

montane environments, tablelands, and pinyon groves. Pottery use began and an increase in shell 

and steatite beads at sites in the eastern Sierra foothills suggest there were robust trade networks. 

Clearly defined house pits point to increased levels of permanent settlement.

At the time of European incursion, the foothills and river valleys on the west side of the Sierra 

Nevada range were some of the most densely populated areas in North America. Sites recorded 

today document large semi-permanent villages, house pits, formal cemeteries, pottery, soapstone 

bowls and decorative objects, rock art. Villages were being reused, populations were increasing in 

size, ceremonial areas developed, and long distance trade networks existed that imported trade 

goods from over long distances.

Historic Period (400 years ago; the present period)

The introduction of European diseases decimated more than 95 percent of the indigenous peoples 

and they were later displaced by miners, ranchers, and other early pioneers. Mines, ranches, built 

towns, and engineered roads were built over many of the old traditional Native settlements. Tribal 

people adapted and changed and accepted paid employment in the mines and on the ranches as 

the landscape evolved with new settlers. Many traditional peoples were displaced as large 

segments of land were allocated to Government ownership and active stewardship by 

Government managers. Administrative Government facilities were built along the trails and 

adjacent to key mining and grazing areas. The rivers were dammed to provide hydroelectric 

power to the growing urban areas in California. Dams, flumes, tunnels, company towns, 

construction camps, railroads and all manner of facilities associated with hydroelectric power 

generation began to be built within the plan area in the early teens of the 20th century. Timber 

harvest increased in the early 1900s. The intensity and extent changed as new methods and 

machinery were developed, starting with logging by horses and mules. The development of steam 

equipment led to more road building and eventually to railroads to meet the demands of growing 

populations in towns and cities. Modern log trucks and heavy equipment allowed access to more 

areas and replaced railroads and created the foundation for many of the current road systems on 

the national forest. Recreational interest and use of the Inyo became important as motor vehicles 

developed and flourished. Campgrounds, recreation residences, resorts, and organizational camps 

expanded throughout the national forest.

Cultural Resources Surveys

The prehistoric Native American past is embodied in the rock art and prehistoric archaeological 

sites that range in size from small stone tool scatters to large villages occupied for hundreds of 

years that dot the contemporary landscape. These sites are highly valued by local Tribes as the 

very embodiment of their past and the places where their ancestors lived, worshiped, and died. It 

is a tangible link to a very long history but despite their persistence through time, sites are 

extremely vulnerable to damage by ground-disturbing activities and even from high-intensity fire. 

Prehistoric Native American sites are also vulnerable to illegal looting and illicit excavation.

Historic period sites are also extremely vulnerable to destruction by disturbing activities including 

wildfire; especially wooden cabins, flumes, lookouts and old mine buildings. Looting of historic 

artifacts at historic sites is as much of a problem as that on deeply buried Native American sites.

The presence of prehistoric and historic sites reflects the human use of the approximate 2 million 

acres encompassing the Inyo National Forest. The total extent of the heritage resource database 

for the Inyo has not been determined. However, from an evaluation of survey data, it is estimated 

that approximately 11 percent of the Inyo National Forest has been inventoried for heritage 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

521

resources. Most of these surveys have been project-specific rather than large-scale or systematic 

surveys. 

Heritage surveys have identified a total of 5,405 sites on the Inyo National Forest. Table 84

displays the number of identified heritage resources on the Inyo National Forest by site type. Of 

those totals, 83 percent of the sites on the Inyo remain unevaluated for the National Register of 

Historic Places. This means that all unevaluated sites are considered to be eligible properties for 

listing on the National Register of Historic Places and must be managed as such until an 

eligibility determination is submitted to the Office of Historic Preservation for the State Historic 

Preservation Officer’s concurrence; or it must be submitted directly to the Keeper of the National 

Register for a determination.

Table 84. Number of heritage sites by type

Type of Site Number

Prehistoric 2,386

Historic 762

Multi-Component 160

Unidentified 2,097

Contemporary 0

Protohistoric 0

Total Sites 5,405

Table 85 summarizes the numbers of site evaluations and designations on the Inyo National 

Forest that have undergone evaluation. Of those evaluated, 73 percent of the evaluated sites on 

the Inyo National Forest were found to be not eligible for listing on the National Register of 

Historic Places. Given that only a small portion of the known heritage sites have been evaluated, 

the Inyo NF is currently managing potentially non-eligible heritage resources, all of which need 

to be considered as eligible during the planning process and avoided.

Table 85. Number of heritage site determinations and number 

of historic landmarks under the National Register of Historic 

Places (NRHP)

Heritage Site Determinations Number

NRHP Listed 0

National Historic Landmark 0

State Historic Landmark 0

NRHP Eligible 249

Not Eligible 688

Total Determinations 937

No Determination 4,468
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

522

Environmental Consequences to Heritage Resources

Nearly every action undertaken by the Forest Service has the potential to affect heritage resources 

either directly or indirectly. Not all effects are necessarily adverse and some effects may be 

avoided either through project design or the implementation of standard protection measures as 

outlined in appendix E of the Programmatic Agreement with the California and Nevada State 

Historic Preservation Officers and the Advisory Council on Historic Preservation (USDA FS 

2013).

Heritage resources are nonrenewable and any effect can result in the unacceptable destruction or 

damage to examples of the area’s heritage. Heritage resources also need to be reviewed not only 

as individual resources, but holistically at larger landscape levels. What may appear to be 

individual sites, or dots on a map may very well be historic districts (for example, mining 

complexes, ranching complexes; or cultural landscapes) that include village sites with 

surrounding special use areas containing trails, plant gathering areas, lithic quarries, and other 

essential resources.

Consequences Common to all Alternatives

Regardless of the alternatives, all site-specific projects would consider effects to heritage 

resources at the outset of every project planning process. Compliance with section 10639 of the 

National Historic Preservation Act of 1966 as amended would be completed prior to making a 

decision to implement a project, approve a permit, or undertake an activity. The section 106 

process may be completed by consultation with the State Historic Preservation Officer, Tribes, the 

public, and other stakeholders, and at times with the Advisory Council on Historic Preservation 

using the regulatory process codified at 36 CFR Part 800 as amended or through implementation 

of the stipulations of the Region 5 Programmatic Agreement (USDA Forest Service and CA 

SHPO 2013).

All alternatives include direction to reduce fuels and restore fire to the landscape, but using 

different approaches and with a different pace and scale of restoration. The extent that each 

alternative reduces the extent and severity of wildfires would reduce the risk of inadvertent 

impacts to heritage sites from fire suppression activities and from damage from high soil heating.

Consequences Common to Alternatives B, B-modified, C, and D

The emphasis on variable treatment intensities and on restoring and managing for vegetation 

heterogeneity in alternatives B, B-modified, C, and D should provide opportunities to design 

projects around small sites to minimize or avoid disturbances to heritage resources. Avoidance 

would follow the standard practice of using the “flag and avoid” strategy, but would also 

encourage designing projects to reduce threats to heritage resources from large high-intensity 

wildfires by allowing low-intensity treatments around small sites to promote an increase in 

resilience and sustainability of forests. A plan objective (CULT-FW-OBJ-01) focuses on 

increasing the number of sites managed and monitored that are listed or eligible for listing, 

increasing the areas inventoried that have not been previously surveyed for heritage resources and 

increasing recordation and evaluation for newly identified heritage assets.

 39 Section 106 of the National Historic Preservation Act of 1966 (NHPA) requires Federal agencies to take into account 

the effects of their undertakings on historic properties, and afford the Advisory Council on Historic Preservation a 

reasonable opportunity to comment.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

523

Management activities (such as mechanical thinning, prescribed burning, and managing wildfires 

to meet resource objectives), appropriately implemented so as to avoid direct and indirect effects 

to heritage resources and tribal values, may afford greater protection compared to consequences 

from continued forest growth and density increases that lead to larger and higher intensity 

wildfires. Activities associated with wildfire suppression under emergency conditions often have 

adverse impacts to heritage resources, such as running a dozer line through sites and areas 

sensitive to Tribes.

Alternatives B, B-modified, C, and D encourage managing wildfires to meet resource objectives, 

especially in the wildfire maintenance zone. Some wildfires are also managed to meet resource 

objectives in alternative A in wilderness and remote areas. Decisions to manage wildfires and onthe-ground activities while managing wildfires would consider the location of known sites and 

where possible, resource advisors would be consulted to develop strategies to minimize or to 

mitigate impacts. The desired outcome is to restore fire to the landscape similar to conditions that 

have occurred historically such that the impacts to sites would not be substantially different than 

they have been exposed to for centuries. There is some additional opportunity in alternatives B, 

B-modified, and D which are discussed separately for those alternatives.

Consequences Specific to Alternative A

Alternative A represents the existing plans (as amended) and would have no measurable direct 

effects on any known heritage resources from continuing activities currently allowed under the 

existing plan. This is because planned projects involving ground-disturbing activity would either 

avoid direct and indirect effects to heritage resources or would include project-specific mitigation 

measures to address any adverse effects to specific heritage resources by reducing them to 

acceptable levels or following existing processes when effects cannot be adequately mitigated.

During wildfires, there are risks to sites and resources from fires that burn at high intensity with 

heat pulses into the soil that can damage individual resources and threaten sites where highintensity fires result in surface erosion and the movement of soils and the rearrangement of sites. 

In some cases, high-intensity fire can ruin the ability to date some artifacts, especially obsidian, 

by changing the hydration bands. Fire can also burn wood or natural fiber artifacts.

Consequences Specific to Alternatives B and B-modified

Alternatives B and B-modified emphasize ecological fire resilience and restoration of fire as an 

ecosystem process with a greater focus on large-scale landscape level projects. There would be 

more mechanical thinning treatments and more prescribed burning than alternative A. As only 11 

percent of the Inyo National Forest, 13 has been inventoried for heritage resources, a large-scale 

on the ground effort would be needed to identify heritage resources in previously unsurveyed 

areas. Known sites that are unevaluated are managed as if they were eligible for listing on the 

National Register of Historic Places resulting in the need to include additional mitigation 

measures when designing projects. Vegetation treatment measures that emphasize low-intensity 

fire, and increased use of hand treatment in and around known sites would lower the potential for 

adverse impacts to heritage resources. Prescribed burning can be compatible with heritage sites 

and heritage resources if the fire can burn at low intensity or with mitigations to protect them 

such as constructing fire lines to exclude fire or covering or protecting features to reduce the risk 

of ignition.

Alternatives B and B-modified recommend additional wilderness on the Inyo National Forest, 

which could reduce the risk of direct human impacts to more known and unknown sites. Sites 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

524

located within designated wilderness and areas recommended as wilderness would benefit from 

the restrictions on motorized use and restrictions on mechanical vegetation treatments but may be 

negatively impacted by continuing fuel accumulations and the risks associated with fires that burn 

at high intensity. 

Alternatives B and B-modified emphasize restoring fire to the landscape, which would include a 

consideration of heritage resources in determining where and how it can be used to meet resource 

objectives. This would benefit heritage resources by reducing fuels while reducing impacts by 

managing the intensity of fire. Projects would be designed to avoid and minimize impacts and 

effects to heritage sites and to indirectly improve the resilience of sites by reducing threats from 

fire and other uses Treatments along strategic roads and ridgetops, especially in the wildfire 

restoration zone are expected to increase the potential to manage wildfires in this zone over time, 

further reducing the risk of high-intensity fire impacts to heritage sites.

Consequences Specific to Alternative C

Alternative C places an emphasis on providing more short-term protections for wildlife habitat. 

This alternative proposes to add the most areas recommended for wilderness designation of all the 

alternatives. Additionally, this alternative has more areas with restrictions or limitations on the 

intensity and extent of treatment using mechanical vegetation management methods, which would 

afford greater short-term protection by resulting in less impacts to known and unknown heritage 

resources. Conversely, those restrictions and protection measures could have more indirect effects 

by leaving more areas with levels of surface fuels outside the natural range of variation which 

could damage sensitive sites and resources if they burn at high intensity in wildfires. Alternative 

C emphasizes more use of prescribed burning in lieu of mechanical treatments where possible. As 

described for alternative B, prescribed burning can be compatible with heritage sites and heritage 

resources, but careful planning is needed, especially where fuels are heavy and there is no 

mechanical pre-treatment to reduce them prior to burning. Some work by hand or to remove 

small-diameter trees and other vegetation may occur, but the extent would be limited by funding. 

Most prescribed burning would need to be designed in existing heavy fuel conditions which may 

mean some burns would become backlogged if suitable conditions for a favorable burn outcome 

do not occur as frequently due to climate change with drier spring conditions and longer fire 

seasons into the fall.

Consequences Specific to Alternative D

Alternative D has the greatest increase in the pace and scale of ecological restoration that could 

involve ground-disturbing activities. Given the increase in development, such as the increase in 

recreation opportunities and the increase in the scale of treatments, the need for project-level 

survey and design mitigations would be the greatest in this alternative compared to the other 

alternatives. There is some uncertainty in how project planning may need to change to ensure 

surveys do not become obstacles to achieving the increased amount of restoration in this 

alternative. 

Alternative D would have similar effects and benefits as described for alternatives B and Bmodified. The increase in area of mechanical treatments with greater fuel reductions would 

require more coordination and consultation to design projects to avoid and minimize impacts and 

effects, but would result in a greater reduction in the potential for large high-intensity fires. 

Alternative D would have the most ability, primarily through increased stewardship funding 

opportunities, to do additional preparatory work, including evaluation of sites, to mitigate impacts 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

525

and to avoid and minimize the potential for impacts to heritage sites and heritage resources during 

mechanical treatments and prescribed burning. 

Cumulative Effects

Direct and indirect effects are considered to be adverse when the project or action may alter, 

directly or indirectly, any of the characteristics of a historic property that qualify the property for 

inclusion in the National Register of Historic Places in a manner that would diminish the integrity 

of the property’s location, design, setting, materials, workmanship, feeling, or association. 

Adverse effects to a historic property may also include reasonably foreseeable effects caused by 

the project or action that may occur later in time, be farther removed in distance or be cumulative. 

Examples of adverse effects are effects that change the character of the property’s use or of 

physical features within the property’s setting that contribute to its historic significance; removal 

of the property from its historic location; or, the introduction of visual, atmospheric or audible 

elements that diminish the integrity of the property’s significant historic features. Because all 

Federal agencies must comply with section 106 of the National Historic Preservation Act, similar 

management approaches are used on lands managed by the National Park Service and Bureau of 

Land Management.

Cumulative effects are difficult to evaluate because of the large proportion of known sites that 

have not been evaluated. The Inyo manages for “no effect” or “no adverse effect” to heritage 

resources for all planned management activities, which lessens the risk of cumulative effects by 

presuming known sites are eligible for inclusion in the National Register of Historic Places and 

protecting them. Some project activities may result in unplanned or inadvertent adverse impacts 

to heritage resources. Such unplanned or inadvertent adverse impacts are addressed and mitigated 

on a case-by-case basis through consultation with the State Historic Preservation Officer, tribal 

partners, other interested parties, the public, and at times the Advisory Council on Historic 

Preservation. Heritage resources are non-renewable resources and the destruction or damage to 

them cannot be reversed. The alternatives all have a restoration component, but care must be 

taken to protect significant heritage resources, such as prehistoric and historic sites, traditional 

cultural properties, traditional gathering and use areas, sacred sites and landscapes, archaeological 

and historic districts.

Analytical Conclusions

At the project level, all of the alternatives have the potential to impact heritage resources given 

that less than 12 percent of the plan area has been systematically inventoried for heritage 

resources and that 83 percent of all known recorded sites remain unevaluated for the National 

Register of Historic Places. A “flag-and-avoid” strategy works for protection of heritage resources 

on “small foot-print” types of projects because scheduling and heritage staff can be made 

available to accomplish compliance with section 106 of the National Historic Preservation Act. It 

becomes more problematic with larger landscape scale projects encompassing thousands of acres 

because of the unknowns relating to heritage resources. Large-scale projects generally have to be 

phased in terms of section 106 compliance, or the use of predictive modeling could be employed 

to assist with informing on the “likely” location of heritage resources, with an outcome for an 

increase in unplanned or inadvertent effects to known or unknown heritage resources.

Alternative A would continue a slow rate of restoration that is suitable for continuing a “flag and 

avoid” strategy but leaves much of the national forest and heritage resources at risk of damage 

from high-intensity fires. Alternative C would reduce the amount of restoration accomplished 

using mechanical methods which would reduce the potential for direct impacts to heritage 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

526

resources. Alternative C would use more prescribed fire but less mechanical pre-treatment of 

fuels, which would require careful planning to avoid burning at high intensity where fuels are 

heavy. Alternatives B, B-modified, and D strive to balance the greater risks of impacts to heritage 

sites by increasing the amount of mechanical thinning treatments and the amount of prescribed 

burning that would restore vegetation conditions and lower the risk of large, high-intensity 

wildfires over time. This would benefit heritage resources that would be damaged by fires that 

burn at high intensity.

Designated Wilderness

Background

The Wilderness Act of 1964 requires the preservation of wilderness character and recognizes 

multiple values and public benefits found in these areas. Wilderness provides outstanding 

opportunities for solitude and for primitive and unconfined recreational experiences. Wilderness 

is also important for maintenance of species diversity, protection of threatened and endangered 

species, protection of watershed, scientific research, and various social values. 

Analysis and Methods

The analysis area for effects to existing designated wilderness includes the nine existing 

designated wildernesses on the Inyo National Forest. The timeframe for the environmental 

consequences related to existing designated wilderness areas is the expected life of the forest 

plan, or 10 to 15 years.

Indicators and Measures

There is one indicator for existing designated wilderness in this analysis: Protection of wilderness 

character.

Methods

This analysis includes a qualitative discussion of the effects of the proposed management 

direction in the different alternatives on the existing designated wilderness areas and 

recommended wilderness areas. Wilderness character, the Inyo’s ability to manage recommended 

wilderness, the Inyo’s ability to conduct fuels, fire and wildlife habitat management, and any 

change in the miles of system trails that allow mechanized transport within areas recommended 

for wilderness are all used to measure the effects of each alternative. 

Wilderness Character

The Wilderness Act, section 4(b) indicates each agency administering any area designated as 

wilderness shall be responsible for preserving the wilderness character of the area. The Forest 

Service has identified five “qualities” that are used to assess wilderness character from the 

statutory language of the Wilderness Act (Landres et al. 2011): natural quality; undeveloped 

quality; untrammeled quality; opportunities for solitude or primitive and unconfined recreation; 

and other features of value described as follows (see appendix B in volume 2 for the evaluation of

the wilderness characteristics of each recommended area).

Natural Quality: This quality pertains to terrestrial, aquatic, and atmospheric resources, and 

ecological processes. The natural qualities of wilderness for this analysis are based on the 

concepts of naturalness discussed in Cole and Yung (Cole and Yung 2012), and the discussion on 

ecosystem connectivity and diversity contained in “Chapter 1: Terrestrial, Aquatic, and Riparian 

Ecosystems” of the Inyo Final Assessment (USDA Forest Service 2013a). The natural quality of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

527

wilderness is protected to the extent biological diversity and ecological resilience is sustained, 

ecosystem structure and function is maintained, and natural disturbance processes are sustained.

Undeveloped quality: This quality pertains to whether wilderness is essentially without 

permanent improvement or modern human occupation. This quality is influenced by what are 

commonly called the “section 4c prohibited uses;” that is, the presence of modern structures, 

installations, habitations, and use of motor vehicles, motorized equipment, or mechanical 

transport.

Untrammeled quality: This quality pertains to whether wilderness is essentially unhindered and 

free from the actions of modern human control or manipulation. This quality is influenced by any 

activity or action that controls or manipulates the components or processes of ecological systems 

inside the wilderness.

Opportunities for solitude or a primitive and unconfined type of recreation: This quality 

pertains to whether visitors can find opportunities for solitude in wilderness, or to engage in 

primitive-type or unconfined recreation activities.

Other Features of Value: A wilderness may also contain ecological, geological, or other features 

of scientific, educational, scenic, or historical value” that occur only in specific locations and are 

unique to an individual wilderness. Features of value may be identified in the law that designates 

a wilderness or through the Congressional legislative history, and are not present in every 

wilderness.

Affected Environment

There are currently three groups of contiguous wilderness located on the Inyo National Forest. 

The first group in the central and southern Sierra Nevada Mountains includes five wilderness

areas with a combined size (managed by the Inyo) of approximately 632,059 acres. This group of 

wilderness areas is notable for being part of the second largest contiguous block of wilderness in 

the continental United States when combined with the other wilderness areas located on the 

Sequoia and Sierra National Forests. The second group is in the Basin and Range Province. This 

group includes two contiguous wilderness areas and the Ancient Bristlecone Pine Forest, with a 

combined size of approximately 260,500 acres. The Ancient Bristlecone Pine Forest is included 

with the wilderness areas in this group because it is a congressionally designated area where all 

natural features are protected. The third group is also in the Basin and Range Province and 

includes one wilderness contiguous with a large portion of the Death Valley Wilderness.

Existing Designated Wilderness Areas

Designated wilderness comprises almost 46 percent of the Inyo National Forest, for a total of 

964,360 wilderness acres. There are nine designated wilderness areas, either in whole or part, 

within the administrative boundary of the national forest. 

General direction for management for all wilderness areas on the Inyo is contained within the 

existing land management plan, which specifies that the Inyo should “maintain a predominantly 

natural and natural-appearing environment, facilitate low frequencies of interaction between 

users, and exercise necessary controls primarily from outside the wilderness boundary” (USDA 

Forest Service 1988a).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

528

Detailed direction for managing the Ansel Adams, Golden Trout, Hoover, and John Muir 

wilderness areas is currently provided by wilderness-specific management plans. The wildernessspecific management direction for each of these areas. 

A trailhead quota system currently manages use within the Ansel Adams, Golden Trout, and John 

Muir Wilderness areas, but not any of the other wilderness areas. Wilderness permits are not 

required for day use, except on the Mount Whitney Trail in the John Muir Wilderness. 

Table 77 displayed in the “Sustainable Recreation and Scenery” section, shows the total number 

of estimated wilderness visits on the Inyo National Forest based upon the most recent National 

Visitor Use Monitoring data from 2006 and 2011. The survey data show that wilderness visitation 

on the Inyo nearly doubled from 2006 to 2011; in 2006, designated wilderness estimated visits 

were 138,000 and in 2011 the estimated wilderness visits were 252,000 (USDA Forest Service

2006 and 2011b).

The following lists existing wilderness areas located on the Inyo National Forest (or adjacent if 

they are pertinent to this analysis), their size, whether they are jointly administered by other 

agencies, and prominent areas that lie along their boundaries. Maps of each wilderness area are 

located in volume 4.

• Ansel Adams Wilderness: The Ansel Adams Wilderness is 231,279 acres and is jointly 

administered by the Inyo National Forest (78,710 acres), the Sierra National Forest 

(152,569 acres), and Devil’s Postpile National Monument (747 acres). It is contiguous with 

Yosemite National Park along its northern boundary, the John Muir Wilderness along its 

southern boundary, and the Owens River Headwaters Wilderness along its eastern 

boundary.

• Boundary Peak Wilderness: The Boundary Peak Wilderness is 10,518 acres solely

administered by the Inyo National Forest. It is contiguous with the White Mountains 

Wilderness along its western boundary.

• Golden Trout Wilderness: The Golden Trout Wilderness is 303,511 acres and is jointly 

administered by the Inyo National Forest (193,630 acres) and the Sequoia National Forest 

(110,746 acres). It is contiguous with the John Muir, Sequoia-Kings Canyon, and John 

Kreb Wilderness Areas along its northern boundary, and the South Sierra Wilderness along 

its southern boundary.

• Hoover Wilderness: The Hoover Wilderness is 128,000 acres and is jointly administered 

by the Inyo National Forest (28,619 acres) and the Humboldt-Toiyabe National Forest 

(99,381 acres). It is contiguous with Yosemite National Park along portions of its 

southwestern boundary.

• Inyo Mountain Wilderness: The Inyo Mountain Wilderness is 198,874 acres and is jointly 

administered by the Inyo National Forest (74,512 acres) and the Bureau of Land 

Management (124,362 acres). It is contiguous with the Death Valley Wilderness along 

portions of its eastern boundary.

• John Muir Wilderness: The John Muir Wilderness is 651,992 acres and is jointly 

administered by the Inyo National Forest (325,315 acres) and the Sierra National Forest 

(326,677acres). It is contiguous with the Ansel Adams Wilderness along its northern 

boundary, the Dinkey Lakes, and Sequoia-Kings Canyon Wildernesses along its western 

boundary, and the Golden Trout and Monarch Wildernesses along its southern boundary.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

529

• Owens River Headwaters Wilderness: The Owen River Headwaters Wilderness is 14,725

acres administered by the Inyo National Forest. It is contiguous with the Ansel Adams 

Wilderness along its southwestern boundary.

• Piper Mountain Wilderness: The Piper Mountain Wilderness is 72,192 acres and is 

administered by the Bureau of Land Management (BLM). Although it is not within the 

boundaries of the Inyo NF, it is part of the wilderness section because it borders a

recommended wilderness area (Piper Mountain Wilderness Addition) proposed in 

alternatives B, B-modified, and C.

• South Sierra Wilderness: The South Sierra Wilderness is 60,084 acres and is jointly 

administered by the Inyo National Forest (31,582 acres) and the Sequoia National Forest 

(28,502 acres). It is contiguous with the Golden Trout Wilderness along its northern 

boundary and is separated only by a narrow road corridor from the Domeland Wilderness.

• White Mountains Wilderness: The White Mountains Wilderness is 230,958 acres in size, 

and is jointly administered by the Inyo National Forest (206,756 acres) and the Bureau of 

Land Management (24,202 acres). It is contiguous with the Boundary Peak Wilderness 

along its northeast boundary.

Environmental Consequences to Existing Designated Wilderness

Consequences Specific to Alternative A 

Under alternative A, the existing forest plan would continue to guide management of existing 

wilderness areas on the Inyo National Forest (USDA Forest Service 1988a). General management 

direction exists but many designated wilderness areas have wilderness management plans that 

provide more specific management guidance.

Existing forest plan direction would continue to protect and maintain the five qualities of 

wilderness character in designated wilderness. The opportunity for solitude and primitive, 

unconfined recreation would be maintained and no new permanent developments or human 

occupancy would be authorized. Natural ecological processes and disturbances would continue to 

be the primary forces affecting the composition, structure and patterns of vegetation. 

The Ansel Adams and John Muir Wildernesses would continue to be managed for low density, 

low disturbance, and widely distributed visitor use. In popular destination areas, impacts 

associated with visitor use would continue to be concentrated by limiting visitor freedom to 

established overnight camping sites and areas. Group size limits, wilderness permits, and other 

restrictions on overnight occupancy would continue to be implemented to effectively manage 

visitor use levels and maintain or improve opportunities for solitude. Biophysical impacts 

associated with recreation would be reduced by prohibiting camping in areas that have 

experienced high levels of impact and are in need of restoration. 

Alternative A has forestwide noxious weed direction, but the direction does not include all 

invasive species like the plan revision alternatives, and direction for aquatic invasive species is 

not adequate. Alternative A lacks specific guidelines and components which would provide for 

restoration in wilderness, address all invasive species, and support social and natural qualities of 

wilderness character. If these aspects of wilderness character are not maintained, there would 

likely be long-term adverse impacts on natural quality of wilderness character.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

530

Consequences to Designated Wilderness from Other Relevant Resource Programs

Alternative A does not provide management direction that would increase restoration activities on 

adjacent lands to existing wilderness. Catastrophic fires and tree mortality on adjacent lands could 

put existing wilderness areas at risk, and could cause a long-term decline in the quality of 

wilderness character in those wilderness areas.

Natural, unplanned ignitions would continue the long-term ecological processes in existing 

wilderness areas. There could be a short-term loss of vegetation, reduction in water quality due to 

sedimentation, and effects from smoke; however, these effects are part of the natural ecological 

processes and would help maintain natural qualities of wilderness character.

Table 86 shows the three different fire management zones in existing designated wilderness areas

under alternative A. Both the Wildland-urban Intermix Defense and Threat Zones emphasize 

hazardous fuels reduction treatments and lack management direction to restore fire as an 

ecological process, which would be likely to have adverse effects on existing wilderness 

characteristics. Some wildfires may be managed to meet resource objectives when conditions 

allow and it can be done in a safe manner which could have beneficial effects on wilderness 

characteristics.

Table 86. Percentage of area in fire management zones for areas in 

designated wilderness, alternative A

Wildland-urban 

Intermix Defense Zone

Wildland-urban 

Intermix Threat Zone Other

less than 1 percent 7 percent 93 percent

Consequences Specific to Alternatives B-modified, B, C, and D

Like alternative A, management would continue to be guided by wilderness management plans in 

those wilderness areas that have plans (Ansel Adams, Golden Trout, Hoover, and John Muir 

wilderness areas), which provide more specific management guidance. 

The Ansel Adams and John Muir Wildernesses would continue to be managed for low density, 

low disturbance, and widely distributed visitor use. In popular destination areas, impacts 

associated with visitor use would continue to be concentrated by limiting visitor freedom to 

established overnight camping sites and areas. Group size limits, wilderness permits, and other 

restrictions on overnight occupancy would continue to be implemented to effectively manage 

visitor use levels and maintain or improve opportunities for solitude. Biophysical impacts 

associated with recreation would be reduced by prohibiting camping in areas that have 

experienced high levels of impact and are in need of restoration.

Under all plan revision alternatives, plan direction would guide management of existing 

wilderness areas using desired conditions and guidelines described in the wilderness section of 

chapter 3 of the revised plan. Management direction under all plan revision alternatives would 

continue to protect and maintain the five qualities of wilderness character in designated 

wilderness. Opportunities for solitude and primitive, unconfined recreation would be maintained 

and no new permanent developments or human occupancy would be authorized. Natural 

ecological processes and disturbances would continue to be the primary forces affecting the 

composition, structure and patterns of vegetation.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

531

Direction under all plan revision alternatives for existing designated wilderness areas would 

continue to ensure that there is a balance between maintaining recreation opportunities for pack 

stock use in wilderness and sustaining ecological resources in wilderness. 

There are guidelines and components under alternatives B-modified, B, C, and D that are not 

addressed under existing forest plan direction. This revised direction would be beneficial to 

aspects of wilderness character not addressed in existing wilderness plan direction, including 

providing for restoration in wilderness, addressing invasive species, and supporting social and 

natural qualities of wilderness character.

In addition to plan components that apply to all designated wilderness areas, the Ansel Adams and 

John Muir Wildernesses have additional desired conditions defined within three wilderness 

recreation categories. Similarly, the South Sierra Wilderness has desired conditions defined by 

four opportunity classes. This direction specific to these three wilderness areas would be 

beneficial to the protection of wilderness character because it would provide a site specific

approach. 

Consequences to Designated Wilderness from other Relevant Resource Programs

Consequences Specific to Alternatives B, B-modified, and D

Alternatives B, B-modified, and D would provide management direction that would likely 

increase restoration activities on adjacent lands to existing wilderness compared to alternative A, 

which would be beneficial to protecting existing wilderness areas.

Like alternative A, natural, unplanned ignitions would continue the long-term ecological 

processes in existing wilderness areas under alternatives B, B-modified, and D. There could be a 

short-term loss of vegetation, reduction in water quality due to sedimentation, and negative 

impacts from smoke; however, these effects are part of the natural ecological processes and 

would help maintain the long-term natural qualities of wilderness character.

In alternatives B, B-modified, and D there are four fire management zones shown in table 87. The 

Community Wildfire Protection Zone and General Wildfire Protection Zone emphasize fuel 

treatments that would not enhance ecological processes and natural characteristics; however,

these would be necessary management tradeoffs to protect communities. The wildfire restoration 

zone prioritizes ecological restoration, which could have short-term adverse effects on wilderness 

characteristics, but long-term benefits to wilderness character would outweigh any short-term 

negative impacts. In areas in the wildfire maintenance zone, fire management activities would be 

likely to retain and have beneficial effects to wilderness characteristics because this zone 

emphasizes management of wildfires to meet resource objectives, and to a slightly greater extent 

under alternative B. This would allow ecological benefits to the natural quality of wilderness 

character to occur under alternatives B, B-modified and D.

Table 87. Percentage of area in fire management zones for areas in designated wilderness, 

alternatives B, B-modified, and D

Alternative

Community 

Wildfire 

Protection Zone

General Wildfire 

Protection Zone

Wildfire 

Restoration Zone

Wildfire 

Maintenance 

Zone

B 3 14 27 56

B-modified and D 2 12 32 53
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

532

Consequences Specific to Alternative C

In alternative C, there are three fire management zones for existing designated wilderness shown 

in table 88: the Wildland-urban intermix Defense Zone which is the same as in alternative A; the 

Wildfire Maintenance Zone is the same as in alternatives B and D; and the General Wildfire Zone 

for the remaining area. The General Wildfire Zone would have an increased emphasis on 

managing wildfire to meet resource objectives and increased use of prescribed fire in fire adapted 

ecosystems and could potentially put wilderness resources at risk. Of the three fire management 

zones in alternative C, the Wildfire Maintenance Zone would be the most likely to have benefits 

to wilderness characteristics, where wildfires could be safely managed while still restoring fire as 

an ecosystem process. The general wildfire zone may make it more difficult to evaluate wildfire 

risk resulting in slightly less wildfires managed to meet resource objectives within existing 

wilderness areas. The fewer fuels reduction treatments that would occur adjacent to wilderness

areas would result in higher risks to managing wildfires inside wilderness, which could negatively 

impact many aspects of wilderness character inside wilderness. 

Table 88. Percentage of area in fire management zones for areas in 

designated wilderness, alternative C

Wildland-urban 

Intermix Defense Zone General Wildfire Zone

Wildfire Maintenance 

Zone

less than 1 46 54

Consequences Specific to Alternative D

Management direction provided under alternative D would likely have the most beneficial effect 

to protection of existing designated wilderness due to the increased pace and scale of restoration 

activities that would occur on lands adjacent to existing wilderness areas. 

Cumulative Effects

Past, present and reasonably and foreseeable actions that have the potential to cumulatively affect 

existing wilderness areas include activities such as vegetation management, mining, recreation 

use, and fuels reduction activities that would occur adjacent to existing wilderness areas. These 

actions could impact the wilderness characteristics of solitude inside existing wilderness areas, 

depending on how close and persistent the actions are. For example, mining activities adjacent to 

an existing wilderness may increase the sights and sounds of motorized equipment heard within a 

wilderness. Expansion of a developed recreation site adjacent to an existing wilderness area could 

increase use levels within the wilderness, which could have impacts on solitude as the number of 

encounters with others could increase within that wilderness. Past, present, and reasonably and 

foreseeable actions when considered with management direction of plan revision alternatives

would not be expected to have long-term cumulative impacts on the wilderness characteristics of 

solitude because there are plan components and wilderness plan direction that protect solitude. 

Population growth in California and Nevada would be likely to increase wilderness visitation that 

could result in cumulative impacts to wilderness character, including opportunities for solitude 

and natural quality. Examples of potential impacts would include decreased opportunities for 

solitude in high use areas, soil compaction or erosion, and threats to native plant species from the 

spread of noxious weeds from sources outside the wilderness. Management direction for 

wilderness in plan revision alternatives would help protect wilderness characteristics of solitude 

and natural qualities from long-term cumulative impacts of population growth.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

533

Analytical Conclusions

Many aspects of wilderness management direction across all alternatives is similar since much of 

the direction is derived from law, regulation, and agency policy. This would result in similar 

effects to wilderness character across all alternatives; however, alternatives differ in the following 

ways:

Alternative A lacks sufficient guidelines and components which would provide for adequate 

restoration in wilderness, address invasive species, and support social and natural qualities of 

wilderness character. If these aspects of wilderness character are not maintained, there would 

likely be long-term adverse impacts on natural quality of wilderness character. Alternative A also 

does not provide management direction that would increase restoration activities on adjacent 

lands to existing wilderness which could cause a long-term decline in the natural quality of 

wilderness character inside wilderness.

There are new guidelines and components under alternatives B-modified, B, C, and D which are 

not addressed under existing forest plan direction. This revised direction would be beneficial to 

aspects of wilderness character not addressed under alternative A, including providing for 

restoration in wilderness, addressing invasive species, and supporting social and natural qualities 

of wilderness character.

Since Alternatives B, B-modified and D have similar fire management direction inside 

wilderness; beneficial impacts to maintain and enhance wilderness character would be similar 

across these three alternatives. A large portion of the existing designated wilderness areas are 

within the wildfire maintenance zone, where fire risk is lower and generally favors managing 

wildfires to meet resource objectives. Plan direction for alternatives B, B-modified, C, and D 

would encourage restoring fire as an ecological process when it is safe to do so in the wildfire 

maintenance zone. Alternative C, although it would result in some benefits to wilderness 

character under the Wildfire Maintenance Zone, it would be the least beneficial to managing 

wildfire while protecting and enhancing wilderness characteristics out of all the plan revision 

alternatives.

Management direction provided under alternative D for fire, fuels, and restoration on lands 

adjacent to wilderness areas would likely have the most beneficial effect to protection of 

bordering wilderness areas. This is due to the increased pace and scale of restoration activities 

that would occur on lands adjacent to existing wilderness areas. 

Recommended Wilderness

The Forest Supervisor for the Inyo National Forest is required by the 2012 Planning Rule40 to 

“identify and evaluate lands that may be suitable for inclusion in the National Wilderness 

Preservation System, and determine whether to recommend any such lands for wilderness 

designation.” Any lands the Forest Supervisor recommends for wilderness designation through 

forest plan revision would be a preliminary administrative recommendation, and are referred to as

“recommended wilderness” below.

 40 36 CFR 219.7 (v)
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

534

Analysis and Methods

The analysis area for effects includes recommended wilderness in alternatives B, B-modified, and 

C and effects under alternatives A and D in the absence of wilderness recommendations. The 

timeframe for the environmental consequences is dependent upon whether the preliminary 

administrative recommendations are addressed by the U.S. Congress. The timeframe for the 

environmental consequences related to any recommended wilderness would be the expected life 

of the forest plans, or 10 to 15 years, unless the recommended wilderness is designated by 

Congress, in which case the timeframe for environmental consequences would be the long term, 

or more than 20 years. 

Indicators and Measures

These indicators were developed in response to comments and to show how management is 

affected by recommended wilderness:

• Protection of wilderness character

• Ability to manage recommended wilderness areas

• Ability to conduct vegetation, fire, watershed and wildlife habitat management 

• Change in miles of system trails that allow mechanized transport within areas 

recommended for wilderness

Methods

This analysis includes a qualitative discussion of the effects of the proposed management 

direction of recommended wilderness areas, or lack thereof, in the different alternatives. 

Wilderness character, the Inyo’s ability to manage recommended wilderness, the Inyo’s ability to 

conduct fuels, fire and wildlife habitat management, and any change in the miles of system trails 

that allow mechanized transport within areas recommended for wilderness are all used to measure 

the effects of each alternative.

Affected Environment

The process to identify and evaluate lands on the Inyo National Forest that may be suitable for 

inclusion in the National Wilderness Preservation System is documented in appendix B: 

Wilderness Evaluation for the Inyo National Forest (volume 2). Appendix B also documents the 

process used for identifying which evaluated areas to analyze in one or more alternatives in the 

draft environmental impact statement. Detailed information and maps for each area included as 

recommended wilderness in the analysis, and the rationale for areas or portions of areas that are 

not included in the analysis, can also be found in appendix B.

Alternatives A and D do not include any new recommended wilderness. Alternatives B and Bmodified include four new recommended wilderness areas totaling 37,029 acres on the Inyo 

National Forest. Alternative C includes 24 new recommended wilderness areas totaling 315,531 

acres. 

Existing designated wilderness comprises almost 46 percent of the Inyo National Forest, for a 

total of 964,360 wilderness acres. There are nine existing designated wilderness areas, either in 

whole or part, within the administrative boundary of the national forest. Existing designated 

wilderness areas are described in the previous section (“Designated Wilderness”).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

535

Overview of Recommended Wilderness Proposed in Alternatives B, B-modified, and C

Alternatives B and B-modified

In alternatives B and B-modified, four areas totaling 37,029 acres are recommended as wilderness 

additions, all of which adjoin existing designated wilderness as shown in table 89.

Table 89. Recommended wilderness additions adjacent to existing designated wilderness in 

alternatives B and B-modified

Recommended Wilderness Addition Size (acres)

Piper Mountain Wilderness Addition 11,840

South Sierra Wilderness Addition 17,622

White Mountains Wilderness Addition – East 2,505

White Mountains Wilderness Addition – West 5,062

Special Uses and Other Uses in Recommended Wilderness under Alternatives B and Bmodified

Wilderness recommendations under alternatives B and B-modified include one known water right 

in the Piper Mountain Addition. Additionally, there may be a special use facility for a creek 

bypass pipeline intake in alternatives B and B-modified in the South Sierra Wilderness Addition 

East (1). There is also a private inholding within the White Mountains Wilderness Additions 

(West). 

There are two existing grazing allotments within recommended wilderness polygons in 

alternatives B and B-modified: one within the White Mountains Additions (East) and one within 

the South Sierra Wilderness Addition – East (1).

Alternative C

In alternative C there are 24 areas totaling 325,352 acres of new recommended wilderness, of 

which 9 areas (73,473acres) are adjacent to existing designated wilderness and 15 areas 

(251,879acres) are not. Approximately 23 percent of the new recommended wilderness areas in 

alternative C is adjacent to existing designated wilderness as shown in table 90.

Table 90. Recommended wilderness additions adjacent to existing designated 

wilderness in alternative C

Recommended Wilderness Addition Size (acres)

Ansel Adams Wilderness Addition – Northeast 7,046

Golden Trout Wilderness Addition – East 6,008

Inyo Mountain Wilderness Addition 7,479

Piper Mountain Wilderness Additions (1) 11,313

Piper Mountain Wilderness Additions (2) 2,726

South Sierra Wilderness Additions – East (1) 25,469

South Sierra Wilderness Additions – East (2) 1,514

White Mountains Wilderness Additions – East 3,288

White Mountains Wilderness Additions – West 8,630
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

536

Approximately 77 percent of new recommended wilderness areas on the Inyo National Forest are 

not adjacent to existing designated wilderness as shown in table 91.

Table 91. Recommended wilderness not adjacent to existing designated 

wilderness in alternative C

Recommended Wilderness Size (acres)

Adobe Hills 10,354

Deadman Canyon 15,910

Deep Springs North 34,716

Dexter Canyon 8,740

Glass Mountains 35,749

Huntoon Creek 8,876

Marble Canyon 15,867

Marble Creek 13,707

Mazourka Peak 42,927

McBride Flat 10,621

Pizona-Truman Meadows 19,957

Redding Canyon 8,906

Silver Creek 8,630

Soldier Canyon 11,024

South Huntoon Creek 5,895

Special Uses and Other Uses in Recommended Wilderness under Alternative C

Wilderness recommendations under alternatives C include one known water right in the Piper 

Mountain Addition and seven additional known water rights within the Ansel Adams, Deadman 

Canyon, and Marble Creek Additions. Additionally, there may be up to 28 water-related special 

use facilities that are within wilderness additions under alternative C. Some of these facilities may 

only be in a proposed status and may not actually exist. There are also two private inholdings in 

alternative C: one within the White Mountains Wilderness Additions (West) and one within the 

Glass Mountain Addition.

There are a total of six grazing allotments within recommended wilderness polygons in 

alternative C. Three of these allotments have no known associated improvements associated with 

the allotments, only grazing activities (these are within the White Mountains Additions (East), the 

South Sierra Wilderness Addition – East (1), the Deadman Canyon Addition). There are three 

grazing allotments with associated improvements such as fences and water troughs (these are 

within the Dexter Canyon Addition, Golden Trout Addition, and South Sierra Addition – East (2).

There are several existing outfitter and guide special use permits under three of the proposed 

wilderness additions in alternative C in the Ansel Adams, Glass Mountain, and Marble Creek 

Additions. These outfitter and guides operate under special use permit for activities such as 

hunting and backpacking.

Under alternative C there is one known active mining claim within the Pizuna-Truman Meadows 

addition and an old mining site in the Marble Creek Addition where some mining activity may 

still occur.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

537

There are wild horse management areas within five of the recommended additions in alternative 

C within Adobe Hills, Huntoon Creek, McBride Flat, Pizona-Truman Meadows, and the South 

Huntoon Creek Additions. There are no known existing structures associated with the wild horse 

management areas.

Environmental Consequences of Recommended Wilderness

Consequences Common to Alternatives B, B-modified, and C

Making the preliminary wilderness recommendation for a forest plan revision does not create or 

designate a wilderness. Congress must pass legislation designating wilderness. The plan direction 

for recommended wilderness would protect the values that make the area suitable for wilderness 

designation.

Recommending wilderness areas adjacent to existing designated wilderness would have the 

beneficial effect of enhancing wilderness character because existing wilderness areas would be 

buffered by the four recommended wilderness areas under alternatives B and B-modified, and 

nine under alternative C. The recommended additional acreage adjacent to these existing 

wilderness areas would serve to buffer the existing wildernesses from sights and sounds of 

humans (motor vehicle sounds, chainsaws, etc.), thereby benefiting wilderness characteristics of 

solitude on the edges of the existing wilderness areas. This would be the most beneficial under 

alternative C since there are nine adjacent recommended additions; however, conversely, 

alternative C also has an increased potential for large wildfires due to the challenges of 

conducting restoration activities in wilderness (see “Terrestrial Vegetation Ecology” section), and

this could also put existing wilderness resources at risk, to the greatest extent in alternative C.

Recommending wilderness areas adjacent to existing designated wilderness could have beneficial 

effects to wildlife by providing additional contiguous habitat for at-risk species, thereby 

improving the natural characteristics of existing wilderness areas. Alternative C would add the 

most acres of contiguous habitat, followed by alternatives B and B-modified. Benefits to 

contiguous wildlife habitat would be the most beneficial under alternative C since there are nine 

adjacent recommended additions. However, recommended wilderness direction also has potential 

to negatively impact contiguous wildlife habitat by limiting the types of restoration activities that 

could occur (see “Terrestrial Vegetation Ecology” section) in newly recommended wilderness 

areas, to the greatest the greatest extent under alternative C.

Recommended wilderness areas under plan revision alternatives could serve to also benefit 

wildlife and at-risk species by precluding management activities (like timber harvest) that might 

reduce habitat quality, and by limiting mechanized and motorized activities such as mountain 

biking and off-highway-vehicle use that could cause breeding disturbance. This conservation 

approach has long been employed as a means to help protect natural resources from degradation 

associated with human actions. Wilderness management areas are also locations where wildfires 

are often managed to meet resource objectives, such as restoring fire as a key ecosystem process 

in Sierra systems, which can substantially improve wildlife habitat condition, heterogeneity, 

structural diversity, and species composition of vegetation (MA-WILD-DC-01; MA-WMZ-STD01 to 02). However, recommended wilderness direction has the potential to also negatively 

impact wildlife (both terrestrial and aquatic species) by limiting restoration activities and by 

continuing or increasing disturbance from wilderness users, to the greatest extent under

alternative C (see “Wildlife, Fish and Plant” and “Fire Trends” section).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

538

Climate change has been associated with and will continue to influence shifts in ecological 

processes and patterns, and species ranges, movements, and phenologies among other newly 

emerging patterns (Cole and Yung 2012, Bradley et al. 1999, Safford et al. 2012)). While 

wilderness recommendations could serve to benefit terrestrial and aquatic wildlife species, and 

offer protection from impacts of climate change, protection of species and community 

assemblages may be limited to a snapshot in time and may not be protective in the future if 

natural processes aren’t sufficient to maintain habitat conditions due to factors such as climate 

change, large high-intensity fire, nonnative species invasions (like invasive plants and barred 

owl), insect outbreaks, and pathogens, among others (See Wildlife, Fish and Plants section).

Alternative C presents the greatest challenge to maintaining wildlife habitat conditions to desired 

conditions since restoration activities in recommended wilderness would be more much more 

difficult under this alternative. Alternatives B and B-modified would provide a balance of 

ecological benefits from adding four additional wilderness areas, while still allowing for 

restoration activities to occur across much of the rest of Inyo National Forest.

None of the recommended wilderness areas in alternatives B, B-modified, or C intersect an 

existing National Forest System road or motorized trail. The process used to identify possible 

suitable wilderness areas took into account whether an area had existing system roads, and 

buffered those roads and removed the buffered area from the polygons (cherry stem roads; see 

volume 2, appendix B). Therefore, the impact of moving motorized users outside of the 

recommended wilderness areas to other areas of the national forest would be minimal; however, 

there may be an effect on access by mountain bikes in alternative C, which could potentially 

displace mountain bikers to other areas. However, given the topography and sandy soil type of 

these trails, the likelihood that this would be an adverse impact is low since very little mountain 

bike use is known to occur on the affected trails. Changing to recreation opportunity settings 

under all plan revision alternatives are displayed in table 78 in the “Sustainable Recreation and 

Scenery” section. There are no other known changes in recreation activities associated with the 

recommended wilderness areas, therefore it is not anticipated that the recommended wilderness 

areas would have impacts to increasing recreation use in non-wilderness areas.

Recreation Settings and Opportunities, Access, and Recreation Management

Consequences Specific to Alternative A

No additional wilderness acreage is recommended under alternative A; however, not 

recommending additional wilderness now, may limit the amount of area that would be 

recommended for designation by Congress in the future. Once inventoried and analyzed for 

potential wilderness recommendation, areas not selected for such recommendation may be 

managed for other purposes in the future which could diminish their wilderness character.

Since there are no recommended wilderness areas under alternative A, there would be no 

reduction in acres of motorized recreation opportunity spectrum settings, which would be

beneficial to motorized recreation settings because motorized opportunities would remain status 

quo. There would also be no change to mechanized access (mountain bikes), so mechanized trail

access eliminated under alternative C would remain under alternative A. This would additionally 

be beneficial to the potential of future mechanized and motorized access, as trails could be added 

in the future in the absence of the recommended additions.

With limited staffing, declining budgets, and almost a million acres of existing wilderness to 

manage, an absence of recommended wilderness areas would have a small benefit of enabling 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

539

recreation management to focus law enforcement and education efforts on existing wilderness 

areas. This would also allow existing trails to be maintained using mechanized equipment, which 

is a much more efficient means to maintain trails. However, in the absence of any recommended 

wilderness, there would no long-term social or ecological benefits derived from new wilderness 

designation.

Consequences Specific to Alternatives B and B-modified

Alternatives B and B-modified identify four areas on the Inyo National Forest as administrative 

recommendations for inclusion in the National Wilderness Preservation System (South Sierra 

Wilderness – East Addition; the White Mountains Wilderness Additions; and the Piper Mountain 

Wilderness Addition). The four areas are adjacent to existing designated wilderness area 

boundaries. These areas would be managed to retain their social and ecological wilderness 

characteristics and other identified features of value until their designation as wilderness or other 

use by Congress (MA-4WLD-DC, MA-RWLD-STD, MA-RWLD-SUIT, MA-RWLD-GOAL). 

General desired conditions, guidelines, and suitability defined in the Revised Forest Plan would 

also apply to the recommended wilderness areas until and unless such time as Congress 

designates the areas for other use (DA-WILD-DC, DA-WILD-GDL, and DA-WILD-GDL). 

The recreation opportunity spectrum map reflects the recreation opportunities settings associated 

with the recommended wilderness areas (see maps in volume 4). Recommended additions under 

alternatives B and B-modified would result in expanded wilderness recreation opportunities for 

nonmotorized users seeking backcountry day-use and overnight opportunities. There would be a 

slight decrease in motorized recreation opportunities from the current plan (alternative A) due to 

the change in recreation opportunity spectrum settings; however, this impact is considered 

negligible since it would not result in any closures of motorized routes. There would be no 

change to mechanized recreation opportunities (mountain bike) because none of the four 

recommended wilderness areas would close off any trails to mountain bikes. Recommended 

wilderness areas would cease to allow mining operations, timber production, or motorized use 

except as specifically provided for in the Wilderness Act. 

There are no known climbing areas with fixed anchors in any of the recommended wilderness 

areas in the preferred alternative. Climbing as a recreation activity is discussed in the Wilderness 

Evaluations (volume 2, appendix B). The use of power drills would be prohibited by law in 

recommended wilderness, however the rock climbing activities would still be allowed as a form 

of primitive recreation under the Wilderness Act 1964. Therefore, wilderness recommendations in 

the draft plan would not affect existing climbing opportunities, it would only prohibit the 

potential for developing future climbing routes that use fixed anchors.

Hunting opportunities in recommended wilderness areas under alternatives B and B-modified

would have minimal impacts since these opportunities would still be allowed in wilderness. There 

is one known wildlife guzzler in recommended wilderness under this alternative, yet it would still 

be considered feasible for the Inyo to continue to maintain this guzzler if mechanized and 

motorized access was not approved under a minimum requirements decision. See the discussion 

under the “Special Uses and Other Uses” section for a more detailed description of impacts to 

guzzlers. 

Consequences Specific to Alternative C

Alternative C includes 24 recommended wilderness areas for a total of 315,531 acres to be 

considered for inclusion in the National Wilderness Preservation System. These recommended 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

540

wilderness areas would be managed in the same manner as designated wilderness to maintain 

their wilderness characteristics, including their natural conditions, opportunities for solitude or 

primitive and unconfined recreation, scenic beauty, and identified special features. 

The Ansel Adams Addition under alternative C is in close proximity to concentrated recreation 

use and facilities, and highways in the south and north portions of the area. The proximity to 

concentrated recreation use and highways would reduce opportunities for solitude in the 

recommended wilderness and could cause negative impacts to that nonmotorized recreation 

setting.

The Wilderness Act specifies wilderness “shall be administered for the use and enjoyment of the 

American people in such manner as will leave them unimpaired for future use as wilderness, and 

so as to provide for the protection of these areas, the preservation of their wilderness character, 

and for the gathering and dissemination of information regarding their use and enjoyment as 

wilderness.” Since the Inyo National Forest currently has just two backcountry rangers to cover 

approximately 1 million acres of existing wilderness, adding such a substantial amount of acreage 

under alternative C would limit opportunities for visitor contacts to inform, educate, and regulate 

activities, as appropriate in both new and existing wilderness areas. Additionally, with substantial 

acreage already allocated to wilderness, trail maintenance and development is challenging. It is 

especially difficult for forest staff to rebuild trails after major damage occurs because of the lack 

of roaded access, and the inability to use motorized or mechanized equipment. This would likely 

cause negative impacts to nonmotorized trail access. 

The Inyo National Forest already has a documented problem with motorized incursion into 

existing wilderness as documented through law enforcement contacts. Inyo staff recorded 51 

incidents of wilderness trespass with a motorized vehicle, and one with a bicycle, from 2010 

through 2016. These incidents were recorded as “ongoing” meaning there was evidence of more 

than one occurrence of trespass at a particular site, such as tire tracks, or vandalized blocking 

installations. Much of this trespass occurs in areas that are within 100 feet of highways, or 

adjacent to towns and ski areas. In many cases, the wilderness trespass was unintentional – the 

entirety of wilderness boundaries can’t be marked, and users are often unaware of the location, 

existence, or rules of wilderness. Adding additional acreage of wilderness to monitor for 

incursions would increase demands for law enforcement patrols and possibly reduce law 

enforcement presence in existing wilderness which could have negative impacts on maintaining

and enhancing wilderness character in existing wilderness.

Alternative C would be the most beneficial to nonmotorized recreation opportunity settings by 

providing increased opportunities for solitude. Although the recommended wilderness areas under 

alternative C would not impact any existing motorized roads or trails, motorized restrictions that 

would likely be imposed in the recommended wilderness areas would limit any future 

development of off-highway vehicle recreation opportunities, to the greatest extent in alternative 

C.

Alternative C would have the greatest impact on mechanized access (mountain bikes) out of all 

the alternatives because of the additional recommended wilderness areas. There are six 

recommended wilderness areas in this alternative that contain 43 miles of system trails which 

currently allow mountain bike use. A plan component (MA-WILD-SUIT-04) makes mechanized 

transport unsuitable in recommended wilderness areas; therefore, trail access by mountain bikes 

would be decreased by 43 miles on system trails, which is a 9 percent reduction in nonmotorized 

trails open to mountain bikes compared to A, B, B-modified, and D. Given the topography and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

541

sandy soils of where these trails are located, only a minor impact to existing mechanized access 

would be expected under this alternative; however, the restrictions associated with wilderness 

designation would also limit any future development of mountain bike access.

There are no known climbing areas with fixed anchors in any of the recommended wilderness 

areas in alternative C. Climbing as a recreation activity is discussed in the Wilderness Evaluations 

(FEIS, Vol. 2, appendix B). The use of power drills would be prohibited by law in recommended 

wilderness, however the rock climbing activities would still be allowed as a form of primitive 

recreation under the Wilderness Act 1964. Therefore, wilderness recommendations in alternative 

C would not affect existing climbing opportunities; however, alternative C would have the 

greatest impact on prohibiting the potential for developing future climbing routes that use fixed 

anchors.

There could be negative impacts to hunting opportunities in recommended wilderness areas under 

alternative C if conditions of guzzlers deteriorated without mechanized and motorized access to 

guzzlers approved under a minimum requirements decision. See the discussion under the Special 

Uses and Other Uses Section for a more detailed description of impacts to guzzlers. There could 

be negative impacts on hunting opportunities if conditions of guzzlers deteriorated because 

wildlife would likely relocate to other areas to find water.

Consequences Specific to Alternative D

No areas are recommended for inclusion in the National Wilderness Preservation System in 

alternative D because the restrictions imposed on wilderness prohibit the use of motorized and 

mechanized equipment and would limit the increased pace and scale of mechanical restoration 

treatments, prescribed burning, and managing wildfires to meet resource objectives proposed in 

this alternative.

Environmental consequences under alternative D on recreation settings and opportunities, access, 

and recreation management would be similar to alternative A except for the following: The tradeoff in this alternative, like alterative A would be a lack of long term social and ecological benefits

in the absence of recommending new wilderness areas, and like alternative A, these lands could 

be susceptible to uses that would not be compatible with nonmotorized uses if kept in the existing 

management status. 

Vegetation, Fire, Wildlife Habitat, and Watershed Management 

The fire management zones that are analyzed for each alternative are described in detail in the 

“Fire Management and Smoke” section.

Consequences Specific to Alternative A

Because there would be no new wilderness recommendations under alternative A, this would 

allow the full suite of management tools to be available for vegetation and fuels management

activities. Landscape-level fuels and forest restoration treatments would be more likely to occur 

in those areas not recommended as wilderness in the absence of the wilderness recommendations; 

however, there would be no ecological or social benefits derived from recommending new

wilderness areas.

Consequences Specific to Alternatives B and B-modified

Wilderness designation does not preclude vegetation and fuels management, but it does make 

many of the usual management tools unavailable. Large-scale fuels treatments and forest habitat 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

542

restoration activities would be more limited in areas recommended for wilderness due to the 

management challenges of working in wilderness. However, under alternatives B and Bmodified, the ecological and social benefits to adding these adjacent wilderness areas would 

likely outweigh the management challenges of conducting fuels and vegetation management 

activities inside wilderness.

When wildfires start, or burn into wilderness, the tools available to manage those fires are more 

limited than outside wilderness; however, fire managers are still able to work with these 

limitations. Employing fire and fuels management activities where necessary would benefit the 

natural character of wilderness and ensure ecosystem protection inside recommended wilderness 

areas. Wilderness just requires a different approach from wildfire response in areas recommended 

or designated as wilderness. Prescribed fire could still be used in recommended wilderness areas, 

when the benefits to overall wilderness character would be improved and documented in a 

minimum requirements analysis decision. 

The fire management zones that are analyzed for each alternative are described in detail in the 

“Fire Management and Smoke” section. In alternatives B and B-modified there are four fire 

management zones that would affect the four recommended wilderness areas (table 92). The 

community wildfire protection zone and general wildfire protection zone emphasize fuel 

treatments that would likely have an adverse effect on wilderness characteristics; however, these 

would be necessary management tradeoffs to protect communities and resources. The wildfire 

restoration zone prioritizes ecological restoration, which could have short-term adverse effects on 

solitude and untrammeled wilderness characteristics, but the long-term benefits to the natural 

quality of wilderness character would outweigh any short-term negative impacts on solitude and 

untrammeled qualities. In areas in the wildfire maintenance zone, fire management activities 

would be likely to retain and have beneficial effects to existing wilderness characteristics because 

this zone emphasizes management of wildfires to meet resource objectives. This would allow 

long-term ecological benefits to the natural quality of wilderness character to occur under these 

alternatives, with alternative B slightly higher since it has higher percent in the wildfire 

maintenance zone.

Table 92. Percentage of area in fire management zones for areas in recommended wilderness, 

alternatives B and B-modified

Alternative

Wildfire 

Protection Zone

General Wildfire 

Protection Zone

Wildfire 

Restoration Zone

Wildfire 

Maintenance 

Zone

B 1 17 6 76

B-modified 2 43 4 51

Wildlife habitat connectivity would be enhanced between the existing and proposed wilderness 

areas. Such connectivity is important to maintaining wildlife corridors and bird migration routes.

The connectedness of open space, species habitat, and ecological processes are important to 

biodiversity and ecological integrity (Lindenmayer and Fischer 2013). The increased connectivity 

would likely benefit species richness.

Recommended wilderness polygons in alternatives B and B-modified would also help enhance 

the natural quality of wilderness by ensuring the functions of ecosystems are maintained in 

recommended areas. These ecosystems contain valuable hydrologic resources which would have 

a higher level of protection from unnatural disturbances, and allowed to have natural processes 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

543

maintained which would protect and enhance hydrologic resources. Acres of wildfires managed 

to meet resource objectives is expected to go up in all alternatives B and B-modified B. This will 

help reduce the risk of a large stand-replacing wildfire that can negatively affect hydrologic 

resources. 

There is a small amount of sage-grouse habitat (a species of conversation concern) within the 

White Mountain West addition in alternatives B and B-modified. This wilderness addition would 

benefit the natural quality of wilderness character by protecting sage-grouse habitat from uses 

that conflict with its habitat protection. Although the Inyo’s ability to manage this habitat would 

be limited to nonmechanized methods and vegetation management methods compatible with

wilderness policy, the benefits of protecting this area as wilderness outweigh the challenges of 

managing habitat for sage-grouse, particularly given the small amount of habitat inside the 

recommended addition. The impacts of managing sage-grouse habitat on wilderness character 

would be minimal given the small amount of habitat inside the addition.

Since only alternative B-modified includes development of conservation watersheds, there would 

be beneficial effects to Cottonwood-Crooked Creek Headwaters conservation watershed in the 

proposed White Mountain East and West additions because future development would be 

prohibited, which would maintain the watershed condition rating of relevant indicators. 

Consequences Specific to Alternative C

As mentioned under alternatives B and B-modified, wilderness designation does not preclude 

vegetation and fuels management, but it does make many of the usual management tools 

unavailable. Large-scale fuels treatments and forest habitat restoration would become 

increasingly difficult under alternative C given the large amount of acreage recommended for 

wilderness designation. Additionally, when wildfires start, or would burn into recommended 

wilderness, the normal tools available to manage those fires are limited. This could impede future 

fire management efforts to the detriment of resources both inside and outside recommended 

wilderness areas. Fire managers are able to work with these limitations, but they require a much 

different approach from wildfire response in areas not recommended or designated as wilderness.

A major wildlife habitat management issue on the Inyo National Forest is pinyon pine 

encroachment on sage-grouse habitat. Although recommended wilderness would provide some 

ecological benefits to sage-grouse habitat, it would also limit the Inyo’s ability to manage the 

habitat for conifer encroachment. Mechanical thinning of sage-grouse habitat would not be 

possible under this alternative and the challenges of managing the habitat for sage-grouse would 

likely outweigh the potential ecological benefits gained in this alternative due to the large amount 

of recommended wilderness acres recommended. In addition, impacts from restoration activities 

that would be required to adequately maintain sage-grouse habitat would impact the untrammeled

quality of wilderness character because conifer removal and prescribed fire activities would be 

evident. Prescribed fire impacts would persist for only short-term periods of time while hand 

thinning activities would be a long term impact on wilderness character because cut stumps 

would be visible for longer periods unless otherwise removed and burned. 

Recommending wilderness areas adjacent to existing designated wilderness could have beneficial 

effects to wildlife by providing additional contiguous habitat for at-risk species, thereby 

improving the natural characteristics of existing wilderness areas. Benefits to contiguous wildlife 

habitat would be the greatest under alternative C since there are nine adjacent recommended 

additions. However, recommended wilderness direction also has potential to negatively impact 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

544

contiguous wildlife habitat by limiting the types of restoration activities that could occur (see 

Terrestrial Vegetation Ecology section), thereby leaving these areas more prone to the risk of 

large catastrophic wildfires. 

In alternative C, there are three fire management zones as shown under table 93: The Wildlandurban Intermix Defense Zone, which is the same as in alternative A; the Wildfire Maintenance 

Zone is the same as in alternatives B and D; and the General Wildfire Zone for the remaining 

area. The General Wildfire Zone would have an increased emphasis on managing wildfire to meet 

resource objectives and increased use of prescribed fire in fire adapted ecosystems. Of the three 

fire management zones in alternative C, the Wildfire Maintenance Zone would be most likely to 

retain wilderness characteristics where wildfires can be safely managed to restore fire as an 

ecosystem process. The General Wildfire Zone may make it more difficult to evaluate wildfire 

risk resulting in slightly less wildfires managed to meet resource objectives within recommended 

wilderness areas. Fewer fuels reduction treatments outside of but adjacent to wilderness area 

would result in higher risks to managing wildfires.

Table 93. Percentage of area in fire management zones for areas in recommended 

wilderness, alternative C

Wildland-urban 

Intermix Defense Zone

General Wildfire 

Zone

Wildfire Maintenance 

Zone

less than 1 59 41

Alternative C would increase the range of elevations and increase the biodiversity of areas 

recommended for inclusion in the National Wilderness Preservation System, which would likely 

benefit wildlife species affected by impacts from climate change. The recommended additions to 

the Ansel Adams Wilderness contain the aspen ecosystem type, which supports very diverse 

understory plant and bird communities. There would be benefits to both ecological resources and 

the natural qualities of wilderness as a result of the wilderness additions under alternative C, but 

with a limited means to conduct restoration activities in proposed wilderness areas, these new 

wilderness resources could be threatened by catastrophic wildfires and tree mortality. 

Recommended wilderness polygons in alternative C (like alternatives B and B-modified) would 

also enhance the natural quality of wilderness by ensuring the functions of ecosystems are

maintained in recommended areas. These ecosystems contain valuable hydrologic resources 

which would have a higher level of protection from unnatural disturbances, and allowed to have 

natural processes maintained which would protect and enhance hydrologic resources. Acres of 

wildfires managed to meet resource objectives is expected to go up in all alternatives, which 

would help reduce the risk of a large stand-replacing wildfire that can negatively affect 

hydrologic resources. However, there would also be management challenges to implementing 

restoration activities with the large number of recommended wilderness areas in alternative C, 

due to the limited tools available to conduct restoration. This could put ultimately put wilderness 

resources at risk.

Consequences Specific to Alternative D

In the absence of wilderness recommendations in alternative D, an increased pace and scale of 

mechanical restoration treatments, prescribed burning, and managing wildfires would help meet 

resource objectives proposed in this alternative. A full suite of management tools would be 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

545

available to conduct fuels, fire management, and restoration activities; however, there would be 

no ecological or social benefits derived from recommending wilderness areas. 

Management direction under alternative D provides for increased restoration activities, which 

would have beneficial impacts to protecting existing adjacent wilderness areas. Although this 

positive impact is also highlighted under the existing wilderness section, it is noted in the 

recommended wilderness section because in the absence of any wilderness area 

recommendations; alternative D would offer the highest level of protection of adjacent borders of 

existing wilderness resources because of the increased pace and scale of restoration activities. 

Those areas not recommended as wilderness would be the more likely to undergo fuels or 

vegetation treatments under this alterative, thereby serving as a buffer to prevent catastrophic 

wildfires and tree mortality in bordering wilderness areas. This could have short-term impacts on 

wilderness solitude in border areas of adjacent wilderness, but the long-term benefits would 

outweigh the short-term impacts. Beneficial impacts are considered minor since they are only in 

the context of border zones of adjacent wilderness areas. 

Special Uses and Other Uses

Consequences Common to Alternatives B, B-modified, and C

Wilderness recommendations under alternatives B, B-modified, and C overlap with several

existing water rights. There is one known water right in the Piper Mountain Addition under 

alternatives B, B-modified and C, and seven additional known water rights under alternative C

within the Ansel Adams, Deadman Canyon, and Marble Creek Additions. Existing valid water 

rights would not be negatively impacted since they would be allowed to continue in the 

recommended wilderness areas. There would be minimal impacts to wilderness character as long 

as these water rights would not require motorized or mechanized access or maintenance. 

There may be a special use facility for a utility company’s water diversion intake in alternatives 

B, B-modified and C in the South Sierra Wilderness Addition East (1). Under alternative C, there 

may be up to 28 water-related special use facilities that are within wilderness additions. Some of 

these facilities may only be in a proposed status and may not actually exist. These existing special 

use developments would not be adversely impacted since they would be allowed to continue as 

long as access and maintenance follow wilderness direction and policy, which generally means 

nonmechanized and nonmotorized access and maintenance. Although these special use facilities 

would not improve wilderness character, they would only minimally affect the undeveloped 

quality of wilderness character where facility structures could be observed. The tradeoff would be 

that wilderness designation could increase the cost and complexity of maintaining those facilities 

because of the need to access by foot or horse and use nonmechanized means of maintenance. As 

a result, the annual operating costs to the current permittee would have the potential to increase 

under these conditions, to the greatest extent in alternative C. The extent of these potential cost 

increases is uncertain at this programmatic level.

There is one known existing wildlife guzzler in alternatives B, B-modified and C within the 

recommended Piper Mountain (1) Addition. Another four known guzzlers are in areas that are 

recommended for wilderness only in Alternative C. In both alternatives the existence of guzzlers 

would be not be adversely affected since existing uses can remain intact and there are plan 

components and standards (MA-RWLD-DC and MA-RWLD-STD) that would minimize impacts 

related to existing infrastructure in recommended wilderness. While guzzlers themselves may not 

be considered inconsistent with recommended wilderness management, the motorized access and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

546

mechanized means to maintain guzzlers would not be allowed in the recommended wilderness 

areas unless otherwise authorized under a minimum requirements decision. If not authorized, 

maintenance of guzzlers could prove more difficult under these conditions and could negatively 

impact the future conditions of the guzzlers. This would be a more substantial impact in 

alternative C since maintaining five guzzlers could prove difficult and costly, and somewhat 

minimal under alternatives B and B-modified since maintaining one guzzler under these 

conditions would be feasible. Deteriorated guzzler conditions could occur under Alternative C 

which could ultimately negatively impact wildlife that depends upon these guzzlers as well as 

hunting opportunities for large game.

The existence of the guzzlers in recommended wilderness would be a minimal impact to 

wilderness character since they are low profile and typically underground. There would be shortterm impacts on the undeveloped quality of wilderness if motorized access or mechanized 

maintenance was authorized under a minimum requirements decision; and these short-term 

impacts would likely happen on an annual basis during needed maintenance activities.

Under alternatives B, B-modified, and C there is a private inholding within the White Mountains 

Wilderness Additions (West). Under Alternative C there is an additional private inholding in the 

Glass Mountain Addition. Existing inholdings would not be negatively impacted since the use 

would be allowed to continue in the recommended wilderness areas. There would be minimal 

impacts to wilderness character as long as the inholdings do not require motorized or mechanized 

access. 

There are two existing grazing allotments within recommended wilderness polygons in

alternatives B, B-modified, and C; one within the White Mountains Additions (East) and one 

within the South Sierra Wilderness Addition – East (1). There are no permitted structures or 

improvements associated with these allotments, only grazing activities. Under alternative C there

is one additional grazing allotment with no improvements and three grazing allotments with

improvements. There would be no adverse impacts to any of these allotments since existing 

grazing use would be allowed to continue in recommended wilderness. There may be economic 

impacts on the allotments as a result of the requirement for nonmotorized and nonmechanized 

access and maintenance, which are also discussed under the “Forest Benefits to People and 

Communities” section, “Economic Conditions.” Overall, this change in access would prohibit 

motorized vehicle use for maintenance of stock water developments, salt placement and restrict 

installation of new range improvements (such as water troughs) unless approved following a 

minimum requirements decision. Overall, the annual operating costs to the current permittees 

would be expected to increase under these conditions. Given the acreages identified for 

recommendation in each alternative, the adverse effects under alternative C, if designated by 

Congress, would be greater than alternatives B and B-modified. The extent of these effects is 

uncertain at this programmatic level.

There would be minimal impacts to wilderness character from the three allotments without 

improvements if these allotments are monitored and administered to standards that protect 

wilderness character. Grazing would impact aspects of solitude, however, this impact would be 

considered minimal given that existing grazing activities are permitted under the Wilderness Act, 

so the public is accustomed to this use. The existing developments under the three grazing 

allotments in alternative C would have impacts to the undeveloped qualities of wilderness

character, but these impacts would be relatively small since they would not be modern

improvements, but more traditional developments like troughs and fences. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

547

Under alternatives B, B-modified, and C, tribal activities could still occur within areas 

recommended as wilderness. Some tribal activities such as gathering and ceremonial uses could 

become more restricted, to the greatest extent under alternative C, but no motorized routes were 

included in any of the recommended wilderness areas, therefore all authorized motorized access 

would remain to cultural sites and gathering areas. Potential impacts to gathering and ceremonial 

uses would be minimized since revised forest plan direction ensures that management plans for 

wilderness areas would include tribal perspectives (TRIB-FW-DC-01) and attempt to incorporate 

traditional ecological knowledge (TRIB-FW-DC-04) and associated traditional practices (TRIBFW-DC-03). Impacts to tribal uses is discussed in greater detail in the “Tribal Relations and 

Uses” section, Environmental Consequences. 

Consequences Specific to Alternative C

There are several existing outfitter and guide special use permits under three of the proposed 

wilderness additions in alternative C. These outfitter and guides operate under special use permit 

for activities such as hunting and backpacking. Management direction in the revised forest plan 

would not allow commercial enterprise unless it is specifically allowed under the Wilderness Act. 

The Wilderness Act does not prohibit outfitter and guides; however, it must be wilderness 

dependent in order to be appropriate. Recommended wilderness areas would negatively impact 

outfitter and guide activities only if those activities become prohibited as a consequence of 

wilderness designation. The outfitter and guide activities, if found appropriate, could continue 

and would not be negatively impacted. The outfitter and guide activities could have potential 

negative impacts on opportunities for solitude in the recommended wilderness areas if visitor use 

increases during outfitter and guide activities in recommended wilderness. 

Under alternative C there is one known active mining claim within the Pizuna-Truman Meadows 

addition. There is also an old mining site in the Marble Creek Addition where some mining 

activity may still occur. Mining operations could continue on valid existing mining claims after

wilderness designation, as long as wilderness characteristics are protected. Mechanical transport, 

motorized equipment, and access to utility corridors may be used after a determination that they 

are the minimum necessary. Use of mechanical transport or motorized equipment would likely 

affect the wilderness character. As long as these uses were allowed to continue there would be no 

impact to the mining claim. 

Under alternative C there are six wilderness additions that include wild horse management areas. 

In order to effectively manage these areas for wild horses, there could be a need to use helicopters 

and install fences and corrals in the future inside the recommended wilderness areas if approved 

under a minimum requirements decision. Management activities that require permanent 

improvements would likely have negative impacts on maintaining wilderness character; however, 

if the improvements were temporary, this could ensure that impacts to wilderness character would 

only be short term. If helicopter access is needed it would impact the undeveloped qualities of 

wilderness character and opportunities for solitude, but the impacts would be short term in nature 

and not a long term impact. 

Cumulative Effects

Reasonable and foreseeable actions on National Forest System lands include vegetation 

management, mining, recreation use, and reduction of fuels in the wildland-urban intermix. These 

actions could impact the wilderness characteristics of solitude, depending on how close and 

pervasive the actions are, although typically just sights and sounds within the recommended 

wilderness area are considered when determining effects to wilderness characteristics. For 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

548

example, vegetation management activities such as timber harvesting adjacent to recommended 

wilderness area may increase the sights and sounds of logging equipment such as chainsaws and 

mechanized equipment within the recommended wilderness area, but because it is outside of the 

recommended wilderness area, it is not considered to degrade the wilderness characteristic of 

solitude. However, an expansion of a developed recreation site adjacent to recommended 

wilderness could increase use levels within the recommended wilderness, which may result in 

cumulative impacts to solitude as the number of encounters with others could increase within the 

recommended wilderness area.

Population growth in California and Nevada is likely to increase recreation use of the Inyo 

National Forest including an increase in use within recommended wilderness. The effects of 

urbanization and population growth on recommended wilderness use and resource conditions are 

likely to be gradual and to extend well beyond the planning period. Increased recreation use may 

negatively impact wilderness characteristics, particularly the opportunity for solitude and natural 

quality. Examples of potential impacts include increased opportunity for crowding in certain 

locations, soil compaction or erosion, and threats to native plant species from the spread of 

noxious weeds from sources outside the wilderness.

Analytical Conclusions

Alternatives B, B-modified, and C recommend additional areas for inclusion in the National 

Wilderness Preservation System. Alternatives B, B-modified, and C also include plan direction 

that would protect the values that make the areas suitable for wilderness designation. Areas 

managed as recommended wilderness would be unsuitable for motorized and mechanized 

transport (mountain bikes) and would limit future development of mountain bike and off-highway 

vehicle recreation opportunities. There would be a slight decrease in motorized recreation 

opportunity settings in alternatives B and B-modified from the current plan (alternative A) due to 

the change in recreation opportunity spectrum settings; however, this impact is considered 

negligible since it would not result in any closures of motorized routes. Alternative C would have 

the greatest decrease in motorized recreation opportunity settings. Mechanized activities 

(mountain bikes) would also be the most affected under alternative C where recommended 

wilderness areas have existing trails open to mechanized transport. Alternatives B and B-modified 

would have the least impacts on mechanized and motorized opportunity settings while still having 

beneficial ecological and social benefits as a result of the four recommended wilderness areas. 

Alternatives B and B-modified would also result in expanded wilderness recreation opportunities 

for nonmotorized users seeking opportunities for solitude. Alternative C would have the most 

beneficial effect on nonmotorized recreation opportunity settings by providing increased 

opportunities for solitude through its 24 recommended wilderness additions. Although alternative 

C provides the highest amount of ecological and social benefits through the recommended 

additions, managing the additional acreage and multitude of other uses that occur in the additions 

would present management challenges for recreation management, fire and fuels management, 

and wildlife management. Although alternative C offers the largest blocks of undisturbed habitat, 

it also has the greatest potential for loss of habitat structure important to at-risk species due to 

increased potential for large wildfires (see “Terrestrial Vegetation Ecology” section). Alternatives 

B and B-modified strike a balance between ecological and social benefits, and the Inyo’s ability 

to adequately manage these areas while ensuring wilderness character is maintained.

Since there are no new recommended wilderness areas under alternatives A and D, this would 

allow the Inyo staff to focus on management of existing wilderness areas and a full suite of 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

549

management tools would be available to conduct fuels and fire management in both alternatives;

and a focus on restoration activities in alternative D. In the absence of wilderness 

recommendations in alternative D, this provides the greatest opportunity of all alternatives for an 

increased pace and scale of mechanical restoration treatments, prescribed burning, and managing 

wildfires to meet resources objectives proposed in this alternative. However, without 

recommended wilderness in either of these alternatives, there would no long-term social or 

ecological benefits derived from recommending new wilderness areas. Although alternative D 

meets resource objectives, it fails to strike a management balance where desired conditions for 

restoration activates are met, but the ecological and social benefits of recommended wilderness 

areas are also considered. 

Large-scale fuels treatments and forest habitat restoration activities would be more limited in 

areas recommended for wilderness in alternatives B and B-modified, due to the management 

challenges of working in wilderness, but fire, fuels and habitat management objectives could still 

be achieved using prescribed burning and nonmechanized methods within recommended 

wilderness areas. Management limitations would be greatest challenge in alternative C and may 

hinder the Inyo’s ability to achieve fire, fuels, restoration, and habitat management objectives.

Alternatives B and B-modified have a mix of fire management zones in the recommended

wilderness areas which take into account fire risk to communities and meeting resource 

objectives. Alternative B would better meet desired conditions for maintaining and enhancing 

wilderness character; however, alternative B-modified still has beneficial impacts to maintaining 

wilderness character. Alternative C includes a substantial portion of the recommended wilderness 

in the general wildfire zone where there is a wide range of fire risk. Limitations on the use of 

mechanized equipment would make it difficult to manage some wildfires to meet resource 

objectives due to the existing levels of fuels within recommended wilderness areas coupled with 

fewer areas of fuel reduction between wilderness and communities. This could result in negative 

impacts to wilderness character and would not achieve desired conditions for fire and fuels 

management. 

Eligible and Suitable Wild and Scenic Rivers

Background

The National Wild and Scenic Rivers System was created by Congress in 1968 to preserve certain 

rivers with outstanding natural, cultural, and recreational values in a free-flowing condition for 

the enjoyment of present and future generations. The Wild and Scenic Rivers Act,

41 which 

established the system, is notable for safeguarding the special character of these rivers, while 

recognizing the potential for their appropriate use and development. It encourages river 

management that crosses political boundaries and promotes public participation in developing 

goals for river protection.

The 2012 Planning Rule requires the Forest Service to conduct an inventory of rivers and 

determine wild and scenic river eligibility and classification during land and resource 

management plan development or revision as outlined in the Wild and Scenic Rivers Act. Section 

5(d)(1) of the rule states:

In all planning for the use and development of water and related land resources, 

consideration shall be given by all federal agencies involved to potential national wild, 

 41 Public Law 90-542; 16 U.S.C. 1271 et seq.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

550

scenic and recreational river areas, and all river basin and project plan reports submitted 

to the Congress shall consider and discuss any such potential. The Secretary of the 

Interior and the Secretary of Agriculture shall make specific studies and investigations to 

determine which additional wild, scenic and recreational river areas within the United 

States shall be evaluated in planning reports by all federal agencies as potential 

alternative uses of the water and related land resources involved.

The Planning Rule specifically requires that during plan development or revision, river eligibility 

must be identified unless an inventory has been completed and no changed circumstances or new 

information warrant further review. The rule also requires the Forest Service to manage those 

eligible and suitable rivers to protect the values that support their inclusion in the National Wild 

and Scenic River System until Congress makes a final determination on their designation.

Analysis and Methods

The process used to identify and evaluate rivers for their potential eligibility is found in the Forest 

Service Land Management Planning Handbook 1909.12, chapter 80. This will be referred to as 

the Wild and Scenic Rivers Evaluation Handbook. This chapter of the handbook contains 

guidance and instruction the agency must use to carry out the direction contained in the Planning 

Rule.

42 Additional guidance can be found in the Interagency Wild and Scenic Rivers Coordinating 

Council technical paper: The Wild & Scenic River Study Process (1999).

The evaluation process includes a sequence of four steps, three of which are required during plan 

revisions. The Wild and Scenic Rivers Handbook directs interdisciplinary teams to complete the 

evaluation of rivers to be studied for eligibility, considering best available scientific information 

and public input. The four steps include:

1. Inventory: The staff at each national forest must develop a systematic and 

comprehensive inventory of rivers to consider for their potential eligibility. Unless a 

previous systematic inventory of study rivers has been completed and eligible rivers 

identified, a comprehensive inventory will be developed to evaluate which rivers are 

eligible for inclusion in the National Wild and Scenic River System. If a systematic 

inventory of eligible rivers has been completed, the extent of the study process during 

plan development or revision can be limited to evaluation of any rivers that were not 

previously evaluated for eligibility and those with changed circumstances.

2. Eligibility determination: The next step is to determine stream eligibility for inclusion 

in the National Wild and Scenic Rivers System. To be eligible for designation, a river or 

stream must be free-flowing and possess one or more “outstandingly remarkable values.” 

Thus, the eligibility analysis consists of an examination of the river’s hydrology, 

including any man-made alterations, and an inventory of its natural, cultural, and 

recreational resources.

3. Classification: After the Forest Service determines if a river or portions of a river are 

eligible, each inventoried segment is then assigned a preliminary classification of “wild,”

“scenic,” or “recreational.” Classification is based on the level of human development of 

the shoreline, watercourse, and access at the time a river is found eligible.

4. Suitability: The fourth step, suitability, may happen during forest plan revision but is not 

required. A suitability study provides the basis for determining which rivers to 

 42 36 CFR 219.7(vi)
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

551

recommend to Congress as potential additions to the national system. This analysis and 

decision-making step will not be completed as part of the current forest plan revision 

process for the Inyo National Forests but will be completed in a future separate National 

Environmental Policy Act environmental review process.

The detailed steps that were used to develop the inventory for the evaluation (step 1) and the 

eligibility of rivers in the inventory (step 2) are described in appendix C: Wild and Scenic River 

Evaluation for the Inyo National Forest in the section titled “Process to Identify Rivers to be 

Considered for Eligibility for Inclusion in the National Wild and Scenic Rivers System.”

Additionally, in the “Results of the Evaluation” section of appendix C, the process is further 

explained.

Indicators and Measures

The indicator for wild and scenic rivers is total miles of newly eligible rivers versus reaffirmed 

eligible rivers by classification.

Under current management, rivers that were identified as eligible for inclusion in the National 

Wild and Scenic Rivers System in previous river studies have been, and will continue to be, 

managed to protect their eligibility until such time as suitability can be completed. During the 

current comprehensive wild and scenic river evaluation, additional rivers have been determined to 

be eligible. This indicator identifies the increase between what is currently being managed as 

eligible and what would additionally be managed as eligible as a result of the current wild and 

scenic river evaluation.

Affected Environment

The Inyo National Forest currently manages a total of approximately 90 miles of designated wild 

and scenic rivers. The extent of the National Wild and Scenic Rivers System currently includes 

approximately 12,708.8 miles of 208 rivers designated by Congress in 39 states and the 

Commonwealth of Puerto Rico; this is a little more than one-quarter of 1 percent of the nation's 

rivers. The National Wild and Scenic Rivers System is managed by the Forest Service, Bureau of 

Land Management, National Park Service, U.S. Fish and Wildlife Service, and portions of the 

National Wild and Scenic River System are also managed by states as shown in table 94 below.

Table 94. Total miles of rivers in the National Wild and Scenic River System by managing entity and 

classification, nationwide

Entity

Wild 

Classification

Scenic 

Classification

Recreational 

Classification Total

Forest Service 1,735.1 1,300.7 1,923.6 4,959.4

Bureau of Land Management 1,531.2 352.4 541.6 2,425.2

National Park Service 1,739.2 745.9 735.6 3,220.7

U.S. Fish and Wildlife Service 1,043.0 8.0 0 1,051.0

States 139.4 343.9 569.2 1052.5

Total 6,187.9 2,750.9 3,770 12,708.8

In California there are 23 designated wild and scenic rivers for a total of 1,999.6 miles, and the 

Forest Service manages about 69 percent of the total miles of designated wild and scenic rivers in 

California. The other 31 percent of wild and scenic rivers are managed by the Bureau of Land 

Management and the National Park Service.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

552

There are three designated wild and scenic rivers on the Inyo National Forest (see maps in 

volume 4). These rivers are included in the total mileage listed above of wild and scenic rivers in 

California (1,999.6 miles).

• The Cottonwood Creek Wild and Scenic River is 21.5 miles total length and is managed 

jointly with the Bureau of Land Management (BLM) with 17.4 miles on the Inyo National 

Forest and 4.1 miles on Bureau of Land Management-managed lands. This river was added 

to the National Wild and Scenic Rivers System in 2009.

• The Kern Wild and Scenic River is 151 miles total length and is managed jointly by the 

Inyo National Forest, Sequoia National Forest, and Sequoia and Kings Canyon National 

Parks with 124 miles on the national forests and 27 miles in Sequoia and Kings Canyon 

National Parks. This river was added to the National Wild and Scenic Rivers System in 

1987.

• The Owens River Headwaters Wild and Scenic River is 19.5 miles total length and is 

managed by the Inyo National Forest. This river was added to the National Wild and Scenic 

Rivers System in 2009.

There is one river that has been found to be suitable in previous wild and scenic river studies and 

have previously been recommended by the Forest Service for inclusion in the National Wild and 

Scenic River System. This river will continue to be managed as “recommended” wild and scenic 

rivers until a decision through an Act of Congress is made.

• The Middle Fork San Joaquin Recommended Wild and Scenic River is 22 miles from 

its headwaters at Thousand Island Lake to the Confluence with the North Fork San Joaquin 

River. Segment 1 (6 miles) and segment 2 (4.5 miles) are managed by the Inyo National 

Forest, segment 3 (2.5 miles) is jointly managed by the Inyo National Forest and Devil’s 

Postpile National Monument, and segment 4 (9 miles) is managed by the Inyo and Sierra 

National Forests.

Environmental Consequences to Eligible and Suitable Wild and Scenic Rivers

Resource Protection Methods

The 2012 Planning Rule specifically requires the Forest Service to manage those rivers that are 

found to be eligible and suitable to protect the values that provide the basis for their inclusion in 

the National Wild and Scenic River System until Congress makes a final determination on their 

designation. It requires that the forest plan provide plan components, including standards and 

guidelines, to provide for the protection of designated wild and scenic rivers as well as 

management of rivers found eligible or determined suitable for the National Wild and Scenic 

River system to protect the values that provide the basis for their suitability for inclusion in the 

system.43

The Forest Service Handbook 1909.12, chapter 80, section 84.2 states, 

A Responsible Official may authorize site-specific projects and activities on National 

Forest System lands within eligible or suitable river corridors only where the project and 

activities are consistent with all of the following:

 43 36 CFR 219.10
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

553

a) The free-flowing character of the identified river is not adversely B-modified the 

construction or development of stream impoundments, diversions, or other water 

resources projects.

b) Outstandingly remarkable values of the identified river area are protected.

c) For all Forest Service-identified study rivers, classification of an eligible river 

must be maintained as inventoried unless a suitability study is completed that 

recommends management at a less restrictive classification (such as from wild 

to scenic or scenic to recreational).

Any site-specific projects and activities that a responsible official authorizes on National Forest 

System lands within Forest Service-identified eligible or suitable river corridors must also be 

consistent with the interim protection measures outlined in section 84.3 of the handbook. These 

interim protection measures have been incorporated into the revised forest plan for the Inyo 

National Forest. These measures are the same in all plan revision alternatives, and only differ 

from alternative A. Additionally, the set of plan components developed for other aspects of the 

plan, such as riparian area plan components, will likely also provide for management of eligible 

and suitable rivers consistent with some parts of the interim protection measures. The eligible 

corridors include one-quarter mile from the normal high-water mark on each side of the river.

Consequences Common to all Alternatives

A total of 1,224.6 miles of river were included in the current inventory that was evaluated for 

wild and scenic river eligibility by the Inyo National Forest. Of that inventory, 245.5 miles of 

river had been evaluated in previous efforts and 128.3 miles had previously been determined to be 

eligible and have been managed to protect their eligibility. Of those eligible rivers, 70.9 miles 

were assigned a preliminary classification of wild, approximately 9.7 miles were assigned a 

preliminary classification of scenic, and 47.7 miles were assigned a preliminary classification of 

recreational (see table 95).

The current effort included development of a comprehensive inventory of rivers on the national 

forest. Rivers that had been previously evaluated for eligibility in earlier efforts were given a 

refreshed look to determine if there were any changed conditions or new information, and 

findings were adjusted accordingly. As shown in table 95, of the 128.3 miles that had previously 

been determined to be eligible, 124.4 miles were reaffirmed as eligible and 4.3 miles were 

determined not eligible. An additional 15.6 miles was determined to be eligible from previously 

studied inventory. Classifications were reviewed and adjusted if changed conditions were present. 

The updated classification findings on the previously evaluated rivers determined approximately 

74.9 miles were assigned a preliminary classification of wild, approximately 5.8 miles were 

assigned a preliminary classification of scenic, and 59.4 miles were assigned a preliminary 

classification of recreational, bringing the total number of miles of eligible rivers from previous 

inventory to 140.1 miles.

New inventory was evaluated to determine if free flow and any outstandingly remarkable values 

were present. Of the 979.1 miles of new inventory that were evaluated for eligibility, 

approximately 101.1 new miles were determined to be eligible. The classification findings on the 

newly evaluated rivers determined approximately 56.6 miles were assigned a preliminary 

classification of wild, 8.7 miles were assigned a preliminary classification of scenic, and 35.8

miles were assigned a preliminary classification of recreational. The detailed results of these 

evaluations can be viewed in “Appendix C: Wild and Scenic River Evaluation for the Inyo 

National Forest.” The total miles of river currently determined to be eligible for inclusion in the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

554

National Wild and Scenic Rivers System is approximately 241.2 miles (based upon 140.1 miles of 

updated miles of previously studied rivers and 101.1 miles of new inventory). The past and 

current findings from evaluations are summarized in table 95.

Table 95. Comparison of past and current wild and scenic river eligibility review findings in miles for 

the Inyo National Forest

Miles

Past Wild and 

Scenic

Eligibility 

Review 

Findings

Updated 

Findings on 

Previously 

Evaluated 

Rivers

Findings for 

New Inventory 

Evaluated for 

Wild and 

Scenic

Eligibility

Total Updated 

Findings

Change from 

Current Wild 

and Scenic

Evaluation

Inventoried 245.5 245.5 979.1 1,224.6 +979.1

Total Found 

Eligible 128.3 140.1 101.1 241.2 +112.9

Preliminary 

Classification: 

Wild

70.9 74.9 56.6 131.5 +60.6

Preliminary 

Classification: 

Scenic

9.7 5.8 8.7 14.5 +4.8

Preliminary 

Classification: 

Recreational

47.7 59.4 35.8 95.2 +47.5

None of the alternatives in the revised plan would be expected to have negative impacts on 

eligible wild and scenic rivers. The interim protection measures that have been incorporated into 

the revised forest plan would protect the free-flowing character and the identified outstandingly 

remarkable values for all eligible rivers. In addition, there are other aspects of the plan, such as 

riparian area plan components, which would likely also provide for the protection of the freeflowing character and associated outstandingly remarkable values for both eligible rivers. It is not 

anticipated that there would be adverse impacts on the Inyo’s ability to conduct management 

activities within the new eligible river sections since a significant portion of those wild portions 

of are within existing wilderness and would be managed in a similar manner.

Cumulative Effects

Additional eligible rivers may be identified in existing or future planning efforts or through 

separate river studies on adjacent national forests and for other agencies (Bureau of Land 

Management, National Park Service, and U.S. Fish and Wildlife Service) that manage the 

National Wild and Scenic Rivers System. There would be no negative cumulative effects 

expected to occur on designated or eligible wild and scenic rivers as a result of any of the 

alternatives.

Analytical Conclusions

For the Inyo National Forest, the required wild and scenic evaluation process resulted in 88

percent (112.9 miles) increase in the miles of river determined to be eligible. The results of the 

classification findings show a 85.4 percent (60.6 miles) increase in the miles of eligible rivers that 

will be managed as wild, a 49.5 percent (4.8 miles) decrease in the miles of eligible rivers that 

will be managed as scenic and an 99.6 percent (47.5 miles) increase in the miles of eligible rivers 

that will be managed as recreational. In all plan revision alternatives, the interim protection 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

555

measures that have been incorporated into the revised forest plan would protect the free-flowing 

character and the identified outstandingly remarkable values for all eligible rivers. Direction in 

the revised plan for all alternatives ensures that any project level planning in these eligible river 

corridors will be consistent with their preliminary classification and protect the values that 

provide the basis for their inclusion in the National Wild and Scenic River System until such time 

as a negative suitability determination is made or Congress makes a final determination on their 

designation.

Since the more than half of the increase in eligible miles are classified as wild and occur in areas 

designated as wilderness, there would be little to no effect on other activities as a result of the 

eligibility and classification findings compared to how these areas have been managed in the past. 

The increase in the miles of eligible rivers that would be managed as recreational and scenic 

would likely have negligible effects on other management activities when the benefits of 

protecting the free-flowing character of these rivers and outstandingly remarkable values are 

considered. 

Pacific Crest National Scenic Trail

Background

The National Trail System is composed of 30 congressionally designated trails (11 national scenic

trails and 19 national historic trails), which stretch for a hundred or thousands of miles each and 

more than 55,000 miles in total. National scenic and historic trails traverse wilderness, rural, 

suburban, and urban areas in 49 states connecting with every distinct ecological area or biome in 

the U.S. They protect crucial conservation areas and provide wildlife migration corridors, as well 

as education, recreation, and fitness for people of all ages.

The Pacific Crest National Scenic Trail was designated in 1968 by Congress as one of the original 

national scenic trails. The National Trails System Act44 directed that these long distance trails 

provide for maximum outdoor recreation potential and for the conservation and enjoyment of the 

nationally significant scenic, historic, natural, or cultural qualities of the areas through which such 

trails may pass. Citizen stewardship and volunteerism were recognized in the Act and have been 

an integral component of the planning, management, and maintenance of the trail.

Beginning in southern California at the Mexican border, the Pacific Crest Trail travels 2,650 

miles through California, Oregon, and Washington until reaching the Canadian border figure 33. 

First conceived in the 1930s, the trail traverses the highest elevations of the Sierra and Cascade 

mountain ranges and was designed to include portions of the historic John Muir and Skyline 

Trails. The Pacific Crest Trail is considered one of the most remote long distance trails with over 

54 percent of its path in designated wilderness. Oriented in a north-south direction, the Pacific 

Crest Trail is the only completed west coast national scenic trail.

 44 Public Law 90-543
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

556

Figure 33. The Pacific Crest National Scenic Trail

The selected route location for the 

Pacific Crest Trail was published in 

the Federal Register on January 30, 

1973. The route traverses portions of 

25 national forests, six national 

parks, seven Bureau of Land 

Management Field Offices, five

national monuments, one national 

scenic area, as well as, state and 

private lands in the states of 

California, Oregon, and Washington. 

The Regional Forester of the Pacific 

Southwest Region is the lead official 

for coordinating matters concerning 

the study, planning, and operation of 

the Pacific Crest Trail (Forest 

Service Manual 2353.04).

The “Pacific Crest National Scenic 

Trail Comprehensive Plan” was 

signed by the Chief of the Forest 

Service in 1982 and set forth 

direction to guide the development 

and management of the Pacific Crest 

Trail (USDA Forest Service 1982). 

The Pacific Crest Trail Corridor is 

administered consistent with the 

nature and purposes for which this 

National Scenic Trail was 

established—to provide for highquality scenic, primitive hiking and 

horseback riding opportunities, and 

to conserve natural, historic, and 

cultural resources along the corridor.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

557

The Comprehensive Plan directed that each “National Park, Bureau of Land Management District 

and National Forest will integrate the direction and guidance provided by the Comprehensive 

Plan into their respective land management planning processes.” Executive Order No. 13195, 

Trails for America in the 21st Century (2001), recognized the importance of “Protecting the trail 

corridors associated with national scenic trails ...to the degrees necessary to ensure that the 

values for which each trail was established remain intact.” The National Trails System Act 

(section 7(a)) directs that management of each segment of the National Trails System shall be 

designed to harmonize with and complement any established multiple-use plans for the specific 

area in order to insure continued maximum benefits from the land. 

The Pacific Crest Trail Association, a 501(c)(3) nonprofit, is recognized as the Federal 

Government’s major partner in managing and maintaining the Pacific Crest Trail. The tenants of 

the U.S. Forest Service, Bureau of Land Management, National Park Service and the Pacific 

Crest Trail Association’s relationship are outlined in a memorandum of understanding (2015).

45

The Pacific Crest Trail Association serves to recruit, train, and supervise volunteers to assist with 

trail management and maintenance. The collaborative work focuses on engaging youth and 

developing citizen stewardship, providing quality recreation experiences for hikers and 

equestrians, and ecosystem restoration and is funded, in part, through cooperative agreements 

with federal agencies.

Analysis and Methods

Analysis Area

Pacific Crest Trail recreationists have three distinct travel use patterns:

1. Day use: The largest user group, these travelers typically originate from within a 75-mile 

(1.25 hour driving time) radius of the Pacific Crest Trail.

2. Section use: The second largest user group, these travelers typically live on the west 

coast in one of the three states the trail travels through; and

3. Entire trail: These thru-hikers and equestrians have a broad geographic draw from 

across the United States and abroad and share the goal of completing the entire trail.

The analysis area for the Pacific Crest Trail Corridor considers local, regional, and national scales 

based on the unique and distinctive role and contributions the trail plays in providing recreation 

opportunities for day, section, and trailwide use in three states and across numerous public land 

entities.46

Methods

To identify the management area boundaries for each alternative, a geographic information 

systems model was constructed with the following criteria (see maps in volume 3).

• Alternative A: Established based on mileage of trail multiplied by 6 feet in width (general 

trail clearing width for 24-inch trail with packstock).

 45 Memorandum of Understanding between USDA Forest Service, National Park Service, Bureau of Land Management 

California and Oregon/Washington State Offices, California State Parks and the Pacific Crest Trail Association, May 

21, 2015.

46 Forest Service Handbook 1909.12, chapter 20, section 22.32 3(f)
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

558

• Alternatives B and B-modified: Established using what topography is seen from the trail 

platform at eye-level (5 feet height) up to one-half mile of centerline (foreground).

• Alternative C: Established using alternative B plus the Scenic Attractiveness A inventory 

layer up to 4 miles (middleground).

• Alternative D: Established using one-quarter mile management area from centerline of the 

trail.

In this section, key components for the environmental consequence analysis for the Pacific Crest 

Trail are based on the scenic and recreation resources. The recreation opportunity spectrum 

provides for the varied recreation opportunities along the trail in terms of setting, activity, and 

experience (USDA Forest Service 1982).

Scenic resources are analyzed based on scenic integrity objectives and distance zones (USDA 

Forest Service 1995b). Scenic integrity objectives range from very high to low. Distance zones 

are defined as foreground, middleground, and background. Foreground views are considered to 

be those within approximately one half-mile of the viewer; middleground views are views of 

objects or scenic resources between approximately one half-mile and four miles away from the 

viewer; background views are views that extend beyond four miles from the viewer, to the 

horizon.

Indicators and Measures

Acres allocated to Pacific Crest Trail corridor by alternative within designated wilderness 

and outside of designated wilderness: The total number of acres within the management area is 

a measure of the amount of surrounding area or trail corridor that provides for high-quality 

scenic, primitive hiking, and horseback riding opportunities, and conserves natural, historic, and 

cultural resources.

Acres within the Pacific Crest Trail corridor allocated to each recreation opportunity 

spectrum class by alternative: The number of acres of each recreation opportunity spectrum 

class in the management area displays the emphasis on recreation activities, setting, and 

experience ranging from primitive to urban.

Acres within the Pacific Crest Trail corridor by alternative allocated to scenic integrity 

objectives: Scenic integrity measures the degree to which a landscape is free from visible 

disturbances that detract from the natural or socially valued appearance, including any visible 

disturbances from human activities or extreme natural events outside of the natural range of 

variation. The number of acres in the management area of each scenic integrity objective displays 

the overall plan for the scenery surrounding the trail to have a natural appearance.

Miles of motorized roads and trails and number of crossings of Pacific Crest Trail in the 

Corridor: Motorized use is prohibited on the Pacific Crest Trail. The miles of motorized roads 

and trails within the corridor and crossing the Pacific Crest Trail displays the amount and 

proximity of motorized use within the corridor.

Assumptions

• Of the scenery management distance zones, details are more easily seen from foreground 

and middle ground, which usually has the most visual sensitivity (USDA Forest Service

1995b).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

559

• The forest plan does not make site-specific decisions regarding travel management within 

the Pacific Crest Trail Management Area. No roads or trails would be opened or closed in 

this forest plan decision.

• The more acres within the Pacific Crest Trail Management Area the higher the protection of 

the resources, qualities, values, associated settings, and the primary uses of the Pacific 

Crest National Scenic Trail.

Affected Environment

Recreation Opportunity

Trailwide: The Pacific Crest Trail is a long-distance trail that is designed with a native surface 

tread to meet pack and saddle “more difficult” design and maintenance standards for most of its 

length. Rustic bridges constructed of native materials may be provided where needed for resource 

protection or to accommodate those users with a moderate skill level. Trailwide, the Pacific Crest 

Trail is open to foot and horse travel and closed to motorized47 and mechanized travel.

48

The current Inyo Forest Plan recognized the Pacific Crest National Scenic Trail, and defined 

visual management standards and guidelines, but did not define a trail corridor or identify other

desired conditions, resources, qualities, or values to be specifically managed.

There are locations along the Pacific Crest Trail where the trail has been located on an interim 

route in order to have a continuous path from Mexico to Canada. On private lands, over 300 miles 

of trail is under easement that may be as narrow as 10 feet and are typically insufficient to 

provide the optimal recreation opportunities and protect the scenic values of the trail. These 

temporary locations may be along motorized road shoulders or motorized trails with the longterm objective of relocating the trail to an optimal nonmotorized location. 

Management of the Pacific Crest Trail Corridor is designed to harmonize with and complement 

established multiple-use plans to ensure continued benefits from the lands. To the extent 

practicable, efforts are made to avoid activities incompatible with the nature and purposes of the 

trail.49 Managers protect the integrity of the trail by avoidance, mitigation, and modifying 

management practices as needed.

Inyo National Forest: The Inyo National Forest manages 86 miles of the Pacific Crest Trail. 

Ninety-four percent of this mileage on the Inyo is located within designated wilderness, including 

the South Sierra, Golden Trout, John Muir, and Ansel Adams Wildernesses. Table 96 displays the 

number of miles50 of the Pacific Crest Trail within designated wilderness, and by activities 

outside of wilderness. The Inyo National Forest has 592 miles of trail outside of wilderness with 

57 percent of those trails open to motorized use and 99 percent open to bicycle use. The sixty-five 

percent of the national forest is in the nonmotorized settings of primitive or semi-primitive 

nonmotorized (see “Sustainable Recreation,” Affected Environment, Recreation Setting section).

The Inyo National Forest is open to motorized and nonmotorized winter recreation activities. 

Currently over-snow vehicles are allowed on routes and open areas outside of designated 

 47 36 CFR 261.20 

48 Regional Order 88-4 and 36 CFR 212.21

49 National Trails System Act (Pub.L. 90–543 Sec. 7(a) and (c) , 82 Stat. 919, enacted October 2, 1968), codified at 16 

U.S.C. § 1241 et seq 

50 Miles of “standard terra” trails, which have a surface consisting predominantly of the ground and are designed and

managed to accommodate use on that surface. It does not include snow or water trails.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

560

wilderness (see “Sustainable Recreation,” Affected Environment, Recreation Opportunities

section).

Table 96. Number of miles of Inyo National Forest System trails and miles of Pacific Crest Trail

within and outside of designated wilderness

Inyo National 

Forest

Total Trail 

Miles

Wilderness 

Trail Miles

Nonwilderness

Trail Miles 

Nonwilderness 

Trail Miles 

Open to 

Motorized Use

Nonwilderness 

Trail Miles 

Open to Bicycle 

Use

Pacific Crest 

Trail 86 83 3 0 0

All Trails 1,669 875 794 342 564

Visitor Use

Trailwide: There are numerous points of entry for the Pacific Crest National Scenic Trail as it 

travels 2,650 miles through 25 national forests, 7 Bureau of Land Management Field Offices, and 

6 national parks (and 48 wilderness areas); therefore obtaining total monthly or annual trail user 

numbers on all parts of the Pacific Crest Trail has been cost prohibitive. The largest segment of 

the Pacific Crest Trail users is day hikers. Since the trail is within two hours travel time from the 

metropolitan centers of San Diego, Los Angeles, Sacramento, Portland, and Seattle, there is a 

high demand for day and weekend use. Interest in long-distance hiking of the Pacific Crest Trail

has been increasing in the past years, and the trend is expected to continue. The New York Times

Bestseller book by Cheryl Strayed, Wild: From Lost to Found on the Pacific Crest Trail (Strayed 

2012) and subsequent movie has increased the interest in the Pacific Crest Trail from a broad 

audience. Visitor use management is the proactive and adaptive process of planning for and 

managing characteristics of visitor use and its physical and social setting, using a variety of 

strategies and tools, to sustain desired resource conditions and visitor experiences.

Both section users (traveling greater than 500 miles) and entire trail users on the Pacific Crest 

Trail receive a permit, and the numbers of permits issued in the past two years are shown in table 

97. Successful completion of the entire length of the trail in one season is highly dependent of 

snow conditions and wildfire activity. Table 97 shows that 2016, the highest number of all total 

permits issued was 5,657. Completion rate for thru-travelers in 2016 was 29 percent of permits 

issued51. The attrition rate and distribution has not been further analyzed to account for travelers 

never using the permit or the locations where trips ended.

Table 97. Section and thru-hike permits issued for the Pacific Crest Trail 2013-2016

Year

Total 

Number of 

permits 

issued

Northbound 

thru-hike 

permits

Southbound 

thru-hike 

permits

Section 

hike 

permits

Thruride 

permits

Section 

ride 

permits

Completions 

reported

2013 1,879 988 53 834 1 3 2711

2014 2,655 1,367 94 1,179 7 8 472

2015 4,453 2,486 322 1,633 4 8 478

2016 5,657 3,164 334 2,159 5 8 701

1. Low number of completions likely due to early season snowfall.

 51 See the Pacific Crest Trail Association Website at: https://www.pcta.org/our-work/trail-and-landmanagement/pct-visitor-use-statistics/.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

561

In 2016, 17 percent of the permits issued were to international travelers from 34 countries with 

the most number from Canada, Germany, and the United Kingdom, respectively. The majority of 

the permits (83 percent) were to recreationists originating from the United States represented by 

all 50 states and the District of Columbia, with the most number being issued to California, 

Washington, and Oregon state residents, respectively.

Within the southern Sierra, land managers within Inyo National Forest, Sierra National Forest and 

Yosemite and Sequoia and Kings Canyon National Parks are monitoring increased visitor use on 

the John Muir Trail and the Pacific Crest Trail. On the Inyo, the Pacific Crest Trail and the John 

Muir Trail are the same trail in several trail sections.

Figure 34 shows from 2011 to 2016 there has been a 242 percent increase in John Muir Trail 

visitor use permits issued. Yosemite National Park implemented an exit quota permit system in

2016 to address access and resource concerns related to increased use.52

Figure 34. John Muir Trail usage (which uses the same trail tread as the Pacific Crest Trail for most 

of its route)

Inyo National Forest: The increased in use on the John Muir Trail is displayed in figure 34 and 

applies to the sections of the trail that cross the Inyo National Forest. Additionally, for a short 

period of a few weeks each year, typically in June, Pacific Crest Trail hikers and equestrians are 

likely to encounter others as thru-hikers travel north. On the Pacific Crest Trail, through the South 

Sierra Wilderness, there is currently a low probability of encountering other users on the trail 

throughout the year. Otherwise, there are no known visitor use management issues within the 

remainder of the trail corridor associated with thru-hikers. 

Recreation Events

Trailwide: Interest in trail running has been increasing in recent years. A study completed by the 

Outdoor Recreation Participation Report (Outdoor Foundation 2014) noted that 6.8 million 

Americans ages 6 and older participated in trail running in 2013, which is 2.3 percent of the 

population. The study concluded that running, including jogging and trail running, was the most 

popular activity among Americans when measured by number of participants and by number of 

 52 See the Yosemite National Park Web site at: http://www.nps.gov/yose/planyourvisit/jmtfaq.htm
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

562

total annual outings. Trail running by individuals is allowed on the Pacific Crest Trail without 

restrictions. Recreation special use permits are required for trail running events that charge fees 

for participation and/or have more than 75 people participating. By policy, recreation event 

permits are not allowed in designated wilderness.53 The concerns regarding commercial 

competitive events displacing the primary users of the Pacific Crest Trail has been raised through 

social media in a variety of Web sites. While there is no comprehensive list of events on the 

Pacific Crest Trail at this time, for the races that that have been compiled, they range in 

participation from 75 to 800 people per event and total approximately 3,500 people annually.

Inyo National Forest: Ninety-four percent of the Pacific Crest Trail is in designated wilderness 

and there are no recreation events allowed by policy. Outside of designated wilderness, there are 

no existing authorizations for competitive events on the trail. Recreation special uses are 

authorized within the Pacific Crest Trail Corridor in the Reds Meadow Valley, including Reds 

Meadow Resort and Pack Station, and Agnew Meadows Pack Station.

Scenery

Trailwide: While on National Forest System lands, the Pacific Crest Trail may pass through a 

variety of management areas, with forestwide direction in place that defines the allowable uses 

(such as hikers and equestrians) of the trail and the visual resource objectives. Since the trail

crosses many national forests, it is important to note that the majority of the forest plans for the 

national forests the Pacific Crest Trail travels through were developed in the 1980s and are still 

under the visual resource management standards and have not been amended to reflect the 

currently used Scenery Management System.

Inyo National Forest: The Pacific Crest Trail offers outstanding scenic vistas and panoramic 

views along the entire 86 miles managed by the Inyo National Forest. In the South Sierra and 

Golden Trout Wilderness Areas, travelers on the Pacific Crest Trail enjoy views of the South Fork 

Kern River drainage and vast meadows located on the Kern Plateau. In the John Muir and Ansel 

Adams Wilderness Areas, Pacific Crest Trail visitors experience stunning vistas of glaciated 

landscapes, including sparkling blue lakes with a backdrop of high, rocky peaks on the Sierra 

Crest.

The current forest plan for the Inyo National Forest provides direction that 96 percent of the 

Pacific Crest Trail corridor will be managed for preservation of the visual quality, while the 

remaining 6 percent of the corridor will be managed to retain visual quality.

Vegetation Management and Wildfire

Trailwide: In the last 10 years, wildfire has played a significant role in the accessibility and 

scenic experience of the Pacific Crest Trail for hikers and equestrians. In the last 50 years, 

235,521 acres of the Pacific Crest Trail corridor has burned, of which, almost half occurred in the 

past 10 years. Vegetation and grazing have been managed to reflect the underlying forestwide and 

management area direction along the trail.

Inyo National Forest: Vegetation within the Pacific Crest Trail corridor has been affected by 

disturbances associated with past wildfire and a severe wind event. Vegetation within the trail

corridor has also been affected by less frequent wildfires resulting from fire suppression.

 53 Forest Service Manual 2323.13h
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

563

Three wildfires occurred during the past 10 to 50 years that affected the trail corridor. Portions of 

all these wildfires burned with high severity. Research found that wildfires historically burned 

every 14 to 18 years with low severity (Caprio, Keifer, and Webster 2006). Fire suppression 

during the past century has resulted in the absence of such regular fire disturbance, which 

increased the density of smaller trees in the understory of mature forests, and led to encroachment 

of conifers into meadows. The increased density of trees creates high fuel loading and elevated 

hazard for high-severity wildfire, such as seen in the Rainbow Fire of 1992. Conifer growth in 

meadows poses potential for loss of grassland sites in the future. The meadow encroachment is 

most notable in the smaller grassland sites along the Pacific Crest Trail near Deer Creek, south of 

Reds Meadow. These meadows may become forested sites in the next few decades without future 

fire disturbance.

In November 2011, a severe wind event toppled thousands of trees within the Pacific Crest Trail

corridor in areas of the Inyo National Forest. The most severe wind damage occurred in the 

vicinity of Reds Meadow, within the Middle Fork San Joaquin River watershed. The legacy of 

this wind damage is high fuel loading and increased wildfire hazard in areas with blowdown.

The current trends in ecological conditions are expected to continue, including elevated fuel loads 

with risk of high-severity wildfire, loss of meadows with conifer encroachment, and other 

ecosystem disturbance associated with climate change.

Lands Special Uses

Trailwide: The national increase in demand for renewable energy, especially wind development, 

has competed with the footpath of this “crest” trail, significantly changing the scenic integrity of 

the trail at a landscape scale in Kern County, California. Additionally, authorizations for new or 

larger transmission lines, pipelines, and other utilities have produced changes in the scenic 

integrity of the trail corridor in all three states the trail passes through. Table 98 and table 99

summarize the number and acres of wind applications and authorizations by the Bureau of Land 

Management as of March 2015, which are primarily concentrated in the desert and southern areas 

of the state (Bureau of Land Management 2015). The wind testing authorizations exclude projects 

submitted for development. For the wind development authorizations, the Bureau of Land 

Management has authorized more than 3,000 wind turbines on public lands before 2003, but they 

are not included in this table.

Table 98. Wind renewable energy summary (number) by Bureau of Land Management in California, 

October 2015

Area

Testing 

Applications

Testing 

Authorizations

Development 

Applications

Development 

Authorizations

Statewide 15 13 3 3

Desert 15 9 1 3

Central CA 0 1 1 0

Northern CA 0 3 1 0
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

564

Table 99. Wind renewable energy summary (acres) by Bureau of Land Management in California, 

October 2015

Area

Testing 

Applications

Testing 

Authorizations

Development 

Applications

Development 

Authorizations

Statewide 219,878 93,590 26,009 26,795

Desert 219,878 52,738 6,720 26,795

Central CA 0 0 7,882 0

Northern CA 0 40,852 11,407 0

Table 100 summarizes the number and acres of solar applications and authorizations by the 

Bureau of Land Management as of October 2015. The Bureau of Land Management has also 

approved six transmission line rights-of-way associated with private land solar facilities.

Table 100. Solar renewable energy summary by Bureau of Land Management in California, Oct 2015

Area

Development 

Applications 

(numbers)

Development 

Applications 

(acres)

Development 

Authorizations 

(number)

Development 

Authorizations 

(acres)

Statewide Acres 5 34,806 8 21,091

Desert Acres 5 34,806 8 21,091

Central CA Acres 0 0 0 0

Northern CA Acres 0 0 0 0

Inyo National Forest There are no authorizations for lands special uses along the Pacific Crest 

Trail, such as wind turbines, utility transmission lines, or pipelines.

Socio Economic Considerations

Trailwide: The Outdoor Recreation Economy Report (Outdoor Industry Association, Western 

Governors' Association, and Moto 2012) identifies that outdoor recreation creates 6.1 million 

American jobs and produced $646 billion in outdoor recreation spending each year and 80 billion 

in Federal, State, and local tax revenue. The outdoor recreation economy thrives when Americans 

spend their dollars in the pursuit of outdoor recreation. This spending occurs in two forms: the 

purchase of gear and vehicles, and dollars spent on trips and travel. It is estimated that for every 

dollar spent on gear and vehicles, four dollars are spent on trips and travel.

The Pacific Crest Trail resupply points within counties that the forest plan revision covers include 

the towns of Lone Pine, Independence, Bishop, Mammoth Lakes, Tuolumne Meadows, and Lee 

Vining and the businesses of Kennedy Meadows General Store, Muir Trail Ranch, Vermillion 

Valley Resort, and Red’s Meadow Resort. These communities receive an influx of recreationrelated supply and service requests as Pacific Crest Trail hikers and equestrians travel through or 

near their communities. While the economic contribution of Pacific Crest Trail travelers alone has 

not been studied, California State Parks (BBC Research & Consulting 2011) estimated 

recreational visitors to California parks and participants in the major recreation activities in 

California spent over $20 billion on trip expenditures and equipment. Trip expenditures include a 

variety of goods and services such as overnight lodging, restaurant meals, groceries, and gasoline. 

The sources of direct recreation expenditures vary considerably among the regions. The Sierra 

region had the largest direct expenditures ($3.5 billion) associated with visitation to federally

managed lands (see the section on economic conditions in the “Recreation and Tourism” section.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

565

Environmental Consequences

The revised forest plan components will provide for management of the Pacific Crest Trail 

corridor based on the applicable authorities and the nature and purposes of the trail. Uses and 

management activities are allowed in designated areas to the extent that these uses are in harmony 

with the purpose for which the area was designated. (FSH 1909.12 24.2). Within designated 

wilderness, the uses allowed reflect wilderness management direction and legislative 

requirements. Outside of designated wilderness (MA-PCT), the desired setting is consistent with 

or complements the semi-primitive nonmotorized recreation opportunity spectrum class which is 

consistent with the nature and purposes of the Pacific Crest Trail. Uses allowed within the 

management area include, vegetation management, prescribed burning and fire suppression, 

grazing, and leasable minerals (no surface occupancy), and utility projects. Use of existing roads 

and trails that are legally open to motorized and mechanized use may continue. Activities that are 

prohibited conflict with the desired conditions for the trail and could substantially impact the 

nature and purposes of the trail. There are 2,455 acres in the Pacific Crest Trail Corridor outside 

of wilderness which is 0.1 percent of the Inyo National Forest. While there are some changes in 

use that will occur, there is opportunity outside the management area to provide for other uses.

Recreation Opportunity (MA-PCTW-DC-02 and MA-PCT-DC-03)

Table 101 outlines the recreation opportunity spectrum class within each alternative. The Pacific 

Crest Trail Comprehensive Management Plan allows for the full range of the recreation

opportunity spectrum to be experienced with rural and urban sections of the trail “generally 

be(ing) as short as necessary to allow passage across or under highways and railroads or passage 

through developed areas.” No acres of the Pacific Crest Trail are classified as urban in the 

recreation opportunity spectrum in any alternative.

Consequences Common to All Alternatives

Alternative A provides the least amount of acres in all categories of the recreation opportunity 

spectrum. Alternative C provides the most acres in the primitive and semi-primitive nonmotorized

classes with alternative A providing the least.

Table 101. Acres of each recreation opportunity spectrum class in the Pacific Crest Trail 

Management Area

Alternative Primitive

Semiprimitive 

Nonmotorized

Semiprimitive 

Motorized

Roaded 

Natural

Roaded 

Modified Rural

Alternative A 112 0 2 2 0 0

Alternative B 37,685 359 0 320 1,610 0

Alternative Bmodified 37,685 359 0 320 1,610 0

Alternative C 119,673 3,493 3,196 0 2,471 1,517

Alternative D 20,975 59 0 297 721 0

Table 102 displays the corridor acres by alternative with alternative C having the most number of 

acres, followed by B, D, and A in all alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

566

Table 102. Acres of Pacific Crest Trail corridor inside and outside of designated wilderness

Alternative

Inside 

Wilderness

Outside 

Wilderness Total

Percent of Acres 

in Wilderness

Alternative A 112 4 116 96%

Alternative B 37,519 2,455 39,973 94%

Alternative B-modified 37,519 2,455 39,973 94%

Alternative C 116,507 13,843 130,350 89%

Alternative D 20,900 1,152 22,052 95%

We received letters expressing concerns about the loss of motorized and mechanized (bicycle) 

opportunities within the Pacific Crest Trail corridor. Table 103 displays the miles of motorized 

roads and trails within the management area that occur outside of designated wilderness areas. 

Ninety-four percent of the Pacific Crest Trail on the Inyo National Forest is within designated 

wilderness where motorized and mechanized use is prohibited and no road construction would be 

allowed.

Table 103. Miles of motorized roads and trails within the Pacific Crest Trail Corridor (outside 

wilderness)

Alternative Miles of System Open Road Miles of System Motorized Trail 

Alternative A 0 0

Alternative B 11.5 0

Alternative B-modified 11.5 0

Alternative C 29.6 2.4

Alternative D 6.7 0

Consequences Common to all Alternatives (MA-PCT-SUIT-04)

Trailwide, the Pacific Crest Trail is open to foot and horse travel and closed to motorized54 and 

mechanized travel.

55 The existing prohibitions to motorized and mechanized use on the trail itself 

would continue. Where the Pacific Crest Trail Corridor is in designated wilderness (MA-PCTW), 

motorized use year around is prohibited by statute. 

Outside of designated wilderness, motorized travel is not suitable within the Pacific Crest Trail 

Corridor (MA-PCT) year around, except at designated crossings of the trail, on interim routes and 

designated roads and trails within the corridor. (MA-PCT-SUIT). . Within the Pacific Crest Trail 

Corridor (MA-PCT), existing roads and trails where motorized and mechanized use is authorized 

is allowed to continue and is not proposed to change within the plan. No change in travel 

management in the Corridor is proposed in the Final Plan. 

The final revised plan (MA-PCT-DC) has a desired condition for the corridor to be naturally 

appearing in winter with few to no sights, sounds, and resource impacts from motorized use.

Existing authorized over snow travel will continue until site-specific analysis through Subpart C 

of the Travel Management Rule determines where over-snow motorized use will be authorized in 

the future. 

 54 36 CFR 261.20

55 Regional Order 88-4
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

567

An indirect effect of limiting motorized and mechanized transport to designated crossings, 

interim routes, and on designated roads and trails may be decreased opportunities in the future for 

new motorized and mechanized trails within the corridor.

Consequences Common to Alternatives B, B-modified, C, and D (MA-PCT-STD-03 and 

MA-PCT-GDL-03)

There are no system roads or trails that are proposed to be closed or a change in management or 

use on trail related to the Pacific Crest Trail corridor in this forest plan revision. New roads (no 

existing footprint) are not permitted unless required by law to provide access to private lands or 

documented as the only prudent and feasible alternative. New motorized and mechanized trails 

within the Pacific Crest Trail corridor may be authorized in site-specific travel management and 

would be designed to minimize the visual, sound, and resource impacts to the Pacific Crest Trail.

Visitor Use (MAs-PCTW and PCT) 

Consequences Common to all Alternatives

We anticipate visitor use to continue to grow based on the increased interest in the Pacific Crest 

Trail in the past 3 years and trends seen on the John Muir Trail, which uses the same trail tread as

the Pacific Crest Trail on the Inyo and Sierra National Forests. Visitor use would not directly vary 

by alternative and visitor use management strategies may be used by managers in all alternatives 

to minimize impacts to the physical trail resource and social setting.

Maintenance of the Pacific Crest Trail (REC-FW-OBJ). Seventy-five percent of the forest 

designated trail system, including the Pacific Crest Trail, is planned to be maintained to standard 

within 10 years. The Pacific Crest Trail, as a national scenic trail designated by Congress, is 

prioritized in terms of maintenance.

Recreation Events (MA-PCT-GDL-02)

Recreation events have a potential to disrupt and displace hikers and equestrians that may be 

using the same section of the Pacific Crest Trail when the event occurs. Some recreationists see 

the events in a positive manner and celebrate the activity, free food, and companionship. Others 

are concerned about the numbers of encounters they make over a short period of time with limited 

sight distance and passing zones on the trail. There are benefits, both economic and health related, 

from endurance running and riding that are very positive for individuals and communities.

Consequences Specific to Alternative A

Currently, there are no existing permits for recreation events on the Pacific Crest Trail on the Inyo 

National Forest.

Consequences Common to Alternatives B, B-modified, C, and D

Recreation events are prohibited in designated wilderness by policy. In alternatives B, Bmodified, C, and D, recreation events may be authorized outside of wilderness to cross the Pacific 

Crest Trail and existing events would be allowed to continue. Additionally, recreation events 

within the Corridor except on the Pacific Crest Trail itself, may be authorized. Since there are no 

existing permits for recreation events on the Pacific Crest Trail, there would be no displacement 

of permittees. The prohibition of new events would decrease the potential for displacement of and 

conflict with the primary Pacific Crest Trail users, hikers (including individual trail runners) and 

equestrians. Five miles of the Pacific Crest Trail outside of wilderness would be closed to 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

568

recreation events. Recreation events could occur on the remaining 587 miles of trails outside of 

wilderness on the national forest with less than a one percent change in opportunity.

Scenery (MAs-PCTW and PCT and PCT-GDL-01)

Table 104 outlines the acres in different scenic integrity objectives, based on the Scenery 

Management System (USDA Forest Service 1995b), by alternative in the Pacific Crest Trail

Management Area. 

Table 104. Acres of scenic integrity objectives within the Pacific Crest Trail Corridor, Inyo National 

Forest

Alternative Very High High Moderate Low

Alternative A 111 4 0 0

Alternative B 37,519 2,447 7 0

Alternative B Mod 37,519 2,447 7 0

Alternative C 119,427 10,509 413 0

Alternative D 20,900 1,150 2 0

Consequences Common to Alternatives B, B-modified, C, and D 

Within the Pacific Crest Trail Management Areas in all alternatives, 99 percent of the scenic 

integrity objectives are in the very high or high categories.

Consequences Specific to Alternative A

Alternative A provides the least scenic integrity objective acres within the very high and high 

categories within the Pacific Crest Trail Management Area.

Consequences Specific to Alternative B and B-modified

Alternative B or B-modified would provide the second greatest number of acres within the Pacific 

Crest Trail Management area for very high and high scenic integrity by identifying the width for 

including the visible foreground, which can be up to one-half mile of centerline of the trail.

Consequences Specific to Alternative C

Alternative C would provide the most number of acres in the very high and high categories for 

scenic integrity for the Pacific Crest Trail. In alternative C, visible foreground of up to one-half 

mile of centerline of the trail is combined with Scenic Attractiveness A landscapes that represent 

the iconic views. Alternative C would have the most number of acres of moderate scenic integrity 

objectives for the Inyo National Forest.

Consequences Specific to Alternative D

Alternative D would provide more acres in the very high and high category within the Pacific 

Crest Trail Management area than alternative A, but less than alternative B and B-modified, by 

protecting scenic integrity up to one-quarter mile of centerline of the trail.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

569

Vegetation Management and Fuels Treatment (MA-PCT-Potential Management 

Approach, DC-02 and MA-PCT-GDL-01)

Vegetation and fuels management have a high potential to alter the landscape and affect scenic 

resources. Activities typically reduce scenic integrity in the short term because of the associated 

slash prior to burning, stumps, and landing and road construction. In the long term, treatment 

activities may maintain or enhance scenic integrity, scenic character stability, and the ability to 

resist insects, disease, and large-scale wildfire. Consequently, treated areas may appear 

moderately to highly altered for longer periods of time, depending upon the treatment and 

mitigation measures implemented.

Consequences Common to all Alternatives

In all alternatives, vegetation management for ecosystem restoration would be allowed in the 

Pacific Crest Trail corridor to retain the desired condition of a naturally appearing landscape. The 

corridor is suitable for timber production because timber harvest and related management actions 

would be designed to be compatible with the Pacific Crest Trail desired conditions and objectives 

for a naturally appearing landscape surrounding the trail.

New roads would not be allowed to be constructed within the Pacific Crest Trail corridor unless 

they are required by law to provide access to private lands or documented as the only prudent and 

feasible alternative (MA-PCT-STD-03). Hauling and skidding along the trail would not be 

allowed to protect the trail integrity (MA-PCT-STD-04).

Fuel reduction efforts (such as mechanical thinning) may result in short-term decreases in scenic 

quality due to cut vegetation, slash, and disturbed soils. Planning for scenic elements and 

adherence to design criteria would minimize short-term impacts and reap long-term benefits, 

thereby meeting scenic integrity objectives. Fuel reduction activities should result in more 

resilient forest conditions, which should be better able to resist uncharacteristic wildfires (MAPCT Potential Management Approach).

Management efforts to control insect infestations and diseases that include removal of infected 

trees and a distance around them often appear as clearcutting to forest visitors. These impacts can 

occur in areas of high scenic value (like along scenic routes) and may reduce scenic quality in the 

short term (MA-PCT Potential Management Approach).

Consequences Common to Alternatives B, B-modified, C, and D (MA-PCT-DC-02 and 

MA-PCT-GDL-01, Potential Management Approach)

The corridor acres are within the lands suitable for timber production. Management area direction 

supports vegetation management and fuel treatment to provide for ecosystem restoration and to 

enhance the trail environment. The short-term effects related to vegetation and fuels management 

activities may decrease scenic integrity. However, long-term effects should increase scenic 

integrity and scenic stability by restoring ecosystem functions.

Short-term negative effects to scenic resources would be the greatest under alternative D, which 

would treat more acres mechanically, with wildfire, and prescribed fire than alternatives A, B, Bmodified, or C. The greatest improvement to scenic integrity and scenic stability over the long 

term would be realized under alternative D as ecosystem functions were restored or maintained.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

570

Lands Special Uses (MA-PCT-SUIT)

Energy corridor rights-of-way, communication sites, and wind towers have a high potential to 

affect scenic resources for a long duration. Cleared rights-of-way and utility structures contrast 

and may be incongruent with existing landscapes. Cleared rights-of-way generally contrast highly 

with the surrounding landscape.

Consequences Common to All Alternatives

Commercial extraction of mineral materials such as sand, gravel, pumice, cinders and other 

common variety minerals would not be permitted issued. Leasable and locatable mineral

exploration and extraction is allowable but must contain a “no surface occupancy” stipulation.

Consequences Common to Alternatives B, B-modified, C, and D

Utility rights-of-way (MA-PCT-STD-02) are to be located using avoidance, on-site mitigation, 

and off-site mitigation (in that order) and should be sufficient to protect trail values.

Alternative C provides the most scenic protection to the Pacific Crest Trail corridor from utility 

development, communication sites, wind towers, mineral materials, and surface occupancy for 

leasable minerals followed by alternatives B, B-modified, and D. Eighty-nine percent of the 

corridor is within designated wilderness where these types of uses are already unsuitable because 

of the wilderness designation. Alternatives A and D provides the least scenic protection to the 

Pacific Crest Trail corridor and the least restrictions to communication sites, energy development, 

mineral materials permits, and surface occupancy for leasable minerals, communication sites, and 

wind energy development.

Cumulative Environmental Consequences

The cumulative effects analysis area for the Pacific Crest Trail corridor is all lands the trail travels 

through in the State of California. This area was selected because of ongoing and proposed 

activities on neighboring national forests, adjacent State and Bureau of Land Management lands 

(such as renewable energy development and energy corridor developments), and private lands, 

where the trail is that the trail traverses connecting to public lands.

Recreation Opportunities and Visitor Use 

Across California, population growth is expected to grow at approximately 500,000 people each 

year and reach 50 million by 2050 (California Department of Finance 2014). Increased demand 

for outdoor recreation opportunities throughout the state and the need for all types of recreation 

(both motorized and nonmotorized) to be provided is expected to continue. 

Along the full length of the Pacific Crest Trail, including the 1,689 miles of the trail in California, 

future opportunities for motorized and mechanized trails within wilderness are prohibited by law. 

Future opportunities for motorized and mechanized trails outside of wilderness and over-snow 

motorized travel may be allowed within the corridor but would require design features to 

minimize the impacts to the trail. Project level planning, such as Travel Management – subpart C, 

will determine where over-snow motorized use is authorized and where crossings over the trail, 

or within the corridor, would occur. On all lands that the Pacific Crest Trail crosses, included 

easements across private lands, future opportunities for motorized and mechanized trails will 

have similar considerations for minimizing the impacts of project proposals on the nature and 

purposes of the trail.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

571

Increased visitor use on the Pacific Crest Trail, especially where the trail overlaps the John Muir 

Trail, will likely trigger management actions by national forests and national parks, to protect 

wilderness resources. Visitor use management actions by Federal land management agencies to 

limit impacts to the trail’s physical resources and social settings are likely to increase as a 

cumulative effect.

Recreation Events 

Trailwide and within California, interest in recreation events for trail running is likely to continue 

with increases in permit applications for races primarily between Memorial Day and Labor Day. 

These commercial recreation special use permits are prohibited in designated wilderness and 

future wilderness designations would also prohibit that activity on approximately 30 percent of 

the Forest Service trails in California. As demand for these types of events increases, other trails 

on National Forest System and Bureau of Land Management lands (outside of wilderness), are 

likely to see more recreation events permitted.

Vegetation Management and Fuels Treatment

While there are no known planned actions for vegetation and fuels treatments within the trail 

corridor in California, it is likely that outside of designated wilderness, projects will be planned to 

ensure a naturally appearing and sustainable landscape. The likely vegetation and fuels 

treatments, within in all alternatives, could result in short term cumulative effects to scenic 

resources. More of the landscape, in the short term, would appear to be moderately to slightly 

altered until the longer-term scenic integrity objective is achieved. In the long term, treatment 

activities may maintain or enhance scenic integrity, scenic character stability, and the ability to 

resist insects, disease, and large-scale wildfire.

Lands Special Uses

The statewide trend in increased renewable energy and energy corridor developments, especially 

within the southern Sierra, is likely to further impact the scenic resources of the trail. These 

developments would result in more permanent landscape modifications with impacts to the scenic 

integrity of the landscape. With the population growth in the state, the demand for renewable

energy is expected to grow, as would the need for additional transmission lines to connect to 

existing or new energy corridors. Project design to avoid the corridor and mitigation strategies to 

minimize impacts to the trail are likely to be needed.

Analytical Conclusions

Overall, based on the amount of area identified within the Pacific Crest Trail Management Area, 

alternative C provides the most protection for the resources, qualities, values, and associated

settings and primary uses of the Pacific Crest National Scenic Trail followed by alternative B, Bmodified, D, and A.

Tribal Relations and Uses

Background

This section summarizes the current tribal relations program on the Inyo National Forest and the 

potential environmental consequences to Tribes and tribal resources of implementing the draft

forest plans and the alternatives.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

572

The indigenous peoples of the Inyo National Forest have an unbroken union with this place for at 

least 14,000 years (Moratto 1984, Spier 1978, Jones and Klar 2007). The long-term relationship 

tribal people have with the landscape differs from that of most members of the public (Zedeño, 

Austin, and Stoffle 1997). A Tribe’s creation stories, indigenous place names, sacred geography 

of ceremonial and religious sites, hunting-gathering and fishing areas, and valued resources all 

culminate to form part of the tribal identity and welfare (McAvoy, Shirilla, and Flood 2004a). 

Changes in any proportion or condition of these closely tied people, places, and resources can 

result in impacts or improvements in the health of Tribes and the environment. Thus, the rivers, 

forests, mountains, and meadows we look at on a map or experience on the national forest are 

intrinsic to the traditions and livelihoods to Tribes, and the Tribes are very concerned about 

impacts or changes to those areas.

The Federal Government has a trust responsibility to federally recognized American Indians, as 

well as a public trust for the management of natural, cultural, and heritage resources. As land 

managers, Forest Service staff know that the areas they currently manage are also ancestral lands 

to many Tribes, creating the need to have effective relationships with these Tribes. The agency is

directed by Federal policy, laws, and associated authorities to engage in formal consultation, and 

to provide avenues for additional communication and collaboration with federally recognized 

Tribes. Nearly every action undertaken by the Forest Service has the potential to affect tribal 

relations and uses either directly or indirectly (Toupal 2003). Effects to tribal relations and uses 

can be adverse or beneficial, short term or long term. Some effects may be mitigated or avoided 

either through tribal consultation (such as, knowledge learned regarding potential impacts or 

consequences of management actions) or redesign (such as, practices that avoid, reduce, or 

mitigate undesired impacts; Toupal 2003, Burger 2008).

Positive relationships with Tribes are important to maintain. Tribes maintain traditional ecological 

knowledge and pass it down through generations through oral and, in modern times, written 

accounts utilizing contemporary technologies and tools. Resources that are important to Tribes 

need to be reviewed not only individually, but holistically at a landscape level (Zedeño, Austin, 

and Stoffle 1997, Watson et al. 2011). Tribal communities are interested in consultation, 

collaboration, and coordination on overall resource condition of the national forest. However,

Tribes are also keenly interested in access to the national forest and in vegetation management 

and watershed function pertaining to ecological goods and services necessary to maintain, 

enhance, and perpetuate tribal traditions and livelihoods. In managing tribal resources, it is 

important to consider the ecocultural attributes for associated ecological goods and services and 

how Tribes may value these resources differently than the public (Burger et al. 2008).

The people of various Tribes rely on different ecosystems across the bioregion that provide

natural and cultural resources necessary to perpetuate tribal traditions and livelihoods (Anderson 

and Moratto 1996, Lake and Long 2014a). This includes gathering from and tending trees such as 

pinyon pines (Zeanah 2002, Farris 1982) for primary food sources, medicinal plants, basketry and 

construction materials from plants, the harvesting of fish and game, and culturally important 

subsistence and spiritual activities (Anderson and Moratto 1996) including cross-Sierra travel and 

trade trips (Arkush 1994), and sacred ceremonies (Kroeber 1925, Moratto 1984).

Conditions on National Forest System lands that are not currently in line with desired conditions 

could contribute to limited or denied access to traditional foods, leading to food insecurity and 

increased mental and physical health problems (Jernigan et al. 2012). This also can increase the 

loss of intergenerational traditional knowledge and practices among tribal communities (Turner 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

573

and Turner 2008), which is an international and national issue of concern for indigenous peoples 

(Pimentel et al. 1997) (Food and Agriculture Organization of the United Nations 2015).

Analysis and Methods

No modeling was used for this analysis, but there are some frameworks and tools that can be 

applied for considering risk, or the consequences with alternatives regarding the change in 

condition or effects, on tribally valued resources and cultural practices in response to alternatives 

(Toupal 2003, Burger 2008, Pollard et al. 2008). This analysis was developed after a series of 

meetings where Tribes, tribal groups and organizations, traditional cultural practitioners, and 

other interested individuals consulted and collaborated on the development of the plan (USDA 

Forest Service 2015d). At these meetings, attendees were able to see draft materials and visit with 

Forest Service officials, staff officers, and subject matter experts regarding the intent of revising 

the plans. Input was considered in developing the proposed action, refining the proposed action,

and developing alternatives. The analysis uses a qualitative analysis of the following indicators 

and measures.

Indicators and Measures

For many years the Forest Service has maintained a primary suppression approach to fire 

management that has led to great success in initial attack and suppression of wildfires (Show and 

Kotok 1924, Stephens and Ruth 2005). This fire management approach has been in direct conflict 

with tribal efforts to continue natural and human-induced fire on the landscape to benefit and 

maintain tribal uses (Lake and Long 2014a). Historic tribal fire use across the landscape provided 

for the numerous resources that were subsequently encountered by the influx of Europeans 

(Anderson and Moratto 1996). Ironically, those same newcomers to the Sierra Nevada chastised,

and subsequently criminalized, the traditional practices of the Native Americans’ use of fires 

(Timbrook, Johnson, and Earle 1993). Fire suppression has led to excessive fuel loading in 

ground, surface, ladder, and canopy fuel. This has resulted in large, high-intensity wildfires 

(Miller, Safford, et al. 2009) with increased fire intensity and severity, some of which has been 

attributed to recent climate change (Miller and Urban 1999). These higher severity and more 

extensive fires across the landscape impact natural and cultural resources, tribal values, tribal 

areas of importance, and sacred sites (Timmons, deBano, and Ryan 2012, Welch 2012). Tribal 

values and interests are impacted by both uncharacteristic fire and fire deficits (for example, 

reduction in natural and tribal ignitions). This change in the frequency and extent of fire has 

contributed to increased forest density and homogeneity and increased fuel loading of 

ecosystems. This has made forests harder to travel through by the Tribes and has decreased shrub 

and non-forest.

Tribal access can be affected by policy decisions, administrative actions, and physical impacts on 

the ground. Specific concerns from resource management activities, including road building or 

other modifications on the landscape, could affect tribal members accessing valued places 

(gathering areas or sacred sites) or practicing cultural activities. These specific concerns are best 

addressed at the site-specific level during project or activity planning. However, designated areas 

located in the plan area (such as, Wilderness, Wild and Scenic Rivers, and National Scenic and 

Historic Trails) and recommending additional areas for designation in forest plans might impact 

the reserved rights and interests of Tribes. Wilderness designations are controversial with the 

general public as well as with Tribes (Stumpff 2000). Forest Service staff recognizes the 

importance of working with Tribes on protected areas, such as Wilderness, to create collaborative 

management strategies that meet mutual interests. The idea of maintaining these areas in their 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

574

“pristine” condition through a “hands off” approach lacks consideration for traditional ecological 

knowledge and associated practices conducted by Tribes, tribal groups and organizations, and 

traditional cultural practitioners (Stumpff 2000, McDonald, McDonald, and McAvoy 2000, 

Watson et al. 2011). This is especially true when it does not recognize that Tribes have 

historically managed these landscapes through the introduction of fire at appropriate times of the 

year and in specific locations (Blackburn and Anderson 1993).

Plants and animals that are traditionally and currently important for cultural uses (for instance, 

food, fiber-basketry, medicinal, spiritual) are not able to be sustainably utilized at levels desired 

by Tribes when the ecosystems they occur within are degraded, managed for other conflicting 

interests or values, or are not accessible to Tribes for traditional cultural purposes. Planning fuels 

and fire treatments across the landscape typically address bio-physical aspects of fire regimes 

(Collins and Stephens 2010), but do not commonly incorporate socio-cultural values with the 

understanding of how tribal communities are dependent upon fire in different ecosystems, 

habitats, and a range of resources affected by fire in the short-and long-term necessary to 

perpetuate tribal traditions and cultural practices (Toupal 2003; Anderson and Moratto 1996;

Raish, González-Cabán, and Condie 2005; Carver et al. 2009). Traditional knowledge can inform 

fuels, wildfire, and forest management approaches better suited to address tribal concerns, as well 

as aid in fulfilling the trust responsibility for the management of natural and cultural resources 

(Lake and Long 2014a, Mason et al. 2012).

Reduction of Threat of Wildfire to Tribal Resources

Large, high-intensity wildfires damage and destroy resources and sites important to Tribes. The 

alternatives take different approaches to reduce fire threat across the national forest. The

reduction in fire threat is evaluated in the “Fire Management” section.

Amount of Recommended Wilderness that May Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Many sites and resources of importance to Tribes are located in remote locations and have been 

used traditionally for many generations. Designating these areas as wilderness may limit or 

impair access to these sites or the ability of Tribes to continue to conduct ceremonies and gather 

resources in traditional ways, including managing the land using traditional practices. The area of 

recommended wilderness in each alternative is used as a proxy for the potential to impact tribal 

use of the land and resources.

Number of Sites Restored Specifically for Tribal Resources

The environment surrounding resources of tribal importance was directly or indirectly managed 

for thousands of years by Tribes. With modern management and the current changed 

environment, many resources used by Tribes are in diminished quantity and quality and are in 

need of restoration. The alternatives vary in their approach to improving resources of tribal 

importance and the number of sites restored for tribal resources will be the metric used as an 

indicator of impact to tribal uses.

Assumptions

• The potential effects to Tribes and tribal resources is an agency consideration at the outset 

of any and every project planning process.

• The Inyo National Forest will continue to regularly conduct Government-to-Government 

meetings to provide opportunities to the tribes to consult on all proposed activities on 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

575

National Forest lands. Consultation with tribes is guided by a variety of laws, regulations, 

executive orders, and policies that provide direction for interacting with tribes on national 

forest lands. For example, USDA Departmental Regulation 1340-007 (United States 

Department of Agriculture 2008) provides policy and implementation guidance to 

implement the 2000 Executive Order 13175 on Consultation and Coordination with Indian 

Tribal Governments. This guidance is independent from forest plan direction and does not 

change across alternatives.

• The Inyo National Forest will continue to also include tribal groups and organizations, 

traditional cultural practitioners (USDA Forest Service 2008), and interested individuals in 

discussions about tribal relations and uses.

• The tribal relations programs on the Inyo National Forest may need to increase as tribal 

consultation increases. Tribes, tribal groups and organizations, traditional cultural 

practitioners, and interested individuals have expressed an interest in more opportunities to 

consult and collaborate on proposed activities. This may be a challenge given expected 

budgets.

Affected Environment

Forests often serve as sources of traditional medicines, food, firewood, and basketry materials for 

Tribes. Certain areas may also be particularly sacred and valued for their importance in sustaining 

cultural traditions and beliefs. When implementing the forest plan, the Forest Service may 

through separate decisions conduct or authorize various types of activities that have a substantial 

impact on Tribes (Vogel 2001, Toupal 2003, Burger et al. 2008). Those impacts would vary 

widely depending on the level of collaboration maintained with tribal concerns. These could 

include grant programs, timber sales, mining, road building, recreational development and use, 

archaeological excavations, energy development, and other program and project activities 

(Yablon 2004).

Many cultural resources are both fire- and water-dependent. Basketry materials such as redbud, 

deer grass, willow, chaparral, and sour berry bush need fire enhancement (Anderson 1999). Mints 

and various teas and medicines, such as yarrow, thrive on water and are found in wetlands, 

meadows, and water drainages, but still need fire to maintain their health and usability (Anderson 

and Moratto 1996). Without an occasional burn these resources would become less abundant, 

have increase diseases or pests, and develop morphological characteristics unsuitable for 

traditional uses. Similarly, without fire, meadows, creek banks, and river and lake shores become 

overgrown with stronger, bigger vegetation (like willows, alders, and conifers that require more 

water from the water table). Pine nuts (pines) are the least ground-water-dependent food sources,

but they must be able to absorb precipitation. Without a good rainfall, or with too much, overhead 

canopy develops and pine nuts will either not grow or they will not produce at the levels desired 

by Tribes. Fire helps to reduce the canopy, and the amount of duff on the ground, which can 

become breeding grounds for insects that destroy the pine nut crops (California Department of 

Water Resources 2014).

Environmental Consequences to Tribal Relations and Uses

Consideration of Climate Change in Alternatives

Climate change and associated disturbances (for example, drought, fire, insect outbreaks) have in 

the past (North, Van de Water et al. 2009), are now, and will likely continue to (Lenihan et al. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

576

2003, Moritz and Stephens 2008) affect tribally valued resources (Voggesser et al. 2013, Chief et 

al. 2014). Several climate change-related risk and modeling assessments have been completed 

that include the geographic scope of the plan area (Sierra Nevada Alliance 2010).

Current and projected changes in forest and water resources affecting tribal communities are

considered in the analysis of the alternatives (see the “Terrestrial Ecosystems” and “Aquatic and 

Riparian Ecosystems” sections). Vulnerability of valued natural resources, tribal coping, and 

adaptive strategies can be informed by tribal consultations (traditional ecological knowledge) and 

available assessments specific to Tribes (Alexander et al. 2011). Incorporating strategies and 

actions from climate vulnerability assessments and risk assessments for species and forest 

resources may need to be broadened to mitigate the potential impacts of climate change on tribal 

communities at a scale beyond the influence of the forest plan (Burger 2008, Burger et al. 2008). 

For example, the use of strategic vegetation restoration may reduce the spread of wildfires, and 

reduce threats to communities, but have little influence on drought and vegetation response in 

more remote areas where tribal activities occur. Similarly, focusing on increasing water 

availability for domestic uses in dams and reservoirs may not address the need for improving 

water supply in seeps and springs that have been traditionally used by Tribes. Assessments and 

planning tools generally are not specifically applicable to Tribes, as Tribes are only identified as 

other “stakeholders” (Sierra Nevada Alliance 2010). Other Federal and State agency approaches

have used tribal consultation frameworks to solicit and incorporate tribal traditional ecological 

knowledge in to climate-related assessments (California Natural Resource Agency 2014).

Consequences Common to all Alternatives

All alternatives retain and continue with existing tribal consultation, sacred site, and non-timber 

forest products mandates and agreements. Forest plan direction for resource management, such as 

heritage, vegetation, soils, water, riparian, aquatic, and wildlife, for all alternatives is designed to 

provide for protection of cultural resource sites or traditional cultural properties.

All alternatives would provide for habitat and watershed conditions that would greatly contribute 

to the persistence of species at sustainable and harvestable levels. Invasive species would be 

managed to avoid encroachments on culturally significant foods, fiber/material, and medicinal 

resources. Also, resource conditions would be monitored. 

Researchers have worked with Tribes in other regions to identify and address approaches for 

mapping tribal landscape values related to fuels and fire management that can benefit Tribes by 

enhancing access to and the quality of resources (Carver et al. 2009, Lake 2013). Fire can be 

targeted at specific locations, forest types, or habitats to promote a range of tribally valued 

resources. For example, in riparian areas where a decreased water supply has degraded 

vegetation, fire can be used to emulate flooding disturbance to enhance willows for basketry 

materials and wildlife habitats. Fire can also be used in different seasons for different objects or to 

align both public and tribal objectives, such as reducing hazardous fuels around communities and 

enhancing access to desired forests and resources (Carver et al. 2009, Lake 2013). This increased 

consideration of the approach and timing of restoring fire to the landscape would occur in all 

alternatives.

Management activities (such as mechanical thinning, prescribed burning, managing wildfires to 

meet resource objectives, and recreation) implemented to avoid or mitigate adverse effects to 

heritage and cultural resources and tribal values (Carver et al. 2009) may afford greater protection 

from large, high intensity wildfires compared to consequences from continued forest growth and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

577

increasing forest density (Miller and Urban 1999, Miller, Knapp, et al. 2009). Activities 

associated with wildfire suppression under emergency conditions can inadvertently have adverse 

impacts to heritage and cultural resources (Welch 2012). For example, during fire suppression 

activities, a dozer line may inadvertently run through sites and areas important to Tribes, tribal 

groups and organizations, traditional cultural practitioners, and interested individuals. Burnout or 

back burning may also adversely affect sites. Establishing water bars on firelines and leaving 

vegetation cover to prevent erosion during mop-up and burn area emergency response could

reduce access and mobility of tribal practitioners who use the fireline which may be along a 

former historic Indian trail along ridge systems (Lake 2011, Welch 2012). However, it is standard 

practice to use resource advisors during wildfires to help identify cultural resources and mitigate 

or avoid these impacts. Additionally, national forest personnel may consider developing fire 

management agreements with Tribes that allow tribal representatives and heritage consultants to 

be officially designated within the incident management team for wildfires (Lake 2011).

Consequences Common to Alternatives B, B-modified, C, and D

The emphasis on variable treatment intensities and on vegetation heterogeneity in alternatives B, 

B-modified, C, and D should provide additional opportunities for Tribes to consult, collaborate,

and actively participate in planning processes, as well as identify potential mechanisms for how 

they can be involved with the implementation of landscape restoration treatments (for instance, 

Tribal Forest Protection Act and along boundaries of Federal and tribal lands).

The revised forest plan would include the desired condition that “the need for tribal access to 

traditional sites is acknowledged and supported.” While the Tribes need access to traditional areas 

and sites, there are some sacred sites where American Indians conduct ceremonies that require 

privacy and solitude and are free from auditory or visual distractions and obstructions. Building 

roads to or near such sites may lead to increased visitation by the public or Forest Service staff 

that could affect ceremonies and undermine cultural practices. Roads or resource management 

activities may alter the character and diminish the value of historic or cultural places. However, 

consultation would occur to identify concerns and adjust management so that adequate access for 

agency management or public use does not compromise cultural practices at traditional, cultural,

and spiritual places.

The forest plan includes a possible management approach which recognizes that the Inyo 

National Forest could increase its capacity to improve tribal relations by considering employee 

exchange opportunities carried out under “Service First” or other mechanisms. Providing 

opportunities for tribal relations staff to temporarily exchange jobs would provide a better 

reciprocal understanding of programs and promote better utilization of tribal programs and 

legislation that would mutually benefit the national forest and Tribe. This approach is similar to 

interagency details, and could extend to inter-governmental details for work assignments between 

Tribes and the Forest Service, or at higher regional or national scales with agreements between 

the Bureau of Indian Affairs for Tribes and the Forest Service.

Consequences Specific to Alternative A

Alternative A represents the continuing direction from the existing plans (as amended). The forest 

plan revision process has provided Tribes, tribal groups and organizations, traditional cultural 

practitioners, and interested individuals additional information regarding the planning process in 

general. Tribes have expressed an interest in not doing business as usual. While the governmentto-government meeting process improves communication and is used in alternative A, Tribes, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

578

tribal groups and organizations, traditional cultural practitioners, and interested individuals may 

have fewer opportunities to be involved in the management process and to maintain or improve 

tribal values. Alternative A does not have tribal interests and values integrated explicitly into plan 

components as much as the other alternatives.

Reduction of Threat of Wildfire to Tribal Resources

Alternative A reduces fuels to try to reduce the impacts of large, high-severity wildfires that can 

affect tribal resources and values, but at a pace and scale where large fires are still likely to occur. 

Amount of Recommended Wilderness that May Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Alternative A would not add new areas recommended for addition to the National Wilderness 

Preservation System and would not contribute to the potential for reduced access. Alternative A 

would not add additional constraints on tribal access to gather, use resources, or hold ceremonies 

in these areas.

Number of Sites Restored Specifically for Tribal Resources

Under alternative A, the Inyo opportunistically develops or designs projects specifically to 

improve or maintain resources of tribal importance. Very few if any improvements are made 

specifically to benefit resources of importance to Tribes.

Consequences Specific to Alternatives B and B-modified

Alternative B is the draft forest plan that carries forward existing direction still relevant and not in 

need of change and also addresses those identified needs for change based on comments received 

during the scoping process and input from tribal forums hosted by the Inyo National Forest. It 

includes integration of tribal interests and values in desired conditions for other resources and a 

plan objective to restore areas of tribal interest.

Reduction of Threat of Wildfire to Tribal Resources

The proposed increase in pace and scale of ecological restoration under alternative B could

improve ecological sustainability and benefit tribal interests and values when projects incorporate 

traditional ecological knowledge, support active involvement (such as, Government-toGovernment consultation and coordination), and foster traditional management practices (Carver 

et al. 2009). For example, areas that are important for basketry materials or traditional food 

sources would benefit from hazardous fuels treatments that reduce surface and ladder fuels, or 

tree density that foster access and mobility, as well as increase the observation and locating of 

valued resources. This alternative considers opportunities for managing wildfires to meet resource 

objectives that can be informed by the tribal consultation process and collaborative fire planning. 

For example, national forest heritage program staff consult and communicate with Tribal historic 

preservation officers and tribal leadership about identifying landscape values at risk, and under 

what conditions fire should be suppressed or managed for ecological and cultural resource 

objectives. See details for “Wildland Fire Decision Support System” (Noonan-Wright et al. 2011), 

and for “Heritage/Tribal Values” (United States Department of the Interior 2010; Timmons, 

deBano, and Ryan 2012, Welch 2012).

An increase in pace and scale that incorporates traditional ecological knowledge (Lake and Long 

2014a) could provide opportunities to Tribes to develop tribal economies (Carver et al. 2009). In 

general, ecological sustainability benefits tribal interests, and can foster access to and support 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

579

uses of habitats and resources for traditional cultural purposes. See sections on ecological 

sustainability of terrestrial, aquatic, and riparian ecosystems for more detail. Most, if not all, of 

traditional tribal management and uses were and are compatible with modern principles of

ecological sustainability. Ecological restoration projects that incorporate tribal place-based 

knowledge would provide Tribes, tribal groups and organizations, traditional cultural 

practitioners, and interested individuals with opportunities to protect, restore, and preserve 

traditional gathering areas, ceremonial areas, and sacred sites (Watson et al. 2009).

Amount of Recommended Wilderness that Might Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Alternative B would add new areas recommended for addition to the National Wilderness 

Preservation System on the Inyo National Forest. While many tribal activities would be allowed 

and could still occur within areas recommended for wilderness, it is the access to these sites that 

may be affected. No motorized routes would be affected but some activities such as gathering and 

ceremonial uses may be restricted or more difficult if areas are managed as wilderness.

Number of Sites Restored Specifically for Tribal Resources

The Inyo National Forest includes a plan objective to implement 1 to 5 restoration or maintenance 

actions to enhance resource availability for traditional tribal collection activities per decade. 

These projects would be determined in consultation with the Tribes and integrated with other 

restoration projects where possible. While these activities could occur under alternative A, they 

are more likely to occur under alternative B because of the specific plan objective.

In addition to areas improved specifically for tribal resources, alternative B includes desired 

conditions for tribal relations and uses that encourage the coordination with Tribes to recognize 

traditional ecological knowledge in managing resources. This encourages silviculture and fuels 

managers to design mechanical treatments to restore tribally valued trees or use areas while 

simultaneously achieving other restoration needs. Ecological restoration of springs and meadows 

would consider those that are important for many tribal uses, including meadows and water 

sources along cross-Sierra traditional travel routes (Arkush 1993, Chartkoff 2001). Reintroducing 

fire that increases ecological sustainability is beneficial to Tribes when designed to avoid using 

diesel and gasoline, such as drip torch fuel mix, where basketry and food plants are gathered, as 

well as considering appropriate seasons and frequencies of burning.

Consequences Specific to Alternative C

Alternative C places an emphasis on providing more short-term protections for wildlife habitat by 

reducing the amount of mechanical thinning and emphasizing more use of fire to restore 

ecosystems. This alternative proposes recommending more acres of wilderness than other 

alternatives.

Reduction of Threat of Wildfire to Tribal Resources

Alternative C treats the least amount of area to restore vegetation and reduce the risk of large,

high-intensity wildfires using mechanical treatments. Alternative C is designed to achieve a 

reduction in the risk of large wildfires through thinning only smaller trees and using prescribed 

burning. Areas with prescribed burning could benefit resources of tribal interest by restoring fire 

to the ecosystem. This alternative has the most area untreated of all the alternatives and the risk of 

large, high-intensity wildfires is the highest compared to the other plan revision alternatives, 

leaving many resources of tribal interest at high risk.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

580

Amount of Recommended Wilderness that May Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Alternative C would add the largest number of new areas recommended for addition to the 

National Wilderness Preservation System. While many tribal activities would be allowed and 

could still occur within areas recommended for wilderness, it is the access to these sites that may 

be affected. No motorized routes would be affected but some activities such as gathering and 

ceremonial uses may be restricted or more difficult if areas are managed as wilderness.

The western approach toward the adoption of wilderness has been found to be controversial in the 

Native American communities (Watson et al. 2011). Tribal leaders and traditional cultural 

practitioners are concerned that access to sacred places, traditional gathering areas, and tribal 

resources would be impacted with additional wilderness designation. Most of the tribal opinions 

are opposed to the addition of wilderness areas because, historically, the tribal communities had 

access to their entire ancestral territory and actively managed those lands now titled as wilderness 

through the use of fire for cultural subsistence, ceremonial, and livelihood objectives at the 

appropriate times and places (Anderson and Moratto 1996). Wilderness designation can hinder 

access to, and severely limit desired tribal practices in tribal cultural properties (Parker and King 

1998) as well as traditional gathering areas, and may limit or potentially prevent some traditional 

practices from occurring (Zedeño, Austin, and Stoffle 1997). Tribes, tribal groups and 

organizations, traditional cultural practitioners, and interested individuals also commented that 

additional restrictions that wilderness status and regulations impose may include the number of 

people who gather at a site for religious purposes may be limited and infringe upon tribal rights. 

Conversely, some Tribes believe that designating areas as wilderness may afford those locations 

with what Tribes would consider as “last resort” significant protections that could prevent over 

access and damage to sacred sites (TRIB-FW-DC-02). Management plans for wilderness areas 

would include tribal perspectives (TRIB-FW-DC-01) and attempt to incorporate traditional 

ecological knowledge (TRIB-FW-DC-04) and associated traditional practices (TRIB-FW-DC-03) 

to maintain the integrity of the area similar to “pristine pre-contact” conditions based upon 

desired conditions and goals (TRIB-FW-GOAL-01 and 04) that are common to the alternatives B, 

C, and D.

Number of Sites Restored Specifically for Tribal Resources

Alternative C would have the same number of sites restored specifically to benefit tribal resources 

as alternative B. However, more of the restoration would be accomplished with prescribed 

burning and with hand treatments and limited mechanical thinning to remove only small-diameter

trees due to restrictions on tree removal for other wildlife species. 

Consequences Specific to Alternative D

Alternative D is the most aggressive in terms of emphasizing an increased pace and scale of 

ecological restoration. Whenever there is an increase in development, such as the increase in 

recreation opportunities afforded under this alternative, or an increase in the scale of treatments, 

there is potential for increased direct and inadvertent effects to tribal resources, traditional 

cultural properties, and sacred sites. This is especially true given the small amount of lands on the 

Forest that has been inventoried for heritage resources (see “Heritage Resources” section).

Reduction of Threat of Wildfire to Tribal Resources

Alternative D reduces the threat of wildfire to tribal resources the most of all alternatives because

the most strategic areas along roads and ridges would be treated. This presents a higher potential 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

581

for inadvertent impacts to tribal resources in the short term, but with greater long-term benefits by 

restoring tribal uses areas across the landscape. 

Amount of Recommended Wilderness that May Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Similar to alternative A, there are no additional areas recommended for wilderness in alternative 

D. Areas that are currently accessible and used by Tribes would continue to be accessible.

Number of Sites Restored Specifically for Tribal Resources

The number of sites restored specifically for tribal resources would be the same as alternative B. 

There would be more area restored indirectly due to the larger treated area where vegetation 

desired conditions could also favor improvement of conditions for resources of value to Tribes 

such as pinyon pine, willow, and meadows.

Cumulative Effects

Tribes, tribal groups and organizations, and traditional cultural practitioners depend on the land 

and resources that cross multiple jurisdictions and ecosystems. Much of the lands in the analysis 

area is managed by Federal land management agencies which all have requirements for 

Government-to-Government meetings with Tribes to consult and coordinate management of the 

land and resources to meet tribal and agency responsibilities. Land and resource management 

under the revised forest plan is generally consistent with management across the Federal agencies 

regarding tribal relations and uses. The increased emphasis on restoring fire to the landscape in all 

alternatives would complement the increased restoration of fire within adjacent national parks. 

This would result in increased resilience of sites and resources important to Tribes across a 

mixed-jurisdictional landscape.

Analytical Conclusion

All alternatives would continue the important Government-to-Government meetings for activities 

that may affect Tribes. Alternatives B, B-modified, C, and D include additional plan direction that 

improves the integration of tribal interests into restoration project planning. These alternatives 

would provide for increased opportunity to improve access to and use of resources important to 

Tribes, tribal groups and organizations, and traditional cultural practitioners.

All of the alternatives could have some level of effect on tribal heritage resources given that less 

than one-fifth of the plan area has been systematically inventoried for heritage resources and that 

most known recorded sites remain unevaluated for their qualifications for inclusion in the 

National Register of Historic Places. However, to meeting the increased pace and scale of 

restoration treatments, a variety of management practices to ensure compliance with section 106 

of the National Historic Preservation Act would be required. This includes pre-project surveys for 

heritage resources and tribal consultation and collaborative risk planning between Forest Service 

heritage and cultural resource staff, Tribal Historic Preservation Officers, and involved tribal 

practitioners, to predict where particular valued resources or potential sacred sites may occur in 

anticipated treatment areas (Timmons, deBano, and Ryan 2012; Welch 2012). A project-level 

planning process before implementation of activities may reduce the impacts of increased 

restoration activities.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

582

Reduction of Threat of Wildfire to Tribal Resources

The amount of active vegetation management that might reduce threats from large, high-intensity 

wildfires to sites and resources of tribal importance increases the most in alternative D, followed 

by alternatives B and B-modified. It would remain the same as current levels in alternative A and 

could decrease in alternative C resulting in an incremental loss of sites or diminished access to 

resources used by Tribes over time. The use of prescribed burning would reduce risks from future 

wildfire and would improve conditions for many resources of interest to Tribes. All alternatives 

would address minimizing impacts to Tribes at specific locations during project planning, and 

alternatives B, B-modified, C, and D include specific plan direction to incorporate opportunities 

to improve sites and resources important to Tribes during project planning.

Amount of Recommended Wilderness that May Limit Access to Areas Important to 

Tribes or Use of Tribal Resources

Alternatives A and D would have the least impact to access to sites and resources by Tribes, tribal 

groups and organizations, and traditional cultural practitioners since no new areas would be 

recommended for wilderness designation. Alternative C would have the most potential impact 

with the most proposed wilderness because access to and use of areas may create additional 

barriers for tribal members. The ability to conduct ceremonies and to gather resources could be 

impaired or limited in areas managed to maintain their wilderness characteristics. For example, 

ground-disturbing activities associated with tribal use of these areas may be limited or perceived 

to be unacceptable by the public. Alternatives B and B-modified include some areas 

recommended for wilderness designation on the Inyo National Forest. Access to and use of 

resources in these areas would be similar to those described for alternative C, though to a smaller 

degree.

Number of Sites Restored Specifically for Tribal Resources

Alternatives B, B-modified, C, and D include a plan objective that provides Tribes, tribal groups 

and organizations, traditional cultural practitioners, and interested individuals with opportunities 

to protect and restore sacred sites and resources used traditionally by Tribes, and to provide 

opportunities for consultation, engagement, collaboration, and tribal economic benefits and 

values. In addition to those specific restoration projects, alternative D would provide more 

opportunities to restore other sites and resources than alternative B by having more landscape 

restoration treatments. Alternative D would also require more coordination to protect tribal sites 

and resources due to the increased amounts of mechanical treatments. Alternative C provides 

fewer additional opportunities to restore tribal resources because mechanical treatments are more 

limited and instead relies more heavily on prescribed burning. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

583

Forest Benefits to People and Communities

Forest Products and Management

This section focuses on the subject of providing forest products and summarizes the current 

environment on the Inyo National Forests in terms of estimated available forest product quantities 

by alternative and the resources (both commercial and noncommercial) associated with harvest of 

those forest products. This analysis, along with the sustained yield limit and the projected wood 

sale program can be found in “Appendix A: Timber Suitability and Management.”

The desired conditions for forest products and management are: 

Wood products are generated on a sustainable basis and contribute to ecological, social 

and economic sustainability, and associated desired conditions by helping to maintain and 

improve local industry infrastructure sufficient to meet the needs of ecological restoration 

over the next several decades. A sustainable mix of forest products is offered under a 

variety of methods in response to market demand and restoration needs.

Salvage of dead and dying trees captures as much of the economic value of the wood as 

possible while retaining key features in quantities that provide for wildlife habitat, soil 

productivity, and ecosystem functions.

Further analysis related to forest products and management may also be found in the “Terrestrial 

Vegetation” section and “Appendix A: Timber Suitability and Management.”

Background

Prior to the early 1990s, Inyo National Forest management of the Jeffrey pine forest north and 

east of Mammoth Lakes, California emphasized production of commercial wood products, such 

as sawlogs and fuelwood. Using an even-aged silvicultural system, the Inyo harvested 7 to 10 

million board feet of wood products annually. The majority of these wood product volumes were 

sawlogs from old, large-diameter Jeffrey pine trees. 

In the early 1990s, a new policy initiative was announced for management of all national forests. 

Forest managers were directed to take a more holistic approach to natural resource management. 

Generally, national forests, including the Inyo, began to deemphasize commercial wood products 

and began promoting retention and development of old growth or pre-European settlement forest 

conditions. Even-aged silvicultural systems were abandoned and replaced with an uneven-aged 

silvicultural system, where thinning of younger stands and retention of older, larger Jeffrey pine 

trees became standard practice. Commercial wood products, while still important, became a byproduct rather than the driving force of this new management strategy.

Before European settlement of the eastern Sierra region, wildland fire was a frequent and integral 

natural process in the Jeffrey pine forest ecosystem. Low-intensity surface fires regularly burned 

under and through the Jeffrey pine forest and similar forest throughout California, scorching or 

consuming duff, needles, grasses, shrubs, and smaller trees. Evidence of these low-intensity 

surface fires can be seen locally on fire-scarred Jeffrey pine trees and stumps. This scarring 

suggests fire return intervals were variable, but usually between 5 and 20 years.

In the early 20th century, a series of large and deadly wildland fires occurred in the Lake States 

and northern Rocky Mountains. As a result, the Forest Service and other land management 

agencies were directed to suppress and control all wildland fires, with little regard for the role fire 

may have played in the ecosystem. In Jeffrey pine forests of the eastern Sierra, regular fire 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

584

scarring of trees and stumps abruptly ends by the 1920s, as natural fire all but disappeared from 

the landscape due to highly successful suppression efforts. As a result, both surface and aerial 

fuels increased, as dead material accumulated on the forest floor and young trees began to grow 

and fill in available space. The Sierra Nevada has suffered frequent high-intensity wildfires since 

the 1970s, especially during the drought years of the 1980s and 1990s and in the past 4 drought 

years. Increasing fuel loads, higher summer temperatures, and prolonged droughts have combined 

to allow fires to burn at higher severity over larger areas than was common under the 

presettlement fire regime.

With the advent of ecosystem management in the early 1990s, the Inyo began to recognize the 

important role fire historically played in reducing fuels and maintaining a healthy Jeffrey pine 

forest ecosystem. A program of regular spring and fall prescribed burning was begun, to slowly 

reintroduce low-intensity surface fire to the Jeffrey pine forest. To date, over 16,000 acres of 

Jeffrey pine forest in the Mammoth Lakes-June Lake area have benefited from use of low to highintensity prescribed fire.

More recently, several regional and national initiatives and environmental analyses have provided 

management direction consistent with, and supportive of, management direction adopted by the 

Inyo for the Jeffrey pine forest since the early 1990s. The Sierra Nevada Forest Plan Amendment

and its associated Final Supplemental Environmental Impact Statement and Record of Decision 

amended land management plans for all Sierra Nevada national forests to promote overall forest 

health and reduce risk of loss from large-scale wildland fires and insect and disease outbreaks.

The 2001 National Fire Plan, 2002 Healthy Forest Initiative, and 2003 Healthy Forest Restoration 

Act all have provided additional direction on managing forest ecosystems to reduce risk of 

catastrophic wildland fire and generally improve forest health and resilience. National forests 

were directed to reduce unnatural fuel accumulations through mechanical treatment and 

prescribed fire, using pre-European settlement conditions as a guide for managing forest 

structure, species composition and density, and reintroduction of fire to ecosystems. Special 

emphasis and priority was placed on the Wildland-Urban Intermix for fuels reduction and forest 

health efforts, so as to better protect homes and communities from wildland fire. Management 

direction found in these documents closely paralleled the Inyo’s efforts since the early 1990s.

Current levels of tree mortality, linked to the collective effects of insects, pathogens, and a 

warming climate—all exacerbated by 4 years of below-average precipitation—appear likely to 

affect future yields of forest products. While projected harvests are well below annual growth 

rates, the sudden loss of living conifers and the beginning of mortality effects on the eastside, 

may result in reduced yields in areas where mortality is high. 

Analysis and Methods

Analysis Area

While the analysis area consists of all National Forest System lands within the Inyo National 

Forest, the primary focus includes lands identified as suitable for timber production.

Lands Suitable for Timber Production

Lands identified as suitable for timber production include forested lands not administratively 

withdrawn that have a reasonable assurance of regeneration, and where forest management is 

consistent with other multiple-use management objectives. The Inyo National Forest includes 

approximately 70,608 to 85,025 acres that are suitable for timber production, depending on 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

585

alternative. See appendix A for more detailed methodology on the determination of suitable lands.

Timber suitability is a part of the plan revision process, that while the Inyo National Forest does 

not currently sell commercial sawlog products (mainly due to prohibitive haul costs), we are

performing this analysis to identify potential options for the planning period.

Lands Not Suited for Timber Production

Timber harvest may be used as a tool for purposes other than timber production to enhance other 

multiple use values. Forest product removal from lands not suited for timber production is most 

common in response to salvage, hazard-tree removal or other safety concern, scenic vista 

enhancement, fuel reduction, wildlife habitat improvement, or access, among other reasons. In 

addition, timber harvest on lands not suitable for timber production may respond to restoration 

objectives such as conifer encroachment in meadows, aspen enhancement, or hardwood 

restoration. In these cases, timber harvest would be used as a tool to achieve the desired 

conditions, but is not part of the programed regeneration harvest plan for lands deemed suitable 

for timber production. As forest product removal from these lands is more responsive than 

proactive, these lands are not the focus of this analysis and will not be discussed further in this 

section.

Temporal Scale

The analysis period consists of two decades (20 years). Although the National Forest 

Management Act provides that forest plans are to be revised at least every 15 years, it limits the 

sale of timber to less than the sustained yield limit for each decade of the plan (16 U.S.C. 1611). 

Providing estimates of the annual projected wood sale quantity and the annual projected timber 

sale quantity, for each of first two decades, aligns with the National Forest Management Act 

decadal periods limiting the sale of timber, and provides an estimate for the second decade, if 

revision of the plan is delayed beyond the 15-year period.

Indicators and Measures

• Amount of forest products removed is a measure of volume. Generally, sawtimber is 

measured in hundred cubic feet (CCF) or million board feet; fuelwood volume is generally 

measured in cords or CCFs. (Note: Volume calculations were determined utilizing the 

Forest Vegetation Simulator (Dixon 2002) to model Forest Inventory and Analysis data by 

vegetation type and prescription class.)

• Area restored to improve forest health and resilience to disturbance is measured in acres. 

(Note: Area treated is a function of available area and workforce capability to treat these 

acreages.)

Assumptions

• “Area restored” refers to areas that are treated and a commercial timber product and/or 

fuelwood removed. On the Inyo National Forest, all products currently are sold as fuelwood 

under either commercial fuelwood contracts or personal use permits. Nothing is currently 

being sold as commercial sawtimber. An area where prescribed burning only or other 

service work is performed, is not a measure under the forest products indicator.

• It is assumed that commercial forest product opportunities (beyond fuelwood and other 

specialty wood markets) on the Inyo National Forest will continue to be limited due to the 

haul distance to existing mills.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

586

• It is assumed that opportunities to utilize biomass will remain the same for the first decade 

of the analysis period, but could increase in the second decade if a demonstrated consistent 

supply of biomass leads to new facilities or utilization opportunities.

• It is assumed the contract authorities for forest product removal will continue to include 

stewardship contracts (both integrated resource service contracts and integrated resource 

timber contracts), and stewardship agreements.

Affected Environment

The Inyo National Forest’s forested lands consist primarily of dry mixed conifer, Jeffrey pine, red 

fir, and lodgepole pine stands. Approximately 1.9 million acres are withdrawn from timber 

production due to administrative designations (such as National Wilderness Preservation System, 

inventoried roadless areas, research natural areas, and other designated areas (appendix A)) and 

lands classified as nonforested lands or lands where adequate stocking is not assured. Of the 

remaining forested area that is not withdrawn, a total of 70,608 to 85,025 acres, depending on the 

alternative considered, have a reasonable assurance of successful conifer regeneration and are on 

lands with management objectives consistent with timber harvest being a primary or secondary 

multiple use objective. These lands are identified as suitable for timber production. See appendix 

A for more information regarding timber suitability determinations for each alternative. Table 105

displays the percentage of area in major California wildlife habitat relationship (CWHR) types for 

alternatives B and B-modified. Table 106 displays the percentage of area in the regional 

dominance types for alternatives B and B-modified.

Table 105. Percentage of cover type (California wildlife habitat 

relationship) of lands suitable for timber production for alternatives B

and B-modified

Cover Type Percent

Eastside Pine 77

Lodgepole Pine 13

Sierra Mixed Conifer 6

Red Fir 2

White Fir 1

Jeffrey Pine 1

Table 106. Percentage of cover type (Regional Dominance Type) of 

lands suitable for timber production for alternatives B and B-modified

Cover Type Percent

Eastside Pine 77

Lodgepole Pine 13

Mixed Conifer - Fir 6

Red Fir 2

White Fir 1

Jeffrey Pine 1

The Terra Bella mill is the last remaining sawmill in California south of Yosemite National Park. 

While this Sierra Forest Products mill in Terra Bella as well as mills in Sonora and Chinese Camp 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

587

are the closest mills to the Inyo National Forest, these mills have long haul distances and narrow 

roads that typically make transportation prohibitive.

Maintenance of local forest products infrastructure is key to sustainable restoration goals. Not 

only does timber harvest contribute to the economy in an ecologically sustainable way, it is a tool 

used to improve forest health by reducing densities in a precise manner, unlike disturbance 

agents, such as, insects, pathogens, and wildfire and the other management tools of prescribed 

fire. Timber harvest can identify specific trees to remove or retain and can manipulate the 

distribution of fuels to influence the effects of prescribed burning or wildfire on residual trees and 

other desired resources, such as particular nest or denning trees or snags used by wildlife. As with 

all actions, timber harvest is designed to achieve desired conditions, taking into account other 

appropriate management objectives such as riparian habitat conservation, habitat management, 

and scenic stability.

On National Forest System lands, trees too small for use as sawtimber can often be removed and 

utilized as biomass, providing enhanced forest management capabilities. Projects that are able to 

efficiently remove both forest products and biomass products are capable of meeting a broad set 

of management objectives. A dependable supply of valuable forest products enhances the 

likelihood that infrastructure would be available to meet these needs.

Forest Products

The term “forest products” generally refers to sawtimber, but for the Inyo National Forest, 

firewood or fuelwood is the main product sold. Many forest users including Tribes, residents, and 

recreationists participate in firewood collection. This has averaged approximately 4,400 cords per 

year (data derived from Region 5 Cut and Sold Reports, 2010–2014; USDA Forest Service 2016).

Special Forest Products

The Inyo National Forest is also a source for a variety of special forest products. Special forest 

products are generally collected in small quantities for personal use, or larger amounts for 

commercial purposes, and are often authorized through a permit system. These products may 

include bark, berries, boughs, bulbs, Christmas trees, cones, ferns, mushrooms and other fungi, 

mosses, nuts, roots, seeds, transplants, and wildflowers. Forest users, including Tribes, depend on 

many of these special forest products for their medicinal properties, decorative uses, native 

propagations, landscaping, family or tribal tradition, or for ceremonial purposes.

Area Restored

Many decades of fire suppression have resulted in overcrowded, dense forests, vulnerable to 

disease and insect infestation, uncharacteristic wildfire, and the effects of a warming climate. 

Many management methods (including timber harvest, prescribed fire, mastication, hand piling, 

and burning) can and would be used to restore the landscape to a more resilient condition. The 

most common treatment is thinning, which improves forest health and resilience and can often 

move treated areas more directly toward desired conditions. Group selection is used to promote 

regeneration of shade-intolerant species (specifically, pine), by creating small openings that are 

large enough that seedlings that need sunlight can grow. Group selection also restores seral stage 

heterogeneity that has been lost due to the ingrowth of shade-tolerant species and the reduction in 

thinning that would have occurred by wildfires because of fire suppression. When available, 

revenue generated from timber removal may be reinvested into other more expensive restoration 

treatments.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

588

Environmental Consequences

Consequences Common to all Alternatives

Special Forest Products

Utilization of special forest products and personal-use fuelwood is generally anticipated to remain 

consistent with current conditions into the future, with minimal increases due to population 

trends. It is also anticipated to be relatively consistent across all alternatives. While alternative C 

includes additional acres recommended for wilderness designation, this is not anticipated to play 

a significant role in special forest product and fuelwood availability considering the scale of 

remaining forested areas available for collection and the typical remoteness of these areas. There 

could be some consequences for tribal gathering in alternative C, which we have described in 

more detail in the “Tribal Relations and Uses” section. Special forest product and fuelwood 

removal is tied more closely with demand than locational availability. In other words, people 

would travel to obtain these products. As demand is not anticipated to change across alternatives, 

special forest products and personal-use fuelwood will not be addressed further in relation to any 

alternative.

Forest Products

All alternatives assume some level of forest product removal. Table 107 displays ranges in 

volumes projected to be removed. The Inyo National Forest has projected sawtimber harvests that 

are a very small fraction of the estimated sustained yield. If considering the projected maximum 

sawtimber levels associated with alternatives B and B-modified, the percent of the sustained yield 

is 4 percent for the national forest.

Table 107. Projected 10-year timber harvest volumes (million cubic feet) by product type and 

alternative

Product Alternative A Alternative B

Alternative 

B-modified Alternative C Alternative D

Sawtimber 1 1–1.5 1-1.5 <1 1.5–3

Fuelwood 6–8 6–9.5 6-9.5 4–7 9.5–14

While the harvest of sawtimber is not estimated for mortality related to high-intensity fire, 

droughts, and other unplanned disturbances, it can have an effect on a projected decadal harvest 

schedule. Initially, this mortality may displace the projected harvest of living trees. It would be 

expected that the quantities would range from very low with alternative C to approximately equal 

amounts in the remaining alternatives. In the longer term, the loss of living forests after 

significant disturbance events, in effect, can erase significant acreages of growing forests and 

reduce the total capacity of a national forest to maintain a specified harvest level.

When the number of acres affected reaches a threshold value, the capability of any specific 

national forest to maintain the projected yields will decline. The ability to minimize or reverse 

this impact is dependent on the successful reestablishment of thriving forests. Without that 

happening, the total available sawtimber volume that would ordinarily be able to offer projected 

harvests, would decline and start a trend that, in essence, reduces the total acreage available and 

suitable for timber production.

Projected sawtimber harvests are displayed in table 107 as a range of values. The minimum value 

in alternatives A, B and B-modified is the current condition based upon a 5-year average, the 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

589

minimum for alternative D is estimated to be the maximum for alternatives B and B-modified due 

to greater flexibility in achieving desired conditions and encouragement of larger, landscape-level 

projects, while the minimum range for alternative C is one-quarter the current condition due to 

limitations on tree removal. The maximum value in the range is the amount of sawlog volume 

available for removal, when consistent with management objectives, and would be part of a 

contract or project that is economically viable. This maximum value is based on Forest Vegetation 

Simulator modeling of likely prescriptions associated with each alternative using Forest Inventory 

and Analysis plot data across the analysis area and assumes an increased agency workforce with 

increased funding over the current condition because of the increased effort needed for project 

design, analysis, and implementation over more treatment areas.

As stated above, fuelwood demand is expected to remain consistent with current conditions or 

increase slightly due to population trends. Fuelwood varies slightly on the Inyo National Forest 

because much of the fuelwood gathering opportunity is associated with piles of logs left after 

mechanical thinning and commercial fuelwood gathering that would vary by restrictions 

associated with the alternatives. 

Due to the long distance between the Inyo National Forest and existing mill facilities, the vast 

majority of local processing of forest products is for fuelwood. Milling of timber resources for 

products other than fuelwood is currently minimal and limited to a few local individuals who 

manufacture items such as posts and poles, rough siding, arts and crafts, furniture, and other 

products. As such, current and projected sawtimber opportunities on the Inyo National Forest are 

projected to remain at the current level for the foreseeable future.

Area Restored

All alternatives include silvicultural practices designed to contribute to the restoration of a more 

resilient landscape. Acres projected for treatment over the next decade are displayed in table 108

as a range. The minimum value for alternatives A, B, and D is projected to approximate the 

current level of harvest; the maximum value is the total estimated number of acres associated 

with the harvest volumes estimated in table 107. Alternative C is anticipated to provide forest 

products over a reduced acreage due to existing and additional constraints on removal of sawlogsize trees, as well as differing treatment prioritization that emphasize the use of prescribed 

burning instead of tree cutting and restoring areas using wildfires that can be managed to meet 

resource objectives.

Table 108. Projected 10-year harvest area in acres by management practice and alternative

National 

Forest

Management 

Practice

Alternative

A

Alternative 

B

Alternative 

B-modified

Alternative 

C

Alternative 

D

Inyo Thinning 8,000 8,000–

11,500

8,000–

11,500

2,300–4,500 11,500–

16,000

Inyo Group 

Selection

1,000 1,000–2,000 1,000–2,000 0 2,000–4,000

It is important to note that the treated acres in table 108 refer to areas harvested with the removal 

of a timber product, which is a subset of the projected total of mechanically treated acres of each 

alternative. Treated areas would be managed primarily with variable density thinning which is an 

approach that selectively removes trees to increase spatial and structural variation, while retaining 

selected elements or biological legacies (large/old trees, snags, and logs) in a desired arrangement 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

590

(such as aggregated in clumps, dispersed in a uniform pattern). Thinning reduces stand density 

and improves overall stand health, as individual trees have increased access to available resources 

such as water, sunlight, and nutrients. These additional resources result in accelerated growth and 

canopy development, while improving the likelihood that individual trees survive, when 

confronted with insects and pathogens, drought, and low- to moderate-intensity wildfire (Latham 

and Tappeiner 2002). Group selection openings would generally be small areas between 0.5 to 3 

acres where most or all trees are removed to facilitate the establishment of a new age cohort. 

Group selection when used in combination with variable density thinning, generally mimics 

historic disturbance processes by regenerating approximately 15 percent of the forested stand, 

increasing heterogeneity across the landscape and contributing early seral regeneration patches, 

within an overall uneven-aged landscape (Franklin et al. 2002; North et al. 2012; North, Stine, 

O'Hara et al. 2009). In addition to providing valuable forest products for society, the precision of 

these treatments increases the likelihood that associated restoration goals are achieved. Fire, even 

if used intentionally, does not allow that level of specificity for tree arrangement, size, and species 

distribution.

Treatment Costs

Table 109 presents a 10-year estimate of the total costs of mechanical treatment, prescribed fire 

and managed fire activities across the plan revision alternatives. Each of these restoration 

activities is used at a different rate under each of the plan revision alternatives and as a result, the 

total costs of these alternatives vary. These results show that alternatives B, B-modified, and D 

have the higher estimated total costs and alternative C has lower total costs. It is important to note 

that this analysis is only looking at costs and not the effectiveness of restoration activities. 

Therefore, a lower cost alternative is not necessarily the best option as it may not yield the best 

restoration outcomes.

Table 109. Ten-year discounted cost estimates for mechanical, prescribed fire and managed fire 

activities in each plan revision alternative

Alternative B-modified Alternative B Alternative C Alternative D

$9.2 million $9.2 million $6.3 million $13.8 million

Consequences Specific to Alternative A

Alternative A maintains the current level of activity, using existing management direction as 

provided by the 2004 Sierra Nevada Forest Plan Amendment Record of Decision (USDA Forest 

Service 2004b). Alternative A assumes future funding and project design consistent with current 

levels. Generally, less than 5 to 10 percent of the landscape has been restored in the last 10 years.

Forest Products

Based on historic averages, alternative A would produce approximately 1 million cubic feet of 

sawtimber, with an additional 3 million cubic feet in other products (miscellaneous convertible 

products such as posts and poles), and 6 to 8 million cubic feet in fuelwood over a 10-year period 

(see table 107 and appendix A, table A-3).

Implementation projects are generally designed to thin relatively small-diameter sawtimber trees, 

reducing fuel adjacent to communities at risk of loss or damage from uncharacteristic wildfire. 

There are some biomass removal opportunities in conjunction with sawtimber removal, but the 

lack of a consistent market combined with pricing structure challenges results in most biomass 

opportunities going unutilized. Most biomass that cannot be economically sold and removed from 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

591

the forest is piled and burned to reduce fuel and meet the project objectives. Revenue generated 

from individual projects could be utilized to offset the costs of other restoration activities that 

require additional funding to implement, such as watershed or habitat improvements. This 

alternative produces more revenue than alternative C, but less than alternatives B, B-modified and 

D.

Area Restored

Alternative A, based on historic averages, would harvest timber from approximately 9,000 acres 

per decade across the Inyo National Forest (see table 108 and appendix A, table A-4). In addition 

to ecological restoration needs, treatments are prioritized based on proximity to the wildlandurban intermix. The majority of treatments would be in the montane ecological zone, with minor 

amounts in the upper montane ecological zone. Forest types in the montane zone include dry 

mixed conifer and montane hardwood-conifer, while the upper montane zone includes red fir, 

Jeffrey pine and lodgepole pine.

Based on historic averages, projects are generally designed to treat approximately 1,000 acres 

across a 5,000 acre area, or approximately 20 percent of a small landscape (generally a 

subwatershed). At the stand level, these acres have an improved likelihood of resilience to the 

effects of insects and pathogens, climate change, and wildfire. This scale of treatment may result 

in less uncharacteristic wildfire activity at the local project scale, but by itself is not sufficient to 

alter the increasing trend in large wildfires expected with climate change (see “Fire Trends” 

section). In addition, many standards and guidelines limit tree density reduction, potentially 

leading to increased inter-tree competition for scarce resources and increased tree mortality. 

Related to thinning and improving the sustainability of forest products, this alternative restores 

more acres than alternative C, but less than alternatives B, B-modified, and D.

Consequences Specific to Alternatives B and B-modified

Alternatives B and B-modified incorporate four strategic fire management zones: community 

wildfire protection; general wildfire protection; wildfire restoration; and wildfire maintenance 

zones. Approximately half of the lands suitable for timber production are located in the two 

“protection” zones. Alternatives B and B-modified prioritize fuel reduction and restoration 

treatment in the two protection zones as well as on strategic ridges and along key roads that can 

facilitate larger landscape prescribed burns or that can increase the opportunity to manage 

wildfires when they can meet resource objectives. At least 20 percent of the landscape is 

anticipated to be restored through various management activities, including timber harvest.

Forest Products

Based on stand modeling combined with projected capabilities, alternatives B and B-modified

would produce approximately 1 to 1.5 million cubic feet of sawtimber and 6 to 9 million cubic 

feet in fuelwood over a 10-year period (see table 107 and appendix A, table A-3). This alternative 

is expected to produce more revenue than alternatives A and C, but less than alternative D.

Revenue generated from implementation of individual projects could be used to offset costs of 

other restoration activities that may otherwise remain unfunded. With an increase in area treated,

more biomass removal opportunities, in conjunction with sawtimber removal, are available, 

provided a consistent market could utilize these opportunities. Larger, landscape-scale ecological 

restoration projects (such as whole watersheds) are encouraged under alternatives B and Bmodified. If designed in ways to increase economic efficiencies, increased revenues may be 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

592

generated per project. Through stewardship contracting, or trust funds, this revenue could be used 

to restore additional or more costly areas than under alternative A.

Area Restored

Alternatives B and B-modified would harvest timber from approximately 9,000 to 13,500 acres 

per decade across the Inyo National Forest based on projected national forest capabilities (see 

table 108 and appendix A, table A-4). Treatments are prioritized based on strategic fire 

management zone, with an emphasis on treating within the two wildfire protection zones. 

However, treatments are not limited to the protection zones. Vegetation types treated in 

alternatives B and B-modified would be comparable to those treated in alternative A.

Alternatives B and B-modified encourage larger landscape-scale projects, with the intent that 

greater areas would by analyzed and more area restored. Fewer limitations on tree removal 

compared to alternative A would increase the likelihood that thinning of dense stands would be 

more biologically effective at achieving resilient conditions and would result in more sustainable 

forest stands over increased acres. At the stand level, these acres would increase the likelihood of 

resilience to the effects of insects, pathogens, climate change, and wildfire, and would come 

closer than alternatives A and C, but would not quite be sufficient to alter the increasing trend in 

large wildfires expected with climate change (see “Fire Trends” section). This scale of treatment 

would result in less uncharacteristic wildfire activity at the project or landscape scale. This 

alternative restores more acres than alternatives A and C, but less than alternative D.

Consequences Specific to Alternative C

Alternative C focuses on emphasizing short-term protections for wildlife habitat, and relies more 

on standards and guidelines to minimize localized effects of active management on species such 

as listed amphibians, and other species of conservation concern. Commercial timber sales are 

generally limited to small-diameter sawtimber removal, with maintenance of greater stand 

densities and higher canopy cover. Treatments similar to alternative A could occur in portions of 

the wildland-urban intermix defense zone. However, it is anticipated that prescriptive constraints 

such as diameter limits would reduce the area treated to one half or less of current levels.

Forest Products

Based on modeling and projected national forest capability, alternative C would produce less than 

1 million cubic feet of sawtimber, with an additional 4 to 7 million cubic feet in fuelwood over a 

10-year period (see table 107 and appendix A, table A-3). This alternative generates the least 

amount of forest products, and associated revenue, of all the alternatives analyzed in detail.

The implementation of alternative C is likely to produce limited revenue, as lower-value product 

removals, such as small-diameter sawtimber, in generally smaller-scale projects, restrict the 

efficiencies more common with projects designed in other alternatives. Smaller projects, 

combined with smaller-diameter removal, contribute to more costly harvest operations that would 

likely need to be supplemented with appropriated dollars to accomplish objectives. Since budgets 

are expected to remain similar to those of the last 5 years, appropriated funds would offset the 

costs of fuel reduction on fewer acres overall.

Area Restored

Alternative C anticipates timber harvest from approximately 2,300 to 4,500 acres per decade 

across the Inyo National Forest (see table 108 appendix A, table A-4). Thinning treatments focus 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

593

on small- to medium-sized trees and are focused primarily in the wildland-urban intermix defense 

zone immediately surrounding communities. Prescribed fires and wildfires managed to meet 

resource objectives are the preferred methods of restoration treatment, thereby substantially 

reducing product output or timber harvest opportunities.

Alternative C encourages less intensive treatments, meant to minimize impacts to existing habitat 

in the short term. At the stand level, these acres would improve the likelihood of resilience to the 

effects of insects and disease, climate change, and wildfire. However, these effects would be to a 

much lesser degree than alternatives A, B, B-modified and D, due to the minor density reductions 

associated with only small-diameter tree removal. Minor reductions in inter-tree competition are 

not likely to provide sufficient increased access to growing space and the related site resources 

and any benefits are very short term because of continued growth of trees. Limited increases in 

tree vigor, combined with the limited acreages affected by treatment, are unlikely to provide a 

significant improvement in the status of forest health. Retention of high stand densities would 

continue to contribute to mortality, thus increasing fuel levels and contributing to stand conditions 

trending away from overall desired landscape conditions.

While wildfire risk would be reduced in the short term at the stand level within the treated areas, 

the low levels of accompanying mechanical thinning that would assist the effectiveness and 

efficiency of prescribed fire or wildfire managed to meet resource objectives may actually limit 

fire use. This scale of treatment may result in less uncharacteristic wildfire activity at the local 

project scale, but would not be sufficient to alter the increasing trend in large wildfires across the 

landscape expected to occur due to climate change and other stressors. Under alternative C, 

almost all funding for vegetation treatments would have to come from congressionally 

appropriated funds or from partnership dollars because there is little opportunity for stewardship 

or trust fund support, both of which depend on the sale of commercial forest products to generate 

funds. This alternative mechanically restores the least amount of acres of all the alternatives 

analyzed in detail.

Consequences Specific to Alternative D

Alternative D includes an emphasis on an increased pace and scale of ecological restoration, 

including improving the resilience of forests to fire, drought, climate change, insects, and 

pathogens. It emphasizes long-term habitat conservation by making areas more resilient to 

stressors, recognizing there may be short-term impacts to habitat associated with active 

management. Treatments focus on effective density reductions, lengthening the time that 

treatments are effective before growth increases stand density to levels outside the natural range 

of variation. More strategic treatments in the restoration zone would occur than under alternative 

B or modified alternative B. By conducting more mechanical treatments in the areas that are easy 

to treat with mechanical equipment, alternative D would create landscape conditions that would 

allow for greater use of fire (both prescribed fire and management of wildfires to meet resource 

objectives) in areas that are difficult to treat with mechanical equipment. This would lessen the 

risks from large, high-intensity wildfires to other forest stands. During thinning, increased 

numbers of medium and large trees would be removed to favor the development and vigor status 

of even larger trees. Up to 60 percent of the treated landscape is anticipated to be restored through 

various activities including timber harvest.

Forest Products

Based on modeling and projected capability, alternative D would produce approximately 1.5 to 3 

million cubic feet of sawtimber and 9.5 to 14 million cubic feet in fuelwood over a 10-year period 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

594

(see table 107, and appendix A, table A-3). This alternative produces the most revenue of any 

alternative analyzed in detail.

Revenue generated from implementation of individual projects could be utilized to offset costs of 

other restoration activities that may otherwise remain unfunded. Provided the existence of 

biomass utilization infrastructure exists, increased biomass removal, often linked with sawlog 

harvests, would increase. Larger, landscape-scale projects (such as whole watersheds) are 

encouraged under alternatives D, B and modified alternative B, resulting in more revenue 

generated per project due to increased efficiencies associated with logging costs. Through 

stewardship contracting, or trust funds, this revenue could be utilized to treat additional or more 

costly areas than under alternatives A and C. For example, funds generated by the sale of forest 

products could be applied to road maintenance, small fuels mastication, prescribed burning, 

habitat enhancements, and aquatic organism passage projects.

Area Restored

Alternative D is anticipated to harvest timber from approximately 13,500 to 20,000 acres per 

decade across the Inyo National Forest (see table 108, and appendix A, table A-4). While 

treatments in the two wildfire protection zones are of higher priority, treatment may occur in all 

strategic fire management zones. The majority of treatments would be in the montane ecological 

zone, with minor amounts in the upper montane ecological zone. The montane zone consists 

primarily of dry mixed conifer and montane hardwood-conifer, while the upper montane zone 

consists of red fir, Jeffrey pine, and lodgepole pine.

Alternative D encourages larger landscape-scale projects, with the intent that greater areas would 

by analyzed and more area restored. Decreased tree density and increased heterogeneity at the 

landscape and stand level would improve the likelihood of resilience to the effects of insects and 

pathogens, drought, climate change, and wildfire in montane and upper montane forests, due to 

increased adaptive capacity. In addition, wildfire risk would be reduced over time (see “Terrestrial 

Vegetation” and “Fire Trends” sections). This scale of treatment would result in less 

uncharacteristic wildfire activity at the project and landscape scale, extending beyond the treated 

areas. Of all alternatives analyzed in detail, this alternative restores the most acres and results in 

more resilient forested stands consistent with desired conditions.

Cumulative Environmental Consequences

There are no private timber producing lands in proximity to the Forest. Timber harvest activities 

on adjacent National Forest System land would not be a factor as the Inyo is separated by 

designated wilderness from both the Sierra and Sequoia National Forests, and the Toiyabe 

National Forest (Intermountain Region) has limited timber harvest opportunities.

Alternatives B, B-modified, and D project an increase in area treated and volume removed as the 

pace and scale of restoration expands. These alternatives would produce enough forest products

to maintain the local specialty markets. Maintenance of existing local markets is important to 

community economic health, as well as ensuring future opportunities for restoration 

implementation. However, in the absence of sawmill infrastructure, existing capacity issues may 

limit achievement of the desired objectives in alternative D.

New markets such as biomass facilities may further increase the pace and scale of restoration, 

especially under alternatives B, B-modified and D. New markets allow for competition, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

595

potentially resulting in increased revenue. There are currently no local biomass facilities within 

communities located within the Forest.

While alternative D projects the greatest annual volume removal, no alternative prescribes harvest 

at levels nearing the sustainable yield limit (see “Appendix A: Timber Suitability and 

Management”). This means there is more opportunity to increase pace and scale of restoration 

given increased fiscal and personnel capacity without jeopardizing the long-term sustainability of 

the forest and forest productivity.

Alternatives B, B-modified and D use a variety of restoration tools, such as mechanical fuel 

reduction treatments, timber harvest, hand treatments, and prescribed fire, to achieve desired 

conditions. Under these alternatives, it is expected that substantial portions of large landscapes 

may be restored in the next 10 to 15 years. In addition to improved forest health, growth, and 

resilience to disturbance agents, treating more area (especially reducing densities in montane and 

upper montane forest stands) increases the likelihood that large landscape areas can withstand the 

adverse effects of many of the fires experienced in recent years, maintaining much of their forest 

structure and composition. These forests may continue to provide habitat as well as future 

multiple-use timber harvest opportunities into the future, without a substantial loss in social, 

ecological, and economic value.

Alternatives A and C are both likely to result in lower levels of restoration treatments intended to 

achieve desired conditions than either alternative B, B-modified or alternative D. The increased 

emphasis in alternative C, to utilize fire, may be more limited than intended, due to the low levels 

of accompanying mechanical thinning that would assist the effectiveness of prescribed fires or 

wildfire managed to meet resource objectives. As the trend of elevated wildfire intensities 

continues to increase under these alternatives, losses of forest structure to wildfire adversely 

impacts habitat availability, aquatic health, recreation opportunities, and future economic and 

multiple-use opportunities associated with timber harvest.

Analytical Conclusions

Alternative A would continue management at current levels of mechanical treatments, with 

limited improvements in forest health and resilience to disturbance agents and climate change at 

the project (stand) level. Landscape resilience would continue to decline. 

Alternative B and modified alternative B could potentially increase pace and scale of mechanical 

treatments from the existing conditions, incrementally improving forest health and resilience to 

disturbance agents and climate change.

Alternative C would decrease the pace and scale of mechanical treatments from the existing 

conditions; however, small improvements in forest health and resilience would occur in the short 

term at the project (stand) level, similar to alternative A.

Alternative D would increase pace and scale of mechanical treatments from the existing 

conditions, improving forest health and resilience to disturbance agents and climate change. 

However, the absence of infrastructure may limit achievement of desired objectives. 

Production Livestock Grazing

This section addresses commercial livestock production on forest rangelands and summarizes the 

current environment on the Inyo National Forest in terms of existing permitted livestock, grazable 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

596

forestlands and rangelands, and likely trends. Livestock production and rangeland management 

includes those lands suitable and not suitable for livestock production from previous decisions. 

The beneficial and adverse effects of production livestock grazing are described throughout this 

document and a summary of those effects is included in this section. A list of current grazing 

allotments and their status is described in Appendix D: Range Management; a map illustration is 

also found in Volume 3: Maps. Range suitability analysis under the 2012 planning rule is not 

required and previous grazing suitability determinations have not changed. The desired conditions 

for grazable rangelands and management are: 

• Rangelands, along with grazable forestlands and woodlands, provide large areas of 

contiguous space supporting native vegetation that has the potential to be grazed. These 

grazable landscapes sustain biological diversity and ecosystem integrity and help to 

preserve the rural landscape and cultural heritage of the central, southern and eastern Sierra 

Nevada.

• Forage, browse, and cover meet the needs of wildlife and authorized livestock are managed 

in balance with available forage. Areas that are grazed have or are trending toward having 

satisfactory soil conditions, functional hydrology and biotic integrity.

• Domestic livestock grazing maintains the desired rangeland vegetation types represented by 

diverse plant functional groups, species richness and diversity, and structure and condition 

of plant communities.

Background

Grazing History

A literature summary on the history of livestock grazing by Allen-Diaz et al. (1999) states that by 

most accounts, the Gold Rush did not lead immediately to widespread grazing in the Sierra 

Nevada. However, droughts, floods, and over-supply of cattle and sheep that followed in the 

1860’s caused ranchers to drive their stock into the foothills (in (Allen-Diaz et al. 1999). 

Competition for level crop lands gradually limited ranching to the foothills and Sierra thereafter 

(Burcham 1982). One author asserts that livestock began to be driven into the Sierra in 1864 in 

response to devastating drought, and that before that time forage in the Central Valley area was 

sufficient (in (Allen-Diaz et al. 1999). The Inyo National Forest was established by presidential 

proclamation in 1907. Prior to establishment of national forests in the Sierra Nevada, grazing of 

these public lands was an example of open access resources, where no clear ownership is

established or enforced (in (Allen-Diaz et al. 1999). 

Allen-Diaz et al. reports (1999) that it is sometimes argued overstocking on federal lands was 

stimulated during both World Wars (Menke 1996). Further, a historian of the national forest, Bill 

Rowley, asserts that while widespread overstocking occurred in response to WWI, the Forest 

Service successfully argued against a similar increase in WWII (Rowley 1985).

As noted in the introduction, historic Euro-American uses on the Inyo National Forest were more 

focused on livestock grazing and mineral prospecting than on timber and recreation opportunities. 

Regulated livestock grazing has occurred on rangelands of the Inyo National Forest since the 

national forest was established and continues to be one of a variety of multiple uses on the Inyo. 

As reported by Menke et al. (1996) in the “Sierra Nevada Ecosystem Project” (SNEP 1996), an 

aggressive grazing adjustment program began on the Inyo National Forest in 1944, and that by 

1950, animal unit months (AUMs) had been reduced by over 40 percent (Vol II, Appendix 50.1, 

p. 1,311).
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

597

Menke et al. (1996) also reported that in the Eastern Sierra region during the post-World War II 

era (1946-1970) many local livestock operations became smaller and most sheep operations were 

converted to cattle. Concern about depleted rangeland conditions led to closure of marginal 

allotments or conversion of sheep allotments to cattle allotments and a reduction in permitted use. 

Beginning in the 1980s management concentrated on resource protection. The Federal Land 

Policy and Management Act of 1976, Public Rangelands Improvement Act of 1978, and other 

environmental laws ushered in a change in management of public rangelands. From 1970 into the 

1990s, many allotments were split into small units in order to make them more economical and 

facilitate management. Stocking rates and seasons of use were reduced; significantly in some 

cases. In the 1988, Inyo Final Environmental Impact Statement for the Forest Plan states, “In 

most areas, range condition is poor to fair by Region 5 standards, the trend is static to improving. 

Meadows and riparian areas are considered poor but improving in terms of range production.” It 

was also noted that these condition ratings would be higher if based on Great Basin vegetation 

types used by the Intermountain Region of the Forest Service. A summary of rangeland 

conditions in the Sierra Nevada Ecosystem Project Report (SNEP 1996), plant species 

composition on meadows of the Sierra Nevada had improved when comparing transects from 

1956-1965 to 1986-1995, including on the Inyo National Forest. Though resource problems 

persisted in 1999 on montane meadows and uplands there had been remarkable recovery over that 

forty year period. The report concluded that rangeland management direction to improve 

ecological functionality and agricultural productivity had not been realized to the full extent 

possible.

Recent forest plan revisions (USDA Forest Service 1995a, 2001b, 2004c) have focused on 

vegetation inventories and monitoring with an ecological approach to livestock grazing and 

management. Conservation and restoration of aquatic, riparian and meadow ecosystems and 

associated species has had been a primary focus of the Sierra Nevada Forest Plan Amendments 

(USDA Forest Service 2001, 2004). On the Inyo National Forest many of those changes to the 

1988 forest plan, focusing on rangeland conservation and restoration, had already been put into 

place during Inyo Forest Plan Amendment 6 – Forestwide Range Utilization Standards (USDA 

Forest Service 1995a). Following the 2001, 2004 Sierra Nevada Forest Plan Amendment,

additional effort has been made on the Inyo to inventory and assess special aquatic features, such 

as fens and springs, aspen communities, willow fly-catcher habitats, and noxious weed 

infestations. Further adjustments were also made to the grazing browse standards for aspen and 

willows. Since 2002, the Inyo has participated in conservation measures for the bi-state greater 

sage-grouse. The Inyo National Forest Sage-grouse Interim Management Policy has been in place 

since 2012 incorporating livestock grazing guideline requirements into existing grazing permits. 

Potential Grazing Effects to Rangeland Ecosystems

Since the 1980s numerous studies have documented the adverse effects and disturbance that 

livestock grazing activities can have on riparian and uplands. Livestock tend to congregate during 

warm weather season in riparian areas. Therefore, disturbance from livestock to riparian areas is 

often disproportionately greater than disturbance to adjoining uplands (Skovlin 1984, Kauffman 

and Krueger 1984, Fleischner 1994, Magilligan and McDowell 1997). Some concluded,

following an extensive review of the literature, that livestock grazing has no documented 

beneficial ecological effects on riparian areas and at best non-significant negative effects; that 

livestock grazing is not sustainable (Belsky, Matzke, and Uselman 1999). Belsky et al. (1999)

cautions about others (Clary and Webster 1989, Elmore and Kauffman 1994, Burton and Kozel 

1996, Weller 1996) who describe the benefits of reduced cattle stocking rates and newer, more 

intensive grazing systems to improving streamside and riparian conditions. Belsky et al. (1999) is 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

598

critical of these publications that contrast newer grazing systems to more traditional and 

destructive grazing systems, such as season-long grazing with high stocking rates not to cessation 

of grazing and total rest.

Livestock grazing and associated management activities has both direct and indirect physical 

disturbance effects of varying degrees to landscapes and associated terrestrial and aquatic 

habitats. These potential disturbances include changes to watershed hydrologic process, primarily 

infiltration and secondary effects on peak flows, erosion, contaminant transport, and water quality 

degradation, removal of vegetation by herbivory, changes in plant communities, changes in 

wildfire frequency and intensity, reductions in ground cover and potential exposed soils leading to 

wind and water erosion, changes to soil structure and bulk density resulting in compaction or 

loose soils from livestock trailing and hoof trampling, loose and exposed soils from stream bank, 

and sod or plant root shearing, lowered water tables.

Repeated grazing in key forage areas can stress individual desirable forage plants leading to 

diminished root reserves, reductions in plant vigor and shifts in composition of plant 

communities. Conversion from deep rooted perennial graminoids to annual species is possible 

when grazing is coupled with other environmental stressors or change agents such as wildfire or 

drought. 

Effects of livestock disturbance to terrestrial wildlife include displacement from resting, foraging 

and breeding habitats, and water sources, trampling of individuals or ground nests, exposure to 

disease and parasites. Effects of livestock herbivory to terrestrial wildlife species include 

reductions in vertical hiding and nesting cover, competition for forage resources, concentrated 

urine and dung defecation in wildlife foraging and resting areas, vector introduction of invasive 

plant species such as cheatgrass, and dewatering of meadow and riparian habitats.

Within the plan area livestock grazing is identified as a potential primary stressor to seven animal 

species of conservation concern including four birds (willow flycatcher, bi-state sage-grouse, 

Mount Pinos sooty grouse, and great gray owl) and three butterflies (Apache fritillary, Mono 

Lake checkerspot and Sierra sulphur). Domestic sheep have been removed from five sheep 

allotments affecting two other species, Sierra Nevada bighorn and Nelson bighorn. See the 

terrestrial wildlife section for a description of those effects. Effects of livestock herbivory to plant 

species of conservation concern include uprooting and removal or defoliation of individual plants, 

interrupted flowering and/or seed dispersal, trampling, concentrated urine and dung defecation on 

individual plants, increased bare ground and vector introduction of invasive plant species (e.g., 

cheatgrass). Within the plan area livestock grazing is identified as a potential primary stressor for 

seventy-four plant species of conservation concern. See the “At-Risk Plants” section for a 

description of those effects.

Effects of livestock disturbance to aquatic species include accelerated erosion and soil deposition 

into streams and lakes, hindered trout fry emergence in gravels and decreased winter survival by 

filling in channel pore spaces, loss of over-hanging streambanks, poor bank stability, reductions 

in shading and increased water temperatures from riparian tree and shrub browsing; shallower 

and wider stream channels, replacement of deep-rooted plant species with shallow-rooted plant 

species and lowered streambank stability. Within the plan area livestock grazing is identified as a 

potential primary stressor for five aquatic species of conservation concern including one fish 

species (California golden trout,) and three invertebrates (western pearl shell, Owen’s Valley 

spring snail, Wong’s spring snail). Two other federally listed trout species (Lahontan cutthroat 

and Paiute cutthroat) and three amphibian species (Yosemite toad, Sierra Nevada yellow-legged 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

599

frog, and Mountain yellow-legged frog) that either have had terms and conditions in place for 

grazing or are outside of any allotments. See the aquatic species section for a description of those 

effects.

A review and summary of grazing effects to ecosystems in the Sierra Nevada was prepared in the 

Sierra Nevada Ecosystem Project Report to Congress (Millar 1996). At the request of the Forest 

Service, that large body of work was given a critical review by the University of California 

Rangeland Science Team, and summarized and reported back to the Forest Service (Allen-Diaz et 

al. 1999). These sources of information provided an assessment of the current science base for 

addressing rangeland issues in the Sierra Nevada; prior to development of the 2001 Sierra Nevada 

Forest Plan Amendment Final Environmental Impact Statement and 2004 Final Supplemental 

Environmental Impact Statement (USDA Forest Service 2001, 2004). The Allen-Diaz report, 

where noted, “grazing” is most often treated as a yes or no proposition, but it really is a complex 

process where timing, frequency, duration, season of use, and intensity matter. The terms 

“grazing” and “overgrazing” are not defined in most of the statements where they are used.

In many studies it is also difficult to determine when “historic grazing” is being discussed versus 

“current grazing.” Without detailed descriptions of grazing season, frequency, intensity, and 

system as well as a quantitative description of the range site, riparian type, or stream class it is 

difficult to interpret the work with regard to current livestock management in the Sierra Nevada. 

Unfortunately, this problem permeates much of the existing rangeland literature.

(Tate 2005) reviewed others and reiterates that Allen-Diaz et al.’s (1999) review illustrates the 

lack of tested, real world solutions in the literature, and the real need for new approaches to study 

and define sustainable riparian grazing. Tate (2005) reported findings from a survey of grazing 

management and corresponding riparian health on 300 stream reaches across California. They 

were able to correlate site-specific grazing management practices to riparian health; that common 

grazing practices (such as herding, off site watering) that move livestock away from riparian areas 

are positively associated with improved riparian and stream health. Tate (2005) concluded that 

sustainable riparian grazing is dependent upon: 1) working directly with grazing managers to 

identify grazing practices which maintain riparian health yet are logistically and economically 

feasible; and conducting research at the ranch and grazing allotment scale to insure the results are 

relevant at the management scale.

Current Grazing 

There are 50 livestock allotments administered by the Inyo National Forest. Thirty-six of the 

allotments are active; 11 are vacant and 3 are closed. Refer to appendix D for an illustration and 

summary table of current allotments. In 2016, 4,540 head of cattle, 54 head of horses and 13,320 

head of sheep were permitted to graze at various times throughout the year on the Inyo, with the 

primary grazing season between June 15 and September 30. A total of 29,710 animal unit months 

(AUMs) were authorized to graze under a term grazing permit on National Forest System lands

(USDA Forest Service 2013a). By contract the Inyo had 56 active allotments in 1984 for a total of 

38,194 animal unit months (USDA Forest Service 1988b); an overall decline of 22 percent in 

permitted animal unit months in the last 28 years. Permitted use has remained stable over the last 

10 years as reported in the Grazing Statistical Report from 2006 to 2016 shown in figure 35.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

600

Figure 35. Inyo National Forest animal unit months (AUMs) from 2006 through 2016 

(Source: Forest Service Natural Resource Manager (NRM) website, Annual Grazing Statistical 

Report: Detail at national forest Level)

Forty of 47 or 85 percent of active and vacant allotments have had environmental analysis and an 

allotment management decision made since passage of the Rescissions Act56 of 1995, which 

addresses grazing permit issuance and a required scheduling of allotment analysis in compliance 

with the National Environmental Policy Act (NEPA). Twenty-two allotments are scheduled for 

environmental analysis or reanalysis within the next decade (2017-2028) as described in the 

National Allotment NEPA Schedule (USDA Forest Service 2017d). Some of these projects 

include possible reactivation of vacant allotments and/or converting former domestic sheep 

allotments to cattle allotments. 

Livestock permittees who use National Forest System lands on the Inyo National Forest

contribute to the local economy in Inyo and Mono Counties. In addition, local ranchers and

national forest permittees contribute to the social well-being and economic sustainability of the 

local community. These families participate and support many local activities and community 

tourism events. The local communities depend on rangeland resources for their livelihood by 

meeting the public needs for interrelated resource uses such as livestock and wildlife forage, 

terrestrial and aquatic wildlife habitats, outdoor recreation, and healthy watersheds. 

Economic sustainability of these ranches owned by permittees over the next 20 years is the most 

difficult to predict. Their future will depend on the ability to maintain a viable and profitable 

livestock operation based on the availability of a sustainable forage base. Ranchers are already 

faced with the need to manage for diverse goals and have been encouraged to produce products 

with a higher market value, such as organic and natural meats. In most cases, it is the herd size 

authorized in the Forest Service grazing permit that limits the ability of many permittees to rely 

on ranch income alone. Each permit has a certain capacity, resulting in a set number of permitted 

livestock that the range can support for the season of authorized use. Many permittees have 

 56 P.L 104-19, section 504(a)
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

601

already diversified their operation to supplement their income from part-time to full-time offranch work. 

In order to cope with reductions of National Forest System lands for summer grazing, ranchers 

favor leasing more private land. However, these lands are in short supply and there is strict 

competition for the leases. In a 2002 University of California Berkeley report to the Sierra 

Nevada Alliance, 40 to 50 percent of ranching income was attributed to their access to these 

summer grazing lands. Those interviewed who graze on National Forest System lands said they 

have no desire to sell their ranches, but a third stated that they would have to consider selling if 

they lost their Forest Service grazing permit. The majority of ranchers surveyed responded that 

living and working amidst natural beauty was a highly important reason to continue ranching, and 

that although ranching is not seen as the ideal way to make a living, most ranchers want their 

children to continue ranching and to pass on the family tradition (Sulak and Huntsinger 2002).

Analysis and Methods

Analysis Area

While the analysis area consists of all National Forest System lands within the Inyo National 

Forest, the primary focus includes lands identified as suitable for livestock production.

Lands Suitable for Production Livestock Grazing

Lands identified as suitable for livestock production include National Forest System lands not 

administratively withdrawn that have been identified in grazing allotments. The status of grazing 

allotments is either active or vacant. Active allotments have current grazing permit holders 

authorized to graze the designated allotment. Vacant allotments have no existing permit holder 

and are generally suspended from grazing until environmental analysis to reactivate the allotment 

has been completed. A project level suitability analysis would also be done prior to an allotment 

re-activation. Approximately 852,201 acres within National Forest System lands administered by 

the Inyo National Forest are considered suitable for livestock grazing and production. Of those 

lands, approximately 275,744 acres or 32 percent are in vacant status. See Appendix D (table D-1

and figure D-1) for a summary of current allotments and a map of lands not suitable for 

production livestock.

Grazing

Lands identified as not suitable for livestock production include National Forest System lands 

administratively withdrawn from production grazing where the allotments have been closed and 

are no longer delineated. Lands not suitable for livestock production are those lands where 

livestock grazing has been found to be incompatible with the desired conditions or result in 

substantial and permanent impairment of the land. Approximately 1,216,142 acres or 59 percent

of National Forest System lands administered by the Inyo National Forest are considered not 

suitable for livestock grazing and production. Suitability determinations were carried forward 

unchanged to the revised plan. See Appendix D, map Figure D-1 for an illustration of lands not 

suitable for livestock production.

Temporal Scale

The analysis period consists of two decades (20 years). Discussion on climate change extends to 

50 years.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

602

Indicators and Measures

The primary indicators used in rangeland management, both regionally and nationally, are:

• Livestock grazing use as measured by amount of animal unit months (AUMs) permitted 

annually as a measure of forage consumed. 

• Rangeland vegetation Improved as measured by area in acres of allotments maintained at or 

improved towards desired conditions.

• Forest plan consistency as measured by area in acres of allotments being administered to 

forest plan standards and guidelines and number of active allotments that have NEPA 

completed in accordance with the 1995 Rescission Act, P.L.104-19 section 504.

Measures used in this analysis and forest plan monitoring: 

• Amount of animal unit months permitted annually as a measure of forage consumed. 

• Area in acres of allotments maintained at or improved towards desired conditions.

• Area in acres of allotments being administered to forest plan standards and guidelines.

• Number of active allotments that are NEPA compliant.

Assumptions

• Previous grazing suitability determinations are carried forward for this plan revision. The 

final decision to authorize or discontinue livestock grazing at the allotment level is made 

following project-level environmental analysis. 

• If implementation of current grazing management standards and guidelines from the forest 

plan (USDA Forest Service 1988a), as amended (USDA Forest Service 1995, 2004a) were 

to continue, vegetation and watershed conditions trends are expected to meet or move 

towards desired conditions for the next 20 years. Monitoring and adaptive management are 

used to adjust management to maintain and improve rangeland resources.

• Acres administered to standard includes the complexity of permit administration workloads 

where a more complex workload is reflected by fewer acres administered to standard as 

compared to a less complex workload.

• It is assumed that commercial livestock grazing opportunities on the Inyo National Forest 

will be constrained at or near current levels. Opportunities for domestic sheep grazing will 

remain static or decline if there is expansion of occupied bighorn sheep habitat.

• It is assumed that average forage production will likely decline over time with warmer 

temperatures, and increased frequency and duration of drought conditions as projected by 

climate modeling (Vose et al. 2016). Local demand for production livestock forage will 

exceed forage being made available and authorized.

Affected Environment

As described in the 1988 forest analysis (USDA Forest Service 1988a), bitterbrush (115,409 

acres), big sagebrush (160,000 acres) and wet meadows (26,000 acres) are the mainstay of the 

rangeland resource. They account for an estimated 80 percent of the Inyo’s grazing outputs. It 

further states:
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

603

. . . approximately 3,900 acres of suitable range brush would need to be rejuvenated each 

year to maintain current grazing outputs (27,000 AUMs in 1988) from brush types over 

the next fifty years.

Also that:

Increases in forage are ultimately limited by physical, biological and statutory factors. 

Most of the rangeland on the Forest is arid (receiving an average of nine to fifteen inches 

of precipitation per year) and high in elevation (much of it above 7,000 feet) with a 

growing season of three to four months. Most soils are derived from granitic or volcanic 

parent rock and have low water-holding capacity. Lack of water and a short growing 

season limit the growth of forage plants. Finally, much of the highest quality wet 

meadowland is in the Golden Trout Wilderness (Kern Plateau). Grazing in wilderness is 

restricted to levels that are compatible with wilderness values.”

The demand for grazing on the Inyo is expected to continue at or above present levels, 

since National Forest summer range is essential for local ranch operations. The Forest 

Service assumes that if additional AUMs were made available, they would be utilized by 

present permittees.” 

The domestic livestock program is currently managed at (low to) moderate level of 

intensity. Most range allotments have some improvements (such as fences or vegetation 

treatments) but the improvements are not sufficient to optimize livestock utilization of 

forage (USDA Forest Service1988a).

Special Aquatic Features

There are a total of 1,479 meadows on the Inyo National Forest of which 384 meadows are in 

active grazing allotments and 202 meadows in vacant grazing allotments (Roche et al. 2015 and 

USDA Forest Service 2017d). Meadows occupy between 26,000 and 50,000 acres on NFS lands, 

depending on the definition and the scale of mapping. When dry alpine or subalpine meadows are 

included, the area is increased. The landscape of meadows extent depends on location. There have 

been no systematic condition assessments of all the meadows on the Inyo National Forest. 

Researchers sampled ten randomly selected meadows on the Inyo National Forest, as part of a 

Sierra Nevada study (Fryjoff-Hung and Viers 2013). Otherwise, assessments have focused on key 

grazing area meadows within active grazing allotments and packstock use areas. Rangeland 

conditions for these are described below. The condition rating of key grazing areas may not 

represent overall condition of special aquatic features across the national forest (Assessment 

USDA Forest Service2013a).

There are a total of 235 known fens on the Inyo National Forest. Generally, these fens are found 

within the larger meadow complexes. A total of 129 fens are within grazing allotments; 59 in 

active allotments and 70 in vacant allotments (Roche et al. 2015 and USDA Forest Service

2017d). Within these meadow complexes fens play an important role in nutrient cycling and 

groundwater discharge, provide habitat for rare species, and are a major sink for atmospheric 

carbon (Weixelman and Cooper 2009). Proper functioning condition information for fens 

indicated that most either were properly functioning, or had an upward trend, or no trend. A small 

proportion was found to have a downward trend.

Current Rangeland Conditions

As reported in the Final Inyo National Forest Assessment (USDA Forest Service 2013a), within 

the last 10 years, condition data has been collected from key areas on 32 allotments on the Inyo 

National Forest. Data includes vegetation condition, watershed condition, and stream channel 

assessments. Because of the varied differences in rangeland types, the allotments have been 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

604

grouped into similar ecosystem types to facilitate management. These groups are Kern Plateau, 

Desert Allotments, Crowley Lake, Mono Lake, White Mountain, Bishop, and Inyo Mountain. 

Ratings for vegetation across the Inyo show that 103 key areas (68 percent) fall within the desired 

condition for vegetation across the national forest. Twenty-seven key areas (26 percent) are in fair 

condition, and six key areas (6 percent) are in poor condition.

The Inyo National Forest Rangeland Condition Evaluation Process includes a Vegetation 

Condition Assessment and a Watershed Condition Assessment. Watershed condition ratings show 

that 71 key areas (50 percent) rate as fully functional, 47 key areas (33 percent) rate as 

functioning at risk, 29 key areas (20 percent) rate as degraded and six key areas (4 percent) rate as 

non-functional. For stream reaches within grazed allotments, 67 reaches (59 percent) are properly 

functioning, 42 reaches (37 percent) are functioning at risk (with different trend ratings), and five 

reaches (5 percent) are non-functioning.

While generally good, rangeland conditions vary throughout the Inyo, based on data collected to 

assess vegetation conditions, watershed function, and hydrologic function. The Inyo National 

Forest conducts annual monitoring of range best management practices to evaluate impacts to 

water quality and aquatic habitat. Of the total 24 range allotment evaluations conducted, 16 were 

rated as both implemented and effective. Another four rated as implemented at risk, meaning that 

although the best management practices were correctly implemented, minor departures from 

effectiveness were noted. The remaining four evaluations were rated implemented but not 

effective, meaning that although the best management practices were implemented as planned, 

they were not effective in preventing adverse effects on water quality.

Effectiveness of Current Grazing Direction and Information Gaps

In 2012, the Forest Service and the University of California Davis Rangeland Watershed 

Laboratory established a partnership to conduct the first comprehensive analysis of the long term 

monitoring program dataset conducted by the Forest Service between 1997 and 2015 on montane 

meadows in the Sierra Nevada; the set of data has included monitoring sites on the Inyo National 

Forest.

Oles et al. (2017) examined modern conservation strategies that better balance riparian 

conservation and livestock production objectives on national forest lands. Oles et al. found that 

changes in plant community were not associated with livestock stocking rates or precipitation at 

the allotment scale. However, changes in both factors significantly affected changes in plant 

communities at the meadow scale. Their findings suggest reductions in stocking rates have 

improved the balance between riparian conservation and livestock production goals. However, 

changing climate conditions (reduced snow packs and change in timing of snowmelt) may negate 

those benefits at specific sites and adaptive site-specific management strategies are required to 

meet grazing pressure limits and safeguard ecosystem services.

Specific to the Inyo National Forest, Freitas et al. (2014) examined the same Forest Service data 

set for 25 monitoring sites on the Kern Plateau within two vacant allotments and two active 

allotments. Freitas et al. concluded that riparian conservation grazing strategies implemented on

the active allotments neither degraded nor hampered recovery of meadow conditions relative to 

non-grazed meadow conditions in the vacant allotments. 

UC Davis, in partnership with the Forest Service is continuing the process of examining these 

data to determine meadow conditions and trends, and relationships between meadow conditions 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

605

and trends, livestock management, weather and environmental drivers. When new information 

becomes available, it will be used to inform the analysis supporting plan revision as applicable. 

An ongoing project by the UC Davis Rangeland Watershed Laboratory titled “Meadow 

Conditions on National Forest Grazing Allotments” represents the most scientifically updated 

assessment of trend and response to grazing management, as well as to weather and other factors 

on national forest meadow and riparian rangelands. Meadow health will be assessed using the 

rooted frequency (Bonham 2013) data to calculate a suite of indicators of meadow condition and 

trend, including species richness, diversity (Simpson’s and Shannon-Wiener indices) and 

evenness. Soil stability scores (Burton, Smith, and Cowley 2010, Winward 2000) will also be 

calculated from plant functional trait groups, which are based on life form, life span, plant height, 

growth form (clonal or not), and nitrogen fixing ability. Current status of the study as well as 

preliminary analysis of long term monitoring sites on the Inyo National Forest can be found at the 

UC Davis Rangeland Watershed Laboratory website: 

http://rangelandwatersheds.ucdavis.edu/main/projects/sierra_nevada_meadows_analysis.html.

Patterns of Rangeland Drought

As stated in the “Climate Change” section of this document, mean annual temperatures in the 

plan area have increased in the last several decades, mostly with increased nighttime temperatures 

(Mallek, Safford, and Sawyer 2012). At higher elevations, overall snowfall and spring snow water 

equivalent (amount of water in snowpack) have remained steady in most southern Sierra Nevada 

areas, but snowmelt occurs earlier in the year. Changes in temperatures and amounts and timing 

of precipitation have led to earlier peak stream flow rates in most Sierra Nevada streams, with 

higher spring flows and lower summer flows. Warming temperatures are leading to glacial 

recession across the southern Sierra Nevada.

As noted by (Vose, Clark et al. 2016) since 1982, the southern part of the United States has 

exhibited unfavorable trends in growing conditions resulting from warmer temperatures and 

decreasing precipitation. During that period the Inyo National Forest showed moderately high 

increases in temperature while precipitation has been decreasing (years 1982-2012). Also, 

moderately high decreases in vegetation abundance (years 2000-2013). Reeves (2016) reported 

cumulative drought (years 2000-2015) and corresponding reductions in biomass to vary from low 

to moderately high across the Inyo National Forest grazing allotments.

Environmental Consequences

Since the 1988 Inyo National Forest Land and Resource Management Plan was implemented 

there have been three forest plan amendments in 1995, 2001 and 2004 with specific updates in 

direction to production livestock grazing (USDA Forest Service 1995b, 2004a). Amendment 6 in 

1995 emphasized establishing proper utilization level base on desired vegetation conditions and 

proper function condition on grazable rangelands. In 2001 and 2004 the emphasis was focused on 

using adaptive management to improve riparian conservation and achieve proper hydrologic 

function of riparian systems and watersheds, in addition to conservation of high value aquatic and 

wildlife habitats like aspen and willow plant communities. The 2001 and 2004 amendments 

complemented the goals and objectives already in place under the 1995 plan amendment.

All active grazing permits have incorporated allowable utilization levels based on the rangeland 

assessments described in the 1995 plan amendment; additional adjustments have been made to 

grazing permits consistent with the 2004 plan amendment. In addition to these two previous plan 

amendments there have been incremental adjustments to the grazing program when addressing 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

606

specific grazing impacts on federally listed species. Management terms and conditions required 

as a result of consultation with U.S. Fish and Wildlife Service and their authorized incidental 

take, have been incorporated in the term grazing permits where applicable. Also, since 2013 the 

Inyo National Forest has implemented Sage-grouse Interim Management Policy. Additional 

changes have also been made for other regional forester listed sensitive species.

Consequences Specific to Alternative A

Livestock Grazing Use

Under alternative A there would be no change to the existing management direction for livestock 

grazing. Current management direction for term grazing permits and allotment management plans 

remain in place. New permits and management plans would follow direction identified in the 

Inyo forest plan, amendment 6 (USDA Forest Service 1995), thought by some to be too 

prescriptive, unnecessarily complex, and based on use of outdated methods. There would be no 

anticipated change in overall permitted use from existing conditions unless identified during 

project-level environmental analysis. Commercial livestock grazing opportunities on the Inyo 

National Forest will continue to be constrained at or near current levels. Opportunities for 

domestic sheep grazing will remain static or decline if there is expansion of occupied bighorn 

habitat within the next 20 years. Interim forest guidelines for management of bi-state sage-grouse 

habitat would stay in effect under alternative A. No active allotments are within Yosemite toad 

habitat therefore management direction specific to those habitats does not apply under alternative 

A.

Permitted livestock use could decline over the next 50 years with warmer temperatures, and 

increased frequency and duration of drought conditions and more frequent and larger wildfires. 

There would be potential for a slight downward trend in permitted animal unit months due to 

annual grass type conversions accompanied with a corresponding increased complexity in permit 

administration and grazing management. Existing local demand for production livestock forage 

will exceed forage being made available and authorized.

Under alternative A there would be no additional wilderness designation recommended. 

Allotment grazing levels and the commitment of forage resources to grazing would continue to be 

assessed and determined at the project (allotment) level during environmental analysis. Existing 

wilderness designation would continue to prohibit access by motorized vehicle and mechanized 

equipment for maintenance of stock water developments, salt placement and potentially restrict 

installation of new range improvements (such as water troughs) unless approved following a 

minimum requirements decision. Overall, the annual operating costs to the current permittees 

would remain static.

Rangeland Vegetation Improved

If implementation of the current Inyo National Forest grazing management strategy (USDA 

Forest Service 1995) were to continue, vegetation and watershed condition trends are expected to 

improve, or continue to improve, for the next 20 years, particularly within riparian conservation 

areas. In terrestrial ecosystems, moderate change is anticipated under all alternatives in amount 

and extent of annual grass conversions due to climate change and trend in large wildfires as 

modeled during the next mid-century (2035-2064). The highest probability of percent change due 

to large wildfires is highest under alternatives A and C and less under alternatives B and D with 

restoration efforts in the foothill, montane and Great Basin ecological zones which correspond 

with the location of active grazing allotments. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

607

Adaptive management, which is a key component of the Inyo forest plan, amendment 6 (1995), 

rangeland assessment process, allows managers to take action to adjust utilization allowances or 

even grazing management strategies to facilitate the upward trend of meadow and upland grazing 

sites. However, any future deviation or updating of the forest plan rangeland analysis process

would require other forest plan amendments. Improved meadow, riparian and upland sites will 

result in increased forage available to grazing animals, along with improved overall ecological 

health of rangelands, which benefit native fauna as well. This may offset anticipated declines in 

forage production due to climate change and annual grass conversions during the next midcentury (50 or more years).

Consequences Common to Alternative B, B-modified, C, and D

Livestock Grazing Use

Under alternatives B, B-modified, C, and D there would be several updates to the existing 

management direction for livestock grazing as compared to alternative A. Current management 

direction for term grazing permits and allotment management plans would be updated where 

applicable for changes in design criteria for disturbance to stream banks, lakeshores and fens. 

New permits and management plans would follow direction identified in the final revised Inyo

forest plan, chapter 2 “Forestwide Desired Conditions and Management Direction,” “Rangeland 

Livestock Grazing.” In the plan revision alternatives, grazing standards are similar though 

simplified and incorporate updates to the regional rangeland plant list (R5-TP-042, USDA Forest 

Service 2017). Procedures for conducting rangeland condition evaluations, used to determine 

allowable utilization standards, would be moved from the existing forest plan into an Inyo 

National Forest supplement to the regional rangeland analysis and planning guide as described in 

the “Rangeland Management Supplemental Report” (Frolli and Sims Specialist Report, January 

2018, planning record) and incorporate the most recent agency rangeland and watershed 

evaluation methods. There would be no anticipated change in overall permitted use from existing 

conditions unless identified during project-level environmental analysis. Commercial livestock 

grazing opportunities on the Inyo National Forest will continue to be constrained at or near 

current levels. Opportunities for domestic sheep grazing will remain static or decline if there is 

expansion of occupied bighorn habitat. Forest guidelines for management of bi-state sage-grouse 

habitat would be more implementable under alternative B-modified compared to alternatives B, 

C, and D. All four plan revision alternatives have more adaptable management direction then 

alternative A. They also would reflect changes in direction that had been incorporated into 

existing grazing permits and allotment management plans in the past. No active allotments are 

within Yosemite toad habitat therefore management direction specific to those habitats does not 

apply under any alternative.

Under alternatives B, B-modified, C, and D permitted livestock use could decline over the next 

50 years with warmer temperatures, and increased frequency and duration of drought conditions 

and more frequent and larger wildfires. There would be potential for a slight downward trend in 

permitted animal unit months due to annual grass type conversions accompanied with a 

corresponding increased complexity in permit administration and grazing management. Where 

feasible and suitable, grazing can be used as a tool to reduce vegetation build-up to lower the risk 

of unwanted wildfire. Post-fire burned areas, within suitable grazing allotments would be 

evaluated to determine appropriate rest for vegetation recovery and adjustments to permitted 

grazing from available forage. Existing local demand for production livestock forage will exceed 

forage being made available and authorized.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

608

Rangeland Vegetation Improved

Under alternatives B, B-modified, C, and D if implementation of this modified Inyo National 

Forest grazing management strategy were to continue, vegetation and watershed condition trends 

are expected to improve, or continue to improve, for the next 20 years, particularly within riparian 

conservation areas. In terrestrial ecosystems, moderate change is anticipated under Alternatives B 

and B-modified in amount and extent of annual grass conversions due to climate change and 

trend in large wildfires as modeled during the next mid-century (2035-2064). Alternatives B, Bmodified and D would have lower probability of percent change due to large wildfires as 

compared to alternatives A and C due to restoration efforts in the foothill, montane and Great 

Basin ecological zones which correspond with the location of active grazing allotments.

Under alternatives B, B-modified, C, and D, adaptive management is a key component of the 

grazing management strategy which allows managers to take action to adjust utilization 

allowances and grazing management strategies to facilitate the upward trend of meadow and 

upland grazing sites. These alternatives also allows future updates rangeland and watershed 

evaluation methods to incorporate best available science and new information in a timely manner. 

Improved meadow, riparian and upland sites will result in increased forage available to grazing 

animals, along with improved overall ecological health of rangelands, which benefit native fauna 

as well. This may offset anticipated declines in forage production due to climate change and 

annual grass conversions during the next 50 or more years.

Cumulative Environmental Consequences

Fire Management. Under alternatives B, B-modified, C, and D where feasible and suitable,

grazing can be used as a tool to reduce vegetation build-up to lower the risk of unwanted wildfire. 

Post-fire burned areas, within suitable grazing allotments would be evaluated to determine 

appropriate rest for vegetation recovery and adjustments to permitted grazing from available 

forage.

Ecological Integrity. Under alternatives B, B-modified, C, and D, for the bi-state greater sagegrouse species-specific plan direction is added. The forest plan direction is based on the existing 

“Inyo National Forest Sage-Grouse Interim Management Policy” (USDA Forest Service 2012c)

and, where appropriate, additional management direction has been developed consistent with the 

“Humboldt-Toiyabe National Forest Greater Sage Grouse Bi-State Distinct Population Segment 

Forest Plan Amendment.” The revised forest plan also includes management direction and 

emphasizes management actions that are consistent with the now updated “Bi-State Action Plan: 

Past, Present, and Future Actions for the Conservation of the Greater Sage-Grouse, Bi-State 

Distinct Population Segment.” 

Acres of sage-grouse habitat improved are projected to be highest under alternatives C and D at 

22,350 acres, less for alternatives B and B-modified at 14,900 acres, and lowest under alternative 

A at 7,450 acres. Acres of riparian ecosystems restored is projected to be highest under alternative 

C at 600 acres of meadow and 20 miles of streams restored; it is slightly lower under alternatives 

B, D, and B-modified at 500 acres of meadow and 20 miles of streams restored. Ecological 

restoration will contribute to the sustainability of grazing on the Inyo National Forest. Restoration 

of sage-grouse and aquatic habitats will remain a priority under all alternatives. Under all 

alternatives short-term impacts from restoration efforts may be adverse to individual permittees at 

the allotment scale if temporary changes in livestock management are needed to minimize 

disturbance on these sites. However, long-term impacts under all plan revision alternatives would 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

609

be beneficial once restoration objectives have been reached; such benefits as sustaining desired 

forage plant species and permitted grazing levels over time.

A rangeland condition and biodiversity assessment on national forests within the region is in 

progress by Forest Service and University of California Davis to estimate trends over the last 20 

years. Over 800 monitoring sites have been established on the national forests in California since 

1999. Results from this study are expected in the near future which will provide a more 

meaningful assessment of rangeland condition and trend and response to grazing management, as 

well as to weather and other factors. Alternatives B, B-modified, C, and D would provide the best 

means of adjusting rangeland and watershed evaluation assessments or adapting management to 

any new information from these monitoring efforts. Alternative A would require an amendment to 

the forest plan to adjust to rangeland and watershed evaluation assessments and possibly delaying 

adaptive management responses.

All five alternatives continue existing design criteria for management and protection of fens. A 

management indicators technical guide has recently been developed to assess ground disturbance 

and it provides managers and livestock producers a quantifiable measure of permitted disturbance 

levels on these special aquatic features and the need to move or remove livestock if disturbance 

levels are exceeded. Alternatives B, B-modified, C, and D provide an additional riparian 

conservation standard to limit disturbance on fens from livestock annually at 15 to 20 percent and 

make further adjustments if fen conditions are trending downward.

Conservation Watersheds. Area-specific management area plan components for watersheds 

seek to attain water quality for state-designated beneficial uses and to retain integrity of the 

aquatic systems. In general, forestwide watershed conditions are fully functioning, with 

connectivity (WTR-FW-DC 02, WTR-FW-STD 01). Conservation watersheds, a subset of 

watersheds, include, in addition, plan components to benefit habitat for at-risk species, mostly 

Species of Conservation Concern. They are important places to protect these species, and the 

networks of connected waterways to help provide resilience in the face of large scale catastrophic 

events. They are areas where first of all, we seek to maintain high quality water, but where we 

would undertake restoration if in fact, we thought it could improve the resilience of the 

populations by diminishing risks and/or establishing connectivity where appropriate. 

As shown in table 110, under alternative A there would be 98,085 acres of critical aquatic refuge 

management areas within active and vacant grazing allotments. Under alternatives B and D there 

would be a 20,476-acre (21 percent) increase in critical aquatic refuge management areas 

compared to alternative A. Under alternative C there would be a 75,332 acre (77 percent) increase 

in critical aquatic refuge management areas compared to alternative A. For alternative Bmodified, conservation watershed management areas would occur on 223,288 acres within active 

and vacant allotments. Conservation watersheds would replace existing critical aquatic refuge 

management areas. Within grazing allotments, under alternative B-modified there would be a

125,203-acre (128 percent) increase in area-specific watershed management as compared to 

alternative A.

Under Alternative B-modified, Conservation Watershed plan components do not directly prohibit 

livestock grazing activities or restrict or limit this use. Forest Plan components for these 

management areas allow for the continued use of livestock and do not prescribe additional 

standards that would necessarily increase burden on livestock operations or limit the variety of

management options available to livestock grazing operations. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

610

Table 110. Comparison of critical aquatic refuge and conservation watershed management areas 

within active and vacant grazing allotments

Alternative

Management

Area

Within Active

Allotments

Within Vacant

Allotments

Within 

Allotments

Alternative A

(critical aquatic refuges) 171,395 32,674 65,411 98,085

Alternatives B and D

(critical aquatic refuges) 192,362 53,150 65,411 118,561

Alternative C

(critical aquatic refuges) 324,533 107,535 65,882 173,417

Alternative B-Modified

(conservation watersheds) 387,677 94,732 128,556 223,288

During implementation of restoration actions within conservation watersheds, specific project 

design features may be created to reduce the impacts of livestock grazing to restoration efforts 

(for example, meadow restoration where willows are planted); to ensure that grazing activities 

promote attainment of functional watershed condition indicators, consistent with the purpose of 

the conservation watershed. Under all alternatives the impacts of these design features to 

livestock grazing would be determined, and analyzed, at the project level. The forest plan 

contains standards and guidelines that apply to livestock grazing within Riparian Conservation 

Areas. Standards MA-RCA-STD 01, 07, 10-14, 17 and 19 and guidelines MA-RCA-GDL 02, 03, 

and 05 would apply at the project level. The following components also apply: RANG-FW-STD 

04 and RANG-GDL-04 thru 07. These are not new standards and guidelines and are adapted from 

the 1988 Inyo Land and Resource Management Plan and 2004 Sierra Nevada Forest Plan 

Amendment. Where conservation watersheds overlap with designated wilderness, DA-WILDGDL 02 related to stock use, applies.

In summary, under alternative B-modified grazing activities would not be constrained by 

conservation watersheds. Under alternatives B, B-modified, C and D grazing could be affected by 

other plan direction that calls for maintaining or improving the quality or quantity of watershed 

resources, such as water quality, while ensuring sustainable continuation of multiple uses.

Recommended Wilderness. Alternative C includes 325,359 acres of new recommended 

wilderness. Alternatives B and B-modified include a much lower amount of new recommended 

wilderness at 37,029 acres. Alternatives A and D have zero new recommended wilderness. Under 

alternatives B, B-modified, and C these recommended wilderness additions, if designated by 

Congress, would restrict vehicle access to four (4) active cattle allotments. Wilderness 

designation would not restrict current permitted grazing levels. However, wilderness designation 

would prohibit access by motorized vehicle for maintenance of stock water developments, salt 

placement and restrict installation of new range improvements (such as water troughs) unless 

approved following a minimum requirements decision. 

Other issues that can arise after a wilderness designation include limited ability to propose new 

rangeland improvements such as water developments or drift fences which can hinder the ability 

to reach desired rangeland conditions. Also, widely held public expectations of pristine conditions 

beyond those conditions used by the Forest Service to describe wilderness character (see 

“Revision Topic 3: Sustainable Recreation and Designated Areas;” also appendix B) often lead to 

frustration in seeing livestock in a wilderness setting. Hazing or malicious harassment of 

authorized livestock in wilderness by some visitors has become more frequent in recent years. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

611

Effectively controlling livestock herds under these circumstances can often require doubled up 

workloads by the grazing permittees (Sims pers. Communication). Adverse effects under 

alternative C, if designated by Congress, would be greater than alternatives B and B-modified. 

Overall, the annual operating costs to the current permittees would have the potential to increase 

under these conditions. The extent of these effects is uncertain at this programmatic level.

Benefit to people and communities. The forestwide rangeland management goal to provide 

stability to local ranching communities would continue under all alternatives. Under alternatives 

B, B-modified, C, and D a desired condition is added to provide for open space, grazable 

landscapes, rural landscapes and cultural heritage. Under alternative A, long-term impacts to 

grazing opportunities could result from no increase in restoration activities to reduce the risk of 

uncharacteristic wildfires or to improve forest and rangeland health. Under alternatives B, Bmodified, C, and D short-term impacts from restoration efforts may be adverse to individual 

permittees at the allotment scale with long-term benefits once restoration objectives have been 

reached. 

Analytical Conclusions

Under all alternatives, there is no change in rangeland suitability acres. Any adjustments to 

suitability analysis and subsequent suitability determinations would involve project-level 

environmental analysis.

All alternatives would continue authorized grazing at current levels over the 20-year analysis 

period. Alternatives B, B-modified, C, and D would have modest improvements in riparian 

conservation areas and resilience to disturbance and climate change at the allotment level. 

Landscape resilience would continue to decline over the next mid-century in the foothill, montane 

and Great Basin ecological zones due to upward trends in large wildfire, annual grass conversion, 

and climate change and prolonged patterns of persistent drought. Permitted livestock use is likely 

to decline over the next 50 years. 

Alternatives B, B-modified, C, and D provides more design criteria then the alternative A in using 

timely adaptive management. Under these alternatives forest plan design criteria are slightly less 

prescriptive. Utilization standards are simplified into fewer categories. Rangeland assessment 

processes are removed from the forest plan and placed in a forest supplement to the regional 

rangeland analysis and planning guide. This approach would allow timely updates to rangeland 

assessment procedures using best available science and new information. 

Alternative A would retain some adaptive management features though more constrained than 

alternatives B, B-modified, C and D due to fixed rangeland analysis procedures which do not 

account for best available science regarding unforeseeable changes and information gaps or the 

uncertainty of ecosystem response to climate change, wildfires, and other factors.

Under all alternatives short-term impacts from restoration efforts would be offset by long-term 

benefits, such as sustaining permitted grazing levels over time, once restoration objectives have 

been reached.

Wilderness designation of those areas recommended under the alternatives would not be expected 

to restrict current permitted grazing levels differently than under the current forest plan. 

Allotment grazing levels and the commitment of forage resources to grazing would continue to be 

assessed and determined at the project (allotment) level during environmental analysis. 

Wilderness designation would prohibit access by motorized vehicle and mechanized equipment 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

612

for maintenance of stock water developments, salt placement and potentially restrict installation 

of new range improvements (i.e. water troughs) unless approved following a minimum 

requirements decision. Overall, the annual operating costs to the current permittees would have 

the potential to increase under these conditions. The extent of these effects is uncertain at this 

programmatic level.

Wild Horses and Burros Territory Management

Three administratively designated wild horse and burro territories occur on the Inyo National 

Forest: Montgomery Pass and White Mountain Wild Horse Territories; and Saline Valley Wild 

Burro Territory in the Inyo Mountains Range (see appendix D, figure D-2). These three territories 

were established with the passage of the Wild Horse and Burro Act of 1971. Management of wild 

horse and burro territories is guided by individual management plans.

The wild horse and burro territories are managed as part of the Rangeland Management Program. 

The desired conditions grazable rangelands within these territories are similar to those for 

livestock grazing allotments. The desired conditions for grazable rangelands and management 

are: 

1. Rangelands, along with grazable forestlands and woodlands, provide large areas of 

contiguous space supporting native vegetation that has the potential to be grazed. These 

grazable landscapes sustain biological diversity and ecosystem integrity and help to 

preserve the rural landscape and cultural heritage of the central, southern and eastern 

Sierra Nevada.

2. Forage, browse, and cover meet the needs of wildlife and wild horses and burros are 

managed in balance with available forage. Areas that are grazed have or are trending 

toward having satisfactory soil conditions, functional hydrology and biotic integrity.

3. Wild horse and burro grazing maintains the desired rangeland vegetation types 

represented by diverse plant functional groups, species richness and diversity, and 

structure and condition of plant communities.

4. The Forest Service national policy objective is to maintain wild free-roaming horse and 

burro populations in a thriving ecological balance in the areas they inhabit on National 

Forests. Specific territory management objectives are described in each of the respective 

territory plans.

Goal (DA-WHT-GOAL)

1. Continue working with other agencies and Forest Service units, such as the Bureau of 

Land Management and the Humboldt-Toiyabe National Forest, and other partners or 

collaborative groups to manage wild horse herds or in the development of wild horse 

management plans. 

Potential Management Approach

• Continue to monitor wild horse populations to determine numbers and use. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

613

Background

Management History

All of the feral horses and burros that now inhabit North America are probably derived from stock 

that escaped or were released from ranchers, miners, or Native Americans (Berger 1986). Few if 

any of these horses show affinities to the Spanish horses that escaped from Hernando Cortes’s 

1519 landing near Vera Cruz, Mexico, or Hernando de Soto’s 1543 travels on the Mississippi 

(Wyman 1945).

The wide-spread grazing by livestock, including horses and burros, in the Sierra Nevada’s and 

eastern California would have corresponded with the Gold Rush era followed by widespread 

grazing into the Sierra Nevada in the mid-1860’s (Allen-Diaz et al. 1999).

Montgomery Pass Wild Horse Territory comprises an area of 207,921 acres in California and 

Nevada, including 65,942 acres on the Inyo National Forest. The remaining territory acres occur 

on the Humboldt-Toiyabe National Forest, and Stillwater and Bishop Field Offices of the Bureau 

of Land Management (BLM). It is located east of Mono Lake, in the southern portion of the 

Excelsior Mountains, approximately 37 miles north of Bishop, California. It crosses the north end 

of the White Mountains at Montgomery Pass, and is bounded by State Highway 6 to the 

southeast. It is situated north of State Highway 120 and bounded by Deep Wells Road to the west. 

The northern boundary in Nevada extends from Granite Springs southeasterly to State Highway 

10. The Montgomery Pass Wild Horse Territory Plan was prepared in 1988 (USDA Forest 

Service). This territory is managed for an Appropriate Management Level (AML) of 138 to 230 

wild horses. There are no wild burros in this wild horse joint management area.

White Mountain Wild Horse Territory comprises an area of 265,820 acres in California and 

Nevada, including 181,820 acres on the Inyo National Forest. The remaining territory acres are 

associated with the BLM’s Fish Lake Valley Herd Management Area that is administered by the 

Tonopah Field Office in Nevada. The White Mountain Wild Horse Territory Plan was prepared in 

1976. This territory is managed for a wild horse herd size of 70 to 80 horses. The territory runs 

along the east side of the White Mountains crest from Montgomery Pass Wild Horse Territory, 

along Highway 6 in the north to Highway 168 and Deep Springs in the south. The BLM’s Fish 

Lake Valley Herd Management Area has an established appropriate management level (AML) of 

32 to 54 wild horses. There are no wild burros in this wild horse joint management area.

Saline Valley Wild Burro Territory includes 27,721 acres along the eastern slopes of the Inyo 

Mountains and is associated with the BLM’s 23,000 acre Waucoba-Hunter Mountain Herd 

Management Area has an established herd appropriate management level of 9 to 11 wild burros. 

The Waucoba-Hunter Herd Management Area borders Death Valley National Park, which is 

known for its hot and dry terrain. The Saline Valley and Lee Flat Burro Herd Management Plan 

was written in 1985. However, a large portion of this joint management area transferred to the 

National Park Service with passage of the California Desert Protection Act in 1994. BLM’s Lee 

Flat Herd Management Area (73,000 acres), located east of Mono Lake and south of WaucobaHunter Mountain Herd Management Area, is now managed as a separate herd with an AML of 12 

to 15 wild burros. BLM is the lead agency for managing these two wild burro herds. There are no 

wild horses present in the Forest Service territory or either wild burro herd management area. 

Potential Grazing Effects to Rangeland Ecosystems

Potential grazing effects from wild horses or wild burros are similar to domestic livestock as 

described under in the “Production Livestock Grazing” section. However, wild horses and burros 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

614

have season long grazing patterns. Berger (1986) describes seasonal vertical migration and 

altitudinal segregation of wild horse bands. Typically there are two distinct seasonal range 

patterns in the Great Basin; high-altitude summer range (above 2,000 m) and low-altitude fallwinter-spring range. Low-altitude ranges were smaller in size than summer ranges. However, 

home ranges vary considerably depending on available forage and water resources and weather 

conditions. In open country with minimal snow depths wild horses and burros occupy the 

landscape year-round with minimal management which often results in long lasting effects on the 

vegetation and soil characteristics of rangelands (Beever 2003).

As summarized in the recent bi-state sage-grouse environmental impact statement (USDA Forest 

Service and USDI Fish and Wildlife Service 2015), prolonged grazing by wild horses has caused 

plant community changes that can have negative impacts on sage-grouse and other sagebrushobligate wildlife. Effects from wild horse and burro grazing have been documented to limit 

sagebrush recruitment, reduce sagebrush density, reduce grass abundance and cover, lower plant 

species diversity, increase dominance of forbs unpalatable to sage-grouse, and compact surface 

soil horizons (Beever and Aldridge 2011, Beever and Herrick 2006, Davies, Collins, and Boyd 

2014). The effects can be especially pronounced during drought conditions (Beever and Aldridge 

2011).

Current Herd Sizes, Distribution and Grazing 

In 2015 systematic aerial surveys were conducted by the BLM and Forest Service on all wild 

horse and burro herd management areas and territories within the habitat range of the bi-state 

sage-grouse. The simultaneous double-count method with sightability bias correction was used 

(Lubow and Ransom 2007, 2016). Estimated population sizes were calculated to 90% confidence

interval. Survey results (Lubow 2016) are reported below. 

Montgomery Pass Wild Horse Territory / Herd Management Area Complex had a population 

size of 537 horses. An estimated 397 horses or 74% were found to be outside of the designated 

herd complex. A total of 19 head were within the Wild Horse Territory on the national forest. The 

population in 2017 is estimated to be 773 horses assuming an annual population growth rate of 20

percent over 2 years. Over the last 5 years, horses have established dispersed bands west of the 

territory to Mono Lake (Mono Basin National Forest Scenic Area) and east to the Nevada border. 

Extensive work by (Turner 2015) has included observation of the Montgomery Pass herd over a 

25 year period beginning in 1987. The Montgomery Pass wild horse population was one of few 

wild or feral horse populations thought to have been self-regulated by mountain lion predation. 

Based on finding from an 11-year predation study, (Turner and Morrison 2001) reported the 

resident lion population was significantly influencing number of horses in the Montgomery Pass 

Complex, primarily through predation of foals. Increased foal survival during the latter part of the 

11-year study appeared related to a substantial decrease in number of lions within the territory.

Turner (2015) also documented the long-tern patterns in the natural relationship between the 

Montgomery Pass wild horses and their environment. He examined environmental impacts on the 

horse population and its activities, movements and distribution on the range. In Turner’s study 

multiple variables in the physical environment (i.e. available forage and water) and in horse 

behavior were monitored seasonally. He found distinct summer (high altitude) and winter (lower 

altitude) range use was characteristic for over 60 percent of the population during the first 7 study 

years. In subsequent years there was a gradual reduction in use of summer range. Turner 

estimates that approximately 20 percent of the population continued to annually use the historical 

summer range. However, the majority of the population divided into two geographically and 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

615

functionally separate subpopulations that resided year round in the historical winter range and 

adjacent areas on opposite sides (east and west) of the Montgomery Pass Complex. These 

findings correspond with horse distribution patterns observed during the 2015 aerial survey 

(Lubow 2016). 

Turner documented that mountain lion predation on foals was restricted to the summer range, and 

exodus of horses from the summer range resulted in increased foal survival where the horse 

subpopulations currently reside. Turner concludes that the Montgomery Pass wild horses have 

been highly adaptive and individually varied in response to environmental pressures; that longterm monitoring of wild horse populations reveals underlying environmental dynamics and their 

potential management implications.

White Mountain Wild Horse Territory – Fish Lake Valley Herd Management Area Complex

had a population size of 188 horses. An estimated 94 horses or 50 percent were found to be 

outside of the designated herd complex. A total of 72 head were within the Wild Horse Territory

on national forest. BLM estimates the Fish Lake Valley population in 2017 to be 149 wild horses 

(United States Department of the Interior 2017). Overall, very little of the White Mountain Wild 

Horse Territory is occupied. Horses occupy the north and east foothills of the White Mountain 

Range along the edge of Fish Lake Valley year around. Single bachelor stallions are occasionally

observed during summer on the crest in the center of the territory. 

Saline Valley/Lee Flat Wild Burro Territory –Wacoba-Hunter Mountain Herd Management 

Area Complex was not surveyed during the 2015 Bi-State flight. Wacoba-Hunter Herd 

Management Area was last surveyed by BLM in 2011 (United States Department of the Interior 

2017). BLM estimates the 2017 population at 77 wild burros. It is unknown how many, if any, 

wild burros from Wacoba-Hunter Herd Management Area are on national forest. Lee Flat Herd 

Management Area was last surveyed by BLM in 2009 (United States Department of the Interior 

2017). BLM estimates the 2017 population at 0 wild burros. It is assumed there are no burros 

from Lee Flat Herd Management Area on national forest. 

Analysis and Methods

Analysis Area

The analysis area consists of all National Forest System lands within the Inyo National Forest 

within the designated wild horse and burro territories. 

Lands Suitable for Wild Horse and Burro Grazing

Lands identified as suitable for wild horses or wild burros are those territories which currently 

exist and which were inventoried and delineated National Forest System lands in the 1973 

following passage of the Wild Horse and Burro Act of 1971. Corresponding lands were identified 

by the BLM on Federal lands under that agency’s jurisdiction.

Lands Not Suitable for Wild Horse and Burro Grazing

Lands identified as not suitable for wild horses or wild burros include all National Forest System 

lands outside of the three designated territory boundaries of Montgomery Pass Wild Horse 

Territory, White Mountain Wild Horse Territory and Saline Valley-Lee Flat Wild Burro Territory.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

616

Temporal Scale

The analysis period consists of two decades (20 years). Discussion on climate change extends to 

50 years.

Indicators and Measures

The primary indicators used in wild horse and rangeland management, both regionally and 

nationally, are:

• Wild horse and burro grazing use as measured by annual population estimates and 

corresponding amount forage consumed, measured in animal unit months (AUMs). 

• Rangeland vegetation Improved as measured by area in acres of allotments maintained at or 

improved towards desired conditions.

• Forest plan consistency as measured by population of wild horses and burros managed to 

appropriate management levels and that achieve forest plan standards and guidelines.

• Number of active territories which are NEPA compliant and have verified appropriate 

management level determinations. 

Measures used in this analysis and forest plan monitoring: 

• Amount of animal unit months (AUMs) used annually as a measure of forage consumed 

based on estimated population size. 

• Area in acres of territories maintained at or improved towards desired conditions.

• Surveyed population numbers and distribution relative to established appropriate 

management levels and territory boundaries; acres of territories being managed to forest 

plan standards and guidelines.

• Number of active territories which are NEPA compliant and have verified appropriate 

management level determinations. 

Assumptions

Several of the assumptions are adapted from analysis presented in the 2015 Humboldt-Toiyabe 

National Forest Plan Amendment Final Environmental Impact Statement for Greater Sage-grouse 

(USDA Forest Service and USDI Fish and Wildlife Service 2015)

• Previous territory suitability determinations are carried forward for this plan revision. Any 

decision to change appropriate management levels or management of a territory is made 

following project-level environmental analysis. 

• Average forage production will likely decline over time with warmer temperatures, and 

increased frequency and duration of drought conditions as projected by climate modeling

(Vose, Clark, et al. 2016). Future changes in abundance and availability of essential habitat 

components (forage, water, cover and space) may require changes to appropriate 

management levels. 

• Territories, when managed to designate appropriate management level, will achieve a 

thriving natural ecological balance and meet yearlong wildlife habitat needs. 

• Wild horses and burros are dependent on the herbaceous component of a shrub/grass plant 

community. Encroachment of shrubs or pinyon and/or juniper onto established range lands 

are adverse, whereas increases in grasses and forbs are beneficial. Vegetation treatments 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

617

such as prescribed burns or weed control can enhance the plant community composition 

and forage availability. 

• Continuous, year-ling wild horse and burro grazing will adversely affect plant composition, 

plant succession, and ground cover. 

• Water is the primary resource associated with wild horse and burro distribution. Water 

developments can improve wild horse and burro distribution. However, failed water 

developments can cause wild horses and burros to disperse outside the territory in search of 

other water sources. 

• Wild horse and burro distribution will and can vary by season, climatic conditions, water 

and forage availability, and population size. 

• Intensive livestock grazing management strategies (scheduled pasture rotations) that 

involve project infrastructure (fences) are generally not appropriate for long-term wild 

horse management. 

Affected Environment

The affected environment is limited to the three designated wild horse and burro territories 

described above under “Management History.”

Current Rangeland Conditions

Over all rangeland conditions for the White Mountain and Inyo Mountain groups are described in 

the Production Livestock section.

Effectiveness of Current Management Direction and Information Gaps

The territory management plans for these three territories pre-date the 1988 forest plan and are in 

need of being updated. An inventory of existing resource conditions and four essential habitat 

components (water, forage, cover and space) is needed. A comprehensive analysis and adjustment 

of appropriate management levels is also needed for each territory which corresponds with 

current management of adjoining BLM Herd Management Areas. The wild horses from 

Montgomery Pass and White Mountain are predominantly outside each designated territory as 

established in 1971; burro abundance and distribution within Saline Valley Wild Burro Territory

is unknown. Management strategies are needed to encourage re-occupancy of those territories and 

discourage establishment dispersed sub-populations outside of the territory/Herd Management 

Area complexes. 

Patterns of Rangeland Drought

Refer to the “Production Livestock Grazing” section for this discussion.

Environmental Consequences

Consequences Common to Alternatives A, B, B-modified, C, and D 

Under all alternatives management actions for wild horses and burros would remain unchanged 

until a territory-specific environmental analysis is conducted. There would be no direct changes 

to wild horse and burro territory status or designation, to established appropriate management 

levels, or acreage designated as wild burro territories.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

618

Under alternative B, B-modified, C, and D where sage-grouse habitat is being degraded due to 

wild horse use site-specific measures would be determined to improve or restore sage-grouse 

habitat. Impacts would be limited to any future changes that may result in appropriate 

management level and/or acreage adjustment as well as possible reconsideration of territory

designations that are based on achievement of sage-grouse habitat objectives for improving 

habitat conditions. 

Wild horse and burro grazing has similar impacts as livestock grazing in their effect on soils, 

vegetation health, species composition, water, and nutrient availability by consuming vegetation, 

redistributing nutrients and seeds, trampling soils and vegetation, and disrupting microbial 

systems (Connelly et al. 2004). As noted previously, wild horses and burros occupy the landscape 

year-round with minimal management which often results in long lasting effects on the vegetation 

and soil characteristics of rangelands (Beever 2003). Those conditions exist on the Montgomery 

Pass and White Mountain Wild Horse Territories. Impacts appear to be on public and private

lands outside of these territories and off the national forest. 

Rangeland Vegetation Improved

If management of each wild horse and burro territory to appropriate management level were 

implemented and the current Inyo National Forest grazing management strategy (USDA Forest 

Service 1995a) were to continue, vegetation and watershed condition trends are expected to 

improve, or continue to improve, for the next 20 years, particularly within riparian conservation 

areas. 

In terrestrial ecosystems, moderate change is anticipated under all alternatives in amount and 

extent of annual grass conversions due to climate change and trend in large wildfires as modeled 

during the next mid-century (2035-2064). The probability of percent change due to large wildfires 

is highest under alternatives A and C and less under alternatives B, B-modified and D with 

restoration efforts in the foothill, montane and Great Basin ecological zones which correspond 

with the location of active grazing allotments and wild horse territories.

Cumulative Environmental Consequences

Fire Management. Under Alternatives B, B-modified, C, and D, where feasible and suitable, 

grazing can be used as a tool to reduce vegetation build-up to lower the risk of unwanted wildfire. 

Fuels projects that protect existing sagebrush ecosystems and associated sag-grouse habitat would 

benefit wild horses and burros where the territories overlap with these habitats. However, 

temporary or long-term management changes to wild horses and burros (such as reduction in 

appropriate management level, designation, removals, movement patterns, and forage access) 

may be necessary to achieve and maintain the desired fires management objectives. Prioritizing 

fire suppression activities to conserve priority sage-grouse habitat would also benefit wild horse 

and burro habitat. 

Ecological Integrity. Refer to the description under Production Livestock Grazing. Restoration 

of sage-grouse and aquatic habitats will remain a priority under all alternatives. Temporary or 

long-term management changes to wild horses and burros (such as reduction in appropriate 

management level, designation, removals, movement patterns, and forage access) may be 

necessary to achieve and maintain the desired restoration project objectives. Long-term impacts 

under all alternatives would be beneficial once habitat restoration objectives have been reached; 

such benefits as sustaining desired forage plant species, grazing levels, and wild horse and burro

appropriate management levels over time.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

619

Conservation Watersheds. Refer to the description under “Production Livestock Grazing.”

Conservation watershed plan components do not directly prohibit wild horse and burro or 

livestock grazing activities or restrict or limit this use. Forest Plan components for these 

management areas allow for the continued wild horse and burro territory designation. During 

implementation of restoration actions within conservation watersheds, specific project design 

features may be created to reduce the impacts from wild horse and burro grazing to restoration 

efforts. Temporary or long-term management changes to wild horses and burros (such as 

reduction in appropriate management level, designation, removals, movement patterns, and 

forage access) may be necessary to achieve and maintain the desired restoration project 

objectives. 

In summary, wild horse and burro management activities would not be constrained by 

conservation watersheds. However, grazing could be affected by other plan direction that calls for 

maintaining or improving the quality or quantity of watershed resources, such as water quality, 

while ensuring sustainable continuation of multiple uses. 

Recommended Wilderness. Under alternatives B, B-modified, and C, new wilderness 

designation would not restrict management of the wild horse and burro territories. Any future 

excess wild horse or burro removals would occur at lower elevations outside of existing 

wilderness area. Like management of grazing allotments, wilderness designation would prohibit 

access by motorized vehicle for maintenance of water developments and restrict installation of 

new range improvements (such as water troughs) unless approved following a minimum 

requirements decision. 

Benefit to People and Communities. The effects to the local communities would be the same 

under all alternatives. 

Analytical Conclusions

Under all alternatives rangeland suitability acres for the three designated territories would remain 

at current levels as illustrated in appendix D. Any adjustments to suitability or population 

appropriate management levels analysis, and subsequent suitability determinations would be done 

with environmental analysis at the territory level. It should be noted that a comprehensive 

analysis and adjustment of appropriate management levels is needed for each territory that

corresponds with current management of adjoining BLM Herd Management Areas. 

Alternatives B, B-modified, C and D would have modest improvements in riparian conservation 

areas and resilience to disturbance and climate change at the allotment level. Landscape resilience 

would continue to decline over the next mid-century in the foothill, montane and Great Basin 

ecological zones due to upward trends in large wildfire, annual grass conversion, and climate 

change and prolonged patterns of persistent drought. Appropriate management levels for wild 

horses and burros are likely to require adjusting to lower population levels over the next 50 years.

Alternatives B, B-modified, C and D provide more design criteria then alternative A in using 

timely adaptive management that may have long-term benefits to wild horses and burros.

Wilderness designation under alternatives B, B-modified, and C would not be expected to restrict 

current appropriate management level or herd management levels differently than under 

alternatives A or D.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

620

Economic Conditions

Background

Forest management influences the economic sustainability of the communities that surround Inyo 

National Forest and impacts the provision of forest benefits that affect the quality of people’s 

lives both locally and further removed from the plan area. This section examines potential effects 

on the benefits to people by examining potential changes in the key benefits that the national 

forest provides (such as, recreational opportunities, clean air and water, grazing, species habitat, 

and energy). Current threats resulting from uncharacteristic wildfire and declining forest health 

bring into question the long-term sustainability of these important benefits. Plan alternatives that 

address these concerns are examined as to their potential to improve the sustainability of key 

forest benefits while also examining the short- and long-term tradeoffs associated with these 

management actions. The information in this section is a summary of the more detailed 

Economics supplemental report.

Analysis and Methods

Study Area and Data Sources

The information describing local economic conditions is obtained from “Chapter 6: Assessing 

Social, Cultural and Economic Conditions” in the individual national forest assessments that were 

written for plan revision (USDA Forest Service 2013a). Key national forest contributions are 

examined for the geographic areas where economic activities are supported by National Forest 

System land management. This area represents the California and Nevada counties where 

national forests provide opportunity for production of commodities and forest visitation (such as, 

grazing, mining, and recreation) and also those counties where the Inyo National Forest has made 

direct expenditures in management (such as, spending on projects and Forest Service employee 

salaries).57 This information on key economic contributions of the Inyo National Forest is 

obtained from the Forest Service Economic Contribution model (USDA Forest Service 2014f).

The Inyo also provides benefits to communities located further away from the administrative 

boundary (such as, water and electricity) and moreover provide nonmarket benefits where 

quantifying economic contributions is difficult (such as, biodiversity). The key forest benefits

were identified using “Chapter 7: Benefits to People” in the national forest assessment referenced 

earlier, as well as the national forest “distinctive roles and contributions” statement that was

developed for plan revision and is included in the forest plan.

Methodology for Analysis

Potential effects are examined for changes in the benefits of Inyo National Forest across the five

plan alternatives. Two separate examinations are conducted: (1) a financial examination looking 

at the potential for funding management activities and resulting challenges, and (2) a national 

forest benefits examination looking at potential short- and long-term effects on the key national 

forest benefits for local economies and improving the quality of people’s lives throughout the 

region.

The financial examination is undertaken to provide decisionmakers with context for the 

challenges that the Inyo will face funding project implementation under each alternative. The 

 57 These are Inyo and Mono counties in California and Esmerelda and Mineral counties in Nevada.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

621

management actions associated with each of the alternatives have consequences for funding that 

present challenges for the Inyo.

Inyo National Forest benefits examination looks at potential changes in six key forest benefits

important for people locally and across the region (water quality and quantity, recreation, air 

quality, grazing, energy generation and biodiversity). This qualitative analysis examines how 

these key national forest benefits are indirectly affected by the plan alternatives and what these 

potential effects mean for people and communities.

Important to this examination of national forest benefits is consideration of the tradeoffs 

associated with potential short- and long-term effects. Short-term effects would be expected while 

the types of restoration activities expected under the various alternatives are occurring. These 

types of effects typically involve restricted national forest access or other consequences to 

resources (such as sedimentation or smoke) due to activities such as mechanical thinning or use 

of prescribed fire. Long-term effects would be expected after restoration activities are completed 

and represent the expected resulting conditions and consequences of these activities on the 

sustainability of national forest benefits. Examples of these types of long-term effects would be 

reduced fuel loads and improved forest heath from restoration activities that lower the long-term 

risk associated with uncharacteristic wildfire, drought, and forest insects and diseases.

The following assumptions are made in conducting these analyses:

• all the potential effects on benefits to people are indirect in nature as the plan is 

programmatic and does not compel any action to occur or authorize any projects or 

activities; 

• national forest base funding and staffing levels remain constant and representative of 

current trends across alternatives and for the life of the plan;

• funding for increased restoration and management activities is obtained from outside 

existing national forest budgets through stewardship contracts and partnership 

opportunities, and thus represents new money into the local economy; and 

• there are no current or expected future changes to mining activities or the associated 

program as a result of the proposed plan alternatives.

Affected Environment

This section presents:

1. A description of the economic conditions within Inyo and Mono counties in California 

and Esmerelda and Mineral counties in Nevada where forests provide opportunity for 

production of commodities and forest visitation and also those counties where the Inyo 

National Forest has made direct expenditures in management;

2. A description of the key economic contributions the national forest makes that influence 

these economic conditions and influence economic sustainability; and

3. A description of how these key national forest economic contributions are currently 

threatened by uncharacteristic wildfire and disease and insect pathogen mortality in 

vegetation.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

622

Economic Conditions

Economic conditions are described by examining three factors: economic health; economic 

diversity, and local fiscal conditions surrounding the national forest.

Economic health is the overall health, or prosperity, of an economy and this influences its ability 

to adapt to change. An economy already facing job loss and low incomes is likely to be less able 

to adapt to national forest management changes that affect key economic sectors. Three key 

statistics are presented below as measures of this economic well-being; the annual unemployment 

rate, average earnings per job, and per capita income.

Economic diversity is the extent to which an economy is dependent on one or only a few sectors 

as opposed to a broad spectrum of economic activities. When determining the economic context 

of national forest management decisionmaking, it is important to identify the key sectors that 

drive the economy and the extent to which the economies of the surrounding area are dependent 

on national forest land activities. Determining this level of diversification and the economy’s 

dependence on these activities provides a good indicator of the potential effects that may result 

from national forest management decisions that impact these activities. That is, a more diversified 

economy that is supported by many different sectors is better able to withstand changes to 

national forest management than is an economy that is dependent mostly on forest-based 

commodity extraction and tourism.

Local fiscal conditions represent the finances of local governments, specifically the sources of 

revenue and the targets of spending. Local governments rely on revenues generated from 

activities on national forest lands. These revenues can be summarized in three broad categories;

direct, indirect, and secondary. Direct includes the direct subventions from the Federal 

Government and include Federal Forest Reserve and Payment in Lieu of Taxes.58 Indirect 

revenues are the transient occupancy taxes collected as a direct result of visitors to the national 

forest buying and paying sales tax and staying transient occupancy taxes. Secondary revenues are 

those taxes collected because those businesses providing these services use a portion of the 

revenues received to pay their taxes. Management decisions that affect these activities have the 

potential to impact these revenues. To determine the context of these payments, it is necessary to 

understand how important these revenues are to local budgets and also understand the current 

overall budget conditions of local governments. Communities facing difficult fiscal conditions 

would feel an impact from changes in these revenues, thus leading to the potential for reduced 

public services provision in the area.

The context of these three factors is examined below. This information is obtained from “Chapter 

6: Assessing Social, Cultural and Economic Conditions” of the individual national forest

assessments that were written for plan revision (USDA Forest Service 2013a).

Economic Health

With high unemployment, lower earnings and lower per capita income than California and similar 

to Nevada as a whole, the counties in the study area for the Inyo National Forest are facing 

challenges to their economic health. Thus, these communities are less able to adapt to forest 

 58 Without Congressional reauthorization of the Secure Rural Schools and Community Self Determination Act, the 

Forest Service must revert to making payments to States under the 1908 Act, commonly called the 25% payments, 

for the 2017 payment year and beyond.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

623

management changes that would affect key economic sectors. This data from the national forest 

assessments (USDA Forest Service 2013a) is presented in table 111.

Table 111. Economic health surrounding the Inyo National Forest

Key Economic Measures

Inyo National 

Forest Bioregion California Nevada

Unemployment rate, 2011 (percentage) 10.3 14.3 11.7 13.5

Average earnings, 2011 (dollars) 42,935 51,744 60,453 48,606

Per capita income, 2011 (dollars) 39,737 36,127 43,856 38,104

The bioregion is meant to represent communities in and around the national forests in the region. It is comprised of the 

counties that intersect the area examined in the “Final Sierra-Nevada Bioregional Assessment” (USDA Forest Service

2013d)

Economic Diversity

Studies conducted for the area surrounding the Inyo National Forest have demonstrated that local 

economies are very dependent on tourism and recreational activities and any changes in the level 

of these activities would be expected to have an effect on the economy (Alkire 2012, Guilliams 

and Clines 2012, Gruen Gruen and Associates 2010). In addition, a recent report examining the 

history and potential of economic opportunities in Mono and Inyo Counties reinforces this 

finding, stating that, “neither county has demonstrated extensive economic diversification beyond 

the government and hospitality/leisure sectors” (Sierra Business Council 2012). As a result, the 

economies of all of these California and Nevada counties are likely susceptible to effects from 

changes in national forest management that lead to changes in visitation to the area.

Local Fiscal Conditions

The counties around the Inyo National Forest receive important revenues from sales taxes on 

temporary lodging from visitors to the region. Available data shows that these sources are a 

significant portion of the tax revenue collected in both Mono (4.6 percent of total revenues) and 

Inyo (4.3 percent) Counties (California State Controller's Office 2012). One study estimated the 

percentage of the county sales tax revenue that was visitor related. This includes spending on 

goods and services while visiting an area, and this visitor spending is again identified as 

important to fiscal consideration for Mono (57.9 percent) and Inyo (20.8 percent) Counties (Dean 

Runyan and Associates 2012). Given the similar rural nature and historical ties to the national 

forest, fiscal contributions from visitation and national forest activities are also important in 

Esmerelda and Mineral Counties. Therefore, it is important to recognize that these smaller rural 

counties are reliant on visitors to the Inyo National Forest to contribute tax revenues essential for 

providing key public services.

Payments in lieu of taxes (PILT) and other federal payments (such as the 25 Percent Fund and 

Secure Rural Schools Act payments) are also an important contribution to local county 

government revenue. This funding source is especially important locally in Inyo County where 

less than 2 percent of the land in the county is privately owned (USDA Forest Service 2015b).

The counties also receive tax revenues from the 348 recreational residences located on Inyo 

National Forest. The majorities of these residences (282) are in the Mono Lake, Mammoth and 

White Mountain Ranger Districts and pay taxes to support services in Mono County. These 

residents pay taxes but only use the resulting county services for a portion of the year.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

624

Key National Forest Economic Contributions

Contributing to community well-being by providing a broad range of economic opportunities for 

national forest communities is consistent with current Forest Service direction from the U.S. 

Department of Agriculture to generate jobs through recreation and natural resource conservation, 

restoration, and management in rural areas (USDA Forest Service 2015d). However, Federal 

forest management alone cannot ensure community stability because jobs in the forest products, 

agricultural, mining, and recreation industries are influenced by market conditions and changes in 

technology outside the control of forest management. As a result, national forests cannot expect to 

ensure community economic wellbeing through their management actions alone (Charnley 2013).

While national forests are not the sole factor determining economic wellbeing, they do contribute 

economically to local communities and also to communities that are located further from the 

national forest. Recreational opportunities on the Inyo that draw visitors to the area are 

specifically important to local economies within the study area. Grazing and mining activities 

also occur on the Inyo and are important to local economies and culture. However, there are no 

current or expected future changes to mining activities or the associated program as a result of the 

proposed plan alternatives, so mining is not examined in detail here. Water from the national 

forest is also examined as a vital resource with economic value both on and off the Inyo that is 

influenced by national forest management.

Other vital national forest benefits besides these commodities may be less apparent in our daily 

lives and their benefits difficult to measure, but these benefits are important because they support 

the ecosystems and social environments in which we live (such as, biodiversity of forest 

landscapes). However, there is no universally accepted methodology for how to quantify the 

benefits of these types of non-market benefits. Instead, the benefits provided by biodiversity are 

described qualitatively to capture the importance of these benefits to people.

Recreation and Tourism

In 2010, travel- and tourism-related industries were important in local communities supporting 50 

percent of the jobs in the counties bordering the Inyo National Forest. This percentage is much 

greater than for other national forests in the bioregion (supporting 18.1 percent of jobs in 

bordering counties) and the state as a whole (15.7 percent). The numbers of travel- and tourismrelated jobs in these counties have been relatively stable from 1998 through 2010. Average annual 

wages in these jobs are below the average wage for all private sector jobs, so these are relatively 

lower paying jobs in local communities (Headwaters Economics 2012). The landscapes in this 

area provide valuable and unique recreational opportunities. The natural amenities provided by 

wilderness on the Inyo National Forest also contribute value to communities through visitor 

spending, attracting potential economic development opportunities and contributing to increasing 

property values (Holmes et al. 2015). Also, the contributions of volunteers are an important 

economic consideration of recreational activities. Many of the national forest volunteers are 

drawn to the area for the recreational opportunities and contribute their time and energy to 

maintain the quality of that experience.

A study examining the value of travel and tourism estimated the percentage of total county 

employment and earnings generated by all travel in California. Travel and tourism around the 

Inyo National Forest generates 48.6 percent of employment and 32.2 percent of earnings in Mono 

County and 23.5 percent of employment and 11.5 percent of earnings in Inyo County (Dean 

Runyan and Associates 2012). Contributions in Nevada counties would also be expected to be 

important to the communities in those areas.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

625

Grazing

Pasture and rangelands within the counties bordering Inyo National Forest comprise around 70 

percent of the total of all land area in farms, which is greater than the percentage for the bioregion as a whole (53.0 percent). In terms of number of farming operations, cattle, sheep and goat 

farming, which are the primary types of animals that are grazed on public lands, account for 

around 43 percent of all operations, again more than the bio-region (22.5 percent; USDA Forest 

Service 2013a).

In addition, summer forage on the Inyo is critical to the economic viability of local ranches. If 

these ranchers did not have summer grazing permits on the Inyo National Forest, then their 

businesses may no longer be economically viable. These ranches have an impact on the local 

economy through an economic multiplier effect from the activity on these ranches requiring 

employees, materials and services from other businesses in local communities.

Commodity-based Estimates of Economic Contributions

Estimates of the jobs, compensation, and tax contributions of activities derived from the 

economic contribution models for Inyo National Forest are provided in table 112 (USDA Forest 

Service 2015f). These values should be used to gain an understanding of the relative context of 

national forest contributions and not as exact measures of these contributions. Therefore, all 

estimates are rounded to the nearest 100. Employment, expressed as jobs supported, represents 

the average annual employment and includes a combination of full and part time, temporary, and 

seasonal workers in Inyo and Mono counties in California and Esmerelda and Mineral Counties 

in Nevada.

Table 112. Estimates of the economic contributions, 2012

Employment (Jobs)

State and Local 

Government 

Total Tax Impact (M$)

Federal 

Total Tax Impact (M$)

2,900 $17,200 $16,200

Given data limitations, state and local government total tax impact does not include tax 

contributions from grazing; source: USDA Forest Service 2014f

The sectors with the most jobs supported by national forest contributions are: government; 

agriculture; retail trade; accommodations; food services; arts and entertainment; and recreation. 

These findings highlight the Inyo National Forest’s key contributions to local economies,

primarily for the visitors it draws to the area.

The Importance of Water to Economic Sectors

Water originating on the Inyo National Forest supplies clean water for 3.8 million people and 

electricity for millions more in local towns and communities as far-ranging as Los Angeles and 

Fresno. Supplying this water for communities is estimated to provide upwards of approximately 

300 jobs to the local Inyo County economy (Richards 2015a). In addition, the water from the Inyo 

National Forest and adjacent lands is used extensively for recreational activities such as fishing, 

boating, and swimming, and aesthetic enjoyment. These recreational activities are vital to 

supporting the local economy in both Mono and Inyo counties.

Wildfires affect these important water resources by removing vegetation and altering soils and 

ground cover, with the magnitude of post-wildfire impacts being dependent on burn severity. 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

626

These changes have large implications to water resources through their effects on transpiration 

rates, water infiltration rates, the rates and magnitudes of erosion, peak and base streamflows, and 

total water yield (California Department of Water Resources 2016). Therefore, forest 

management plays a large role by influencing the economic value of water from Inyo National 

Forest. 

Biomass Utilization for Energy

The wave of biomass utilization has rose and subsided in the past, and may be on the rise again 

with the level of mortality experienced in California in recent years. National Forest System lands 

can be an important source of fuel for biomass facilities if in proximity. Biomass utilization can 

be an important tool for reducing project-generated fuels, but on the Inyo National Forest, to date 

such infrastructure is lacking in the local region. Given expected volumes, biomass generated on 

the Inyo would need to be supplemented by fuels from other sources in order to make biomass 

energy sustainable.

Biodiversity

The changing elevation across the Inyo National Forest combined with the variability in aspect 

and slope, the variety of geology and soils, and the amount and timing of precipitation, creates an 

extremely high diversity of ecosystems. These varied ecosystems across the Inyo are inhabited by 

a diversity of wildlife including 300 wildlife species and more than 1,300 plant species (see 

“Wildlife, Fish, and Plants” section). As a result, fishing, wildlife hunting, and wildlife viewing 

are important benefits provided to the public by the national forest. The Inyo’s terrestrial and 

aquatic plant and animal species are dependent on resilient, diverse ecosystems that also sustain a 

social and economic fabric connected to a healthy forest. Sustaining these plant and animal 

species contribute to local communities by providing a quality environment where visitors can 

enjoy these landscapes. In addition, the diversity of the plant community supports a wide range of 

important economic and social beneficial uses such as food (such as mushrooms, fruits, and 

ferns), medicines, floral greens, seeds and cones, and transplants.

Important Inyo National Forest Benefits to Inyo County

The communities of Inyo County have typically relied upon activities on public lands, and the 

Inyo National Forest in particular, for their well-being. The county’s economy historically 

developed based on resource extraction and agriculture, which has since transitioned toward a 

service economy tied to tourist-oriented recreation on the Inyo National Forest. This history has 

shaped the society and culture of the county. In addition, more than 98 percent of Inyo County is 

managed by government agencies,

59 and therefore decisions on the use of these lands have a large 

influence on the economy of the county. Given these critical economic and social ties between the 

Inyo National Forest and Inyo County, an important part of understanding the affected 

environment is identifying the key locations and activities on the Inyo National Forest and how 

they contribute to Inyo County.

Visitation and tourism resulting from recreational activities in the Inyo National Forest is a major 

contributor to the local Inyo County economy. As shown in table 112, national forest

contributions are important to the counties surrounding the Inyo National Forest. Contributions to 

the recreation- and service-based sectors comprise the majority of this activity. While the Forest 

 59 Inyo National Forest, Death Valley National Park, China Lake Naval Weapons Center, and Bureau of Land 

Management holdings total approximately 92 percent; the City of Los Angeles, as part of the Owens Valley aqueduct 

and associated lands, owns nearly 4 percent; and the State of California controls nearly 2.5 percent.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

627

Service Economic Contributions model is not able to break out these estimated totals by county, 

other available data can help to illustrate the degree to which Inyo County relies on these national 

forest contributions. Inyo County estimates that wilderness activities generate approximately 

$4.5 million in visitor spending there annually. Fishing and hunting provide additional visitor 

spending estimated as $2.7 million and $544,000, respectively.

60 Off-highway vehicle users 

spend about $305,000 annually. Grazing on Inyo National Forest System lands in the county are 

estimated as providing $5 million in revenues (Richards 2015a, Inyo County 2015). Finally, the 

potential for future mining is also an important economic consideration because of the potential 

for jobs and incomes in the county (Richards 2015b). Therefore, management decisions that

affect visitation, mining, and grazing would have economic consequences for Inyo County 

communities.

Working in collaboration with the county, key forest locations and activities for socioeconomics

were identified; these are presented in table 4 and figures 1 and 2 of the Economics Supplemental 

Report. These key activities focus on recreation, mining, and agriculture (grazing). Actions 

associated with plan revision and future national forest projects that would have implications on 

these important national forest contributions should be evaluated as to the significance of such 

effects.

Environmental Consequences to Economic Conditions

Financial Examination

National forest project-level planning and implementation is guided by the budget as received 

from Congress and passed down through the Department of Agriculture to the Forest Service and 

then to the national forest. Therefore, to reflect this budget reality, the analysis assumes 

continuation of the trend of recent national forest budget obligations. Given this assumption, this 

section examines the potential funding opportunities and challenges of funding outside of the 

appropriated national forest budget that would be expected to be available to achieve the increase 

in pace and scale of activities.

Consequences Common to Alternatives B, B-modified, C, and D

There are challenges to project funding that is outside of the forest plan and the plan revision 

process. Increases in the pace and scale of restoration would involve increases in the costs 

associated with project preparation and project planning. Alternatives B, B-modified, C, and D 

would need to identify efficiencies for these planning processes in order to reduce the increased 

costs associated with additional project planning and preparation. Given current budget trends, 

identifying and implementing these efficiencies will be critical to the success of any alternative 

that is chosen.

Potential increases in national forest revenues provide new opportunities for additional project 

funding resources. National forest revenues potentially affected by the proposed plan alternatives 

are associated with activities occurring in the recreation program and the forest product program. 

Recreation staff members do not foresee significant changes in the revenues that would be 

generated by the recreation program on the national forest as a result of alternatives B, Bmodified, C, or D. Therefore, new funding opportunities resulting from changes in recreation 

revenues are expected to be limited and to be similar across all the alternatives. Forest product 

 60 This estimate is a lower bond calculated using hunting and fishing licenses that were purchased in Inyo County. 

Visitors who purchase licenses in other counties also visit the forest for these activities and would also contribute to 

the local economies.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

628

activities on the Inyo National Forest are limited and therefore forest product value is not likely to 

be a significant funding source for restoration activities under any of the alternatives.

An important option will be establishing funding opportunities and partnerships with Federal, 

State, and local agencies as well as capable stakeholder groups. All plan revision alternatives

highlight working collaboratively with stakeholders to develop these types of funding 

opportunities. Successful implementation would require national forest project goals to align with 

the goals for outside agencies and stakeholder groups willing to partner to fund restoration 

activities. Examples of these types of opportunities include cost-share agreements, memorandums 

of understanding, and stewardship agreements with partners taking on active management roles 

that allow the Forest Service to leverage resources and staff from other organizations to conduct 

or assist in treatments on and adjacent to national forest lands. Developing these types of 

opportunities requires the additional cost of time and resources associated with engaging potential 

partners and establishing agreements.

Forest Benefits Examination

Wildfire, disease, and insect pathogen mortality in vegetation is increasing in severity across the 

bioregion, and a high percentage of the landscape that provides the key national forest benefits

outlined previously are under threat (Metcalfe et al. 2013). As a result of these threats, there is 

great potential for disruption in the underlying ecological processes and for resulting loss and 

interruption in forest benefits. This loss of benefits has a cost to the local communities in 

California and Nevada and to the region as a whole. Examples of more localized costs include the 

loss of recreational opportunities for visitors, reductions in local employment and tax revenues 

from national forest commodities such as grazing, and the effects on the economies of local 

communities through reduced tourism in the area. When other important benefits such as water 

supply, electricity generation, and biodiversity are lost, the potential effect moves beyond the 

local area to people across the state who are affected by the loss of these services even if they do 

not live near the national forest nor ever plan to visit there.

The potential indirect effects of plan alternatives on these important forest benefits to people are 

examined as follows, first highlighting the similarities between the plan alternatives B, Bmodified, C, and D, and then highlighting their key differences. Important to this analysis is 

capturing the effects of plan alternatives on the economic health, diversity, and fiscal conditions 

that are outlined in the affected environment section above. Therefore, a local communities 

section highlighting these potential effects for the local communities in California and Nevada is 

included in each alternative description. The description of effects below is a summary of 

findings and a more detailed description of potential effects on national forest benefits are

provided in the Economics supplemental report.

Consequences Common to Alternatives B-modified, B, C, and D

There are three important potential effects that are relevant to all of the plan revision plan revision 

alternatives. These common effects result from the increased pace and scale of restoration that is 

called for in all of these alternatives.

First, alternatives B, B-modified, C, and D increase restoration activities in total (through more 

focus on mechanical thinning in alternatives B, B-modified, and D and through more focus on use 

of prescribed fire and managed fire in alternative C). Therefore, all of the plan revision 

alternatives provide greater potential to improve the long-term sustainability of key national 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

629

forest benefits and contributions when compared to alternative A, which maintains current 

restoration activity levels.

Second, alternatives B, B-modified, C, and D also have the potential for adverse short-term

effects. These effects result from increased restoration activity that can temporarily interrupt these 

same national forest benefits and contributions.

Third, the increased pace and scale of restoration in alternatives B, B-modified, C and D supports 

jobs. Contractors from local communities are often hired to perform these restoration activities 

and this is important since employment opportunities in these areas are often limited. The Pacific 

Southwest Region has been working to improve processes to allow for more businesses in these 

local communities to obtain contracts for work and benefit from restoration activities. A study 

examining forest and watershed restoration work found that approximately 16 to 24 jobs are 

supported for each $1 million that is invested in restoration activities (Nielsen-Pincus 2010). This 

range is dependent on the type of activities that are performed in restoration. Investments in 

labor-intensive activities (such as site preparation, tree and shrub planting, and cutting small trees 

and brush by hand) support the greater number of jobs, whereas equipment- and technicalintensive activities (such as forest thinning, small-diameter and selective logging, masticating 

ground fuels, constructing stream habitat features and excavating of floodplain and wetland 

features) support fewer jobs.

Increased pace and scale of restoration also leads to employment and economic activity in a 

variety of other economic sectors throughout the economy beyond the effects of employment

generated by the activities themselves. These multiplier effects arise from materials and 

equipment being purchased from suppliers as well as restoration workers spending their 

paychecks for goods and services. The top two economic sectors typically affected by this 

multiplier effect are wholesale and retail trade, including transactions for fuel, wood products, 

rock, metal, and other building and landscaping products. Other common but less affected sectors 

include employment services, commercial and industrial machinery rental, commercial and 

industrial machinery repair and maintenance, and professional services (such as insurance brokers 

and accountants; Nielsen-Pincus 2010).

Table 113. Summary of short-term and long-term potential effects on key national forest benefits by 

alternative

National 

Forest 

Contribution

Alternative A

short-term / 

long-term 

effects

Alt B-modified

short-term / longterm effects

Alternative B

short-term / longterm effects

Alternative C

short-term / longterm effects

Alternative D

short-term / longterm effects

Water adverse/ 

adverse

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

Sustainable 

recreation

adverse/ 

adverse

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

Air quality adverse/ 

adverse

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

uncertain/ 

beneficial

Energy 

generation

adverse/ 

adverse

beneficial/ 

beneficial

beneficial/ 

beneficial

uncertain/ 

uncertain

beneficial/ 

beneficial

Grazing none/ adverse adverse/ 

uncertain

adverse/ 

uncertain

uncertain/ 

uncertain

adverse/ 

beneficial

Biodiversity none/ adverse adverse/ 

beneficial

adverse/ 

beneficial

adverse/ 

beneficial

adverse/ 

beneficial
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

630

There are some important differences between alternatives B, B-modified, C, and D. These 

differences arise primarily from differences in the intensity and the approach to restoration under 

each alternative and are described below. A summary of the potential short- and long-term effects 

on six key national forest benefits is provided in table 113 (water quality and quantity, recreation, 

air quality, grazing, energy generation, and biodiversity).

Consequences Specific to Alternative A

Under the current forest plan, trends in current resource conditions are expected to continue, and 

therefore the long-term sustainability of all six key national forest benefits provided by these 

resources to people locally and across the region is threatened. Particularly important are the 

threats of uncharacteristic wildfire, disease, and insect mortality of forest vegetation that 

contribute to declining forest health and increase interruptions both in the short term and long 

term for all of these national forest benefits.

Potential Implications for Local Communities in California and Nevada

Under the current forest plan, the resulting decline in the long-term sustainability of all six key 

national forest benefits would result in significant adverse economic effects for local 

communities. These effects would be felt most directly through the potential loss of recreational 

visitation as a result of declining quality of recreational settings and increasing limits on 

opportunities from wildfire closures. Declining trends in species biodiversity would also 

adversely affect national forest visitation for important activities such as hunting, fishing, plant 

gathering, and wildlife watching. Rural communities located along access routes to the national 

forest often have a strong tie to the economic contributions that recreational visitors provide. This 

includes the visitor spending that supports jobs and also the contributions to local tax revenues 

through the sales and lodging taxes collected. These local tax revenues support important public 

services that improve the quality of life in these communities. The connection between 

recreational visitation and local economies is especially true for the Inyo National Forest and the 

critical importance of recreational-based, service-oriented businesses located within Inyo County. 

Maintaining the current plan direction would not contribute to improving the sustainability of this

important recreational visitation.

Increases in the smoke from wildfires also contribute to this potential adverse economic effect 

resulting from decreasing recreational visitation. Under the current forest plan, trends for more 

and larger wildfires would be expected to continue, thus increasing the likelihood that visitors 

even far from the fire area would stay away due to smoke during at least some portion of the fire 

season, which is expected to be starting earlier and lasting later into the year. In addition, this 

smoke from wildfires adds to air pollution and adversely affects the health of residents in local 

communities. Alternative A does not contribute to improving the sustainability of air quality 

benefits to people and communities.

The important local economic benefits provided by water would also decline under alternative A. 

The water used downstream from Inyo National Forest is valuable for municipal and agricultural 

uses. It is also valuable for recreational and ecological uses on the national forest because this 

water sustains the important water-based recreational setting and forest biodiversity that draws 

visitors. Given expected restoration levels in alternative A, the quantity and quality of water 

would be expected to continue current trends in declining stream flows and increasing 

temperatures, thus reducing and interrupting the benefits this water provides. As a result, there 

would be expected costs to users from reduced local recreational opportunities, reduced water use 

and the need to utilize higher cost alternative water supplies.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

631

Grazing opportunity would potentially be adversely affected as a result of no increase in 

restoration activities to reduce the risk of uncharacteristic wildfire and to improve forest health. 

These types of events increase the potential for future interruptions to grazing opportunities. 

Therefore, there are potential adverse long-term effects on the local communities that are 

dependent on forest grazing.

Biomass provides the opportunity to generate electricity for the region and also support local job 

opportunities in biomass harvesting. The current forest plan does not have the potential to provide 

any additional biomass to support development of industry infrastructure. The current plan also 

does not help to create an environment with a reliable supply of biomass that would be more 

favorable to investment in such new biomass facilities. The current forest plan does not contribute 

to improving the sustainability of benefits from energy generation from biomass.

Consequences Specific to Alternatives B-modified and B

The restoration activities in B-modified and B, would be expected to help reverse current trends 

and to improve the long-term sustainability of five of the six key national forest benefits that 

provide benefits to people locally and across the region. Long-term effects on grazing are 

uncertain. Grazing would benefit in the long-term from restoration but also could be adversely 

affected by restrictions in the areas recommended for wilderness. In the short term, the potential 

effects would be mixed across the different national forest benefits. These effects would be

adverse for biodiversity and grazing from increases in disturbances related to the increasing of 

restoration activities. The effects would be mixed for water, recreation and air quality. Water 

quality may be impacted from the potential for increased sedimentation from additional 

restoration activities. Recreation would benefit in the short term from reduced wildfire, but it 

would be adversely affected by the potential for some restrictions on activities as a result of 

restoration projects. The new recreational zones developed in alternatives B-modified and B are 

not expected to result in any changes to the number of visitors or types of recreational activities 

occurring on the Inyo. Air quality also would benefit in the short term from reduced wildfire, but 

the use of prescribed fire under alternatives B-modified and B would create the potential for some 

short-term decreases in air quality as a result of these activities. Energy generation potentially

would benefit in the short term from increased restoration activities that: (1) yield increased 

biomass to support potential development of infrastructure in the area, and (2) support the 

potential for more water quantity for electricity generation.

Potential Implications for Local Communities in California and Nevada

The restoration activities in alternatives B-modified and B would be expected to improve the 

long-term sustainability of all six key national forest benefits and result in significant beneficial 

economic effects for local communities when compared to alternative A, the current forest plan. 

These effects would be felt most directly through the potential gain in the long-term sustainability 

of recreational visitation as a result of maintaining the quality of recreational settings and the 

opportunities of visitors. Maintaining species biodiversity would also contribute to sustaining 

national forest visitation for important social and economic activities such as hunting, fishing, 

plant gathering, and wildlife watching. Alternatives B-modified and B contribute to improving the 

long-term sustainability for all of this recreational visitation.

Given the increases in restoration activities, alternatives B-modified and B have the potential to 

result in adverse short-term effects through closures of recreational areas during restoration 

project activities and disturbances to species diversity. This potential adverse effect is expected to 

be minor and is off-set by the potential for reduced wildfire when compared to the current forest 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

632

plan, and therefore fewer related closures of recreational areas during fires and fewer adverse 

wildfire effects on species would be expected to occur. The overall effect of these two opposing 

factors is uncertain and is dependent on the specifics of the projects developed under this 

alternative. Project-level environmental analysis would be conducted to better understand the 

trade-offs to communities from these potential project economic effects on recreation. The new 

recreational zones and winter recreation opportunity spectrum settings developed in alternative Bmodified are not expected to result in any changes to the number of visitors or types of 

recreational activities occurring on Inyo National Forest. Wilderness recommendation, and any 

subsequent wilderness designation, would restrict mountain biking. Current mountain-biking use 

in these areas is limited given the topography, vegetation and sandy soil. In addition, other local 

alternative mountain biking opportunities exist, so any potential effects to mountain biking are 

expected to be minimal. The direction in aquatic strategy and the introduction of conservation 

watersheds in alternative B-modified are not expected to have any effect as the plan components 

do not hinder, prohibit, or restrict activities within these areas. Therefore, any potential adverse 

economic effects to communities are expected to be negligible.

Reductions in the smoke from potential future wildfires also contribute to this potential beneficial 

economic effect resulting from sustaining recreational visitation. Under alternatives B-modified

and B, restoration activities would potentially result in fewer larger wildfires in the long term, 

thus reducing the likelihood that visitors stay away from the area. In addition, the long-term 

reduction in smoke from wildfires would help to improve air quality and the health of residents in 

local communities. There would be some use of prescribed fire under alternatives B-modified and 

B that could lead to reduced air quality and reduced recreational access in the short term. This use 

of prescribed fire would be planned to occur under favorable conditions to mitigate potential 

adverse effects. Still, the overall effect of these two opposing factors is uncertain and is dependent 

on the specifics of the projects developed under this alternative. Project-level environmental 

analysis should be conducted to better understand the trade-offs to communities from these 

potential project economic effects on air quality.

Alternatives B-modified and B would contribute to sustaining the important local economic 

benefits provided by water from the Inyo. The water that is used downstream from the Inyo is 

valuable for municipal and agricultural uses, and also for recreational and ecological uses on the 

national forest because this water sustains the important water-based recreational setting and 

biodiversity that draws visitors. The quantity and quality of this water would be expected to 

improve in the long term under alternatives B-modified and B as compared to the current forest 

plan, as current trends in decreasing stream flows and higher temperatures could be tempered. In 

the short term, there would be the potential for adverse effects from increased sedimentation as a 

result of increased restoration activities. This could potentially have adverse short-term economic 

consequences on recreational visitation, and increase the downstream costs of using water from 

the national forest.

Grazing opportunity would benefit in the long term from the increase in restoration activities that 

would reduce the risk of uncharacteristic wildfire and improve forest health. Wilderness 

designation of those areas recommended under these alternatives would not restrict current 

permitted grazing levels. However, wilderness designation would prohibit access by motorized 

vehicle for maintenance of stock water developments, salt placement and restrict installation of 

new range improvements (such as water troughs) unless approved following a minimum 

requirements decision. Overall, the annual operating costs to the current permittees would be 

expected to increase under these conditions. Given the acreages identified for recommendation in 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

633

each alternative, the adverse effects of alternatives B-modified and B would be less than under 

alternative C (if designated by Congress), which recommends the most wilderness. The extent of

these effects is uncertain at this programmatic level.

There would be some short-term potential for disruption to grazing opportunity due to increased 

restoration project activity in and around allotment areas. This short-term disruption is expected 

to be minimal. Conservation watershed plan components do not directly prohibit livestock 

grazing activities or restrict or limit this use. Plan components for these management areas allow 

for the continued use of livestock and do not prescribe additional standards that should increase 

hardship or burden on livestock operations, including the variety of management options 

available to livestock grazing operations. Overall, there are potential adverse short-term and 

uncertain long-term effects on the local communities that are dependent on forest grazing.

Biomass provides the opportunity to generate electricity for the region and also support local job 

opportunities in harvesting. Alternatives B-modified and B provide the potential to contribute 

additional biomass to support developing an industry workforce and also creating a more 

favorable environment with a reliable biomass supply to support the investment in biomass 

facilities. This investment would be required in the long term to increase the pace and scale of 

restoration. The restoration activities proposed under alternatives B-modified and B also 

contribute to reducing adverse effects associated with the quantity and timing of water, and as a 

result improve the economic benefits from electricity generation through hydropower as 

compared to alternative A, the current forest plan.

Consequences Specific to Alternative C

The restoration activities proposed in alternative C focusing on managed fire and use of 

prescribed fire would be expected to help reverse current trends and to improve the long-term 

sustainability of four of the six key national forest benefits (water, recreation, air quality, grazing

and biodiversity) that provide benefits to people locally and across the region. The long-term 

sustainability of grazing is uncertain (similar to alternatives B and B-modified) and the long-term 

effects for energy generation from biomass would be adversely affected and would be similar to 

long-term effects identified under alternative A, the current forest plan.

In the short term, the potential effects are mixed across the different national forest benefits. 

These effects would be adverse for biodiversity from increases in disturbances related to the 

increasing of restoration activities. The short-term effects are mixed for water, recreation, energy 

generation, grazing, and air quality. Water quality could potentially be adversely affected from the 

potential for increased sedimentation from restoration activities. Recreation benefits in the short 

term from reduced wildfire, but is adversely affected by the potential for some restrictions on 

activities as a result of restoration projects. The overall effect on energy generation is uncertain 

because, while there would be reduced biomass utilization for energy generation, there is also the 

potential for improvements in water quantity and timing that could improve hydropower 

generation. Grazing would potentially be limited in the short-term by project activity but would 

also benefit from fire based restoration activities that could improve grazing settings. Air quality 

benefits in the long term from reduced wildfire, but effects are uncertain in the short term as a 

result of the amount of use of prescribed fire that is emphasized under alternative C and the fact 

that this burning would be used under favorable atmospheric conditions and thus effects could be 

mitigated.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

634

Potential Implications for Local Communities in California and Nevada

The restoration activities in alternative C focusing on managed fire and use of prescribed fire

would be expected to improve the long-term sustainability of four of the six key national forest

benefits and result in significant beneficial economic effects for local communities. These effects 

would be felt most directly through the potential gain in the sustainability of recreational 

visitation as a result of maintaining the quality of recreational settings and the opportunities of 

visitors. Maintaining species biodiversity would also contribute to sustaining national forest

visitation for important social and economic activities such as hunting, fishing, plant gathering,

and wildlife watching. Alternative C contributes to improving the long-term sustainability for all 

of this recreational visitation.

The additional areas identified in alternative C as potentially suitable for recommended 

wilderness would potentially result in economic effects for local communities within Inyo 

County. Specifically important are current and historic grazing areas on the east side of Monache 

Meadow. Potential effects on grazing in this area could impact communities because of increases 

in expenses for ranchers as well as increased difficulty transporting cattle to the area and 

maintaining infrastructure. There are also some active small-scale mining activities and mining 

claims in the areas of Redding Canyon, Marble Canyon and the Montezuma Mine. Even though 

these activities are currently limited, potential losses or restrictions to current and future mining 

opportunities would have potential effects for local communities.

Given the use of prescribed fire and managed fire restoration activities, alternative C has the 

potential to result in adverse short-term effects through closures during restoration project 

activities and disturbances to species diversity. This short-term disturbance would be expected to 

be similar to alternatives B and B-modified, and less than alternative D. This potential adverse 

effect is off-set by the potential for reduced wildfire, and therefore fewer related closures of 

recreational areas and fewer adverse wildfire effects on species. The overall effect of these two 

opposing factors is uncertain and is dependent on the specifics of the projects developed under 

this alternative. Project-level environmental analysis would be conducted to better understand the 

trade-offs to communities from these potential project economic effects on recreation.

Alternative C emphasizes investment in dispersed recreational opportunities over developed 

opportunities. The types of goods and services needed by visitors to dispersed areas and the 

resulting spending of these visitors are different than for developed areas. Therefore, emphasis on 

projects that could lead to a long-term shift in the type of visitor to the national forest would be 

examined at the project level to determine potential economic impacts on local communities as 

well as on other resources.

Reductions in the smoke from wildfires also contribute to potential beneficial economic effects 

resulting from improved sustainability of recreational visitation. Under alternative C, restoration 

activities would result in fewer larger wildfires in the upper montane areas treated with managed 

fire and use of prescribed fire, thus reducing the likelihood that visitors stay away from these 

areas. In addition, the reduced smoke from wildfires would help to improve air quality and the 

health of residents in local communities. There would be an emphasis on the use of prescribed 

fire and wildfire managed to meet resource objectives under alternative C that could lead to 

reduced air quality and recreational access in the short term. These activities would be planned to 

occur under favorable conditions in order to mitigate potential adverse effects. Still, the overall 

effect given the dependence of alternative C on fire for restoration is for some short-term adverse 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

635

effects on air quality that would have effects on human health, recreational visitation, and 

economic conditions in local communities.

Alternative C would contribute to sustaining the important local economic benefits provided by 

water from the national forest. The water that is used downstream from the Inyo is valuable for 

municipal and agricultural uses and is also valuable for recreational and ecological uses on the 

national forest because this water sustains the important water-based recreational setting and 

biodiversity that draws visitors. The quantity and quality of this water would be expected to 

improve in the long term under alternative C as compared to the current forest plan, given 

restoration activities that would reverse declining stream flows and increasing temperatures. In 

the short term, there would be the potential for adverse effects from increased sedimentation as a 

result of increased restoration activities; this sedimentation would be similar to alternatives B and 

B-modified, and less than alternative D. This could potentially have adverse short-term economic 

consequences on recreational visitation, and increase downstream costs of using water from the 

Inyo National Forest.

Grazing opportunity would benefit in the long-term from the increase in restoration activities to 

reduce the risk of uncharacteristic wildfire and improve forest health. Wilderness designation of 

those areas recommended under the alternative would not restrict current permitted grazing 

levels. However, wilderness designation would prohibit access by motorized vehicle for 

maintenance of stock water developments, salt placement and restrict installation of new range 

improvements (such as water troughs) unless approved following a minimum requirements 

decision. Overall, the annual operating costs to the current permittees would be expected to 

increase under these conditions. Given the acreages identified for recommendation in each 

alternative, the adverse effects under alternative C, if designated by Congress, would be greater 

than alternatives B and B-modified. The extent of these effects is uncertain at this programmatic 

level.

There would be some short-term potential for disruption to grazing opportunity due to increased 

restoration activity in and around allotment areas. This short-term disruption is expected to be 

minimal. There is also the potential for a short-term benefit from increased restoration using 

prescribed and managed fire as a primary restoration tool. These restoration activities would 

reduce woody biomass and increase herbaceous plants in large areas of the national forest thus 

having the potential to improve grazing settings. Overall, there are uncertain short- and long-term 

effects on the local communities that are dependent on forest grazing as there is the potential for 

both adverse and beneficial effects.

Biomass provides the opportunity to generate electricity for the region and also supports local job 

opportunities in harvesting. However, the focus on fire for restoration and the lack of higher value 

timber harvests to subsidize biomass removal does not result in expected development of biomass 

opportunities for energy generation. Long-term local job creation from hydropower generation is 

less than it is from biomass energy given there is no need for continual harvesting and processing 

of materials. Restoration activities proposed under alternative C contribute to reducing adverse 

effects associated with the quantity and timing of water, and as a result improve the long-term 

local economic benefits from electricity generation through hydropower as compared to 

alternative A, the current forest plan.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

636

Consequences Specific to Alternative D

The restoration activities in alternative D would be expected to help reverse current trends and 

improve the long-term sustainability of all six key national forest benefits that provide benefits to 

people locally and across the region. These effects would be similar to the effects outlined in 

alternatives B and B-modified. Key differences with alternatives B and B-modified would be that 

the increased pace and scale of restoration in alternative D would be expected to provide greater 

potential benefits to the long-term sustainability of these six national forest benefits, but also lead 

to potential increases in adverse short-term effects resulting from increased restoration activities.

Potential Implications for Local Communities in California and Nevada

The restoration activities in alternative D would be expected to improve the long-term 

sustainability of all six key national forest benefits and result in significant beneficial economic 

effects for local communities. These effects would be felt most directly through the potential gain 

in the sustainability of recreational visitation as a result of maintaining the quality of recreational 

settings and the opportunities of visitors. Maintaining species biodiversity would also contribute 

to sustaining national forest visitation for important social and economic activities such as 

hunting, fishing, plant gathering, and wildlife watching. Alternative D contributes to improving 

the long-term sustainability of this recreational visitation.

Given the increases in restoration activities, alternative D does have the potential to result in 

adverse short-term effects through closures during restoration project activities and disturbances 

to species diversity. This short-term disturbance would be expected to be larger than in 

alternatives B and B-modified. This potential greater adverse effect is off-set by the greater 

potential for reduced wildfire, and therefore fewer related closures of recreational areas and fewer 

adverse wildfire effects on species. The overall effect of these two opposing factors is uncertain 

and is dependent on the specifics of the projects developed under alternative D. Project-level 

environmental analysis would be conducted to better understand the trade-offs to communities 

from these potential project economic effects on recreation.

Alternative D emphasizes investment in developed recreational opportunities over dispersed 

opportunities. The types of goods and services needed for developed activities and the spending 

patterns of these visitors are different than they are for dispersed visitors. Therefore, emphasis on 

projects that could lead to a long-term shift in the type of visitor to the Inyo National Forest

should be examined at the project level to determine potential economic impacts on local 

communities as well as on other resources.

Reductions in the smoke from wildfires also contribute to potential beneficial economic effect 

resulting from sustaining recreational visitation. Under alternative D, restoration activities would 

potentially result in fewer larger wildfires, thus reducing the likelihood that visitors stay away 

from the area. In addition, the reduced smoke from wildfires would help to improve air quality 

and the health of residents in local communities. There would be some use of prescribed fire

under alternative D that could lead to reduced air quality and recreational access, but increased 

mechanical thinning before burning would help to limit this potential effect. In addition, this use 

of prescribed fire would be planned to occur under favorable conditions in order to mitigate 

potential adverse air quality effects. Still, the overall effect of these two opposing factors is 

uncertain and is dependent on the specifics of the projects developed under this alternative. 

Project-level environmental analysis would be conducted to better understand the trade-offs to 

communities from these potential project economic effects on air quality.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

637

Alternative D would contribute to sustaining the important local economic benefits provided by 

water from Inyo National Forest. The water that is used downstream from the Inyo is valuable for 

municipal and agricultural uses. It is also valuable for recreational and ecological uses on the 

national forest because this water sustains the important water-based recreational setting and 

biodiversity that draws visitors. The quantity and quality of this water would be expected to 

improve in the long term under alternative D as compared to alternative A, the current forest plan. 

In the short term, there would be the potential for adverse effects from increased sedimentation as 

a result of increased restoration activities and this sedimentation would be greater than under 

alternatives B and B-modified. This could potentially have adverse short-term economic 

consequences on recreational visitation as well as on the downstream costs of using water from 

the national forest.

Grazing opportunity would benefit in the long-term from increases in restoration activities to 

reduce the risk of uncharacteristic wildfire and improve forest health. There would be some shortterm potential for disruption to grazing opportunity due to increased restoration project activity in 

and around allotment areas. This short-term disruption is expected to be minimal. Overall, there is 

potential adverse short-term and beneficial long-term effects on the local communities that are 

dependent on forest grazing.

Biomass provides the opportunity to generate electricity for the region and also supports local job 

opportunities in harvesting. Alternative D provides the potential to contribute additional biomass 

to support developing an industry workforce and also support investing in new biomass facilities. 

This investment would be required in the long term if the State is to establish a market for 

biomass, which would be necessary in order to increase the pace and scale of restoration. Longterm local job creation from hydropower generation is less than it is from biomass energy, given 

there is no need for continual harvesting and processing of materials. Restoration activities 

proposed under alternative D contribute to reducing adverse effects associated with the quantity 

and timing of water and as a result, improve the economic benefits from electricity generation 

through hydropower as compared to alternative A, the current forest plan.

Cumulative Effects

The Inyo National Forest represents only a portion of the landscape that comprises the natural 

landscape in this area. The resources throughout this entire region provide economic 

contributions to local communities and regional benefits that improve the quality of people’s 

lives.

Forest restoration projects developed under the revised plan could potentially have short-term 

effects on forest benefits resulting from disruptive project activities (such as area closures and 

resource disturbance). These short-term effects need to be evaluated on a case by case basis in 

order to determine if there would be cumulative effects from projects occurring on other lands in 

the area. 

Recreation in and surrounding the national forest, national parks as well as State and local public 

lands does not follow administrative boundaries, and therefore changes in management of 

recreation on all of these lands together affects the long-term economic conditions in local 

communities. Visitors are drawn to the entire recreational experience of the area and spend time 

and money near their destinations as well as in communities on the way to their destinations. The

revised forest plan (alternative B-modified) is not expected to result in changes to the types of 

recreational opportunities available on Inyo National Forest. Therefore, the revised plan is not 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

638

expected to have any long-term cumulative effects on the numbers or types of activities enjoyed 

in the area. However, events like wildfire that result in closure of areas and in smoke that reduces 

enjoyment of visiting the area would adversely affect communities whether the fire is burning on 

the national forest or on neighboring Federal, state, or private lands. The restoration activities in 

the revised forest plan are expected to reduce the risk of these types of large scale events in the 

long-term and therefore would have a positive cumulative effect on recreational opportunity and 

air quality in conjunction with other restoration activities undertaken in the area.

There are no expected long-term changes to grazing use on the Inyo as a result of the final revised 

plan. The final revised plan does have the potential to result in cost increases for current grazing 

allotments that are located within the areas recommended for consideration for wilderness. 

However, there are no expected cost increases to these grazing allotments associated with past or 

expected future decisions. Therefore, no additional long-term cumulative effects to recreational or 

grazing use are expected.

Current trends in declining forest product infrastructure and workforce has resulted in only one 

sawmill remaining south of Yosemite National Park in Terra Bella. The management of all the 

lands in this area affects future trends in the harvesting of forest products and all of these other 

benefits need to be considered in conjunction with any changes in the forest plan. The resulting 

cumulative effects on communities are critical in maintaining economic health, diversity of 

economic activity, and sustainable fiscal conditions for counties and local municipalities. The 

operational mills in Terra Bella, Sonora and Chinese Camp are the closest mills to the Inyo 

National Forest. These mills have long haul distances and narrow roads that typically make 

transportation prohibitive. Therefore, given the limited use of these mills for Inyo National Forest 

harvested volumes, no changes resulting from the revised forest plan are expected to have any 

long-term cumulative effects on the economic sustainability of these mills.

Analytical Conclusions

Alternative A, the current forest plan, would adversely affect the long-term sustainability of all 

six key national forest benefits that are examined. The continuation of current management 

activities in the face of current resource conditions and trends is expected to result in more 

disruptive events, such as uncharacteristic wildfire, and additional declines in forest health that 

would interrupt and eliminate these benefits. This would have adverse short- and long-term 

effects on social and economic conditions in local communities and on people’s lives, both those 

located near the national forest and those across the region that enjoy these benefits.

Alternatives B-modified and B would be expected to help reverse current trends and to improve 

the long-term sustainability of five of the six key national forest benefits that provide benefits to 

people locally and across the region. In the short term, effects are mixed across the different 

national forest benefits. These short-term effects would be adverse for biodiversity and grazing, 

from increases in potential disturbances related to the increasing of restoration activities. The 

effects are mixed (both adverse and beneficial) for water, recreation and air quality. Water quality 

could be affected given the potential for increased sedimentation. Recreation receives benefits in 

the short term from reduced wildfire imposed closures, but is adversely affected by the potential 

for restrictions on activities resulting from restoration project activities. Air quality also benefits 

in the short term from reduced potential for wildfire, but the use of prescribed fire creates the 

potential for some short-term decreases in air quality as a result of these activities. Energy 

generation benefits from increased restoration activities that yield biomass and the potential for 

more water quantity for electricity production. Overall, the alternatives would have long-term 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

639

beneficial effects on economic conditions in local communities and on the national forests’ 

benefits to people’s lives, both those located near the national forest and those across the region 

that enjoy these benefits. In the short term, there is the potential for disruption to some of these 

benefits from increased activities, but this potential is less than in alternative D.

Alternative C would be expected to help reverse current trends and to improve the long-term 

sustainability of four of the six key national forest benefits (water, recreation, air quality and 

biodiversity) that provide benefits to people locally and across the region. The emphasis on fire 

for restoration instead of mechanical treatments means that the long-term sustainability of 

developing biomass utilization for energy generation would be adversely affected. The long-term 

effects on grazing are uncertain and similar to alternatives B and B-modified. In the short term, 

the potential effects are similar to those in alternatives B and B-modified with two important 

differences. Air quality is expected to be adversely affected in the short term as a result of the 

increased amount of prescribed and managed fire emphasized under alternative C, but given that 

these events would be planned to occur under favorable conditions, the overall effect is uncertain. 

For grazing, there is the potential for a short-term benefit from increased restoration using 

prescribed and managed fire as a primary restoration tool. These restoration activities would 

reduce woody biomass and increase herbaceous plants in large areas of the Inyo National Forest

thus having the potential to improve grazing settings. Overall, alternative C would have some 

long-term beneficial effects on economic conditions in local communities and on the Inyo’s

benefits to people’s lives. However, there is long-term loss of the opportunities for developing 

biomass industries as a result of this alternative.

Alternative D would be similar to alternatives B and B-modified and expected to help reverse 

current trends and improve the long-term sustainability of all six key national forest benefits that 

provide benefits to people locally and across the region. Key differences with alternatives Bmodified and B result from the increased pace and scale of restoration through mechanical 

treatments in alternative D that could potentially provide even greater benefits to the long-term 

sustainability of these six national forest benefits. However, this increased intensity would also 

lead to potential increases in the short term adverse effects resulting from these restoration 

activities.

Social Conditions

Background

This section summarizes current social conditions in the analysis area for the Inyo National Forest

and potential impacts of implementing the revised plan or alternatives on these conditions.

The 2012 Planning Rule requires that plans contain guidance that helps a national forest

contribute to social sustainability. In this plan revision effort, desired conditions were developed 

for the Inyo National Forest to address the following identified needs: supporting the long-term 

sustainability of forest benefits to people, encouraging the use of partnerships, and improving 

communication and outreach to the public, including underrepresented populations.

Many of the challenges we face in managing National Forest System lands are rooted in the 

values that people hold, which influence what is desired from forest management and also help 

define the quality of life that is important to individuals and communities (Allen et al. 2009). 

People are often concerned with the potential impacts of changes in land management on their 

quality of life and at the same time, shifting population demographics also influence value 

orientations and what is considered important to individuals and communities. These values can 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

640

change over time and the analysis here is a snapshot of values obtained during the environmental 

analysis process. Values should be examined at the project level to capture any changes over time. 

This plan revision effort aims to develop plans that emphasize working together with and 

understanding the needs of the public in order to manage forests in a way that contributes to 

social sustainability.

Analysis and Methods

This analysis focuses on three key indicators to examine impacts of alternatives on social 

conditions: values, civil rights, and environmental justice. While social conditions include a wide 

range of factors, values were chosen as an indicator because they effectively help us understand 

differences among alternatives from a social perspective, as well as concerns raised by the public. 

In addition, examining impacts of alternatives on civil rights and environmental justice are a 

required part of an environmental impact statement and help ensure more vulnerable populations 

are considered in land management decisions. These three indicators are described below.

Indicators and Methods

Values

Understanding how people are potentially affected by different alternatives includes looking at 

what those changes mean in terms of people’s different value sets. Several comments received 

during scoping reveal the diverse values that stakeholders have regarding the management of 

National Forest System lands. People would be impacted differently because certain alternatives

would align more closely with personal values compared to other alternatives. This analysis 

qualitatively examines potential impacts of alternatives on different value sets. The analysis does 

not attempt to weigh the impacts on all possible values but instead examines those identified in 

public comments received during the environmental analysis process.

Based on scoping comments and previous input, including a stakeholder analysis conducted by 

the Center for Collaborative Policy prior to the assessment phase, we developed broad categories 

of forest management values that may be affected by different alternatives. We then took these 

categories along with analyses from other resources areas to summarize the extent to which the 

different alternatives aligned with different values. This analysis does not discuss every aspect of 

these very broad values. Rather, it focuses on those aspects that best help us understand 

differences across alternatives and concerns raised by the public.

The area of focus for this indicator includes the Inyo National Forest. We used information 

provided by the public regardless of location to examine people’s values toward the management 

of the national forest. This includes viewpoints from both local and regional stakeholders, as well 

as stakeholders in more distant locations.

Civil Rights

U.S. Department of Agriculture civil rights policy (U.S. Department of Agriculture 2003) requires 

each agency to analyze the civil rights impact(s) of policies, actions, or decisions that will affect 

the Department workforce or federally conducted and federally assisted programs and activities. 

A civil rights impact analysis facilitates the identification of the effects of agency actions that 

may adversely and disproportionately impact employees or program beneficiaries based on their 

membership in a protected group.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

641

A protected group is any person, group, or class of persons protected under Federal law and 

executive order from discrimination on any prohibited basis, that is, discrimination based on race, 

color, national origin, age, disability, and where applicable, sex, marital status, familial status, 

parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or 

because all or part of an individual’s income is derived from any public assistance programs (U.S. 

Department of Agriculture 2003).

For environmental or natural resources actions, civil rights impact analyses are not separate 

reports, but are an integral part of the social impact analysis in the environmental impact 

statement (U.S. Department of Agriculture 1986).

The theory of “disparate impact” is used in this civil rights impact analysis. Disparate impact is 

the evenhanded application of neutral policies, actions, or decisions that have the effect of 

excluding or otherwise adversely and disproportionately affecting protected groups. This analysis 

qualitatively describes whether:

• Protected groups were provided the same opportunities to participate in the forest plan 

revision process as others.

• Management under the draft forest plans has the effect of excluding or otherwise adversely 

and disproportionately impacting protected groups.

The area of focus for this indicator includes the Inyo National Forest. The analysis examines any 

potential civil rights impacts as a result of the national forest’s plan revision process or revised 

plans. A qualitative analysis of public engagement and review of the scope and nature of public 

comments was used to assess potential disproportionate impacts to protected groups.

Environmental Justice

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 (U.S. Department of Agriculture 1997).

In 1994, Executive Order 12898, "Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations" was signed requiring that each Federal agency make 

achieving environmental justice part of its mission by identifying and addressing, as appropriate, 

disproportionately high and adverse human health or environmental effects of its programs, 

policies, and activities on minority populations and low-income populations (Council on 

Environmental Quality 1997).

The memorandum specifically recognized the role of the National Environmental Policy Act in 

identifying and addressing environmental justice concerns, particularly related to analyzing 

environmental effects on minority populations, low-income populations, and Indian Tribes; 

identifying mitigation measures as appropriate; and providing opportunities for community 

participation in the environmental analysis process (Council on Environmental Quality 1997).

This analysis examines whether there may be disproportionately high and adverse environmental 

effects on minority and low-income populations across alternatives. Environmental effects 

include human health, economic, and social effects. This is done qualitatively by examining 

whom and where these environmental justice communities may be, describing how they interact 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

642

with the national forest, and, as a result, how they may be disproportionately and adversely 

impacted by the different alternatives.

The Council on Environmental Quality has oversight of the Federal government’s compliance 

with Executive Order 12898 and NEPA. They have defined “minority” and “low-income” 

populations as follows (Council on Environmental Quality 1997):

Low-income Populations: Low-income populations in an affected area should be 

identified with the annual statistical poverty thresholds from the Bureau of the Census’ 

Current Population Reports, Series P-60 on Income and Poverty. In identifying lowincome populations, agencies may consider as a community either a group of individuals 

living in geographic proximity to one another, or a set of individuals (such as migrant 

workers or Native Americans), where either type of group experiences common 

conditions of environmental exposure or effect.

Minority: Individual(s) who are members of the following population groups: American 

Indian or Alaskan Native; Asian or Pacific Islander; Black, not of Hispanic origin; or 

Hispanic.

Minority Populations: Minority populations should be identified where either: (a) the 

minority population of the affected area exceeds 50 percent (may be made up of one 

minority or a sum of all minorities together) or (b) the minority population percentage of 

the affected area is meaningfully greater than the minority population percentage in the 

general population or other appropriate unit of geographic analysis.

To identify potential environmental justice populations, we used demographic data from the 2011 

American Community Survey (ACS) 5-year estimates from the U.S. Census Bureau. The 5-year 

estimates in 2011 were the most recent data available when originally collected, analyzed, and 

mapped during the assessment phase. The 5-year estimates were chosen over the 3- or 1-year 

estimates because they provide information for smaller geographies, are more precise, and better 

for small populations.

We used the area of influence previously defined for the Inyo National Forest in the assessment 

phase. This is the set of census county divisions (CCD) that intersects the national 

forest administrative boundary. Census county divisions are county subdivisions delineated by the 

United States Census Bureau in cooperation with state, tribal, and local officials for statistical 

purposes (U.S. Census Bureau 2015). The CCDs and counties associated with the Inyo National 

Forest are: North Mono and Mammoth Lakes CCDs in Mono County; Bishop, Independence, and 

Lone Pine CCDs in Inyo County; Mina CCD in Mineral County; and Silver Peak CCD in 

Esmeralda County (see figure 36).

We considered a census county division a minority population if greater than 50 percent of the 

population identified as non-white or Hispanic/Latino. We considered a census county division a 

low-income population if the percentage of people below the poverty threshold was substantially 

greater than at the county level.

In determining the poverty status of families and individuals, the Census Bureau uses income 

cutoffs that vary by family size, number of children, and age. If the total income of a person’s 

family in the last 12 months is less than the threshold appropriate for that person’s family size and 

composition, then that person is considered “below the poverty level” together with every family 

member.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

643

To better understand the geographic location of potential environmental justice communities and 

more specific information regarding race and ethnicity, we examined census block-grouppopulation demographics for the following categories: American Indian and Alaska Native; 

Asian; Black or African American; Native Hawaiian and Other Pacific Islander; Hispanic or 

Latino; and Poverty (percent of people whose income is below the poverty level). Census block 

groups are the second to smallest geographical unit used by the Census Bureau and are generally

defined to contain between 600 and 3,000 people (United States Census Bureau 2015). We used 

this information to identify more specific places that had relatively large minority populations and 

where outreach efforts could be targeted.

Assumptions

• The framework for the social analysis uses generalities. Area residents and national forest

visitors have diverse preferences and values that may not be fully captured in the 

description of social consequences. The general categories are useful for assessing social 

impacts based on particular forest-related values.

• Individuals may hold one or more of the values described in this section. As a result, the 

impacts of alternatives on specific individuals may be cumulative or mixed, depending on 

the values they hold.

• Demographics are generally the same at the time of writing this analysis as they were 

during the assessment.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

644

Figure 36. Census county divisions that intersect the Inyo National Forest administrative boundary
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

645

Affected Environment

This section describes the social environment of the area relevant to the indicators used in the 

social impact analysis. More general, comprehensive background information regarding social 

conditions and trends related to the Inyo National Forest can be found in the national forest

assessment.

Values

Values are relatively enduring concepts that people hold and often share within a given society or 

culture about important life principles, including what is good or bad and desirable or undesirable 

(Allen et al. 2009). People’s values influence how they use national forests, as well as their 

expectations regarding how National Forest System lands should be managed. The values that 

people in the Sierra Nevada hold have been passed on through generations. However, values have 

also been changing over time due to new knowledge, recreation and tourism growth, migration 

from urban areas, and demographic shifts.

The diverse values that people hold can create complex situations for national forest land 

management. In addition, many communities outside a national forest’s immediate area of 

influence have an interest in how it is managed, whether they directly use the national forest

(such as recreation and tourism) or not (such as water demand from urban and agricultural areas, 

concern for endangered species; Long, Quinn-Davidson, and Skinner 2014a).

Baseline, representative data regarding public values for the Inyo National Forest are unavailable, 

so it is not possible to describe what values are most important to the public when it comes to 

management. However, based on what we heard from stakeholders throughout the revision 

process, we extracted the broad value categories. Because the viewpoints used to establish 

different value categories came from volunteered stakeholder responses, they are not necessarily 

representative of the general public. (Brown, Kelly, and Whitall (2013) reveal differences in 

national forest values between people who volunteered to participate in a values mapping 

exercise versus those who were randomly selected to participate. Still, interviews, meetings, and 

submitted comments often provide the only source of information regarding the national forest

values that people hold and help us better understand how national forest management decisions 

may have an impact on those values. The following sections describe the broad value categories 

we discerned from people throughout the plan revision process.

Aesthetic – Manage for the Scenery, Sights, Sounds, and Smells of Nature

As described in the national forest assessment, scenery is a major component of people’s 

recreation experience on the Inyo National Forest and greatly contributes to their sense of place 

and connection with the land. Ecosystem stressors such as excessively dense vegetative 

conditions, fire-return-interval conditions susceptible to severe wildfire, and outbreaks of insects 

and diseases continue to diminish valued scenery attributes, particularly socially valued large 

trees and diverse vegetation.

Biodiversity – Protect Animal and Plant Species and Their Habitat

The diverse landscape of the Inyo National Forest provides a rich array of ecosystems and habitat 

types that support hundreds of wildlife, fish, and plant species. These species contribute to the 

lifestyles, cultures, and traditions of many national forest users through activities such as hunting, 

fishing, plant gathering, and nature viewing. People have also expressed concern regarding 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

646

adequate protection of habitat for species that are “at-risk,” as described in the “At-risk Species”

section.

Cultural – Protect Forest Uses that Help Maintain Traditions and Cultures

Native American culture is inextricably connected to the land. Many Native Americans 

participate in traditional activities that carry on family and tribal traditions, provide sustenance for 

families, and continue a spiritual connection to the land and to animal and plant resources 

(McAvoy, Shirilla, and Flood 2004b). Tribal members have expressed concern about continued 

use of and access to areas on the Inyo National Forest that support their cultural traditions.

Learning – Support Opportunities to Learn About the Environment, History, and 

People

The Inyo National Forest fosters people’s connection to nature and each other through education 

and interpretation. People have expressed a desire to increase outreach, education, and 

interpretation efforts, particularly related to issues such as fire, invasive species, cultural 

resources, tribal histories and uses, and recreation etiquette and impacts.

Recreation – Maintain and Enhance a Diverse Set of Recreation Activities

Outdoor recreation is a large part of the culture and lifestyle in the Sierra Nevada and one of the 

main ways that residents and visitors connect to the land and enjoy the natural world. 

Recreational trends and the mix of outdoor activities chosen by the public evolve over time, and 

these demands influence national forest lands and management decisions (USDA Forest Service

2012). Because everyone recreates on the Inyo National Forest in a wide variety of ways, people 

also have expressed a wide range of concerns regarding potential impacts to their preferred 

recreation activities. In addition, many people would like to see more opportunities on Inyo 

National Forest for the types of recreation activities in which they participate.

Wellbeing – Promote and Protect Human Health and Safety

The Inyo National Forest contributes to the well-being of human populations in a variety of ways, 

including basic life necessities such as clean air and water, physical and mental health benefits, 

and protection from the spread of fire into communities. People are concerned about the impacts 

of national forest management decisions on their health and safety, particularly in regard to 

climate change and expected increases in the occurrence and severity of drought and fire. Many 

stakeholders are concerned with impacts to water supply, including downstream agricultural and 

urban communities.

Stakeholders have expressed concerns regarding health impacts associated with increased 

prescribed fire and wildfire managed to meet resource objectives. People are concerned that these 

actions would result in prolonged days of smoke exposure, affecting human health, people’s 

ability to recreate and go about daily activities, and tourism. This is of particular concern to the 

Inyo National Forest and people living in the eastern Sierra. In addition, people have expressed 

safety concerns about using prescribed fire or wildfire managed to meet resource objectives near 

communities, particularly where fuels loads are high. Concerns have been raised regarding 

impacts to access for fire suppression activities and public evacuation routes in the community 

wildfire protection zone.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

647

Civil Rights

All members of the public were invited to participate in the plan revision process. The main 

public notices and meetings held by Inyo National Forest are listed below. No specific 

information concerning respondents’ race, sex, national origin, or age was collected from public 

comments or meetings.

• On December 26, 2013, the Federal Register published the Forest Service’s notice to 

initiate plan revision for the Inyo, Sequoia, and Sierra National Forests. The public was also 

notified in the newspaper of record for the Inyo National Forest, the Inyo Register.

• In January 2014, public meetings were held in Bishop on the preliminary need to change, 

desired conditions, and forest roles and contributions. Based on sign-in records, at least 75 

people attended the meeting.

• In June 2014, public meetings were held in Bishop on the updated need to change, desired 

conditions, wilderness inventory, and timber suitability. Based on sign-in records, at least 

80 people attended the meeting.

• The notice of intent to prepare an environmental impact statement for revised forest plans 

was published in the Federal Register on August 29, 2014. The scoping comment period 

concerning the proposed action in the notice of intent ended on September 29, 2014. The 

public was also notified in the newspaper of record for the Inyo National Forest. The notice 

of intent and supporting documents were available to the public on the Forest Service 

project website. Scoping comments were accepted through the project website, email, hard 

copy, or fax.

• In September 2014, public meetings were held in Bishop to answer questions about the 

notice of intent and proposed action and to receive scoping comments. Based on sign-in 

records, at least 76 people attended the meeting in Bishop. During the scoping period, we 

received more than 7,200 separate public comment letters or emails from tribes, Federal 

agencies, state agencies, county governments and agencies, local agencies and 

organizations, and other groups and individuals.

• In November 2014, public meetings were held in Bishop on scoping issues and the 

conceptual range of alternatives. Based on sign-in records, at least 80 people attended the 

meeting.

• In June 2015, the Inyo National Forest held an additional public meeting in Bishop to share 

information on the wilderness evaluation. Based on sign-in records, at least 50 people 

attended the meeting.

• In June 2016, the Inyo National Forest held public meetings at the beginning of the 90-day 

comment period in Mammoth Lakes and Bishop. Based on sign-in records, a total of at 

least 80 people attend both meetings. Forest staff also participated in public meetings held 

in Northridge, Los Angeles and San Francisco, and in an on-line webinar. These additional 

forums reached more than 100 people. All forums were to orient the public to the draft 

environmental impact statement and draft forest plan. 

• In August 2016, the Inyo National Forest held public meetings in Mammoth Lakes and 

Bishop to answer questions and offer clarification on the draft environmental impact 

statement and draft forest plan prior to the end of the 90-day public comment period. Based 

on sign-in records, a total of at least 90 people attend both meetings
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

648

Beyond these general public notifications and meetings, the “Environmental Justice” section 

describes additional efforts the Forest Service made to reach out to more diverse audiences.

There were no comments received that indicated concerns about discrimination based on race, 

sex, national origin, age, or disabilities during the plan revision process. Inyo National Forest

offered accommodations and provided paper copies of forest plan revision materials to people 

who requested them due to disabilities or other reasons. All web-based materials were developed 

to be accessible for people with disabilities as required by section 508 of the Rehabilitation Act.

Some senior citizens expressed a desire for meetings closer to home to avoid long drives at night. 

We also heard this from members of the public from rural mountain communities. Meeting 

locations and times were based on the availability of meeting space and trying to find centralized 

locations and times that accommodate the greatest possible attendance. Meetings were adjusted to 

end earlier over the course of the plan revision process. Forest staffs were also available to 

answer questions or provide information to those people who could not attend the meetings.

Some comments received during environmental analysis process suggest concerns regarding 

potentially disparate impacts from the proposed action and are further examined in the 

“Environmental Consequences” section. These include the following:

• Concerns that new wilderness recommendations would result in road and trail closures that 

would impact seniors, children, and people with disabilities who rely on motorized or 

mechanized travel to access the national forest.

• Concerns that new wilderness recommendations would add areas predominantly used by 

white males and that exclude minorities and women.

• Concerns that prohibiting pack goats in wilderness would impact seniors, children, and 

people with disabilities who rely on pack goats to access these areas.

• Concerns that prohibiting bicycles on the Pacific Crest Trail would impact people with 

disabilities who can bike but not walk for long distances.

• Concerns with health impacts of wildfire smoke on seniors, children, and people with 

health problems.

Environmental Justice

None of the seven CCDs (census county divisions) that make up the Inyo National Forest’s area 

of influence have minority populations over 50 percent (table 114). However, certain areas within 

or near Bishop, Mammoth Lakes, and Lee Vining have relatively large proportions of their 

populations who identified as minorities, particularly people who identified as American 

Indian/Alaska Native and/or Hispanic/Latino.

Of the seven census county divisions that make up the Inyo National Forest’s area of influence, 

the Lone Pine CCD in Inyo County and the Mina CCD in Mineral County have substantially 

greater percentages of people who are below poverty compared to county levels (table 114). In 

addition, certain areas within or near Sonora Junction, Mammoth Lakes, and Bishop have 

relatively large proportions of their populations that are low-income.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

649

Table 114. Percentage of minority populations and people living below the poverty level in the area 

of influence for the Inyo National Forest

Area Minority Population

People Below

Poverty Level

Mono County 31 percent 11 percent

North Mono Census County Division (CCD) 27 percent 12 percent

Mammoth Lakes CCD 32 percent 11 percent

Inyo County 33 percent 12 percent

Bishop CCD 35 percent 11 percent

Independence CCD 26 percent 7 percent

Lone Pine CCD 35 percent 18 percent

Mineral County 27 percent 22 percent

Mina CCD 0 percent 63 percent

Esmeralda County 20 percent 22 percent

Silver Peak CCD 32 percent 21 percent

Meaningful involvement in decision-making processes is an important part of environmental 

justice considerations. This includes reaching out to potential environmental justice communities 

and inviting them to participate in the plan revision process so we can better understand their 

concerns.

Efforts have been made to engage Tribes early and throughout the plan revision process. In fall 

2012, prior to the official start of plan revision, the Center for Collaborative Policy conducted 

informational interviews with 31 tribal members representing 14 Tribes and tribal organizations 

associated with the Inyo, Sequoia, and Sierra National Forests. The purpose of the interviews was 

to better understand tribal concerns that may be relevant to national forest planning, better 

understand how to improve tribal consultation and involvement, and develop recommendations 

for tribal involvement during the plan revision process. A Tribal Collaboration and 

Communication Plan was developed from the results of these interviews to inform how the three 

national forests would interact with Tribes during the plan revision process.

Tribal forums specific to plan revision related to the Inyo National Forest have been held as 

described below.

• In January 2014, we held tribal forums in Bishop on the preliminary need to change, 

desired conditions, and forest roles and contributions.

• In June 2014, we held tribal forums in Bishop on the updated need to change, desired 

conditions, wilderness inventory, and timber suitability. 

• In September 2014, we held tribal forums in Bishop on the notice of intent and proposed 

action. 

• In June 2016, we held a tribal forum in Bishop to orient the tribes to the draft 

environmental impact statement and draft forest plan.

• In August 2016, we held a tribal forum in Bishop to answer questions and provide 

clarification to the draft environmental impact statement and draft forest plan.

In addition to the meetings above, we had several meetings with individual Tribes and tribal 

groups throughout the process that have included forest plan revision as an agenda topic.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

650

In our work and interactions with Tribes and tribal organizations, we have gained a better 

understanding of tribal interests and concerns related to plan revision. Broad categories of 

concern include protection of and access to sacred sites, gathering areas, and ceremonial areas; 

traditional land uses and management, including the role of fire on the landscape; tribal 

economies; traditional knowledge and education; conflict between recreation uses and traditional 

tribal activities; and overall forest resilience and sustainability. Further discussion of tribal 

interests and concerns can be found in the “Tribal Relations and Uses” section.

Aside from tribal communities, limited information is available regarding how minority and lowincome populations use and interact with the Inyo National Forest. National and regional 

information about how minority populations recreate can provide some insights regarding 

potential uses. Despite a U.S. population that is becoming increasingly ethnically diverse, 

minority populations are still underrepresented in outdoor recreation (Cordell 2012). Based on 

national outdoor recreation trends (Mahler 2012), running is the most popular outdoor recreation 

activity among African Americans, Asian/Pacific Islanders, and Hispanics. Biking is the second 

most popular activity among African Americans and Asian/Pacific Islanders, while fishing is the 

second most popular activity among Hispanics. Studies have found that Latinos are primarily 

day-use visitors, recreate in larger groups, prefer developed sites with amenities and facilities, and 

often spend extended periods at picnic sites cooking several meals throughout the day (Chavez 

2012). Studies on four national forests in southern California show that picnics, barbecues, and 

playing in streams were among the activities in which Latino visitors usually engaged (Chavez 

and Olson 2008).

In addition to general public notification, we haves been trying to find new ways to reach out to 

more diverse audiences to better understand their concerns and how they use the national forest.

The Inyo National Forest has expanded outreach to their Spanish language newspaper and is

working on coordinating localized interpretation and outreach to the Spanish speaking population. 

Programs are expected to start late summer to fall that involved several long-term ideas into the 

upcoming years. We have also starting work with Outdoor Afro, which aims to connect AfricanAmericans with natural spaces and one another through recreational activities.

Continuing to build on this outreach work can help increase diversity in participants in future 

efforts, particularly projects and activities developed under the revised plans. During this plan 

revision effort, we have developed a better understanding of where potential environmental 

justice communities may be located. The Inyo has started to do some work on identifying trusted 

community contacts who can help provide a bridge between the national forest and these 

communities. This information can further assist in developing outreach efforts when we are 

developing projects in certain areas.

Environmental Consequences to Social Conditions (All Alternatives)

Values

Aesthetic – Manage for the Scenery, Sights, Sounds, and Smells of Nature

Scenery is closely tied to vegetation and fire management as described under the “Sustainable 

Recreation” section. The alternatives differ in terms of ecological restoration objectives, which 

define the rate at which we aim to move vegetation toward desired conditions. As vegetation and 

fire-return intervals across more landscapes are restored toward their natural range of variation, 

the degree to which valued scenic attributes can be sustained through time is expected to increase 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

651

as well. In the short term, however, some people may perceive restoration activities as having a 

negative impact to scenery.

Long-term sustainability of scenic character would be at greater risk under alternative A 

compared to alternatives B, B-modified, or D. Alternative A continues to use the existing visual 

management system for managing scenery and does not include evaluating the sustainability of 

scenic character as part of project planning. As described in the “Terrestrial Ecosystems” section, 

alternative A provides limited treatments across ecological zones.

Alternatives B and B-modified better align with aesthetic values in the long term compared to 

alternatives A and C, but less than alternative D. These alternatives include evaluating 

sustainability of scenic character as part of project planning. Alternatives B and B-modified are

expected to better integrate management across resources compared to alternative A, particularly 

in places that are of high recreation importance and where protection of scenic character is 

especially critical. These alternatives provide more potential for increasing ecological restoration 

opportunities across ecological zones than alternatives A and C.

Similar to alternatives B, B-modified, and D, alternative C includes evaluating sustainability of 

scenic character as part of project planning. However, this alternative is more restrictive in terms 

of ecological restoration opportunities compared to all other alternatives. Therefore, long-term 

sustainability of scenic character is likely to be at greatest risk under alternative C compared to all 

other alternatives.

Similar to alternatives B, B-modified, and C, alternative D includes evaluating sustainability of 

scenic character as part of project planning and is expected to better integrate management across 

resources compared to alternative A. Compared to all other alternatives, alternative D is expected 

to best align with aesthetic values in the long term, because it provides the most potential for 

increasing ecological restoration opportunities across ecological zones.

Biodiversity – Protect Animal and Plant Species and Their Habitat

Fishing, hunting, plant collection, and nature viewing are important activities to people who use 

the Inyo National Forest. The Forest Service is responsible for managing wildlife habitats on 

national forest lands whereas individual species are managed by California Department of Fish 

and Wildlife.

As described in the “Aquatics and Riparian Ecosystems” section, the slow pace of restoration of 

habitats for aquatic at-risk species under alternative A would result in a continuing risk of

downward trend for aquatic species diversity. The goal to increase restoration of aquatic habitats 

under alternatives B, B-modified, C, and D is expected to address species needs and improve 

aquatic biodiversity compared to alternative A. While there are different tradeoffs between shortterm consequences of restoration and long-term risk of intense wildfire among the alternatives B,

B-modified, C, and D, over the long term, they are expected to have similar effects on aquatics 

species diversity.

As described in the “At-risk Plant Species” section, because broad-scale restoration of ecosystem 

structure and function would be more limited under alternative A, there may be long-term 

negative effects to federally listed plant species under this alternative compared to the other 

alternatives. In comparison to alternatives B, B-modified, C, and D, alternative A would least 

provide the ecological conditions necessary to conserve candidate species and to maintain or 

restore their habitats in the plan area, which would contribute to preventing them from being 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

652

federally listed. Alternative A would consider fewer rare plants in the project planning process, as 

compared to alternatives B, B-modified, C, and D. Each of the three alternatives would provide 

for ecological conditions necessary to provide for the persistence of at-risk plant species. 

However, alternatives B and B-modified would provide the most long-term benefits to species of 

conservation concern habitat extent and quality. Alternatives B and B-modified would also have 

the most beneficial short- and long-term effects for whitebark pine.

Ecological restoration and use of wildfire primarily to meet resource objectives is limited in 

alternative A, providing for less opportunity to create habitat heterogeneity that is needed for 

many of the hunted and viewable wildlife species. Alternatives B and B-modified continue to 

provide for large tree and forest canopy cover, as with alternative A, but with additional emphasis 

to increase the amount of forest restoration treatments to create greater habitat resiliency and 

heterogeneity. The consequences to hunted and viewable species are expected to be mixed in 

alternative C with some benefits due to less disturbance, but also less benefit from more limited 

habitat restoration opportunities compared to alternatives B, B-modified, and D. There is a higher

likelihood of very large, high-intensity fires with implementation of alternative C, according to 

the fire-climate scenario predictions (Westerling et al. 2015), which can have a long-term 

negative impact on the distribution and sustainability of habitat. Alternative D would have the 

greatest increase in the pace and scale of ecological restoration of all alternatives, and would 

provide the most areas with increased vegetation resilience and heterogeneity, which would 

generally benefit hunted and viewable species. The increased pace and scale of mechanical 

thinning and use of strategic treatments along ridgetops in alternative D would be expected to 

produce greater forage for herbivores. The increased restoration of fire as an ecological process 

would also provide more sustainable forage. This influx of forage also could help bolster predator 

populations, such as mountain lions, bobcats, and coyotes and other viewable wildlife species.

Cultural – Protect Forest Uses that Help Maintain Traditions and Cultures

All alternatives contribute to the cultural connections that people have with the Inyo National 

Forest through the various uses and activities that the Inyo provides.

Alternative A does not provide the level of integration of tribal interests and values into project 

considerations that alternatives B, B-modified, C, and D do. Alternative A only includes existing 

designated wilderness and does not recommend new areas for inclusion in the National 

Wilderness Preservation System, allowing for the same level of tribal access to areas traditionally 

used by Tribes and that may have been part of the wilderness evaluation.

Alternatives B, B-modified, C, and D provide a greater level of integration of tribal interests and 

values into project considerations than alternative A, due to the addition of new plan components 

that would be included in each alternative. The increased opportunities for ecological restoration 

in alternatives B-modified and B are expected to benefit tribal interests by incorporating 

traditional ecological knowledge, traditional management practices, and tribal involvement into 

restoration projects. By working with Tribes, more ecological restoration activities are expected 

to lead to more opportunities that benefit habitats and resources used for traditional purposes. 

Alternatives B-modified and B recommend new areas for inclusion in the National Wilderness 

Preservation System on the Inyo National Forest. As described in the “Tribal Relations and Uses”

section, while many tribal activities could still occur within areas recommended for wilderness, 

some activities such as gathering and ceremonial uses may be restricted or more difficult if areas 

are managed as wilderness.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

653

Due to the limited opportunities for ecological restoration in alternative C, areas and resources of 

tribal interest are at greatest risk to large, high-intensity wildfire under this alternative. Alternative 

C recommends the most new areas for inclusion in the National Wilderness Preservation System, 

which could potentially lead to the most restrictions on traditional tribal uses.

The increased opportunities for ecological restoration in alternative D are expected to benefit 

tribal interests by incorporating traditional ecological knowledge, traditional management 

practices, and tribal involvement into restoration projects. By working with Tribes, more 

ecological restoration activities are expected to lead to more opportunities that benefit habitats 

and resources used for traditional purposes. Because alternative D provides the most ecological 

restoration activities, there may be greater risks to inadvertently impacting tribal resources, 

traditional cultural properties, and sacred sites. However, this is expected to be mitigated through 

close coordination with Tribes. Alternative D does not recommend new areas for inclusion in the 

National Wilderness Preservation System, allowing for the same level of tribal access to areas 

traditionally used by Tribes and that may have been part of the wilderness evaluation.

Learning – Support Opportunities to Learn About the Environment, History, and People

Under alternative A, the Inyo would continue to provide opportunities for people to learn about 

the environment and the history of the land and its people. However, more opportunities are 

expected under alternatives B, B-modified, C, and D because of added plan direction related to 

volunteering, interpretation, partnerships, and stewardship. New plan direction emphasizes the 

delivery of effective messaging regarding natural and cultural resources, climate change, land 

stewardship, responsible recreation use, and Native American heritage and culture, as well as 

communicating regularly with the public about Forest Service projects, management activities, 

and volunteer and partnership opportunities. This includes consideration of the diverse 

backgrounds and needs of visitors in developing communication materials. In addition, 

alternatives B, B-modified, C, and D would include an objective to generate cultural resources 

products, providing for more cultural learning opportunities. This objective would not vary across 

alternatives B, B-modified, C, and D and does not exist in current forest plans under alternative 

A.

Across alternatives B, B-modified, C, and D, there is an increased emphasis on partnerships. 

Partnerships not only help us do our work, but also create opportunities for learning. While 

emphasis on partnerships across these alternatives is basically the same, the focus of the 

partnerships may vary across them. For example, there would be more opportunities for 

partnerships around primitive recreation in alternative C compared to developed recreation in 

alternative D.

There is an also and increased emphasis on working with Tribes in alternatives B, B-modified, C, 

and D compared to alternative A. An important aspect of this coordination is finding opportunities 

for increased learning and understanding between the agency and Tribes as we carry out projects 

and activities. Another important aspect includes incorporating traditional ecological knowledge, 

traditional management practices, and tribal involvement into restoration projects, which may not 

only improve land management decisions, but also promote transmission of traditions and 

knowledge to younger generations.

Recreation – Maintain and Enhance a Diverse Set of Recreation Activities

Demand for outdoor recreation opportunities is expected to increase, while the types of recreation 

activities and experiences that people are seeking would continue to shift. With expected stable or 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

654

declining agency budgets in the future, the Forest Service would need to rely on volunteers and 

partners to continue to provide a set of recreation opportunities that meet the need of a growing 

and changing public. Over the past 15 years, there have been significant declines nationally in 

programs that contribute to providing recreation opportunities as financial and human resources 

have been shifted to wildfire management (USDA Forest Service 2015e). This has resulted in the 

agency being unable to more fully implement sustainable recreation, heritage, volunteer services, 

wilderness, and wild and scenic rivers programs to provide consistent, quality recreation 

opportunities to the public. The reductions in funding and staff have also impacted the agency’s 

ability to work with partners and volunteers, as well as to manage permits needed by outfitters 

and guides and other recreation-focused small business to provide recreation opportunities on 

National Forest System lands.

Alternatives B, B-modified, C, and D better emphasize sustainable recreation concepts and 

integrated resource management compared to alternative A. In addition, these alternatives 

emphasize increasing the sustainability of recreation through stewardship and partnership 

opportunities with local communities, engaging diverse populations, and targeting highest priority 

recreation needs to help focus limited resources. However, the types of recreation opportunities 

that are emphasized vary across alternatives.

The threat of large, high-intensity fire is greater under alternative A (the current forest plan)

compared to alternatives B, B-modified, or D due to limited ecological restoration treatments and 

limited ability to use wildfire to restore and maintain landscapes. As a result, recreation 

opportunities and access are expected to be more at risk under alternative A, increasing the 

potential for closures and displacement and associated overcrowding in the long term. The 

deferred maintenance backlog would continue to grow, further increasing the potential for site 

and infrastructure closures. Under alternatives B and B-modified, strategic treatment of fuels and 

treatment is expected to improve sustainability of recreation infrastructure and limit losses and 

damage due to wildfire, allowing more recreation resources to go toward reducing the deferred 

maintenance backlog over the long-term. Alternative D includes more opportunities for ecological 

restoration than alternatives B and B-modified, further decreasing the risk to recreation 

opportunities from high-intensity wildfires and reducing the potential for closures and 

displacement over the long term, as well as further reductions in the deferred maintenance 

backlog. Additionally, alternative D may have the greatest potential to reduce overcrowding 

compared to other alternatives because it best addresses the growing demand for developed 

recreation opportunities. Under alternative C, restoration is most limited and recreation 

opportunities are at greatest risk to negative impacts from high-intensity wildfire. As a result, 

alternative C has the most potential for increasing overcrowding due to closures and 

displacement. Under alternative C, the deferred maintenance backlog would increase more than 

all other alternatives due to its focus on dispersed and undeveloped recreation and more limited 

opportunities for fuels treatments.

Wellbeing – Promote and Protect Human Health and Safety

There are several aspects of human and community wellbeing that may be influenced by national 

forest management. This analysis focuses on health and safety related to wildfire. These aspects 

of wellbeing highlight the main differences expected to occur across alternatives for this value 

category. As described in the affected environment section, these are some of the most important 

areas of concern that stakeholders have raised regarding human and community wellbeing. 

Wildfires are growing larger, becoming more destructive, and occurring more frequently outside 

the traditional fire season due to vegetation buildup from years of suppression, climate change, 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

655

and drought. Large, high-intensity wildfires have the potential to negatively affect stream and 

watershed quality, reduce air quality with increased smoke, and destroy nearby homes and 

communities.

As described in the “Fire Management” section, managing fires more holistically, rather than 

trying to emphasize suppression only, is the most effective and efficient way to reduce fuels, 

reduce impacts to resources and communities, and restore and maintain landscapes. Not enough 

resources are available to reduce fuels with mechanical or prescribed fire treatments alone on 

enough areas to effectively reduce the risk to communities. As a result, safety concerns regarding 

the direct impacts of wildfire are best addressed by alternatives B, B-modified, and D, which use 

a four-zone approach to categorize risk and remove many of the uncertainties on the location and 

source of potential damages and benefit to highly valued resources and assets. This allows for 

more use of wildfire to meet resource objectives and ability to meet overall restoration goals, 

which ultimately reduces risks to communities. The greater amounts of ecological restoration and 

the enhancement of strategic fire management features in alternatives B, B-modified, and D,

compared to alternatives A and C, further contribute to reducing fire risk to communities and 

allow for more opportunities for implementing large, prescribed fires or managing wildfire to 

meet resource objectives. More ecological restoration treatments in alternative D than B or Bmodified are expected to further reduce fire risk to communities.

Under all alternatives, there would be continued coordination with local partners and 

communities for protection and prevention in high wildfire risk areas to enhance the effectiveness 

of initial response. All alternatives prioritize fuel reduction treatments around communities. 

However, alternatives A and C do not account for the likelihood of fires to spread from adjacent 

areas that contribute to the risk to communities or infrastructure. Because risk-based zones are not 

used in alternative A, opportunities for using wildfire to restore and maintain landscapes are 

greatly limited. Additionally, mechanical fuels treatments are more limited under alternative A 

than alternatives B, B-modified, and D. Alternative C includes the risk-based wildfire 

maintenance zone that alternatives B, B-modified, and D have, allowing for more wildfire 

managed to meet resource objectives within this zone. However, this alternative has the least 

amount of mechanical fuel reduction, as well as higher uncertainty of where risk resides, so there 

are less options for fire management outside this zone.

As described in the “Aquatic and Riparian Ecosystems” section, the risk to water quality over the 

long term increases as the risk of large, high-intensity wildfire increases. The risk of these types 

of fires is most reduced under alternative D, because the greatest amount of ecological restoration 

is expected to occur under this alternative, followed by alternatives B-modified, B, A, and C, 

respectively. While fuels management activities such as mechanical treatment and prescribed fire 

can have a variety of negative, short-term impacts to soil and water quality, implementation of 

best management practices can effectively mitigate potential impacts from these actions. In 

addition, alternative D is expected to have the greatest number of properly functioning watersheds 

that are resilient to the impacts of climate change due to the amount of ecological restoration in 

aquatic and riparian systems that is expected to occur.

As described in the “Fire Management” section, smoke management opportunities are limited 

during large wildfires and can result in serious air quality impacts, disrupting the lives of 

residents and adversely impacting human health. The level of smoke emissions from large 

wildfires is expected to double over the next half a century, given current vegetation conditions 

and trends in climate and fire ignitions. Under the current forest plan in alternative A, there would 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

656

generally be a continuation of current trends in large wildfires that produce large smoke 

emissions. Alternative A does not contribute to altering current trends or improving the long-term 

sustainability of air quality benefits that the national forests provide to people. Under alternatives 

B, B-modified, and D, there would be more prescribed fire, thinning, and in some areas wildfires 

managed to meet resource objectives. All of these restoration activities would reduce potential 

emissions from large, undesirable wildfires. There would be increased smoke emissions from 

prescribed fires, but prescribed fires are generally planned under favorable conditions for smoke 

dispersion to limit human health impacts, impacts to transportation corridors, and smoke sensitive 

populations. Emissions from prescribed fire can be managed to reduce short-term impacts on air 

quality more effectively than emissions from wildfire. Alternatives B, B-modified, C, and D 

contribute to reducing current trends in large uncharacteristic wildfires that adversely affect the 

long-term sustainability of air quality. However, under alternative C, there is less mechanical 

thinning proposed than in alternatives B, B-modified, and D. As a result, prescribed fires would 

have a greater quantity of smoke associated with restoration activities because more fuels are 

available to burn. In addition, the ability of alternative C to alter current trends depends on the 

extent to which larger, landscape prescribed burning occurs.

Civil Rights

The Inyo National Forest is open to all groups for activities allowed under existing laws, 

regulations, and policies. This will not change under any alternative. Specific concerns described 

in the affected environment section that were raised during the environmental analysis process are 

further discussed below.

Members of the public expressed several concerns regarding potential wilderness 

recommendations. The concerns expressed were that potential wilderness recommendations 

would result in road and trail closures that would impact seniors, children, and people with 

disabilities who rely on motorized or mechanized travel to access the Inyo National Forest.

Changes to the trail and road system are project-level decisions and are not part of the plan 

revision process. While motorized and mechanized travel is considered unsuitable in 

recommended wilderness areas, current, authorized uses of roads and trails will not change under 

any alternative for the following reasons:

• Unless restricted by law or regulation, the plan alone cannot prohibit public uses without a 

closure order from the responsible official. To prohibit a use, the responsible official needs

to analyze the effects of a proposed closure and issue a project decision. Without a closure 

order, public uses may continue even if the uses are not considered suitable on the lands 

where they are occurring. Plan components can, however, bar the Forest Service from 

authorizing such uses, for example, when they would be conducted as an event requiring a 

special use authorization.

• Proposed changes to roads and trails within recommended wilderness areas would need to 

be analyzed at the project level for adverse and disproportionate impacts on seniors, 

children, and people with disabilities.

Concerns were also raised that prohibiting pack goats in wilderness would impact seniors, 

children, and people with disabilities who rely on pack goats to access these areas. No changes 

regarding the use of pack goats within wilderness are being made under the current forest plan 

revision process. Wilderness areas are currently open to the use of pack goats. However, further 

determinations of the appropriate use of pack goats within certain areas may be made at the 

project level.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

657

The final wilderness concerns raised were that new wilderness recommendations would add areas 

predominantly used by white males and that exclude minorities and women. All areas on the 

national forest, including recommended wilderness, are open to all members of the public. Based 

on the latest national visitor use monitoring data for Inyo National Forest, people from culturally 

diverse backgrounds are generally underrepresented as visitors. The vast majority of visitors are 

white, non-Hispanic, and male. The Forest Service recognizes the demographic shifts that are 

occurring locally and regionally and is working to better understand how and why people do and 

do not visit national forests, as well as outreach to underrepresented populations. Research has 

shown that people from culturally diverse backgrounds may not be visiting national forests for a 

variety of reasons, including comfort and safety, accessibility, strong and positive connections, 

and lack of information (Roberts et al. 2009). Under alternatives B, B-modified, C, and D, there 

are plan components to consider diverse backgrounds in designing communication and 

interpretive messages, as well as to actively engage urban populations, youth, and underserved 

communities in educational and community outreach programs. In general, there is more 

emphasis within plan components on connecting people with nature.

In addition to concerns related to wilderness, members of the public expressed concerns that 

prohibiting bicycles on the Pacific Crest National Scenic Trail would impact people with 

disabilities who can bike but not walk for long distances. No changes regarding bicycle use on the

Pacific Crest National Scenic Trail are being made under the current forest plan revision process. 

Regional Order 88-4 currently prohibits using or possessing bicycles on the Pacific Crest 

National Scenic Trail along the entire length of the trail.

Other concerns regarding potential health impacts of wildfire smoke on more vulnerable 

populations, including seniors, children, and people with health problems were also expressed. 

While most healthy adults and children are expected to recover quickly from smoke exposure and 

not have long-term consequences, certain sensitive populations may experience more severe 

short-term and chronic symptoms, including people with respiratory problems, the elderly, and 

children (California Air Response Planning Alliance 2008). As described above and in the “Fire 

Management” section, the level of smoke emissions from large wildfires is expected to double 

over the next half a century, given current vegetation conditions and trends in climate and fire 

ignitions. No alternative offers both short-term and long-term improvements to air resource 

indicators. Restoration treatments would slow the progress of increasing wildfire emissions. As a 

result, alternative D has the highest short-term emissions from treatments followed by alternatives

B-modified and B and then C. In the long term, alternative D would result in the greatest 

reduction in emissions from wildfires followed by alternatives B-modified, B, C, and lastly A. 

Alternatives B, B-modified, C, and D also include goals to help the public reduce smoke exposure 

through early notification and outreach efforts and participation in interagency collaborative 

smoke management. In addition, alternatives B, B-modified, C, and D include a guideline to 

identify mitigation actions for smoke-sensitive areas when managing wildfires and prescribed 

burns.

Environmental Justice

Because we do not have good data on how low-income populations use Inyo National Forest, it is 

difficult to examine how the alternatives may impact them. As described above in the “Economic

Conditions” section, the counties bordering the Inyo National Forest can have higher 

unemployment, lower earnings, and lower per capita income compared to California as whole. 

They are likely more vulnerable to national forest management changes that affect key economic 

sectors, as well as the impacts of large, high-intensity wildfires. While there is no indication that 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

658

any alternative disproportionately impacts low-income populations, the alternatives have varying 

effects creating more resilient landscapes. As described in the “Economics” section, over the long 

term, alternatives B, B-modified, and D are likely to have beneficial effects on economic 

conditions in local communities. As such, these alternatives are not expected to exacerbate the 

poverty rate or disproportionately worsen the economic well-being of low income individuals 

over the long term. Alternative C is likely to have some beneficial effects, but with losses in the 

forest products and biomass industries. Alternative A is expected to have overall adverse effects 

on economic conditions in local communities. It will be important to better understand how lowincome populations are using the national forest and how management actions impact them. This 

may be particularly true for projects that occur near key places where relatively large proportions 

of the population are low-income, as described in the affected environment section.

Native American Tribes have integral connections to the national forest that cross an array of 

social institutions, including family, government, economy, education, and religion. Areas across 

the Inyo play a key role in defining these institutions. As a result, all aspects of national forest

management are generally of great interest to Tribes. As described in the “Tribal Relations and 

Uses” section, alternative C is the only alternative that may result in an incremental loss of sites 

or diminished access to resources used by Tribes over time due to the high risk of large, highintensity wildfires. In addition, alternatives B, B-modified, and C include new recommended 

wilderness areas, potentially impacting tribal access to and use of culturally important areas. 

Alternative D provides the most opportunities to restore sites and resources important to Tribes 

and to reduce the threats from large, high-intensity wildfires due to the increased amount of 

vegetation management treatments. At the same time, alternative D would require additional 

coordination to protect these sites and resources due to the increased amount of mechanical 

treatments. All alternatives would address minimizing impacts to Tribes at specific locations 

during project planning, and alternatives B, B-modified, C, and D include specific plan direction 

to incorporate opportunities to improve sites and resources important to Tribes during project 

planning.

There is limited information regarding the use of Inyo National Forest by other minority 

populations. Currently, people from culturally diverse backgrounds are still underrepresented as 

national forest visitors according to the Forest Service national visitor use monitoring data. This 

may be due to language barriers, lack of information, or other constraints (Roberts et al. 2009). 

Based on the lack of information about how minority groups use the national forest, it is difficult 

to determine how the alternatives could impact them. However, there is no indication that the 

alternatives are expected to disproportionately and adversely impact minority populations.

Based on general observation at public meetings, there has been limited involvement by minority 

populations, aside from Tribes, during the plan revision effort. In order to have more involvement 

from culturally diverse stakeholders in processes such as plan revision, a relationship first needs 

to exist between Inyo National Forest staff and minority populations to provide a foundation to 

work from and build on. During the plan revision process, the Inyo staff has pursued efforts to 

start building those relationships and to outreach in new ways that may be more effective at 

reaching minority populations.

Cumulative Effects

Other federally managed lands in the area, including lands managed by the National Park Service 

and Bureau of Land Management, support the diversity of values that people hold for the natural 

landscapes in the southern Sierra Nevada. Restoration efforts across all lands would be important 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

659

to sustaining these landscapes and how they contribute to people’s lives. As described in the 

“Terrestrial Ecosystems” section, under all alternatives, the impacts of climate change and 

increased probability of large, high-intensity fires may override the beneficial impacts of 

restoration treatments, particularly in the near term while projects are being planned and 

implemented. There is uncertainty as to when or where large, high-intensity fires may occur or 

severe drought. The role that the Inyo National Forest will play in the future in supporting certain 

values may change over time as the landscape changes. In addition, demographic, cultural, and 

societal changes will continue to influence how people use their national forest and what is 

important to them in terms of forest management.

Analytical Conclusions

The current forest plan, alternative A, does not contribute to sustaining a diverse set of forestrelated values in the long term as much as alternatives B, B-modified, and D. Current trends of 

increasing fire activity, drought, and insect outbreaks pose the greatest threat to many of the 

values people have related to the national forest because these values are heavily dependent on 

resilient ecosystems that can support a variety of uses and needs in the long term. Because 

ecological restoration treatments are limited under alternative A, values are more at risk to 

negative impacts over the long term.

Alternatives B and B-modified effectively support a diverse set of forest-related values in the 

long term. These alternatives provide for increased ecological restoration over the planning 

period compared to alternative A and C, though less than D. As a result, alternatives B and Bmodified effectively moves forest conditions closer to ecosystem desired conditions and fire 

resilient landscapes, though not as quickly as alternative D. By moving toward these desired 

conditions, aesthetic, biodiversity, cultural, economic, learning, recreation, and wellbeing values 

are sustained over the long term. In terms of biodiversity values, alternatives B-modified and B 

are expected to provide more long-term benefit for plant species of conservation concern habitat 

than all other alternatives.

Similar to alternative A, alternative C does not contribute to sustaining a diverse set of forestrelated values in the long term as much as alternatives B, B-modified, and D because ecological 

restoration treatments are also limited under alternative C. Values are more at risk to negative 

impacts over the long term. Biodiversity and learning value sets under alternative C are better 

aligned than continuing with current management direction under alternative A.

Alternative D best supports a diverse set of forest-related values in the long term compared to all 

other alternatives. Alternative D provides for the greatest amount of ecological restoration over 

the planning period, moving us closer than other alternatives to ecosystem desired conditions and 

fire-resilient landscapes. As a result, alternative D best aligns with sustaining aesthetic, cultural, 

economic, learning, recreation, and wellbeing values over the long term. Alignment with 

biodiversity values are somewhat mixed. Alternative D best aligns with values related to hunting 

and viewing terrestrial wildlife. Alternatives B, B-modified, C, and D provide similar alignment 

with values related to aquatic species. Alternatives D and C provide more long-term benefits to 

plant species of conservation concern habitat than alternative A, but less than alternatives Bmodified and B.

Management direction under all alternatives is not expected to adversely or disproportionately 

impact protected groups. In addition, alternatives B, B-modified, C, and D include plan 

components to improve communication with and outreach to more diverse audiences and often 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

660

underrepresented populations, as well as to increase connections between Inyo National Forest

and people in general. Through this effort, we have heard concerns in particular related to impacts 

to seniors, children, and people with disabilities. Future projects will need to evaluate whether 

there may be adverse and disproportionate impacts to these and other protected groups. It will be 

important to continue to learn about how these groups use the national forest and potential 

impacts of the national forest on them.
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

661

Other Required Disclosures

Unavoidable Adverse Effects

The revised forest plan provides a programmatic framework that guides site-specific actions but 

does not authorize, fund, or carry out any project or activity. Therefore, decisions made in the 

land management plan do not cause, or have the potential to result in, actual irreversible or 

irretrievable commitment of resources (see next section). Application of the land management 

plan standards and guidelines during future project and activity decisionmaking would provide 

resource protection measures and limit the extent and duration of any adverse environmental 

impacts. For a detailed discussion of types of consequences expected from future activities, see 

specific topic areas in this chapter.

Irreversible and Irretrievable Commitments of Resources

Irreversible commitments of resources are those that cannot be regained, such as the extinction of 

a species or the removal of mined ore. Irretrievable commitments are those that are lost for a 

period of time such as the temporary loss of timber productivity in forested areas that are kept 

clear for use as a power line right-of-way or road.

The revised plan provides a programmatic framework that guides site-specific actions but does 

not authorize, fund, or carry out any project or activity. Because the land management plan does 

not authorize or mandate any site-specific project or activity (including ground-disturbing 

actions), none of the alternatives cause an irreversible or irretrievable commitment of resources.

Short-term Uses and Long-term Productivity

The National Environmental Policy Act (NEPA) requires consideration of “the relationship 

between short-term uses of man’s environment and the maintenance and enhancement of longterm productivity” (40 CFR 1502.16). As declared by Congress, this includes using “all 

practicable means and measures, including financial and technical assistance, in a manner 

calculated to foster and promote the general welfare, create and maintain conditions under which 

man and nature can exist in productive harmony, and fulfill the social, economic, and other 

requirements of present and future generations of Americans” (National Environmental Policy 

Act, section 101). Short-term uses are those that generally occur for a finite time period. Longterm productivity refers to the ability of the land to produce a continuous supply of a resource.

The change in the programmatic management of the Inyo National Forest under alternatives B, Bmodified, C, or D would not jeopardize the short-term or long-term productivity of the lands and 

resources of the Inyo National Forest. Discussion of short- and long-term effects is included in 

the analysis of the environmental consequence for each need for change.

Laws Requiring Consultation

The regulations for implementing the National Environmental Policy Act at 40 CFR 1502.25(a) 

direct “to the fullest extent possible, agencies shall prepare draft environmental impact statements 

concurrently with and integrated with . . . other environmental review laws and executive orders.” 

As a proposed Federal project, the revised plan decisions are subject to compliance with other 

Federal and State laws. Determinations and decisions made in the revised plan have been 

evaluated in the context of relevant laws and executive orders. Throughout the development of 

the revised plans, there has been collaboration with various State and Federal agencies. The 
Chapter 3. Affected Environment and Environmental Consequences

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

662

following actions have been taken to document and ensure compliance with laws that require 

consultation and/or concurrence with other Federal agencies.

• Endangered Species Act, Section 7: Consultation with the U.S. Department of the Interior, 

Fish and Wildlife Service, regarding federally listed threatened, endangered, and proposed 

species, and designated and proposed critical habitat is in progress. A biological assessment 

for federally listed species has been prepared and submitted to the U.S. Fish and Wildlife 

Service for consultation according to the Endangered Species Act.

• National Historic Preservation Act: Consultation with the California and Nevada State 

Historic Preservation Officers is mandated by section 106 of the National Historic 

Preservation Act. 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 was executed in December 2012. This Programmatic Agreement prescribes the 

manner in which Region 5 and the State Historic Preservation Officer shall cooperatively 

implement this Programmatic Agreement in California and portions of Nevada. It is 

intended to ensure that Region 5 organizes its programs to operate efficiently and 

effectively in accordance with the intent and requirements of the National Historic 

Preservation Act and that Region 5 integrates its historic preservation planning and 

management decisions with other policy and program requirements. The Programmatic 

Agreement streamlines the National Historic Preservation Act section 106 process by 

eliminating case-by-case consultation with the State Historic Preservation Officer on 

undertakings for which there is no or little potential to affect historic properties and for 

undertakings that either culminate in no historic properties affected or no historic properties 

adversely affected with approved Standard Protection Measures (36 CFR 800.4(d)(1) and 

800.5(d)(1).

• Government-to-government consultation was completed with American Indian tribes who 

have aboriginal territory within the lands now part of the Inyo National Forests, as required 

by the National Historic Preservation Act; Executive Orders 13007 and 13175; and the 

Programmatic Agreement cited above. More information on this consultation can be found 

in the “Public Participation” section of chapter 1 and in the “Tribal Relations and Uses”

section of chapter 3 of this document.
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

663

Chapter 4. Preparers, Consultation, and Coordination

Preparers and Contributors 

The following individuals and Forest Service staff groups contributed to development of this 

environmental impact statement. A steering committee guided the plan revision process 

comprised of: the Forest Supervisors of the Inyo, Sequoia, and Sierra National Forests; the 

Regional Office Directors of Ecosystem Planning, Ecosystem Management, and Public Services; 

and a representative from the Forest Service Office of General Council.

Responsible Officials

Tammy Randall-Parker, Forest Supervisor for the Inyo National Forest.

Interdisciplinary Team Members

The interdisciplinary team was comprised of a core team and an extended team. While all 

interdisciplinary team members contributed to the development of the draft and final 

environmental impact statements and forest plan, the core team members and primary authors of 

the statement are listed below and their major contributions are noted in parentheses in the “Title 

and Contribution” section. The term “detail” indicates a formal or informal temporary work 

assignment to the interdisciplinary team.

Name Title and Contribution Education and Experience

Adamic, Denise Public Affairs Specialist

(Core Team)

• M.A., Communication, University of 

Colorado, Denver

• Masters Certification, Public Relations, 

University of Colorado, Denver

• B.A., English and Mass 

Communication, Fort Lewis, Colorado

• 4 years with the Forest Service; 6 years 

with the Bureau of Land Management

Anderson, 

Jennifer

Regional Fuels Planner

(Extended Team and co-author: 

Fire Management)

• Master of Forest Resources, University 

of Georgia 

• B.A., Geography, Georgia State 

University

• 8 years with U.S. Fish & Wildlife; 

6 years with National Park Service; 

2 years with the Forest Service

Beres, Virginia Regional Strategic Planner 

(Planning Support; Species of 

Conservation Concern)

• B.S., Forest Management, Humboldt 

State University

• B.S., Computer Science, The University 

of Montana

• 18 years with the Forest Service; 3 

years with the Bureau of Land 

Management
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

664

Name Title and Contribution Education and Experience

Boston, 

Christina

Regional Wilderness and Wild and 

Scenic Rivers Program Leader

(Core Team and author: 

Wilderness and Wild and Scenic 

Rivers sections)

• M.S. Program (completed all program 

requirements except thesis), Natural 

Resources Recreation and Tourism, 

emphasis in parks and protected areas 

management, Colorado State University

• B.A., Geography, Minor in International 

Relations, Humboldt State University

• 15 years with the Forest Service; 

7 years with the National Park Service; 

3 years municipal parks and open 

space agencies

Bowden, Phil Regional Fuels Planner

(Core Team and co-author: Fire 

Management section)

• B.S., Forestry, Michigan Technological 

University 

• 32 years with the Forest Service

Boyst, Beth Pacific Crest Trail Manager

(Extended Team and author: 

Pacific Crest Trail section)

• M.S., Forestry, Colorado State

• B.S., Nursing, Univ. of Pittsburgh

• 28 years with the Forest Service

Brenzovich,

Erika

Acting Recreation Planner(Core 

Team: Recreational support and 

author: Sustainable Recreation 

and Designated and 

Recommended Wilderness 

sections)

• B.S., Natural Resources Planning & 

Interpretation, Humboldt State 

University

• 19 years with the Forest Service

Brough, April GIS Programmer/Analyst

(GIS Analyses)

• M.S., Forest Ecology, Utah State 

University

• B.S., Chemistry, Brigham Young 

University

• 4 years with the Forest Service

Bulaon, Beverly Forest Entomologist

(Extended Team and co-author: 

Agents of Change - Insects and 

Pathogens)

• M.S., Forest Entomology, Humboldt 

State University 

• B.S., Ecology, Humboldt State 

University 

• 16 years with the Forest Service

Charley, Dirk Tribal Relations Specialist

(Core Team and author: Tribal 

Relations and Uses)

• A.S. in Liberal Studies

• 36 years with the Forest Service

Cole, Mary Forest Landscape Architect, 

Sequoia National Forest

(Core Team: Recreation - former / 

Extended Team: Sequoia National 

Forest Recreation)

• M.A., Landscape Architecture, 

California State Polytechnic University 

at Pomona

• 26 years with the Forest Service

Coppeto, 

Stephanie

Wildlife Biologist, Lake Tahoe 

Basin Management Unit, 

(Extended Team: Wildlife support, 

terrestrial wildlife)

• M.A., Ecology Graduate Group, U.C. 

Davis; 

• B.S. Biology, Boston University 

• 5 years with Forest Service

Davidson, 

Andrea

Recreation Planner

(Core Team: Recreational support)

• M.S., Natural Resource Management, 

University of Idaho 

• B.S., Recreation and Resource 

Management, University of Montana 

• 11 years with the Forest Service
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

665

Name Title and Contribution Education and Experience

Dietl, Mike Regional Planning Team Leader

(Overall Team Leader – Left 

agency)

• B.S., Fisheries, California State 

University Humboldt

• 1 year with the Forest Service

• 16 years with the U.S. Army Corps of 

Engineers

Downie, Denise Regional Planner (Detail)

(Planning support)

• M.S., Agriculture, Soil Science 

Specialization, Cal Poly State 

University, San Luis Obispo, CA

• B.A., English Literature, University of 

California at Los Angeles

• 18 years with the Forest Service

Ehmann, 

Brenda 

Forest Environmental Coordinator 

(Forest Planner, retired)

• A.S., Soil and Water Conservation 

• 10 years with Natural Resources 

Conservation Service

• 28 years with the Forest Service

Ellsworth, Todd Watershed Program Manager

(Extended Team: Soils)

• B.S., Soil and Water Science, University 

of Arizona

• 27 years with the Forest Service

Emly, Virginia Regional Geospatial Data 

Manager

(Extended Team: Geospatial 

Analyst Project Lead)

• M.S., Botany and Range Management

• 30 years with the Forest Service

Fairweather, 

MaryLou

Biologist - Planner

(Core Team)

• M.S., Plant Pathology, University of 

Arizona

• B.S., Biology, Fort Lewis College

• Forest Pathologist

• 28 years with the Forest Service

Fites-Kaufman, 

Jo Ann

Planning Team Ecologist

(Core Team and author: Terrestrial 

Ecosystems, retired)

• Ph.D., Ecosystem Analysis

• M.S., Forest Resources

• B.A., Ecology

• 23 years with the Forest Service

Flebbe, Patricia Monitoring Coordinator

(Extended Team and author: Plan 

Monitoring Programs - retired)

• Ph.D., Ecology, University of Georgia

• M.A., Ecology, University of Kansas

• B.A., Biology, Mathematics

• Certified Senior Ecologist, Ecological 

Society of America

• 30 years with the Forest Service

Friedlander, 

Joan

Wildlife Biologist

(Core Team and support: At-risk

species-retired)

• M.S., Range Ecology, University of 

Arizona

• B.S., Wildlife Ecology, University of 

Arizona

• 32 years with the Forest Service

Goodwin, Bob Tribal Relations Officer

(Extended Team and co-author: 

Tribal Relations and Uses – Left 

agency)

• 3 years with the Forest Service, 21 

years with California Highway Patrol

Hawley, Karla Forest Plan Revision Writer-Editor 

(retired)

(Core Team: Writer-editor for 

Forest Plans)

• B.A., English, University of Utah

• 21 years with the Forest Service
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

666

Name Title and Contribution Education and Experience

Hemphill, Nina Program Manager Fish, Aquatic 

Ecology, Watersheds and 

Hydrology(Extended Team: Coauthor Aquatic and Riparian 

Ecosystems)

• Ph.D., Aquatic Ecology, UC Santa 

Barbara 

• M.A., Aquatic Ecology, UC Santa 

Barbara 

• 4 years with the Forest Service, 10 

years with the Department of Interior

Kanwar, Pooja Regional Planning Team Leader 

(Detail) (Planning Support)

• Ph.D., Natural Resources, University of 

Vermont 

• M.S., Resource Management and 

Administration, Antioch University New 

England 

• B.S., Geography and Environmental 

Studies, University of Iowa

• 2 years with the Forest Service

Kunert, Ken Planning Team Recreation 

Specialist (Detail - retired)

• B. L.A., Landscape Architecture, 

Michigan State Univ.

• 36 years with the Forest Service

Lin, Sonja Regional Strategic Planner

(Co-lead for Forest Plan 

development; Author: Social 

Conditions)

• M.S. and M.P.A., Forest Resources –

Social Science, University of 

Washington

• B.S., Fisheries, Wildlife and 

Conservation Biology, University of 

Minnesota

• 5 years with the Forest Service

McElroy, Keli Planning Team Silviculturist 

(Detail)

(Extended Team and co-author: 

Forest Products)

• B.S., Forestry, Environmental and 

Forest Biology, State University of New 

York College of Environmental Science 

and Forestry

• 15 years with the Forest Service

Metcalfe, Mark Regional Economist

(author: Economic Conditions)

• Ph.D., Economics, North Carolina State 

University

• M.S., Natural Resource Economics, 

University of Maine

• B.A., Geography, Boston University

• 26 years in natural resource and 

environmental economics

Meyer, Marc Southern Sierra Province 

Ecologist (Core and Extended 

Team and co-author: Agents of 

Change and Terrestrial 

Ecosystems sections)

• Ph.D., Ecology, University of California, 

Davis

• M.S. and B.A., Environmental Biology, 

California State University Northridge

• Certified Senior Ecologist, Ecological 

Society of America

• 11 years with the Forest Service

Montgomery, 

Andrea

Region 5 Planning Botanist 

(Detail)

• M.S., Botany and Plant Pathology, 

Oregon State University

• B.S., Biology, University of Puget 

Sound

• 16 years with the Forest Service

Murphy, Leeann Resource and Planning Staff 

Officer, Inyo National Forest

(Forest Planner)

• B.S., Wildlife Management, New Mexico 

State University

• 15 years with the Forest Service
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

667

Name Title and Contribution Education and Experience

Murphy, Tim Regional Planning Hydrologist

(Core Team and author: 

Watersheds and Hydrology 

section)

• M.F.R.C., Forestry, University of Florida

• B.S., Soil & Water Science, University 

of Arizona

• Certified Forester (CF)

• 28 years in natural resource and 

environmental science

• 8 years with the Forest Service

Nick, Andrea Air Quality Specialist

(Extended Team and co-author: 

Air Quality section)

• M.A. Natural Resources, Utah State 

University

• M.A. Geography, California State 

University, Northridge

• B.A. Geography, California State 

University, San Bernardino

• 11 years with the Forest Service

Olmedo, 

Eduardo

Regional Planner Wildlife Biologist

(Core Team: Species of 

Conservation Concern)

• B.S. Wildlife Biology, Humboldt State 

University, Arcata, CA

• A.A. Biology, Santa Monica College, 

Santa Monica, CA

• 29 years with the Forest Service

O’Brien, Colleen

(Chaz)

Recreation Specialist (Detail)

(Core Team and co-author: 

Sustainable Recreation) 

• BA Human Ecology College of the 

Atlantic 

• MLA Royal Melbourne Institute of 

Technology

• 13 years with USFS 

Proctor, Trent Region 5 Air Quality Program 

Manager

(Extended Team and co-author Air 

Quality section)

• B.S., Natural Resource Management, 

Cal Poly SLO

• 38 years with the Forest Service

Sawyer, Sarah Assistant Regional Ecologist

(Extended Team and contributor: 

At-risk Wildlife section)

• Ph.D, Environmental Science -

specializing in Wildlife and Forest 

Ecology, Univ. of California, Berkeley

• M.A., in Anthropology - specializing in 

wildlife-human interactions, Stanford 

University

• B.S., Human Biology - specializing in 

primatology, Stanford University

• 3 years with the Forest Service

Schlick, Kary Fish and Wildlife Biologist, Inyo 

National Forest

(Extended Team: Aquatic and 

Riparian Ecosystem section)

• B.S., Zoology and Biodiversity, 

Humboldt State University

• 21 years with the Forest Service

Schroer, Greg Regional Wildlife Program Leader

(Extended Team (former) and coauthor: At-risk Wildlife section)

• M.S., Wildlife Science, Oregon State 

University

• B.S., Natural Resources Mgmt., 

Forestry, Colorado State University

• 6 years with the Forest Service, 2 years 

National Park, 18 years Private Sector

Sherlock, 

Joseph

Regional Silviculturist

(Extended Team: Forest Products)

• B.S., Forest Management

• Certified Silviculturist, 32 years

• 37 years with the Forest Service
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

668

Name Title and Contribution Education and Experience

Shibley, 

Penelope

District Planner (Project Record 

Management)

• B.A., Environmental Studies, UC Santa 

Cruz

• 6 years with the Forest Service

Slaton, Michele Inyo National Forest Acting Forest 

Botanist

(Extended Team and author: Atrisk Plants and Botany sections)

• Ph.D. and M.S., Botany, Univ. of 

Wyoming

• B.A., Biology, Reed College

• 14 years with the Forest Service, 3 

years with National Park Service

Smith, Francine Enterprise Program, Fisheries 

Biologist 

(Extended Team and coauthor: 

Aquatic Species)

• Graduate Studies in Fisheries 

• B.S., Entomology 

• 26 years with the Forest Service, 5 

years with the National Park Service

Stevens, Rick Regional Planner

(Planning Support)

(retired)

• 15 years with the Forest Service

• M.S. Fish and Wildlife Management, 

Montana State University

• B.S., Wildlife Biology, University of 

Montana

Stratton, Susan Regional Heritage Program 

Leader/Regional Archaeologist

(Extended Team and author: 

Cultural Resources section and 

SHPO consultation)

• Ph.D., Anthropology

• 2 years with the Forest Service 

• 8 years with the California Office of 

Historic Preservation

Striplin, Randy Ecologist (Detail)

(Core Team: Terrestrial 

Ecosystems)

• M.S., Biology/Certified Wildland Fire 

Ecologist

• 11 years with the Forest Service

Tapia, Judi Planning Staff Officer/Business 

Manager, Sierra National Forest

(Forest Planner)

• B.S., Biochemistry, UC Davis

• 7 years with the Forest Service 

• 9 years with the Bureau of Reclamation

Ulloa, Maria Natural Resources Planning Staff 

Officer, Sequoia National Forest

(Forest Planner)

(transferred)

• B.S., Agronomy and Soils, Washington 

State University, Pullman; Botany 

credentials California State University, 

Chico. 

• 24 years with the Forest Service

• 5 years with the Bureau of Land 

Management. 

Villanueva, 

Garrett

Regional Trail Program Manager, 

Public Services (Detail)

(Core Team and co-author: 

Recreation section)

• B.S., Geology

• 17 years with the Forest Service

Whitall, Debra Regional Social Scientist

(Core Team oversight)

• Ph.D., Pubic Administration and Policy, 

Portland State University

• B.S., Hydrology and Soil Science,

Humboldt State University

• 34 years with the Forest Service

Yasuda, Don Regional Analyst

(Co-lead for DEIS development)

• B.S., Wildlife and Fisheries Biology, 

University of California, Davis

• Certified Wildlife Biologist, 15 years

• 27 years with the Forest Service
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

669

Name Title and Contribution Education and Experience

York, Judy Writer-Editor • B.S., Wildlife Resources, University of 

Idaho

• M.S., Natural Resources 

Communications, University of Idaho

• 29 years with the Forest Service

Support to the Interdisciplinary Team

Review and input to the development of the draft revised plans and draft environmental impact 

statement were received from the staffs of the Inyo, Sequoia, and Sierra National Forests 

Supervisor’s Office and Ranger Districts, and the Pacific Southwest Regional Office. Additional 

Geographic Information System support was provided by staff on the three national forests, the 

Pacific Southwest Regional Office, and the Pacific Southwest Region Remote Sensing 

Laboratory. Many other staff and contractors have contributed support to the development of the 

proposed forest plans and the draft environmental impact statement and are not listed.

Inyo National Forest

Jaqueline Beidl, Forest Archaeologist and Tribal Liaison

Jennifer Ebert, Recreation Support

Sue Farley, Interagency Vegetation Management Team Leader/Acting Recreation Staff Officer

Jeff Novak, Wilderness Manager, White Mountain and Mount Whitney Ranger Districts

Richard Perloff, Wildlife Biologist, Mono Lake and Mammoth Ranger Districts

Diana Pietrasanta, Forest Recreation and Lands Staff Officer

Deb Schweizer, Forest Public Affairs Officer

Lisa Sims, Forest Rangeland Management Specialist

Dan Yarborough, GIS Coordinator 

Lesley Yen, Forest Planner

Pacific Southwest Region of the Forest Service

David Bakke, Pesticide-Use Specialist, Invasive Plants Program Manager

Danielle Chi, Regional Planner (temporary detail)

Arthur Duggan, Appeals and Litigation Analyst (transferred)

Thomas Flowe, GIS Analyst

Tom Frolli, Regional Range Program Manager

Joseph Furnish, Regional Aquatic Ecologist (retired)

MaryBeth Hennessy, Deputy Director, Ecosystem Planning

Laura Hierholzer, Regional Environmental Coordinator

Crispin Holland, Acting Regional Rangeland Program Manager (detailed)

Trini Juarez, Landscape Architect

Patti Krueger, Regional Threatened and Endangered Species Coordinator

Kathy Mick, Recreation Management Program Manager

Jules Riley, Hydrologist (detailed)
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

670

Rebecca Robinson, GIS Analyst

Dana Roth, Regional Planner

Sheri Smith, Regional Entomologist

Neil Sugihara, Regional Fire Ecologist

Denise Tolmie, Fire Management Specialist

Jamie Tripp, Regional Fuels Operation Specialist

Pacific Southwest Region, Remote Sensing Laboratory

Tanya Kohler, GIS Programmer and Analyst (contract)

Carlos Ramirez, Vegetation Mapping and Inventory Lead

Consultation and Coordination

The Forest Service consulted the following Tribes; Federal, State, and local agencies; groups; and 

individuals during development of this environmental impact statement. Tribes, agencies, and 

others who provided comments during the scoping period are indicated with an asterisk following 

their name.

Tribes and Tribal Organizations

The following Tribes and tribal organizations or associations were consulted: 

American Indian Council of Mariposa

Antelope Valley Indian Community

Benton Paiute Reservation Utu Utu Gwaitu 

Paiute Tribe

Big Pine Paiute Tribe of Owens Valley

Big Sandy Rancheria

Bishop Paiute Indian Tribal Council

Bridgeport Paiute Indian Colony

Chaushilha Yokuts

Cold Springs Rancheria

Council for the Interpretation of Native 

Peoples

Dumna Wo-Wah Tribal Government

Dunlap Band of Mono Indians

Ft. Independence Community of Paiute 

Indians

Haslett Basin Traditional Committee

Kawaiisu Tribal Council

Kern River Paiute Council

Kern Valley Indian Community

Kern Valley Indian Council

Kitanemuk & Yowlumne Tejon Indians

Lone Pine Paiute-Shoshone Reservation

Monache Inter-Tribal Association

Mono Lake Kutzadika’a Tribe

Mono Nation

North Fork Mono Tribe

North Fork Rancheria

Picayune Rancheria of Chukchansi Indians 

Sierra Mono Museum

Sierra Nevada Native American Coalition

Southern Sierra Miwuk Nation

Table Mountain Rancheria

Tachi-Yokuts- Santa Rosa

Tejon Indian Tribe

Timbisha Shoshone of Death Valley

Timbisha Shoshone Tribe (Bishop)

Tubatulabel Tribe of Kern Valley

Tule River Indian Tribe

Walker River Paiute Tribe

Washoe Tribe of Nevada and California

Wukchuni Tribal Council

Wuksachi Tribe

Yurok Tribe
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

671

Federal, State, County,

and Local Agencies and Organizations

Numerous Federal, State, county, and local agencies and organizations have been consulted in 

development of the revised plan and this environmental impact statement. Complete mailing lists 

for the scoping periods are available in the planning record. Some of the agencies consulted 

include:

Cooperating Agencies

In accordance with 36 CFR 1501.6, “any other Federal agency which has jurisdiction by law shall 

be a cooperating agency. In addition any other Federal agency which has special expertise with 

respect to any environmental issue, which should be addressed in the statement may be a 

cooperating agency upon request of the lead agency.” The U.S. Environmental Protection Agency 

is a cooperating agency. In accordance with 36 CFR 219.4(a)(1)(iv), “...Where appropriate, the 

responsible official shall encourage States, counties and other local governments to seek 

cooperating agency status in the NEPA process for development, amendment, or revision of a 

plan.” Inyo County is a cooperating agency, and contributed significantly to the economic data 

development and analysis in the plan, among other areas.

Federal Agencies and Representatives

The U.S. Environmental Protection Agency is a cooperating agency.

National Park Service, Death Valley 

National Park

National Park Service, Devils Postpile 

National Monument

National Park Service, Sequoia and Kings 

Canyon National Parks

National Park Service, Yosemite National 

Park

U.S. Army Corp of Engineers

U.S. Department of Transportation, Federal 

Highways Administration

USDA, Forest Service, Humboldt-Toiyabe 

National Forest

USDA, Natural Resource Conservation 

Service

USDA, Pacific Southwest Research Station

USDA, Pacific Southwest Research Station, 

Redwood Science Lab

USDI, Bureau of Land Management

USDI, Bureau of Reclamation

USDI, Office of Environmental Policy and 

Compliance

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

U.S. Geological Survey

U.S. Marine Corps, Mountain Warfare 

Training Center

U.S. Navy, China Lake Naval Air Warfare

Center

U.S. Navy, Naval Air Station Lemoore

U.S. Navy, Naval Facilities Engineering 

Command Southwest Division

U.S. Representative 4th District

U.S. Representative 8th District

U.S. Representative 20nd District

U.S. Representative 21nd District

U.S. Representative 22nd District

U.S. Representative 23rd District

U.S. Senator, Barbara Boxer

U.S. Senator, Dianne Feinstein
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

672

State Agencies

California Air Resources Board

California Department of Fish and Wildlife

California Department of Forestry and Fire 

Protection

California Department of Justice

California Department of Parks and 

Recreation, Office of Historic Preservation

California Department of Transportation

California Regional Water Quality Control 

Board

Lahontan Regional Water Quality Control 

Board

Nevada Department of Wildlife

Nevada Division of Environmental 

Protection

Nevada Division of Forestry

County Governments and Agencies

Inyo County is a cooperating agency for the Inyo National Forest.

California Assemblywoman 32nd District

California Assemblywoman 34th District

California Governor

California Senator 14th District

California Senator 16th District

California Senator 18th District

Fresno County Board of Supervisors

Fresno County Department of Public Works

Inyo County Agricultural Commissioner

Inyo County Board of Supervisors

Inyo County Planning Department

Inyo County Public Works Department

Inyo County Water Department

Esmeralda County Commissioners

Esmeralda County Road Department

Kern County Air Pollution Control District

Kern County Board of Supervisors

Kern County Board of Trade

Kern County Fire Department

Kern County Parks and Recreation

Kern County Planning Department

Madera County Board of Supervisors

Mariposa County Board of Supervisors

Mineral County Commissioners

Mineral County Public Works Department

Mono County Community Development

Mono County Environmental Health

Mono County Local Transportation 

Commission

Mono County Public Works Department

Tulare County Board of Supervisors

Tulare County Office of Education

Tulare County Parks & Recreation

Tulare County Planning Department

Tulare County Resource Management 

Agency

Tuolumne County Board of Supervisors

Local Agencies and Organizations

Apple Valley Town Hall

Bakersfield City Council

Bakersfield College Library

Bakersfield Convention and Visitors Bureau

Big Pine Community Services District

Carlton College, Gould Library

City of Bishop

City of Bishop, Chambers of Commerce

College of the Sequoias Library

CSU Bakersfield, Walter W. Stiern Library

CSU Fresno, Henry Madden Library

Eastern Sierra Transit Authority

Fresno City College Library

Fresno City Council
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

673

Fresno County Public Library

Independence - Chamber of Commerce

June Lake - Chambers of Commerce

June Lake Public Utility District

Kings River Conservation District

Kings River Water Association

Kern County Black Chamber of Commerce

Kern County Hispanic Chamber of 

Commerce

Kern County Library

Kern River Valley Chamber

Kern River Valley Council

Kern River Valley Fire Safe Council

Kern River Watermaster

Kings County Public Library

Lake Isabella Public Library

Lee Vining Public Utility District

Lone Pine - Chamber of Commerce

Los Angeles Department of Water and 

Power

Mammoth Community Water District

Mammoth Lakes Chamber of Commerce

Mammoth Lakes Fire Protection District

Merced County Public Library

Midland School

Mojave Desert-Mountain RC&D

Montana State University

Porterville City Library

Porterville City Planning Department

Porterville College Library

Reedley College

Ridgecrest Chamber of Commerce

Ridgecrest Public Library

Rolling Green Utilities

San Joaquin Valley Air Pollution Control 

District

Shafter-Wasco Irrigation District

Town of Mammoth Lakes

Town of Mammoth Lakes Public Works

Tulare County Library

Tulare Kings Hispanic Chamber of 

Commerce

University of Arizona

University of California, Berkeley

University of California, San Diego

University of California, Stanislaus

Visalia City Council

Others

Numerous groups and individuals participated in the process through written comments and by 

attending public meetings. Complete mailing lists are available in the public record. Some of the 

groups that provided comment include:

Alliance for Environmental Concerns

American Forest Resource Council

American Lands Access Association

American Whitewater

Back Country Horsemen

Bakersfield Californian

Bakersfield Trailblazers

Bakersfield Yamaha

Baymiller Family Trust

Blue Ribbon Coalition, Inc.

Brechbuehl Timber

The Bristlecone Chapter of the CNPS

Brown-Berry Biological Consulting

Californians for Alternative to Toxics

California Association of 4WD Clubs, Inc.

California Cattlemen’s Association

California Equestrian Trails Coalition

California Forestry Association

California Indian Basketweavers 

Association

California Institute of Technology, 

Combined Array for Research in Millimeterwave Astronomy (CARMA)
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

674

California Land Management

California Native Plant Society

California Off-Road Vehicle Association

California Trail Users Coalition

California Trout, Inc.

California Wilderness Coalition

CalWild

Camp Max Straus

Camp Nelson Mutual Water Company

Camp San Joaquin

Carver Bowen Ranch

Cedarbrook Cabin Owners

Center for Biological Diversity

Church of Jesus Christ of Latter Day Saints

Concerned Citizens – Piutes

Cyrus Partners

D&B Partnership

The Daily Independent

David Wood Ranches

Dinuba Centinel

Dowville Tract Association

Dunn School

Eagle Rafting

Eastern Sierra Audubon Society

Eastern Sierra Interpretive Association

Eastern Sierra Recreation Collaborative

Equestrian Trails and Lands

Eshom-Kaweah Ranch

Evergreen Helicopter, Inc.

Far Horizons, Inc.

Fresno Bee

Friends of the Inyo

Geos Institute

Giant Sequoia National Monument Assn

Guest Services, Inc.

Hafenfeld Ranch

High Desert Multi Coalition

High Sierra Guide Service

HMS Veterinary Development, Inc.

Hume Lake Christian Camps

Huntington Lake Association

Inland Valley Mountain Bike Association

International Mountain Bicycling 

Association

John Muir Project

Kern River Courier

Kern River Revitalization

Kern River Tours

Kerncrest Audubon

Kiper & Kiper

Klamath Forest Alliance

KMPH TV Channel 26

Lake Isabella-Bodfish Property Owners 

Assn

Mammoth Lakes Recreation

Mammoth Mountain Ski Area, LLC

Mammoth Times

McGee Creek Pack Station

Mammoth Lakes Trails and Public Access 

Foundation

Mike Berry Guide Service

Mono Hot Springs Resort

Mono Lake Committee

National Forest Recreation Association

Natural Resources Defense Council

News Review (Ridgecrest)

North American Packgoat Association

Northern California Society of American 

Foresters

OA Outfitting Inc., KR Outfitter

Off Road Vehicle Watch

Outdoor Alliance

Pacific Crest Trail Association

Pacific Crest Trail Reassessment Initiative

Pacific Gas and Electric

Pacific Rivers Council

Particle Media Group

Pecks Camp

Ponderosa Lodge

Ponderosa Property Owners
Chapter 4. Preparers, Consultation, and Coordination

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

675

Q.A.B. Media

Quaker Meadow Ministries

Recreational Aviation Foundation

R.M. Pyles Boys Camp

Roger Camp Homeowners Association

Sageland Ranch

San Joaquin Houndsmen Club

San Joaquin River Trails Council

Santiago Outfitter Fishing

Sequoia Crest

Sequoia Forest Alliance

Sequoia Forest Keeper

Sequoia Lake Conference of YMCA

Sequoia Snowmobilers

Sierra Club

Sierra Forest Legacy

Sierra Forest Products

Sierra Reader

Snowlands Network

Southern California Edison

Southern Mono Historical Society

Southern Sierra Fat Tire Association

Spanish Radio Group

Stewards of the Sequoia

Stewards of the Sierra

Sugarloaf Community Group

Sugarloaf Mountain Park

Sustainable Forest Action Coalition

Tehachapi Mountain Trails Association

Track and Trail Publications

Trout Unlimited

Tulare County Audubon Society

Tulare County Sportsman

United Church of God

United Trail Maintainers of California

Upper Tule Association, Inc.

Upper Tule News

Visalia Times Delta

West Coast Development Co.

Western Watersheds Project

White Mountain Research Center

Whitewater Voyages

WildEarth Guardians

The Wilderness Society

Winter Wildlands Alliance

W.M. Beaty & Associates, Inc.

Agencies, Organizations, and Persons Sent

Copies of the Final Environmental Impact Statement

This environmental impact statement has been distributed to, or made electronically available to, 

over 3,300 individuals and groups who specifically requested a copy of the document or 

commented during public involvement opportunities. In addition, copies have been sent (or in 

some cases made electronically available) to Federal agencies, federally recognized Tribes, State 

and local governments, and organizations that have requested to be involved in the development 

of this analysis. Some of these entities include the U.S. Environmental Protection Agency; U.S. 

Department of the Interior; Advisory Council on Historic Preservation; USDA National 

Agricultural Library; State wildlife and fisheries management agencies; Tribes; county 

supervisors; and local community governments. Due to the number of people, agencies, and 

organizations, a complete listing has been omitted from this environmental impact statement, but 

is available upon request.

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

677

Glossary

Active management: Planned, intentional actions in an area that are specifically designed to obtain or 

move toward a desired objective or result. 

Adaptive management: An approach to natural resource management in which decisions are made as 

part of an ongoing process. Adaptive management involves planning, implementing, monitoring, evaluating, 

and incorporating new knowledge into management approaches based on scientific findings and the needs 

of society. Effects are monitored for the purpose of learning and adjusting future management actions, which 

improves the efficiency and responsiveness of management.

Administrative site: Areas such as work centers, fire lookouts, permitted ranch headquarters, seed 

orchards, communication sites, utility corridors, developed campgrounds, and other areas that are occupied 

or used by the Forest Service during the administration of work associated with national forest lands. 

Administrative use: Use by the Forest Service.

Allowable sale quantity (ASQ): The quantity of timber that may be sold from the area of suitable land 

covered by the land management plan for a time period specified by the plan. This allowable sale quantity 

(ASQ) is usually expressed on an annual basis as the “average annual allowable sale quantity.” For timber 

resource planning purposes, the allowable sale quantity applies to each decade over the planning horizon 

and includes only chargeable volume. Consistent with the definition of timber production, ASQ does not 

include firewood or other nonindustrial wood in the allowable sale quantity.

Aspen clone: A genetically identical set of aspen trees all connected by the same root system, as in 

vegetative reproduction. A clone is a distinct aspen stand, or it may be a smaller inclusion within a conifer 

stand, or it may cover an entire mountainside as a large stand or patch.

Available forage: That amount of growth of a vigorous and healthy plant that can be utilized as feed 

(regardless of what animal is using it) without impairing the plant’s long-term health and productivity or other 

uses such as riparian filtering. The amount of available forage may be less where there is a need to restore 

health and vigor of forage plants. That amount may also depend on time of year and plant physiological 

stage, or other conditions such as drought.

Basal area: The common term used to describe the average amount of an area (usually an acre) occupied 

by tree stems. It is defined as the total cross-sectional area of all stems in a stand measured at breast 

height, and expressed as per unit of land area (typically square feet per acre).

Beneficial use: Any of the various uses which may be made of the water, including, but not limited to, 

domestic water supplies, fisheries and other aquatic life, industrial water supplies, agricultural water 

supplies, navigation, recreation in and on the water, wildlife habitat, and aesthetics.

Best management practices (BMPs) for water quality: Methods, measures or practices selected by an

agency to meet its nonpoint source control needs. Best management practices for water quality include but 

are not limited to structural and nonstructural controls and operation and maintenance procedures. Best 

management practices for water quality can be applied before, during, and after pollution-producing 

activities to reduce or eliminate the introduction of pollutants into receiving waters (36 CFR 219.19).

Biocultural diversity: In this document, the diversity of plants, animals, insects, fungi and other natural and 

cultural resources found across the landscape that provide for the diversity of cultural and traditional uses, 

knowledge systems and practices of Native American Tribes.

California spotted owl protected activity center (PAC): An area established around an occupied 

California spotted owl site to help ensure successful reproduction and species viability. A protected activity 

center is approximately 300 acres in size and includes the best owl nesting and roosting habitat. 

Management in protected activity centers is limited except in the community wildfire protection zone where it 

is focused on reduction of surface and ladder fuels and includes retention of key habitat elements such as 

higher levels of basal area and canopy cover to provide the cool understory conditions owls need, and the 

down woody debris and forage (cover, fungi, seeds) needed by their prey. Management may involve limited 

thinning and/or burning to reduce the risk of high-intensity wildfire, often with timing restrictions to prevent 

disturbance to owls during the breeding season.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

678

Candidate species: Candidate species are plants and animals for which the U.S. Fish and Wildlife Service 

has sufficient information on their biological status and threats to propose them as endangered or 

threatened under the Endangered Species Act, but for which development of a proposed listing regulation is 

precluded by other higher priority listing activities. 

Canopy: In a forest, the branches from the uppermost layer of trees; on rangeland, the vertical projection 

downward of the aerial portion of vegetation. 

Canopy closure: The percentage of the sky hemisphere obscured by vegetation when viewed from a 

single point.

Canopy cover: The proportion of the forest floor covered by the vertical projection of the tree crowns 

(Jennings et al. 1999).

Cavity: The hollow excavated in a tree that is used by birds or mammals for roosting and/or reproduction.

CCF: Hundred cubic feet.

Class I airshed: An airshed classification where areas require the highest level of protection under the 

Clean Air Act of 1963.

Class II airshed: An airshed classification representing National Forest System land that is not classified as 

a Class I airshed. These areas may receive a greater amount of human-caused pollution than Class I areas.

Climate refugia: Locations where taxa survive periods of regionally adverse climate; locations that provide 

habitats for the long-term persistence of populations. These areas are relatively more buffered against 

climate change and climate-related disturbances than others. These refugia have resisted climate changes 

occurring elsewhere, often providing suitable habitat for relict populations of species that were previously 

more widespread.

Clump: A tight cluster of two or more trees that are generally of similar age and size, have adjacent or 

interlocking crowns, and share a common rooting zone. 

Code of Federal Regulations (CFR): A codification of the general and permanent rules published in the 

Federal Register (FR) by the executive departments and agencies of the Federal Government.

Complex early seral forests or habitat: Complex early seral habitat is a type of early successional forest 

habitat that develops following a stand-replacing event (e.g., high severity fire) and contains structural, 

compositional, or functional elements of ecological complexity or integrity. These elements may include 

biological legacies such as large snags, logs, and isolated live trees or tree clumps, as well as patches of 

young and diverse native shrubs, hardwoods, herbaceous plants, or tree regeneration. Other characteristic 

elements of complexity in early seral forests may include spatial heterogeneity in vegetation structure, 

diversity in vegetation composition, and variability in functional processes (e.g., nutrient cycling) during postdisturbance recovery.

Critical habitat: For a threatened or endangered species is: (1) the specific areas within the geographical 

area occupied by the species, at the time it is listed and in accordance with the provisions of section 4 of the 

Endangered Species Act (16 U.S.C. 1533), on which are found those physical or biological features (a) 

essential to the conservation of the species, and (b) which may require special management considerations 

or protections; and (2) specific areas outside the geographical area occupied by the species at the time it is 

listed in accordance with the provisions of section 4 of the Endangered Species Act, upon a determination 

by the Secretary that such areas are essential for the conservation of the species (16 U.S.C. 1532 (3)(5)(A)). 

Critical habitat is designated through rulemaking by the Secretary of the Interior or Commerce (16 

U.S.C.1533 (a)(3) and (b)(2)).

Coarse woody debris: Woody material, including logs, on the ground greater than 3 inches in diameter—a 

component of litter. Large coarse woody debris is often considered to be downed logs at least 12 inches in 

diameter and 8 feet in length.

Communications site: An area of National Forest System land used for telecommunications services. A 

communications site may be limited to a single communications facility, but most often encompasses more 

than one facility. 

Community wildfire protection plans (CWPP): Plans for at-risk communities that identify and prioritize 

areas for hazardous fuels treatments. Several communities adjacent to the Inyo National Forest have 

developed these plans.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

679

Connectivity: The ecological conditions that exist at several spatial and temporal scales to provide 

landscape linkages, including to: permit the exchange of flow, sediments, and nutrients; the daily and 

seasonal movements of animals within home ranges; the dispersal and genetic interchange between 

populations; and the long distance range shifts of species, such as in response to climate change.

Conservation Agreement or Conservation Strategy: Plans to remove or reduce threats to candidate and 

sensitive species of plants and animals so that a listing as threatened or endangered is unnecessary.

Consultation: (1) An active, affirmative process that (a) identifies issues and seeks input from appropriate 

American Indian governments, community groups, and individuals; and (b) considers their interests as a 

necessary and integral part of the Forest Service’s decision-making process; 

(2) the Federal government has a legal obligation to consult with American Indian Tribes. This legal 

obligation is based in such laws as the Native American Graves Protection and Repatriation Act, the 

American Indian Religious Freedom Act, and numerous other executive orders and statutes. This legal 

responsibility is, through consultation, to consider Indian interests and account for those interests in the 

decision; 

(3) the term also refers to a requirement under section 7 of the Endangered Species Act (ESA) for Federal 

agencies to consult with the U.S. Fish and Wildlife Service with regard to Federal actions that may affect 

listed threatened and endangered species or critical habitat.

Cumulative effects or impacts: Cumulative effects or impacts are the impacts on the environment that 

results from the incremental impact of the action when added to other past, present, and reasonably 

foreseeable future actions, regardless of what agency (Federal or nonfederal) or person undertakes such 

actions. Cumulative impacts can result from individually minor but collectively significant actions taking place 

over a period of time. Effects and impact are synonymous (40 CFR 1508.7).

Desired condition: A desired condition is a description of specific social, economic, and/or ecological 

characteristics if the plan area, or a portion of the plan area, toward which management of the land and 

resources should be directed. This description is specific enough to allow progress toward achievement to 

be determined but does not include a completion date.

Developed recreation site: A distinctly defined area where facilities are provided by the Forest Service for 

concentrated public use (campgrounds, picnic areas, and swimming areas).

Diameter at breast height (d.b.h.): The diameter of a forest tree species at the bole (or trunk) typically 

measured at 4.5 feet above ground level.

Dispersed recreation: Outdoor recreation in which visitors are spread over relatively large areas. Where 

facilities or developments are provided, they are more for access and protection of the environment than for 

the comfort or convenience of the visitors.

Ecological integrity: The quality or condition of an ecosystem when its dominant ecological characteristics 

(such as composition, structure, function, connectivity, and species composition and diversity) occur within 

the natural range of variation and can withstand and recover from most perturbations imposed by natural 

environmental dynamics or human influence.

Ecological restoration: The process of assisting the recovery of an ecosystem that has been degraded, 

damaged, or destroyed. Ecological restoration focuses on reestablishing the composition, structure, pattern, 

and ecological processes necessary to facilitate terrestrial and aquatic ecosystem sustainability, resilience, 

and health under current and future condition.

Ecoregion: Ecoregion sections and subsections are units in the National Hierarchy of Ecological Units 

ranging in size from 13 million acres (section) down to 10,000 acres (subsection) that describe areas of 

similar environmental and biological features. 
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

680

Ecosystem: A spatially explicit, relatively homogeneous unit of the Earth that includes all interacting 

organisms and elements of the abiotic environment within its boundaries. An ecosystem is commonly 

described in terms of its: (1) composition or the biological elements within the different levels of biological 

organization, from genes and species to communities and ecosystems; (2) structure or the organization and 

physical arrangement of biological elements such as, snags and down woody debris, vertical and horizontal 

distribution of vegetation, stream habitat complexity, landscape pattern and connectivity; (3) function or the 

ecological processes that sustain composition and structure, such as energy flow, nutrient cycling and 

retention, soil development and retention, predation and herbivory, and natural disturbances such as wind, 

fire and floods; and (4) connectivity.

Ecosystem diversity: The variety and relative extent of ecosystem types, including their composition, 

structure, and processes within all or a part of an area of analysis. 

Ecosystem management: The use of an ecological approach to achieve multiple-use management of 

public lands by blending the needs of people and environmental values in such a way that lands represent 

diverse, healthy, productive, and sustainable ecosystems. 

Ecosystem function (processes): The collective biotic processes of ecosystems and their effects on the 

physical and chemical conditions of their environment. These processes include nutrient cycling, plant 

primary production, decomposition, biotic interactions (such as food web interactions), carbon storage, 

hydrologic cycles, and soil respiration.

Ecosystem services: Benefits people obtain from ecosystems: (1) provisioning services, such as clean air 

and fresh water, energy, food, fuel, forage, wood products or fiber, and minerals; (2) regulating services, 

such as long-term storage of carbon; climate regulation; water filtration, purification, and storage; soil 

stabilization; flood and drought control; and disease regulation; (3) supporting services, such as pollination, 

seed dispersal, soil formation and nutrient cycling; and (4) cultural services, such as educational, aesthetic, 

spiritual, and cultural heritage values, recreational experiences, and tourism opportunities.

Ecosystem sustainability: The capacity of ecosystems to maintain ecological integrity, including 

ecosystem diversity, productivity, health, and resilience to stressors.

Eligible wild and scenic rivers: River segments that have been identified as eligible for inclusion in the 

national Wild and Scenic Rivers System under the authority of the Wild and Scenic Rivers Act. The river 

segment must be free-flowing and it must possess one or more outstandingly remarkable scenic, 

recreational, geological, fish and wildlife, historical, cultural, ecological or other value. See wild and scenic 

rivers.

Endangered species: Species that the Secretary of the Interior or the Secretary of Commerce has 

determined is in danger of extinction throughout all or a significant portion of its range. Endangered species 

are listed at 50 CFR sections 17.11, 17.12, and 224.101.

Endemic: Species or population that is limited in distribution to a specific geographic area.

Energy corridor: A linear strip of land identified for the present or future location of utility right-of-way (such 

as above or belowground electric transmission line, gas pipeline).

Energy development: Infrastructure associated with the provision or transport of energy (biomass power 

generation, wind turbines, and solar panels).

Environmental impact statement (EIS): A statement of the environmental effects of a proposed action and 

alternatives to it. It is required for major Federal actions under section 102 of the National Environmental 

Policy Act (NEPA), and released to the public and other agencies for comment and review. A draft EIS is 

released to the public and other agencies for review and comment. A final EIS is issued after consideration 

of public comments. A record of decision is based on the information and analysis in the final EIS.

Environmental justice: 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.

Evapotranspiration: Loss of water from the earth’s surface through evaporation from the soil and surface

waterbodies and transpiration by plants.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

681

Federal reserved water rights (reserved rights): When Congress designates Federal lands for a specific 

purpose it also reserves sufficient water to serve the purposes of that designation. These water rights are 

known as “Federal reserved water rights” or simply, reserved rights. Reserved rights are implied rights, 

meaning that Congress need not expressly state in a bill that it intends to reserve Federal water right. The 

right exists whether or not Congress explicitly mentions it.

Federally listed species: Threatened or endangered species listed under the Endangered Species Act, as 

amended. Candidate and proposed species are species which are being considered for Federal listing.

Fire intensity: The degree of energy and heat released from a fire.

Fire Management includes the entire scope of activities from planning, prevention, fuels or vegetation 

modification, prescribed fire, hazard mitigation, fire response, rehabilitation, monitoring and evaluation to 

meet land management objectives. 

Fire regime: The long-term fire pattern characteristic of an ecosystem described as a combination of 

seasonality, fire return interval (length of time between fires), size, spatial complexity, intensity, severity, and 

fire type (e.g., surface fire, active crown fire). There are five fire regimes which are classified based on the 

fire return interval or frequency (average number of years between fires) and severity (amount of 

replacement of the dominant overstory vegetation) of the fire. These five regimes are:

• Fire regime I: 0- to 35-year frequency and low (surface fires most common, isolated torching can 

occur) to mixed severity (less than 75 percent of dominant overstory vegetation replaced)

• Fire regime II: 0- to 35-year frequency and high severity (greater than 75 percent of dominant 

overstory vegetation replaced)

• Fire regime III: 35- to 100+-year frequency and mixed severity

• Fire regime IV: 35- to 100+-year frequency and high severity

• Fire regime V: 200+-year frequency and high severity.

Fire regime condition class: A classification of the degree of departure from the natural fire regime. The 

fire regime condition class classification is based on a relative measure describing the degree of departure 

from the historical natural fire regime. This departure can result in changes (or risks) to one, or more, of the 

following ecological components: vegetation (species composition, structural stages, stand age, canopy 

cover, and mosaic pattern across the landscape); fuel composition; fire frequency, severity, and pattern; and 

other associated disturbances. 

Condition class 1: Fire regimes are within the natural (historical) range, and the risk of losing key 

ecosystem components is low. Vegetation attributes (species composition, structure, and pattern) are intact 

and functioning within the natural (historical) range. 

Condition class 2: Fire regimes have been moderately altered from their natural (historical) range. Risk of 

losing key ecosystem components is moderate. Fire frequencies have departed from natural frequencies by 

one or more return intervals (either increased or decreased). This result in moderate changes to one or 

more of the following: fire size, intensity and severity, and landscape patterns. Vegetation and fuel attributes 

have been moderately altered from their natural (historical) range. 

Condition class 3: Fire regimes have been substantially altered from their natural (historical) range. The 

risk of losing key ecosystem components is high. Fire frequencies have departed from natural frequencies 

by multiple return intervals. Dramatic changes occur to one or more of the following: fire size, intensity, 

severity, and landscape patterns. Vegetation attributes have been substantially altered from their natural 

(historical) range.

Fire restoration refers to the use of fire as a tool for restoration or the restoration of fire to the landscape 

within the historic fire return interval for the associated ecosystem. 

Fire severity: Degree to which an ecosystem has been altered or disrupted by fire; also used to describe 

the product of fire intensity and residence time; commonly applied to vegetation or soils but may include 

other ecosystem components such as watersheds and wildlife. In this document, fire severity refers to 

vegetation burn severity unless otherwise specified.

Foliar: Pertaining to foliage (green tree leaves or needles).

Forest Service Handbook (FSH): Directives that provide detailed instructions on how to proceed with a 

specialized phase of a program or activity. 
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

682

Forest Service Manual (FSM): A system of manuals that provides direction for Forest Service activities.

Fragmentation: The break-up of a large continuous land area by reducing and dividing into smaller patches 

isolated by areas converted to a different land type. Habitat can be fragmented by natural events or 

development activities. It is the opposite of connectivity.

Free-flowing: Water existing or flowing in natural conditions without impoundment, diversion, straightening, 

rip-rapping, or other modification of the waterway.

Fuel: Plants, both living and dead, and associated woody vegetative materials capable of burning. 

Fuel load: The dry weight of combustible materials per unit area; usually expressed as tons per acre. 

Fuels Management is the act or practice of controlling flammability and reducing resistance to control of 

wildland fuels through mechanical, chemical, biological, or manual means, or by fire, in support of land 

management objectives.

Fuel treatment: Any manipulation or removal of fuels to reduce the likelihood of ignition or to lessen 

potential damage and resistance to control.

Fuels reduction refers to the different tools used for treatments including fire, mechanical, or hand 

treatments to reduce fuels. 

Fugitive dust: Fine particulate matter from windblown soil and dust which becomes airborne.

Geographic Information System (GIS): An information processing technology to input, store, manipulate, 

analyze, and display data; a system of computer maps with corresponding site-specific information that can 

be combined electronically to provide reports and maps.

Geomorphic: Refers to the process of erosion and sediment transport and deposition.

Global climate models (GCMs): Climate models are a mathematical representation of the climate. These

models divide the earth, ocean and atmosphere into a grid. The values of the predicted variables, such as 

surface pressure, wind, temperature, humidity and rainfall are calculated at each grid point over time, to 

predict their future values. The GCMs used in the Fire-Climate section examined the expected change in 

large fire size with different future climate and vegetation restoration scenarios, and are defined below:

• CCSM: Community Climate system Model

• GFDL: Geophysical Fluids Dynamic Laboratory

• CNRM: Centre National de Recherches Météorologiques

Government-to-Government Consultation: The active and continuous process of contacting tribal 

leadership, soliciting their participation, involvement, comments, concerns, contributions, and traditional 

knowledge that will assist the agency in making informed decisions in planning, managing and decisionmaking actions.

Guideline: A guideline is a constraint on project and activity decisionmaking that allows for departure from 

its terms, so long as the purpose of the guideline is met. (§ 219.15(d)(3)). Guidelines are established to help 

achieve or maintain a desired condition or conditions, to avoid or mitigate undesirable effects, or to meet 

applicable legal requirements.

Habitat: A place that provides seasonal or year-round food, water, shelter, and other environmental 

conditions for an organism, community, or population of plants or animals.

Hazard Tree Removal: The abatement of tree hazards, generally near roads, trails and facilities. Tree 

hazards include dead or dying trees, dead parts of live trees, or unstable live trees (due to structural defects 

or other factors) that are within striking distance of people or property (a target). Hazard trees have the 

potential to cause property damage, personal injury or fatality in the event of a failure.

Herbaceous: Plants lacking aboveground woody stems including grasses and forbs.

Herbivory: Loss of vegetation due to consumption by another organism.

Historic range of variation: See Natural Range of Variation.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

683

Home range core area (HRCA): Areas established surrounding each territorial California spotted owl 

activity center detected after 1986. The core area amounts to 20 percent of the area described by the sum of 

the average breeding pair home range plus one standard error. For the Sierra National Forest, the home 

range core area size is 600 acres. Aerial photography is used to delineate the core area. Acreage for the 

entire core area is identified on national forest lands. Core areas encompass the best available California 

spotted owl habitat in the closest proximity to the owl activity center. The acreage in the 300-acre protected 

activity center counts toward the total home range core area. Core areas are delineated within 1.5 miles of 

the activity center. When activities are planned adjacent to non-national forest lands, 1.5-mile-circular core 

areas are delineated around California spotted owl activity centers on non-national forest lands. Using the 

best available habitat as described above, any part of the circular core area that lies on national forest lands 

is designated and managed as a California spotted owl home range core area.

Hydrologic: Refers to the movement, distribution, and quality of water.

Hydrologic function: The behavioral characteristics of a watershed described in terms of ability to sustain 

favorable conditions of waterflow. Favorable conditions of waterflow are defined in terms of water quality, 

quantity, and timing.

Hydrologic Unit Code (HUC): The U.S. is divided and subdivided into successively smaller hydrologic units 

(watersheds), which are identified by unique hydrologic unit codes (HUCs). The average size of a 4th level 

HUC watershed is 1 million acres, 5th level HUC watersheds are around 165,000 acres, and 6th level HUC 

watersheds are about 21,000 acres.

Hydrophytic vegetation: The sum total of macrophytic plant life that occurs in areas where the frequency 

and duration of inundation or soil saturation produce permanently or periodically saturated soils of sufficient 

duration to exert a controlling influence on the plant species present.

Instream flow: Seasonal stream flows needed for maintaining aquatic and riparian ecosystems, wildlife, 

fisheries, and recreation opportunities at an acceptable level.

Invasive species: Are alien species whose introduction does or is likely to cause economic or 

environmental harm or harm to human health; species that cause, or is likely to cause harm and that is 

exotic to the ecosystem it has infested. Invasive species infest both aquatic and terrestrial areas and can be 

identified within any of the following four taxonomic categories: plants, vertebrates, invertebrates, and 

pathogens.

LANDFIRE: (Landscape Fire and Resource Management Planning Tools Project) is an interagency 

Program producing consistent and comprehensive data describing landscape change, disturbance, 

vegetation, fuel, and fire regimes across the United States.

Leasable minerals: Leasable minerals include coal, oil, gas, oil shale, sodium, phosphate, potassium, and 

geothermal. Leasable minerals also include the hardrock minerals, if they are found on lands that have 

“acquired” status. Leases are obtained through the Bureau of Land Management to extract these mineral 

resources.

Litter: Litter consists of dead, unattached organic material on the soil surface that is effective in protecting 

the soil surface from raindrop splash, sheet, and rill erosion and is at least 1⁄2 inch thick. Litter is composed of 

leaves, needles, cones, and woody vegetative debris including twigs, branches, and trunks.

Livestock grazing: Foraging by permitted livestock (domestic foraging animals of any kind).

Locatable minerals: In general, the hardrock minerals mined and processed for metals (gold, silver, 

copper, uranium, and some types of nonmetallic minerals such as sandstone). They are called “locatable,” 

meaning subject to mining claim location under the United States mining laws. Locatable minerals are 

limited to lands with “reserved public domain” status.

Low-income population: Any readily identifiable group of low-income persons who live in geographic 

proximity to, and, if circumstances warrant, migrant farm workers and other geographically 

dispersed/transient persons who would be similarly affected by USDA programs or activities. Low-income 

populations may be identified using data collected, maintained and analyzed by an agency or from analytical 

tools such as the annual statistical poverty thresholds from the Bureau of the Census’ Current Population 

Reports, Series P-60 on Income and Poverty.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

684

Management practices (vegetation management practices): Silvicultural practices such as reforestation, 

prescribed fire, thinning to reduce stand density, and other practices designed to facilitate growth and 

development of trees.

Managing wildfires to meet resource objectives: A strategic choice to use unplanned wildfire starts to 

achieve resource management objectives and ecological purposes under specific environmental conditions. 

Such fires are monitored closely to ensure safe conditions for people, property, and other highly valued 

resources.

Meadows are classified based on multiple environmental factors that include: hydrology, vegetation, soil 

characteristics, geomorphology, physiography, altitude, and range type. Meadows are broadly defined as 

groundwater-dependent ecosystems composed of one or more herbaceous plant communities, where 

woody vegetation is often present, but not dominant. Meadows in the plan area include wetland areas; 

however, not all meadows are wetlands. Meadows fall along a hydrologic gradient of wet to dry. Peatlands 

are at the wettest end of this hydrologic spectrum, occurring primarily as fens in the plan area. Dry meadows 

occur in the most arid topographic positions and are primarily precipitation-dependent. In general, wet 

meadows tend to have lower amounts of bare soil compared to dry meadows that have a wider spacing of 

vegetation and more exposed soil.

Mechanical treatment: For the purposes of this analysis, mechanical treatments include most vegetation 

treatments except fire. They may include mechanical thinning, hand thinning, and other silvicultural 

treatments.

Mechanized travel/transport: Movement using any contrivance over land, water, or air, having moving 

parts, that provides a mechanical advantage to the user and that is powered by a living or nonliving power 

source. This includes, but is not limited to, sailboats, hang gliders, parachutes, bicycles, game carriers, 

carts, and wagons. It does not include wheelchairs when used as necessary medical appliances. It does not 

include skis, snowshoes, rafts, canoes, sleds, travois, or similar primitive devices without moving parts.

Minority: A person who is a member of one or more the following population groups: American Indian or 

Alaskan Native, Asian or Pacific Islander, Black, or Hispanic.

Minority population: Any readily identifiable group of minority persons who live in geographic proximity to, 

and, if circumstances warrant, migrant farm workers and other geographically dispersed/transient persons 

who would be similarly affected by USDA programs or activities.

Motorized travel: Movement using machines that use a motor, engine, or other nonliving power sources 

other than a vehicle operated on rails or a wheelchair or mobility device, including one that is battery 

powered, designed solely for the use by a mobility-impaired person for locomotion, and that is suitable for 

use in an indoor pedestrian area.

National Forest System (NFS): Includes national forests, national grasslands, and the National Tallgrass 

Prairie.

National Forest System road: A road wholly or partly within or adjacent to and serving the National Forest 

System that the Forest Service determines is necessary for the protection, administration, and utilization of 

the National Forest System and the use and development of its resources. A forest road other than a road 

which has been authorized by a legally documented right-of-way held by a state, county, or other local public 

road authority. (36 CFR 212.1)

National Forest System trail: A trail wholly or partly within or adjacent to and serving the National Forest 

System that the Forest Service determines is necessary for the protection, administration, and utilization of 

the National Forest System and the use and development of its resources A forest trail other than a trail 

which has been authorized by a legally documented right- of-way held by a state, county, or other local 

public road authority. (36 CFR 212.1)

National Wild and Scenic Rivers System: It was created by Congress in 1968 (Public Law 90-542; 16 

U.S.C. 1271 et seq.) to preserve certain rivers with outstanding natural, cultural, and recreational values in a 

free-flowing condition for the enjoyment of present and future generations.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

685

Natural Range of Variation (NRV): Spatial and temporal variation in ecosystem characteristics under 

historic disturbance regimes during a reference period. The reference period considered should be 

sufficiently long to include the full range of variation produced by the dominant natural disturbance regimes, 

often several centuries, for such disturbances as fire and flooding, and should also include short-term 

variation and cycles in climate. NRV is a term used synonymously with the historic range of variation. The 

NRV is a tool for assessing ecological integrity, and does not necessarily constitute a management target or 

desired condition. The NRV can help identify structural, functional, compositional, and connectivity 

characteristics, for which plan components may be important for either maintenance or restoration of such 

ecological conditions.

Nonmotorized travel: Movement not relying on machines that use a motor, engine, or other nonliving 

power source (walking, canoeing, and horseback riding).

Nonpoint source pollution: Refers to water pollution affecting water quality from diffuse sources, such as 

polluted runoff from agricultural areas draining into lakes, wetlands, rivers, and streams. Nonpoint source 

pollution can be contrasted with point source pollution, where discharges occur to a body of water at a single 

location, such as discharges from a chemical factory, urban runoff from a roadway or storm drain. Nonpoint 

source pollution may derive from many different sources with no specific solution to rectify the problem, 

making it difficult to regulate.

Objective: An objective is a concise, measurable, and time-specific statement of a desired rate of progress 

toward a desired condition or conditions. Objectives are based on reasonable foreseeable budgets.

Old forest: Old forests are characterized by the presence of large and old trees in the Sierra Nevada 

montane zone. Old forests vary widely based on forest type, soil type, topography, and fire history. Tree size 

is not necessarily related to tree age. Old forests often contain large snags and logs in addition to large live 

trees. The density and other structural features of these old forests vary widely.

Outstandingly remarkable value: A value that a river or river segment possesses that reflects its unique, 

rare, or exemplary qualities. In the Wild and Scenic River Act, river values identified include scenic, 

recreational, geologic, fish and wildlife, historic, cultural, or other similar values. Examples of other similar 

values include botanical, hydrological, paleontological, scientific, or heritage. A river must have at least one 

outstandingly remarkable value to be eligible for wild and scenic river designation.

Protected Activity Center: The areas that surround nest areas. They represent an area of habitat used for 

nesting and raising young until the time of leaving the nest. 

Patch: Refers to a relatively homogeneous area that differs from its surroundings. Patches are the basic unit 

of the landscape that change and fluctuate. Patches have a definite shape and spatial configuration, and 

can be described compositionally by internal variables such as number of trees, number of tree species, age 

of trees, height of vegetation, or other similar measurements.

Planned ignition: A fire ignited by management actions under certain predetermined conditions to meet 

plan desired conditions. Prescribed fire is a synonymous term.

Planning period: The life of the plan, generally 10 to 15 years from plan approval. As a general rule, this 

analysis uses 10 years to define the planning period.

Primitive recreation: The reliance on personal, nonmotorized, or nonmechanized skills to travel and camp 

in an area, rather than reliance on facilities or outside help.

Recreation opportunity spectrum (ROS): Recreation settings allow a range of experiences to be 

achieved, from remote and challenging to easily navigated and supported by tourism services in surrounding 

communities. The recreation opportunity spectrum has six distinct classes in a continuum to describe 

settings that provide this range of experience, from highly modified and developed settings to primitive and 

undeveloped settings. The classes are:

Primitive (P): Characterized by essentially unmodified natural environment. Interaction between users is 

very low and evidence of other users is minimal. Essentially free from evidence of human-induced 

restrictions and controls. Motorized use within the area is generally not permitted. Very high probability of 

experiencing solitude, closeness to nature, tranquility, self-reliance, and risk.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

686

Semiprimitive Nonmotorized (SPNM): Characterized by a predominantly natural or natural-appearing 

environment. Interaction between users is low, but there is often evidence of other users. The area is 

managed in such a way that minimum onsite controls and restrictions may be present, but are subtle. 

Motorized use is generally not permitted. High probability of experiencing solitude, closeness to nature, 

tranquility, self-reliance, and risk.

Semiprimitive Motorized (SPM): Characterized by a predominantly natural or natural- appearing 

environment. Concentration of users is low, but there is often evidence of other users. The area is managed 

in such a way that minimum on site controls and restrictions may be present, but are subtle. Motorized use 

is generally permitted. Moderate probability of experiencing solitude, closeness to nature, tranquility, selfreliance, and risk.

Roaded Natural (RN): Characterized by a predominantly natural-appearing environment with moderate 

evidence of the sights and sounds of other humans. Such evidences usually harmonize with the natural 

environment. Interaction between users may be low to moderate but with evidence of other users prevalent. 

Resource modification and utilization practices are evident but harmonize with the natural environment. 

Conventional motorized use is provided for in construction standards and design of facilities. Opportunity to 

affiliate with other users in developed sites but with some chance for privacy.

Roaded Modified (RM): Characterized by substantially modified natural environment except for campsites. 

Roads and management activities may be strongly dominant. There is moderate evidence of other users on 

roads. Conventional motorized use is provided for in construction standards and design of facilities. 

Opportunity to get away from others, but with easy access.

Rural (R): Characterized by substantially modified natural environment. Resource modification and 

utilization practices are to enhance specific recreation activities and to maintain vegetative cover and soil. 

Sights and sounds of humans are readily evident, and the interaction between users is often moderate to 

high. A considerable number of facilities are designed for use by a large number of people. Facilities are 

often provided for special activities. Moderate densities are provided far away from developed sites. 

Facilities for intensified motorized use and parking are available. Opportunity to observe and affiliate with 

other users is important, as is convenience of facilities.

Urban (U): Characterized by a substantially urbanized environment, although the background may have 

natural-appearing elements. Resource modification and utilization practices are to enhance specific 

recreation activities. Vegetative cover is often exotic and manicured. Sights and sounds of people onsite are 

predominant. Large numbers of users can be expected, both onsite and in nearby areas. Facilities for highly 

intensified motor use and parking are available with forms of mass transit often available to carry people 

throughout the site. Opportunity to observe and affiliate with other users is very important, as is convenience 

of facilities.

Reforestation: The natural or artificial reestablishment of an area with forest tree cover.

Research natural area: A physical or biological unit in which current natural conditions is maintained and 

can be observed. These conditions are ordinarily achieved by allowing natural physical and biological 

processes to prevail without human intervention. Research natural areas are principally for non-manipulative 

research, observation, and study. They are designated to maintain a wide spectrum of high quality 

representative areas that represent the major forms of variability found in forest, shrublands, grassland, 

alpine, and natural situations that have scientific interest and importance that, in combination, form a 

national network of ecological areas for research, education, and maintenance of biological diversity.

Resilience: The ability of an ecosystem and its component parts to absorb, or recover from, the effects of 

disturbance through preservation, restoration or improvement of its essential structures and functions, and 

redundancy of ecological patterns across the landscape.

Restoration: See ecological restoration.

Riparian area: Include terrestrial and aquatic ecosystems that extend down into the groundwater, up above 

the canopy, outward across the floodplain, up the near-slopes that drain to the water, laterally into the 

terrestrial ecosystem, and along the water course at variable widths.

Riparian Conservation Areas: An area of vegetation or forest litter located adjacent to stream courses 

and/or riparian areas for the purpose of filtering sediment, providing bank stability, and providing shade for 

fisheries habitat in tree/shrub ecosystems.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

687

Road maintenance: The upkeep of the entire transportation facility including surface and shoulders, parking 

and side areas, structures, and such traffic control devices as are necessary for its safe and efficient 

utilization (36 CFR 212.1). This work includes brushing of roadside vegetation, falling danger trees, road 

blading, cleaning ditches, cleaning culvert inlets and outlets, etc.

Sacred sites: Defined in Executive Order 13007 as “any specific, discrete, narrowly delineated location on 

Federal land that is identified by an Indian Tribe, or Indian individual determined to be an appropriately 

authoritative representative of an Indian religion, as sacred by virtue of its established religious significance 

to, or ceremonial use by, an Indian religion; provided that the Tribe or appropriately authoritative 

representative of an Indian religion has informed the agency of the existence of such a site.”

Scenic integrity objectives– In the context of the forest plan are equivalent to goals or desired conditions. 

Scenic integrity describes the state of naturalness or a measure of the degree to which a landscape is 

visually perceived to be “complete.” The highest scenic integrity ratings are given to those landscapes that 

have little or no deviation from the landscape character valued by constituents for its aesthetic quality. 

Scenic integrity is the state of naturalness or, conversely, the state of disturbance created by human 

activities or alteration. Scenic integrity is measured in five levels:

• Very high: landscapes where the valued landscape character “is” intact with only minute, if any 

deviations. The existing landscape character and sense of place is expressed at the highest 

possible level.

• High: landscapes where the valued landscape character appears unaltered. Deviations may be 

present but must repeat the form, line, color, texture and pattern common to the landscape 

character so completely and at such scale that they are not evident.

• Moderate: landscapes where the valued landscape character appears slightly altered. Noticeable

deviations must remain visually subordinate to the landscape character being viewed.

• Low: landscapes where the valued landscape character appears moderately altered. Deviations 

begin to dominate the valued landscape character being viewed but they borrow valued attributes 

such as size, shape, edge effect, pattern of natural openings, vegetative type changes or 

architectural styles outside the landscape being viewed. They should not only appear as valued 

character outside the landscape being viewed, but compatible or complimentary to the character 

within.

• Very Low: landscapes where the valued landscape character appears heavily altered. Deviations 

may strongly dominate the valued landscape character. They may not borrow from valued 

attributes such as size, shape, edge effect, pattern of natural openings, vegetative type changes or 

architectural styles within or outside the landscape being viewed. However, deviations must be 

shaped and blended with the natural terrain so that elements such as unnatural edges, roads, 

landings and structures do not dominate the composition.

Scenic character - is defined as the combination of the physical, biological, and cultural images that gives 

an area its scenic identity and contributes to its sense of place. Scenic character provides a frame of 

reference from which to determine scenic attractiveness and to measure scenic integrity.

Scenic stability - Scenic stability measures the degree to which the scenic character and its scenery 

attributes can be sustained through time and ecological progression. In other words, it looks at the 

ecological sustainability of the valued scenic character and its scenery attributes. Because attributes such as 

rock outcroppings and landforms change relatively little over time, scenic stability focuses on the dominant 

vegetation scenery attributes. It recognizes the often subtle, incremental changes that can severely diminish 

or eliminate scenic character.

Scoping period: The time during which a proposed action has been provided to the public for review and 

comment so that the scope of issues related to the proposed action can be determined.

Seral stage: A particular plant and animal community developmental stage which is transitional between 

other stages along the continuum of succession or change. Following disturbance, ecological communities 

often undergo directional change in composition and structure over time from early to late seral stages 

through localized, successional processes. . Early seral forest is an example of a seral state that, without 

disturbance over time, will eventually transition to a subsequent seral state dominated by mid-sized conifers.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

688

Silviculture: The art and science of controlling the establishment, growth, composition, health, and quality 

of forests and woodlands using species silvics to meet the diverse needs and values of landowners and 

society on a sustainable basis.

Slash: The residue (such as branches or bark) left on the ground after a management activity, such as 

logging, or natural ecological process such as a storm or fire.

Snags: Standing dead or partially dead trees (snag topped), often missing many or all limbs and/or bark. 

Snags (generally 12 inches or larger) provide essential wildlife habitat for many species and are important 

forest ecosystem structures.

Soil productivity: The inherent capacity of the soil to support appropriate site-specific biological resource 

management objectives, which includes the growth of specified plants, plant communities, or a sequence of 

plant communities to support multiple land uses.

Special use authorization: A permit, term permit, temporary permit, lease, easement, or other written 

instrument that grants rights or privileges of occupancy and use subject to specified terms and conditions on 

National Forest System land.

Stand: A contiguous group of trees sufficiently uniform in age class distribution, composition, and structure, 

and growing on a site of sufficiently uniform quality, to be a distinguishable unit, such as mixed, pure, evenaged and uneven-aged stands.

Standard: A standard is a mandatory constraint on project and activity decisionmaking, established to help 

achieve or maintain the desired condition or conditions, to avoid or mitigate undesirable effects, or to meet 

applicable legal requirements.

Standard terra trails: Trails that have a surface consisting predominantly of the ground and are designed 

and managed to accommodate use on that surface. They do not include snow or water trails.

Structure: Structure includes both the vertical and horizontal dimensions of a vegetation type or plant 

community. The horizontal structure refers to spatial patterns of individual and groups of plants and 

openings, as well as plant size and species composition. The vertical component refers to the layers of 

vegetation between the forest floor and the top of the canopy. Each vegetation type has its own structure. 

For example, forests have greater vertical structure than a grassland or woodland based on the height of the 

dominant species.

Suitable timberlands: Land to be managed for timber production on a regulated basis. Such lands are 

those which have been determined to meet the following criteria: (a) are available for timber production (not 

withdrawn for wilderness or other official designation by Congress, the Secretary of Agriculture, or Chief of 

the Forest Service); (b) are physically capable of producing crops of industrial wood without irreversible 

resource damage to soils productivity or watershed conditions; (c) adequate tree restocking within 5 years of 

final harvest is reasonably assured; (d) adequate information exists about responses to timber management 

activities; (e) timber management is cost efficient over the planning horizon in meeting forest objectives that 

include timber production; (f) timber production is consistent with meeting the management requirements 

and multiple-use objectives specified in the forest plan or plan alternative; and (g) other management 

objectives do not limit timber production activities to the point where it is impossible to meet management 

requirements set forth in 36 CFR 129.27 (per Forest Service Handbook 2409.13, WO Amendment 2409.13-

92-1, O Code and Chapter 20).

Suitability of Lands: The suitability of lands is determined for specific lands within the plan area. The lands 

are identified as suitable or not suitable for various uses or activities based on desired conditions applicable 

to those lands. The suitability of lands is not identified for every use or activity. Every plan must identify 

those lands that are not suitable for timber production (§ 219.11).

Sustainability: The capability to meet the needs of the present generation without compromising the ability 

of future generations to meet their needs. For the purposes of the land management planning regulation at 

36 CFR part 219, ecological sustainability refers to the capability of ecosystems to maintain ecological 

integrity; economic sustainability refers to the capability of society to produce and consume or otherwise 

benefit from goods and services, including contributions to jobs and market and nonmarket benefits; and 

social sustainability refers to the capability of society to support the network of relationships, traditions, 

culture and activities that connect people to the land and to one another, and support vibrant communities.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

689

Sustainable recreation - the set of recreation settings and opportunities on the National Forest System that 

is ecologically, economically, and socially sustainable for present and future generations.

Thinning: An intermediate treatment made to reduce the stand density of trees primarily to improve growth, 

enhance forest health, to recover potential mortality, or to emphasize desired tree species. Includes crown 

thinning (thinning from above, high thinning), free thinning, low thinning (thinning from below), mechanical 

thinning (geometric thinning), and selection thinning (dominant thinning). Thinning can be used with both 

even and uneven-aged management systems.

Timber production: The purposeful growing, tending, harvesting, and regeneration of regulated crops of 

trees to be cut into logs, bolts, or other round sections for industrial or consumer use (36 CFR 219.19).

Total maximum daily load (TMDL): A TMDL is a written analysis that determines the maximum amount of 

a pollutant that a surface water can assimilate (the “load”), and still attain water quality standards during all 

conditions. The TMDL allocates the loading capacity of the surface water to point sources and nonpoint 

sources identified in the watershed, accounting for natural background levels and seasonal variation, with an 

allocation set aside as a margin of safety.

Traditional cultural properties (TCP): Defined in National Register Bulletin 38 as properties associated 

“with cultural practices or beliefs of a living community that (a) are rooted in that community’s history, and (b) 

are important in maintaining the continuing cultural identity of the community.” TCPs can range from 

structures, mountains, and other landforms to plant gathering locations to communities. These areas are 

considered historic properties that may be eligible to the National Register of Historic Places

Travel Management Rule (November 29, 2005, 36 CFR 212.51): requires that each national forest 

designate a system of roads, trails, and areas for motor vehicle use by vehicle class and, if appropriate, by 

time of year. Once the system is designated, the rule will prohibit motor vehicle use off the designated 

system.

Unauthorized road or trail: A road or trail that is not a forest road or trail or a temporary road or trail and 

that is not included in a forest transportation atlas (36 CFR 212.1, Forest Service Manual 2353.05, and 

Forest Service Manual 7705).

Uncharacteristic wildfire: Refers to wildfire that exceeds the natural range of variation in fire severity (high 

severity proportion, high severity patch size) and other fire effects indicators for a specific vegetation type61.

Undesirable wildfire: Wildfire that does not meet the desired conditions for a specific vegetation type.

Unplanned ignition: A wildfire, not including planned ignitions.

Vegetation Burn Severity: The degree of vegetation mortality caused by a fire and the fire severity from 

the ecological effect of the fire. As used in this Forest Plan, refers to the effect of the fire on the dominant 

vegetation, which are coniferous trees. Three levels of fire severity are recognized:

• High severity: greater than 75 percent of the dominant overstory vegetation (trees) are killed. Also 

referred to as stand-replacement fire.

• Moderate severity: 25 to 75% of the dominant overstory vegetation (trees) are killed.

• Low severity: less than 25% of dominant overstory vegetation (trees) are killed.

Wild and scenic river: A river designated by Congress as part of the National Wild and Scenic Rivers 

System that was established in the Wild and Scenic Rivers Act of 1968 (16 U.S.C. 1271 (note), 1271–1287).

• Wild: Those rivers or sections of rivers free of impoundments and generally inaccessible except by 

trail, with watersheds or shorelines essentially primitive and waters unpolluted. These represent 

vestiges of primitive America.

• Scenic: Those rivers or sections of rivers free of impoundments, with shorelines or watersheds still 

largely primitive and shorelines largely undeveloped, but accessible in places by roads.

• Recreational: Those rivers or sections of rivers readily accessible by road or railroad that may 

have some development along their shorelines, and that may have undergone some impoundment 

or diversion in the past.

 61 Hardy, C. C. 2005. Wildland fire hazard and risk: Problems, definitions, and context. Forest ecology and 

management, 211(1), 73-82.
Glossary

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

690

Wildland-urban intermix (WUI): Includes those areas of resident populations at imminent risk from 

wildfire, and human developments having special significance. These areas may include critical 

communications sites, municipal watersheds, high voltage transmission lines, church camps, scout camps, 

research facilities, and other structures that if destroyed by fire, would result in hardship to communities. 

These areas encompass not only the sites themselves, but also the continuous slopes and fuels that lead 

directly to the sites, regardless of the distance involved (Forest Service Manual 5140.5).

Xeric: Very dry region or climate; tolerating or adapted to dry conditions. Dry soil moisture regime. Some 

moisture is present but does not occur at optimum levels for plant growth. 
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

691

References

Agee, J.K., and C.N. Skinner. 2005. Basic principles of forest fuel reduction treatments. Forest 

Ecology and Management 211 (1-2):83-96. doi: 10.1016/j.foreco.2005.01.034.

Alexander, Clarence, Nora Bynum, Elizabeth Johnson, and others. 2011. Linking Indigenous and 

Scientific Knowledge of Climate Change. BioScience 61 (6):477-484. doi: 

10.1525/bio.2011.61.6.10.

Alkire, C. 2012. Economic contribution of Mono Basin National Forest Scenic Area designation. 

Prepared for The Wilderness Society.

Allen, C.D., D.D. Breshears, and N.G. McDowell. 2015. On underestimation of global 

vulnerability to tree mortality and forest die-off from hotter drought in the Anthropocene. 

Ecosphere 6 (8). doi: 10.1890/ES15-00203.1.

Allen, S. D., D. A. Wickwar, F. P. Clark, R. Potts, and S. A. Snyder. 2009. Values, beliefs, and

attitudes technical guide for Forest Service land and resource management, planning, and 

decisionmaking. General Technical Report - Pacific Northwest Research Station, USDA 

Forest Service (No.PNW-GTR-788):iii + 112 pp.

Allen-Diaz, B., R. Barrett, W. W. Frost, L. Huntsinger, and K. Tate. 1999. Sierra Nevada 

ecosystems in the presence of livestock: a report to the USDA Forest Service Pacific 

Southwest Research Station and Pacific Southwest Region. University of California, 

Berkeley.

Anderson, M. K. 2006. The use of fire by Native Americans in California. In, Sugihara, N., Fire 

in California’s ecosystems. Berkeley, California, USA: University of California Press.

Anderson, M. K. 1999. The fire, pruning, and coppice management of temperate ecosystems for 

basketry material by California Indian tribes. Human Ecology 27 (1):79-113. doi: 

10.1023/a:1018757317568.

Anderson, M. K., and M.J. Moratto. 1996. Native American land-use practices and ecological 

impacts. In Sierra Nevada Ecosystem Project (SNEP): Final Report to Congress, 187-

206. Davis, CA: University of California, Centers for Water and Wildland Resources.

Archdeacon, T. P., and S. A. Bonar. 2010. Intraspecific predation in endangered Mohave tui chub. 

California Fish and Game 96 (3):213-215.

Arkle, Robert S., and David S Pilliod. 2010. Prescribed fires as ecological surrogates for 

wildfires: a stream and riparian perspective. Forest Ecology and Management 259 

(5):893-903.

Arkle, Robert S., David S. Pilliod, Steven E. Hanser, and others. 2014. Quantifying restoration 

effectiveness using multi-scale habitat models: implications for sage-grouse in the Great 

Basin. Ecosphere 5 (3):1-32.

Arkush, Brooke S. 1993. Yokuts Trade Networks and Native Culture Change in Central and 

Eastern California. Ethnohistory 40 (4):619-640. doi: 10.2307/482590.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

692

Arkush, Brooke S. 1994. Prehistoric Trade Networks and the Ethnographic Record in Central 

California. North American Archaeologist 14 (3):191-197. doi: doi:10.2190/CRNXY93A-HEQF-MY46.

Arno, S. F., and J. K. Brown. 1991. Overcoming the paradox in managing wildland fire. Western 

Wildlands 17:40-46.

Asner, G. P., P.G. Brodrick, C. B. Anderson, N. Vaughn, D. E. Knapp, and R.E. Martin. 2015. 

Progressive forest canopy water loss during the 2012-2015 California drought. 

Proceedings of the National Academy of Sciences 113:E249-E255.

Association of Fire Ecology, International Association of Wildland Fire, and The Nature 

Conservancy. 2015. Reduce wildfire risks or we’ll continue to pay more for fire disasters. 

Position statement.

Auble, Gregor T., Jonathan M. Friedman, and Michael L. Scott. 1994. Relating riparian 

vegetation to present and future streamflows. Ecological Applications 4 (3):544-554. doi: 

10.2307/1941956.

Badino, G. 2004. Cave temperatures and global climatic change. International Journal of 

Speleology 33:103-114.

Baldwin, B. G., D. H. Goldman, R. Patterson, and T. J. Rosatti. 2012. The Jepson Manual. 

Berkeley, CA: Univ. of California Press.

Bales, Roger C, John J Battles, Yihsu Chen, Martha H Conklin, Eric Holst, Kevin L O’Hara, 

Philip Saksa, and William Stewart. 2011. Forests and water in the Sierra Nevada: Sierra 

Nevada watershed ecosystem enhancement project. Sierra Nevada Research Institute 

report 11.

Baumer, Amy, Nancy East, Joe Echenique, Marcy Haworth, Marianne F. Leinassar, Chris 

Papouchis, tom Stephenson, Diane Weaver, and Genny Wilson. 2009. A Process for 

Identifying and Managing Risk of Contact between Sierra Nevada Bighorn Sheep and 

Domestic Sheep. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=27671

Baumsteiger, J., and P. B. Moyle. 2017. Assessing Extinction. Bioscience 67 (4):356-365. doi: 

10.1093/biosci/bix001.

BBC Research & Consulting. 2011. California outdoor recreation economic study: statewide 

contributions and benefits. California State Parks. Denver, CO.

Beck, T.W., and J. Winter. 2000. Survey protocol for the great gray owl in the Sierra Nevada of 

California. Edited by United States Department of Agriculture. Vallejo, CA: Forest 

Service.

Beesley, D. 1996. Reconstructing the landscape: an environmental history, 1820-1960. In Sierra 

Nevada Ecosystem Project (SNEP): Final Report to Congress. Davis, CA: University of 

California.

Beever, E. 2003. Management implications of the ecology of free-roaming horses in semi-arid 

ecosystems of the western United States. Wildlife Society Bulletin 31 (3):887-895.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

693

Beever, E. A., and C. L. Aldridge. 2011. Influences of free-roaming equids on sagebrush 

ecosystems, with a focus on greater sage-grouse. In Greater sage-grouse: Ecology of a 

landscape species and its habitats, edited by S.T. Knick and J.W. Connelly, 273-290. 

Berkeley, CA: Cooper Ornithological Union, University of California Press.

Beever, E. A., and J. E. Herrick. 2006. Effects of feral horses in Great Basin landscapes on soils 

and ants: Direct and indirect mechanisms. Journal of Arid Environments 66 (1):96-112. 

doi: 10.1016/j.jaridenv.2005.11.006.

Belsky, A. J., A. Matzke, and S. Uselman. 1999. Survey of livestock influences on stream and 

riparian ecosystems in the Western United States. J. of Soil and Water Cons. 54:419-431.

Bentz, B. J. 2005. Bark Beetle outbreaks in Western North America: Causes and Consequences. 

Bark Beetle Symposium, Snowbird, UT.

Bentz, B. J., J. Régnière, C.J. Fettig, E.M. Hansen, J. Hayes, J.A. Hicke, R.G. Kelsey, J.F. 

Negrón, and SJ. Seybold. 2010. Climate change and bark beetles of the western United 

States and Canada: direct and indirect effects. Bioscience 60:602-613.

Berger, J. 1986. Wild horses of the Great Basin: Social completion and population size. Chicago, 

IL: The University of Chicago Press.

Besser, Thomas E., E. Frances Cassirer, Kathleen A. Potter, and others. 2014. Epizootic 

pneumonia of bighorn sheep following experimental exposure to Mycoplasma 

ovipneumoniae. PloS one 9 (10):e110039.

Besser, Thomas E., E. Frances Cassirer, Kathleen A. Potter, and others. 2008. Association of 

Mycoplasma ovipneumoniae infection with population-limiting respiratory disease in 

free-ranging Rocky Mountain bighorn sheep (Ovis canadensis canadensis). Journal of 

Clinical Microbiology 46 (2):423-430.

Bettaso, J. B., and D. H. Goodman. 2010. A Comparison of Mercury Contamination in Mussel 

and Ammocoete Filter Feeders. Journal of Fish and Wildlife Management 1 (2):142-145. 

doi: 10.3996/112009-jfwm-019.

Betts, M.G., Joan C. Hagar, Jim W. Rivers, and others. 2010. Thresholds in forest bird occurrence 

as a function of the amount of early-seral broadleaf forest at landscape scales. Ecological 

Applications 20 (8):2116-2130.

Bi-State Technical Advisory Committee Nevada and California. 2013. Bi-State Action Plan—

Past, Present, and Future Actions for Conservation of the Greater Sage-Grouse Bi-State 

Distinct Population Segment.

Blackburn, Thomas C., and Kat Anderson. 1993. Before the wilderness: Environmental 

management by native Californians. Review of Before the Wilderness: Environmental 

Management by Native Californians. Ballena Press Anthropological Papers No. 40, 

Thomas C. Blackburn, Kat Anderson. Journal of California and Great Basin 

Anthropology 15 (2):261-263.

Bland, J.D. 2013a. Apparent extirpation of the sooty grouse from the sky islands of south-central 

California. Western Birds 44:294-308.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

694

Bland, J.D. 2013b. Apparent extirpation of the sooty grouse from the sky islands of south-central 

California. Western Birds 44:294-308.

Bland, J.D. 2017. Mt. Pinos sooty grouse location. Personal communication, via email, between 

Valerie Stein, wildlife biologist, USDA Forest Service, and Dr. Bland, professor retired, 

Santa Monica College, CA. in, Vallejo, CA.

Bohlman, GN, M North, and HD Safford. 2016. Shrub removal in reforested post-fire areas 

increases native plant species richness. Forest Ecology and Management 374:195-210. 

doi: 10.1016/j.foreco.2016.05.008.

Bourne, A., and S.C. Bunting. 2011. Guide for quantifying post-treatment fuels in the sagebrush 

steppe and juniper woodlands of the Great Basin. Denver, CO, USA: Bureau of Land 

Management.

Bradford, David F., Roland A. Knapp, Donald W. Sparling, Maliha S. Nash, Kerri A. Stanley, 

Nita G. Tallent-Halsell, Laura L. McConnell, and Staci M. Simonich. 2011. Pesticide 

distributions and population declines of California, USA, alpine frogs, Rana muscosa and 

Rana sierrae. Environmental Toxicology and Chemistry 30 (3):682-691. doi: 

10.1002/etc.425.

Bradley, Bethany A. 2009. Regional analysis of the impacts of climate change on cheatgrass 

invasion shows potential risk and opportunity. Global Change Biology 15 (1):196-208.

Bradley, Nina L., A. Carl Leopold, John Ross, and Wellington Huffaker. 1999. Phenological 

changes reflect climate change in Wisconsin. Proceedings of the National Academy of 

Sciences 96 (17):9701-9704. doi: 10.1073/pnas.96.17.9701.

Brautigam, K., K.J. Vining, C. Lafon-Placette, and others. 2013. Epigenetic regulation of adaptive 

responses of forest tree species to the environment. Ecology and Evolution 3 (2):399-415. 

doi: 10.1002/ece3.461.

Briggs, Cheryl J., Vance T. Vredenburg, Roland A. Knapp, and Lara J. Rachowicz. 2005. 

Investigating the population-level effects of chytridiomycosis: an emerging infectious 

disease of amphibians. Ecology 86 (12):3149-3159. doi: 10.1890/04-1428.

Brooks, ML, and RA Minnich. 2006. Southeastern deserts bioregion. Fire in California’s 

Ecosystem: 391-414.

Brookshire, Jack E., Boone J. Kauffman, Danna Lytjen, and Nick Otting. 2002. Cumulative 

effects of wild ungulate and livestock herbivory on riparian willows. Oecologia 132 

(4):559-566. doi: 10.1007/s00442-002-1007-4.

Brown, Cathy, Marc P. Hayes, Gregory A. Green, and Diane C. Macfarlane. 2014. Mountain 

Yellow-Legged Frog Conservation Assessment for the Sierra Nevada Mountains of 

California, USA. United States Department of Agriculture, Forest Service, Pacific 

Southwest Region.

Brown, Cathy, Marc P. Hayes, Gregory A. Green, Diane C. Macfarlane, and Amy J. Lind. 2015. 

Yosemite Toad Conservation Assessment. United States Department of Agriculture, 

Forest Service, Pacific Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

695

Brown, G. , M. Kelly, and D. Whitall. 2013. Which ‘public'? Sampling effects in public 

participation GIS (PPGIS) and volunteered geographic information (VGI) systems for 

public lands management. Journal of Environmental Planning and Management 57 (2).

Bryant, B. P., and A.L. Westerling. 2014. Scenarios for future wildfire risk in California: links 

between changing demography, land use, climate, and wildfire. Environmetrics 25:454-

471.

Buehler, D. A. 2000. Bald Eagle (Haliaeetus leucocephalus). In The Birds of North America 

Online, edited by A. Poole. Ithaca: Cornell Lab of Ornithology.

Bull, E. L., and R. S. Holthausen. 1993. Habitat use and management of pileated woodpeckers in 

Northeastern Oregon. Journal of Wildlife Management 57 (2):335-345. doi: 

10.2307/3809431.

Bull, E.L., and J.R. Duncan. 1993. Great gray owl (Strix nebulosa). The Birds of North America 

Online (A. Poole, ed.). Cornell Lab of Ornithology. https://birdsna.org/SpeciesAccount/bna/species/grgowl.

Bunch, T.D., W.M. Boyce, C.P. Hibler, W.R. Lance, T.R. Spraker, and E.S. Williams. 1999. 

Diseases of North American wild sheep. In Mountain sheep of North America, edited by 

R. Valdez and P.R. Krausman, 209-237. Tuscon, Arizona: University of Arizona Press.

Burcham, L. T. 1982. California range land: An historico-ecological study of the range resource 

of California [1957]. Davis, CA: University of California, Center for Archaeological 

Research at Davis.

Bureau of Land Management, CA State Office. 2015. Renewable Energy Summary. 

https://www.blm.gov/.

Burger, Joanna. 2008. Environmental management: Integrating ecological evaluation, 

remediation, restoration, natural resource damage assessment and long-term stewardship 

on contaminated lands. Science of the Total Environment 400 (1–3):6-19. doi: 

http://doi.org/10.1016/j.scitotenv.2008.06.041.

Burger, Joanna, Michael Gochfeld, Karen Pletnikoff, and others. 2008. Ecocultural Attributes: 

Evaluating Ecological Degradation in Terms of Ecological Goods and Services Versus 

Subsistence and Tribal Values. Risk Analysis 28 (5):1261-1272. doi: 10.1111/j.1539-

6924.2008.01093.x.

Burton, T.A., and S. J. Kozel. 1996. Livestock grazing relationships with fisheries. In: Sustaining 

rangeland ecosystems Special Report 953, edited by W. D. Edge and S. L. Olson-Edge, 

140-145. Corvallis, OR: Oregon State University Extension Service.

Burton, T.A., S. Smith, and E. Cowley. 2010. Riparian area management: Multiple indicator 

monitoring (MIM) of stream channel and streamside vegetation. Edited by Bureau of 

Land Management United States Department of Interior. Denver, CO.

Bytnerowicz, A., M. Fenn, and J.W. Long. 2014. Air Quality. Chapter 8.1. In Science synthesis to 

support socioecological resilience in the Sierra Nevada and southern Cascade Range

Albany, CA: USDA Forest Service.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

696

Bêche, Leah A, Scott L Stephens, and Vincent H Resh. 2005. Effects of prescribed fire on a Sierra 

Nevada (California, USA) stream and its riparian zone. Forest Ecology and Management 

218 (1):37-59.

Cahill, M. 2013. Personal Communication. University of Vermont: University of Vermont.

California Air Resources Board. 2013. San Joaquin Air Basin 2013 Emissions almanac. 

http://www.arb.ca.gov/ei/emissiondata.htm.

California Air Response Planning Alliance. 2008. Wildfire smoke: a guide for public officials. 

Sacramento, CA.

California Department of Finance. 2014. Report P-1 (Age): State and County Population 

Projections by Major Age Groups, 2010-2060 (by decade).

California Department of Fish and Wildlife. 2015a. California State Wildlife Action Plan, 2015 

Update: A Conservation Legacy for Californians. Edited by A. G. Gonzales, J. Hoshi and 

Inc. Prepared with assistance from Ascent Environmental. Sacramento, CA.

California Department of Fish and Wildlife. 2015b. Letter on the Inyo National Forest Draft 

Proposed Species of Conservation Concern.

California Department of Fish and Wildlife. 2016. INF/CDFW R6 RASI Population Trends 

Through 2016.

California Department of Fish and Wildlife. 2017a. Rana sierrae/muscosa Populations and Native 

Species Restoration Opportunities, 18 Management Units displayed North to South. 

Edited by Region 6 North Inland Deserts.

California Department of Fish and Wildlife, Natural Diversity Database. 2017b. Special Plant 

List. Edited by Biogeographic Data Branch California Department of Fish and Wildlife. 

Sacramento, CA.

California Department of Water Resources. 2014. 2014 CA Water Plan update: Water dependent 

cultural resources strategy. Tribal Advisory Committee.

California Department of Water Resources. 2016. Forest Management: A Resource 

Management Strategy of the California Water Plan. California Natural Resources 

Agency.

California Native Plant Society. 2015. Inventory of rare and endangered plants. Accessed May 27. 

http://www.rareplants.cnps.org.

California Natural Resource Agency. 2014. Safeguarding California: Reducing climate risk: An 

update to the 2009 California Climate Adaptation Strategy. Sacramento, CA: California 

Natural Resources Agency.

California Outdoor Recreation Planning Program. 2002. California Outdoor Recreation Plan 

2002: an element of the California Outdoor Recreation Planning Program. Sacramento, 

CA: California State Parks, Planning Division.

California State Controller's Office. 2012. Counties annual report FY 2011. 
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

697

California State Energy Commission. 2012. Desert Renewable Energy Conservation Plan, 

Baseline biology report. Sacramento, CA.

Calkin, D. E., K. M. Gebert, J. G. Jones, and R. P. Neilson. 2005. Forest Service large fire area 

burned and suppression expenditure trends, 1970-2002. Journal of Forestry 103:179-183.

Caprio, AC, M Keifer, and K Webster. 2006. Long-term effects of the 1992 Rainbow Fire, Devils 

Postpile National Monument, California. Extended abstract of oral presentation at the 

third international fire ecology and management congress, Association for Fire Ecology.

Carver, Steve, Alan Watson, Tim Waters, Roian Matt, Kari Gunderson, and Brett Davis. 2009. 

Developing computer-based participatory approaches to mapping landscape values for 

landscape and resource management. Edited by S. Geertman and J. Stillwell, Planning 

support systems best practice and new methods: Springer Science+Business Media B.V.

Chambers, Jeanne C, Matthew L Brooks, Burton K Pendleton, and Carol B Raish. 2013. The 

Southern Nevada Agency Partnership Science and Research Synthesis: Science to 

Support Land Management in Southern Nevada.

Chambers, J. C., D. A. Pyke, J. D. Maestas, M. Pellant, C. S. Boyd, S. B. Campbell, S. Espinosa, 

D. W. Havlina, K. E. Mayer, and A. Wuenschel. 2014. Using resistance and resilience 

concepts to reduce impacts of invasive annual grasses and altered fire regimes on the 

sagebrush ecosystem and greater sage-grouse: A strategic multi-scale approach RMRSGTR-326. USDA, Forest Service, Rocky Mountain Research Station. Fort Collins, CO.

Chambers, Jeanne C, Bruce A Roundy, Robert R Blank, Susan E Meyer, and A Whittaker. 2007. 

What makes Great Basin sagebrush ecosystems invasible by Bromus tectorum? 

Ecological Monographs 77 (1):117-145.

Charnley, S. 2013. Chapter 9.4. Strategies for Job Creation through Forest Management. In 

Science synthesis to support forest plan revision in the Sierra Nevada and southern 

Cascades, Draft final report, edited by J. W. Long, L. Quinn-Davidson and C. N. Skinner. 

Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Research 

Station.

Chartkoff, Joseph L. 2001. Exchange Systems and Sociopolitical Complexity in the Central 

Sierra Nevada: Perspectives on the Impact of Coastal Colonization on Inland 

Communities. Journal of California and Great Basin Anthropology 23 (1):125-138.

Chavez, D.J. 2012. Latinos and outdoor recreation. In Outdoor recreation trends and futures: a 

technical document supporting the Forest Service 2010 RPA Assessment. Gen. Tech. Rep. 

SRS-150, edited by H.K. Cordell, 74-77. Asheville, NC: U.S. Department of Agriculture 

Forest Service, Southern Research Station.

Chavez, D.J., and D.D. Olson. 2008. Chapter 6: Diverse users of four urban National Forests: 

Participation, preferences, and perceptions. In Recreation visitor research: Studies of 

diversity. PSW-GTR-210, edited by D. J. Chavez, P. L. Winter and J. D. Absher: Pacific 

Southwest Research Station, USDA Forest Service.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

698

Chen, Y., and B. May. 2003. Introgression, hybridization, and genetic differentiation of

endangered Owens tui chub populations. Final Report to California Department of Fish 

and Game, Eastern Sierra and Inland Deserts Region, Bishop, California.

Chen, Y.J., S. Parmenter, and B. May. 2007. Introgression between lahontan and endangered 

Owens tui chubs, and apparent discovery of a new tui chub in the Owens Valley, 

California. Conservation Genetics 8 (1):221-238. doi: 10.1007/s10592-006-9164-3.

Chief, Karletta, John J Daigle, Kathy Lynn, and Kyle Powys Whyte. 2014. Indigenous 

experiences in the US with climate change and environmental stewardship in the 

Anthropocene. Forest conservation and management in the Anthropocene, Fort Collins, 

CO.

Chiono, Lindsay A., Kevin L. O’Hara, Michael J. De Lasaux, Glenn A. Nader, and Scott L. 

Stephens. 2012. Development of Vegetation and Surface Fuels Following Fire Hazard 

Reduction Treatment. Forests 3 (3):700.

Clark, Darren A., Robert G. Anthony, and Lawrence S. Andrews. 2011. Survival Rates of 

Northern Spotted Owls in Post-fire Landscapes of Southwest Oregon. Journal of Raptor 

Research 45 (1):38-47. doi: 10.3356/jrr-10-42.1.

Clark, R.N., and G.H. Stankey. 1979. The Recreation Opportunity Spectrum: A framework for 

management, planning, and research. USDA Forest Service General Technical Report 

GTR-PNW-98. Portland, OR: Pacific Northwest Forest and Range Experiment Station.

Clary, W. P., and B. F. Webster. 1989. Managing grazing of riparian areas in the Intermountain 

Region GTR-INT-263. Edited by Forest Service. Ogden, UT: United States Department 

of Agriculture, Intermountain Research Station.

Clifford, Deana L., Brant A. Schumaker, Thomas R. Stephenson, Vernon C. Bleich, Maya L. 

Cahn, Ben J. Gonzales, Walter M. Boyce, and Jonna A.K. Mazet. 2009. Assessing disease 

risk at the wildlife-livestock interface: A study of Sierra Nevada bighorn sheep. 

Biological Conservation 142:2559-2568.

Coalition, Western Forestry Leadership. 2009. Western bark beetle assessment: A framework for 

cooperative forest stewardship update, Lakewood, CO, March 9.

Coates, Peter S., and David J. Delehanty. 2010. Nest Predation of Greater Sage-Grouse in 

Relation to Microhabitat Factors and Predators. Journal of Wildlife Management 74 

(2):240-248. doi: 10.2193/2009-047.

Coates, Peter S., Brian J. Halstead, Erik J. Blomberg, Brianne Brussee, Kristy B. Howe, Lief 

Wiechman, Joel Tebbenkamp, Kerry P. Reese, Scott C. Gardner, and Michael L. Casazza. 

2014. A hierarchical integrated population model for greater sage-grouse (Centrocercus 

urophasianus) in the Bi-State Distinct Population Segment, California and Nevada. In 

Open-File Report. Reston, VA.

Coen, J. L. 2005. Simulation of the Big Elk Fire using coupled atmosphere-fire modeling. 

International Journal of Wildland Fire 14:49-59.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

699

Coen, J. L., E.N. Stavros, J. A. Fites-Kaufman, V.Kane, R.E. McGaughey, P. Oliva, C. Ramirez, 

D. Schimel, W. Schroeder, H. Singh, and Z. Tane. 2015. The King Megafire: Coupled 

weather-fire modeling enhanced by pre-HyspIRI imaging spectrometer and LiDAR fire 

and fuel products. . Fire Ecology and Management Conference: Advancing Ecology in 

Fire Management. San Antonio TX, November 16-20, 2015.

Cole, David N, and Laurie Yung. 2012. Beyond naturalness: rethinking park and wilderness 

stewardship in an era of rapid change. Washington, DC: Island Press.

Cole, Kenneth L. 2010. Vegetation response to early Holocene warming as an analog for current 

and future changes. Conservation biology: the journal of the Society for Conservation 

Biology 24 (1):29-37.

Collins, B., and C.N. Skinner. 2014a. Chapter 4.1 Fire and Fuels. In Science Synthesis to Support 

Socioecological Resilience in the Sierra Nevada and Southern Cascades, edited by J.W. 

Long, L. Quinn-Davidson and C.N. Skinner. Albany, CA: USDA Forest Service, Pacific 

Southwest Research Station.

Collins, B. M., and S. L. Stephens. 2010. Stand-replacing patches within a 'mixed severity' fire 

regime: quantitative characterization using recent fires in a long-established natural fire 

area. Landscape Ecology 25:927-939.

Collins, B., and C.N. Skinner. 2014b. Chapter 4.1 Fire and Fuels. In Science Synthesis to Support 

Socioecological Resilience in the Sierra Nevada and Southern Cascades, edited by J. W. 

Long, L. Quinn-Davidson and C. N. Skinner. Albany, CA: USDA Forest Service, Pacific 

Southwest Research Station.

Collins, B.M., J.D Miller, A.E Thode, J.W Van Wagtendonk, and S.L. Stephens. 2009. 

Interactions among wildland fires in a long-established Sierra Nevada natural fire area. 

Ecosystems 12 (1):114-128

Collins, B.M., and C. Skinner. 2014c. Fire and fuels. In Science synthesis to support 

socioecological resilience in the Sierra Nevada and southern Cascade Range, edited by 

J.W. Long, L. Quinn-Davidson and C.N. Skinner. Albany, CA: USDA Forest Service.

Collins, Brandon M, Richard G Everett, and Scott L Stephens. 2011. Impacts of fire exclusion 

and recent managed fire on forest structure in old growth Sierra Nevada mixed-conifer 

forests. Ecosphere 2 (4):art51.

Collins, Brandon M, Jason J Moghaddas, and Scott L Stephens. 2007. Initial changes in forest 

structure and understory plant communities following fuel reduction activities in a Sierra 

Nevada mixed conifer forest. Forest Ecology and Management 239 (1):102-111.

Collins, Brandon M, and Gary B Roller. 2013. Early forest dynamics in stand-replacing fire 

patches in the northern Sierra Nevada, California, USA. Landscape Ecology 28 (9):1801-

1813.

Collins, Brandon M., Jamie M. Lydersen, Richard G. Everett, Danny L. Fry, and Scott L. 

Stephens. 2015. Novel characterization of landscape-level variability in historical 

vegetation structure. Ecological applications: a publication of the Ecological Society of 

America 25 (5):1167-74.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

700

Connelly, J. W., S. T. Knick, M. A. Schroeder, and S. J. Stiver. 2004. Conservation assessment of 

greater sage-grouse and sagebrush habitats. Western Association of Fish and Wildlife 

Agencies. Unpublished Report. Cheyenne, WY. 610 pp.

Coppoletta, Michelle, Kyle E. Merriam, and Brandon M. Collins. 2016. Post-fire vegetation and 

fuel development influences fire severity patterns in reburns. Ecological Applications 26 

(3):686-699. doi: 10.1890/15-0225.

Cordell, H. K. 2012. Outdoor recreation trends and futures: a technical document supporting the 

Forest Service 2010 RPA Assessment. In Gen. Tech. Rep. SRS-150. Asheville, NC: U.S. 

Department of Agriculture Forest Service, Southern Research Station.

Council on Environmental Quality. 1997. Environmental Justice: Guidance Under the National 

Environmental Policy Act. Washington, D.C.

Crimmins, Shawn M., Solomon Z. Dobrowski, Jonathan A. Greenberg, John T. Abatzoglou, and 

Alison R. Mynsberge. 2011. Changes in Climatic Water Balance Drive Downhill Shifts in 

Plant Species’ Optimum Elevations. Science 331 (6015):324-327. doi: 

10.1126/science.1199040.

Croft, Brian, Amy Fesnock, Marcy Haworth, Rachel Mazur, Leeann Murphy, Steven Nelson, 

Richard Perloff, and Tom Stephenson. 2010.

Cushman, S. A., and E. L. Landguth. 2012. Multi-taxa population connectivity in the Northern 

Rocky Mountains. Ecological Modelling 231:101-112.

Cushman, S. A., E. L. Landguth, and C. H. Flather. 2012. Evaluating the sufficiency of protected 

lands for maintaining wildlife population connectivity in the US northern Rocky 

Mountains. Diversity and Distributions 18:873-884.

Cvijanovic, Ivana, Benjamin Santer, Celine Bonfils, Donald Lucas, John Chiang, and Susan 

Zimmerman. 2017. Future loss of arctic sea-ice cover. Nature Communications 8 

(1947):1-10. doi: 10.1038/s41467-017-01907-4.

Davidson, Carlos, and Gary M. Fellers. 2005. Bufo canorus Camp 1916, Yosemite Toad. Edited 

by M. Lannoo, Amphibian declines: The conservation status of United States species. 

Volume 2: Species accounts. Berkeley, CA: University of California Press.

Davidson, Carlos, and Roland A. Knapp. 2007. Multiple stressors and amphibian declines: dual 

impacts of pesticides and fish on yellow-legged frogs. Ecological Applications 17 

(2):587-597. doi: 10.1890/06-0181.

Davies, K. W., G. Collins, and C. S. Boyd. 2014. Effects of feral free-roaming horses on semiarid rangeland ecosystems: an example from the sagebrush steppe. Ecosphere 5 (10). doi: 

10.1890/es14-00171.1.

Dean Runyan and Associates. 2012. California travel impacts by county, 1992-2010 2011 

Preliminary State & Regional Estimates April 2012.

DeBano, Leonard F. 2000. The role of fire and soil heating on water repellency in wildland 

environments: a review. Journal of Hydrology 231:195-206.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

701

Dolanc, Christopher R., Hugh D Safford, James H Thorne, and Solomon Z Dobrowski. 2014. 

Changing forest structure across the landscape of the Sierra Nevada, CA, USA, since the 

1930s. Ecosphere 5 (8):1-26.

Elliot, William J, Ina Sue Miller, and Lisa Audin. 2010. Cumulative watershed effects of fuel 

management in the western United States. In General Tech Report. Fort Collins, CO: U.S. 

Department of Agriculture, Forest Service, Rocky Mountain Research station.

Elmore, W., and B. Kauffman. 1994. Riparian and watershed systems: degradation and 

restoration. In Ecological implications of livestock herbivory in the West, edited by M. 

Vavra, W. A. Laycock and R. D. Pieper, 212-231. Denver, CO: Soc. for Range Manage.

English, Donald B.K., Pam Froemke, and Kathleen Hawkos. 2014. Paths more traveled: 

Predicting future recreation pressures on America’s national forests and grasslands-a 

Forests on the Edge report.

Epps, Clinton W., Dale R. McCullough, John D. Wehausen, Vernon C. Bleich, and Jennifer L. 

Rechel. 2004. Effects of Climate Change on Population Persistence of Desert-Dwelling 

Mountain Sheep in California

Efectos del Cambio Climático sobre la Persistencia de la Población de Borrego Cimarrón en 

California. Conservation Biology 18 (1):102-113. doi: 10.1111/j.1523-

1739.2004.00023.x.

Environmental Protection Agency (EPA). 2015. California water quality assessment report. 

Washington, DC. United States Environmental Protection Agency. Available at: 

http://ofmpub.epa.gov/tmdl_waters10/attains_state.control?p_state=CA.

Estes, B. 2013a. Historic range of variability for chaparral in the Sierra Nevada and Southern 

Cascades. USDA Forest Service. http://www.fs.usda.gov/detail/r5/plantsanimals/?cid=stelprdb5434436.

Estes, B. 2013b. Historic range of variation for aspen in the Sierra Nevada and Southern 

Cascades. U.S. Department of Agriculture, Forest Service, Pacific Southwest Region.

Unpublished report. Vallejo, CA. 

Ewell, C., A. Reiner, and S. Williams. 2012. Wildfire Interactions of the 2011 Lion Fire and 

Recent Wildfires on the Sequoia National Forest and Sequoia National Park. USDA 

Forest Service, Adaptive Management Services Enterprise Team.

Ewell, Carol, Alicia Reiner, Jo Ann Fites, and Ryan Bauer. 2012. When fire burns through heavy 

brush and snags of a recent fire: Fire Behavior on the 2012 Chips Fire. USDA Forest 

Service unpublished report.

Eyes, SA, SL Roberts, and MD Johnson. 2017. California Spotted Owl (Strix occidentalis 

occidentalis) habitat use patterns in a burned landscape. Condor 119 (3):375-388. doi: 

10.1650/CONDOR-16-184.1.

Farris, Glenn J. 1982. Pine nuts as an aboriginal food source in California and Nevada: some 

contrasts. J. Ethnobiol 2:114-122.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

702

Feeney, S, T.E. Kolb, W.W. Covington, and M.R. Wagner. 1998. Influence of thinning and 

burning restoration treatments on presettlement ponderosa pines at the Gus Pearson 

natural Area. . Canadian Journal Forest Research 238 (24-53).

Fettig, C. J., R. R. Borys, S. McKelvey, and C.P. Dabney. 2008. Blacks Mountain Experimental 

Forest: bark beetle responses to differences in forest structure and application of 

prescribed fire in interior ponderosa pine. Canadian Journal of Forest Research 38: 924-

935.

Fettig, C. J., and S.R. McKelvey. 2010. Bark Beetle responses to stand structure and prescribed 

fire at Blacks Mountain Experimental Forest, California, USDA: 5-year data. Fire 

Ecology 6:26-41.

Fettig, C., K. Klepzig, R.F. Billings, A.S. Munson, T.E. Nebeker, J.F. Negron, and J. T. Nowak. 

2007. The effectiveness of vegetation management practices for prevention and control of 

bark beetle infestations in coniferous forest of the western and southern United States. 

Forest Ecology and Management 238: 24-53.

Fettig, C.J. 2012. Managing Sierra Nevada Forests. USDA Forest Service, Pacific Southwest 

Research Station, General Technical Report, PSW-GTR-237. In Chapter 2: Forest Health 

and Bark Beetles., edited by M. North.

Finch, Deborah M. 2012. Climate change in grasslands, shrublands, and deserts of the interior 

American West: a review and needs assessment.

Finney, M.A., and S.S. McAllister. 2011. A review of fire interactions and mass fires. Journal of 

Combustion.

Fites-Kaufman, J. A. 2014. Fire Behavior Case Study: 50,000 acre Run on King Fire, September 

17th, 2014. Vallejo, CA: USDA Forest Service.

Fites-Kaufman, J. A. 2015. Personal conversation of Dr. Jo Ann Fites-Kaufman Forest Service 

Ecologist with Calvin Farris, National Park Service employee, concerning analysis of fire 

severity data and fire size. Edited by C. Farris.

Fites-Kaufman, J.A., A.F. Bradley, and A.G. Merrill. 2006. Fire and plant interactions. Edited by 

N. G. Sugihara, J. W. van Wagtendonk, K. E. Shaffer, J. Fites-Kaufman and A. E. Thode, 

Fire in California’s Ecosystems. Berkeley, CA: University of California Press.

Fites-Kaufman, Jo Ann, Erin Noonan, and David Ramirez. 2005. Evaluation of Wildland Fire Use 

Fires on the Sequoia and Stanislaus National Forests in 2003: Effects in Relation to 

Historic Regimes and Resource Benefits.

Fites-Kaufman, Jo Ann, Phil Rundel, Nathan Stephenson, and Dave A Weixelman. 2007. 

Montane and subalpine vegetation of the Sierra Nevada and Cascade ranges, Terrestrial 

Vegetation of California. Berkeley, CA: University of California Press.

Fleischner, T.L. 1994. Ecological costs of livestock grazing in Western North America. Cons. 

Biol. 8 (3):629-644.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

703

Fogg, Alissa M, L Jay Roberts, and Ryan D Burnett. 2014. Occurrence patterns of Black-backed 

Woodpeckers in green forest of the Sierra Nevada Mountains, California, USA. Avian 

Conservation and Ecology 9 (3).

Fontaine, J.B., and P.L. Kennedy. 2012. Meta-analysis of avian and small-mammal response to 

fire severity and fire surrogate treatments in U.S. fire-prone forests. Ecological 

Applications 22 (5):1547-1561.

Food and Agriculture Organization of the United Nations, FAO. 2015. Social protection for 

building resilience of forest dependent people, Discussion No. 114: Global Forum on 

Food Security and Nutrition.

Forister, Matthew L., Andrew C. McCall, Nathan J. Sanders, James A. Fordyce, James H. Thorne, 

Joshua O’Brien, David P. Waetjen, and Arthur M. Shapiro. 2010. Compounded effects of 

climate change and habitat alteration shift patterns of butterfly diversity. Proceedings of 

the National Academy of Sciences 107 (5):2088-2092. doi: 10.1073/pnas.0909686107.

Franklin, J. F., and J. Fites-Kaufman. 1996. Assessment of late-successional forests of the Sierra 

Nevada. Sierra Nevada Ecosystem Project: Final Report to Congress. Volume II: 

Assessments and scientific basis for management options: 627-635.

Franklin, Jerry F, and K Norman Johnson. 2012. A restoration framework for federal forests in the 

Pacific Northwest. Journal of Forestry 110 (8):429-439.

Franklin, Jerry F., Thomas A. Spies, Robert Van Pelt, Andrew B. Carey, Dale A. Thornburgh, 

Dean Rae Berg, David B. Lindenmayer, Mark E. Harmon, William S. Keeton, David C. 

Shaw, Ken Bible, and Jiquan 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 (1–3):399-423. doi: 

http://doi.org/10.1016/S0378-1127(01)00575-8.

Freitas, M. R., L. M. Roche, D. Weixelman, and K. W. Tate. 2014. Montane Meadow Plant 

Community Response to Livestock Grazing. Environmental Management:1-8.

Frissell, C.A., M. Scurlock, and R. Kattelmann. 2012. SNEP Plus 15 Years: Ecological and 

conservation science for freshwater resource protection and federal land management in 

the Sierra Nevada. Summary Report for Scientific Workshop, Davis, CA. Pacific Rivers 

Council Science Publication 12-001. Portland, Oregon, USA.

Fryjoff-Hung, A., and J.H. Viers. 2013. Sierra Nevada meadow hydrology assessment. Final 

project report to the USDA Forest Service Pacific Southwest Region. Davis, CA: 

University of California, Davis.

Fulé, Peter Z, Thomas W Swetnam, Peter M Brown, Donald A Falk, David L Peterson, Craig D 

Allen, Gregory H Aplet, Mike A Battaglia, Dan Binkley, and Calvin Farris. 2014. 

Unsupported inferences of high-severity fire in historical dry forests of the western 

United States: response to Williams and Baker. Global Ecology and Biogeography 23 

(7):825-830.

Furnish, J. 2013. Management indicator species: Aquatic invertebrate monitoring report. Vallejo, 

CA: U.S. Department of Agriculture, Forest Service.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

704

Gabriel, M. W., L. W. Woods, R. Poppenga, R. A. Sweitzer, C. Thompson, S. M. Matthews, J. M. 

Higley, S. M. Keller, K. Purcell, R. H. Barrett, G. M. Wengert, B. N. Sacks, and D. L. 

Clifford. 2012. Anticoagulant Rodenticides on our Public and Community Lands: Spatial 

Distribution of Exposure and Poisoning of a Rare Forest Carnivore. Plos One 7 (7). doi: 

10.1371/journal.pone.0040163.

Gardali, Thomas, Nathaniel E Seavy, Ryan T DiGaudio, and Lyann A Comrack. 2012. A climate 

change vulnerability assessment of California's at-risk birds. PLoS One 7 (3):e29507.

Gilbert-Norton, Lynne, Ryan Wilson, John R Stevens, and Karen H Beard. 2010. A meta-analytic 

review of corridor effectiveness. Conservation biology 24 (3):660-668.

Glick, P., B. A. Stein, and N. A. Edelson, editors. 2011. Scanning the Conservation Horizon: A 

Guide to Climate Change Vulnerability Assessment. National Wildlife Federation, 

Washington, D.C. 

Green, G. A., H. Bombay, and M. Morrison. 2003. Conservation assessment of the willow 

flycatcher in the Sierra Nevada. Unpublished Report. Foster Wheeler Environmental 

Corporation; USDA, Forest Service, Pacific Southwest Region and Intermountain 

Region. Vallejo, CA. 67 pp.

Grenfell, Jr., W.E. 1988. Montane Riparian. California Department of Forestry and Fire 

Protection. https://www.wildlife.ca.gov/Data/CWHR/Wildlife-Habitats.

Griffin, D, and KJ Anchukaitis. 2014. How unusual is the 2012-2014 California drought? 

Geophysical Research Letters 41 (24):9017-9023. doi: 10.1002/2014GL062433.

Gross, S., and M. Coppoletta. 2013. Natural range of variation (NRV) for meadows in the 

bioregional assessment area, including the Sierra Nevada, southern Cascades, and Modoc 

and Inyo National Forests. Vallejo, CA: USDA Forest Service, Pacific Southwest Region.

Gruen, Gruen and Associates. 2010. A county at risk: The socio-economic impacts of the 

proposed Yucca Mountain High-Level Nuclear Waste Repository on Inyo County 

California. A Report to the County of Inyo California.

Guilliams, C.M., and J. Clines. 2012. Conservation assessment for Calyptridium pulchellum

(Eastw.) Hoover – Mariposa pussypaws. Vallejo, CA: USDA Forest Service, Pacific 

Southwest Region.

Gutierrez, R.J., P.N. Manley, and P.A. Stine. 2016. The California spotted owl: current state of 

knowledge DRAFT-General Technical Report. Albany, California: USDA Forest Service.

Hall, F.A., S.C. Gardner, and D.S. Blankenship. 2008. Greater Sage-Grouse (Centrocercus 

urophasianus). In California Bird Species of Special Concern: A ranked assessment of 

species, subspecies, and distinct populations of birds of immediate conservation concern 

in California, 96-101. Western Field Ornithologists.

Hanberry, B. B., R. F. Noss, H. D. Safford, S. K. Allison, and D. C. Dey. 2015. Restoration Is 

preparation for the future. Journal of Forestry 113:425-429.

Harris, Lucas, and Alan Taylor. 2017. Previous burns and topography limit and reinforce fire 

severity in a large wildfire. Ecosphere 8 (11):e02019. doi: 10.1002/ecs2.2019.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

705

Hastie, L. C., and K. A. Toy. 2008. Changes in density, age structure and age-specific mortality in 

two western pearlshell (Margaritifera falcata) populations in Washington (1995–2006). 

Aquatic Conservation: Marine and Freshwater Ecosystems 18:671-678.

Haufler, Jonathan B. 1999. Strategies for conserving terrestrial biological diversity. Edited by R. 

K. Baydack, H. Campa, III and J. B. Haufler, Practical Approaches to the Conservation of 

Biological Diversity. Covelo, CA: Island Press.

Hauptfeld, R.S., and J.M. Kershner. 2014a. Sierra Nevada ecosystem vulnerability assessment 

briefing: Aquatic. Version 1.0. . Bainbridge Island, WA: EcoAdapt.

Hauptfeld, R.S., and J.M. Kershner. 2014b. Sierra Nevada individual species vulnerability 

assessment briefing: American marten. EcoAdapt. 

http://ecoadapt.org/data/documents/SierraNevada_Marten_VABriefing_9Oct2014.pdf.

Hayes, C., C.J. Fettig, and L.D. Merrill. 2009. Evaluation of multiple funnel traps and stand 

characteristics for estimating western pine beetle-caused tree mortality. Journal of 

Economic Entomology (102):2170–2182.

Hayward, G.D., C.H. Flather, M.M. Rowland, R. Terney, K. Mellen-McLean, K.D. Malcolm, C 

McCarthy, and D.A. Boyce. 2016. Washington, D.C.

Economic Porfile System - Human Dimensions Toolkit (EPS-HDT), 

http://headwaterseconomics.org/tools/eps-hdt.

Heller, Nicole E, and Erika S Zavaleta. 2009. Biodiversity management in the face of climate 

change: a review of 22 years of recommendations. Biological conservation 142 (1):14-32.

Hicke, JA, MC Johnson, LHD Jane, and HK Preisler. 2012. Effects of bark beetle-caused tree 

mortality on wildfire. Forest Ecology and Management 271:81-90. doi:

10.1016/j.foreco.2012.02.005.

Hicke, Jeffrey A, Jesse A Logan, James Powell, and Dennis S Ojima. 2006. Changing 

temperatures influence suitability for modeled mountain pine beetle (Dendroctonus 

ponderosae) outbreaks in the western United States. Journal of Geophysical Research: 

Biogeosciences 111 (G2).

Higgs, E., D.A. Falk, A. Guerrini, M. Hall, J. Harris, R.J. Hobbs, S.T. Jackson, J.M. Rhemtulla, 

and W. Throop. 2014. The changing role of history in restoration ecology. Frontiers in 

Ecology and the Environment 12 (9):499-506.

Hoffman, J., K. Roby, and B. Bohm. 2013. Effects of Meadow Restoration on Stream Flow in the 

Feather River Watershed. In A Review Based on Monitoring Data and Pertinent 

Research: The Feather River Coordinated Resource Management (CRM) Steering 

Committee.

Holmes, T. P., R.J. Huggett Jr, and A.L. Westerling. 2008. Statistical analysis of large wildfires.

In: The Economics of Forest Disturbances. Springer Netherlands.

Holmes, Thomas, J Bowker, Jeffrey Englin, Evan Hjerpe, John Loomis, Spencer Phillips, and 

Robert Richardson. 2015. A Synthesis of the Economic Values of Wilderness. Journal of 

Forestry 114 (3):9.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

706

Holthausen, R. 2002. White paper on managing for population viability. USDA Forest Service, 

Washington DC, USA.

Hood, S.M., C.W. McHugh, K.C. Ryan, and others. 2007. Evaluation of post-fire tree mortality 

model for western USA conifers. International Journal of Wildland Fire 16:679-689.

Hopkinson, P., M. Hammond, J. Bartolome, M. Brooks, and others. 2013. A natural resource 

condition assessment for Sequoia and Kings Canyon National Parks: Appendix 13–

Meadows. In Natural Resource Report NPS/SEKI/NRR–2013/665.13. National Park 

Service, Fort Collins, Colorado. Fort Collins, Colorado: National Park Service.

Hovingh, P. 2004. Intermountain freshwater mollusks, USA (Margaritifera, Anodonta, Gonidea, 

Valvata, Ferrissia): geography, conservation, and fish management implications. 

Monographs of the Western North American Naturalist 2 (1):109-135.

Howard, J. K. 2008. Strategic inventory of freshwater mussels in the northern Sierra Nevada 

province. In Report prepared by Western Mollusk Sciences (San Francisco, California) 

for USDA Forest Service, Vallejo, California. Vallejo, CA: US Forest Service.

Howard, Jeanette K., Kirk R. Klausmeyer, Kurt A. Fesenmyer, and others. 2015. Patterns of 

freshwater species richness, endemism, and vulnerability in California. PloS one 10 

(7):20.

Howard, Jeanette K., and Kurt M. Cuffey. 2006. Factors controlling the age structure of 

Margaritifera falcata in 2 northern California streams. Journal of the North American 

Benthological Society 25 (3):677-690. doi: 10.1899/0887-

3593(2006)25[677:FCTASO]2.0.CO;2.

Hull, J.M., J.J. Keane, W.K. Savage, S.A. Godwin, J. Shafer, E.P. Jepsen, R. Gerhardt, C. 

Stermer, and H.B. Ernest. 2010. Range-wide genetic differentiation among North 

American great gray owls (Strix nebulosa) reveals a distinct lineage restricted to the 

Sierra Nevada, California. Molecular Phylogenetics and Evolution 56:212-221.

Hunsaker, C., and J.W. Long. 2014. Forested riparian areas. Chapter 6.2. In Science synthesis to 

support socioecological resilience in the Sierra Nevada and southern Cascade Range, 

edited by Jonathan W. Long, Lenya Quinn-Davidson and Carl N. Skinner. Albany, CA: 

U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station.

Hunsaker, C., J.W. Long, and D. Herbst. 2014a. Watershed and stream ecosystems. Chapter 6.1. 

In Science synthesis to support socioecological resilience in the Sierra Nevada and 

southern Cascade Range, edited by Jonathan W. Long, Lenya Quinn-Davidson and Carl 

N. Skinner. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Research Station.

Hunsaker, Carolyn T., Jonathan W. Long, and David B. Herbst. 2014b. Watershed and stream 

ecosystems. Science Synthesis to Support Socioeco logical Resilience in the Sierra 

Nevada and Southern Cascade Range. General Technical Report PSW-GTR-247 1:265-

322.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

707

Hunsaker, Carolyn T., and Daniel G. Neary. 2012. Sediment loads and erosion in forest headwater 

streams of the Sierra Nevada, California. International Association of Hydrological 

Sciences, General Assembly, Melbourne.

Huntzinger, M. 2003. Effects of fire management practices on butterfly diversity in the forested 

western United States. Biological Conservation 113:1-12.

Hurteau, Matthew D., George W. Koch, and Bruce A. Hungate. 2008. Carbon protection and fire 

risk reduction: toward a full accounting of forest carbon offsets. Frontiers in Ecology and 

the Environment 6 (9):493-498.

Hurteau, Matthew D, and Malcolm North. 2010. Carbon recovery rates following different 

wildfire risk mitigation treatments. Forest Ecology and Management 260 (5):930-937.

Hurteau, Matthew D, Anthony L Westerling, Christine Wiedinmyer, and Benjamin P Bryant. 

2014. Projected effects of climate and development on California wildfire emissions 

through 2100. Environmental science & technology 48 (4):2298-2304.

Hurteau, Matthew, and Malcolm North. 2009. Fuel treatment effects on tree-based forest carbon 

storage and emissions under modeled wildfire scenarios. Frontiers in Ecology and the 

Environment 7 (8):409-414.

ICF Jones & Stokes. 2010. Hatchery and Stocking Program Environmental Impact 

Report/Environmental Impact Statement. Final. State Clearinghouse 2008082025. 

Sacramento, California: Prepared for the California Department of Fish and Game and

U.S. Fish and Wildlife Service.

Intergovernmental Panel on Climate Change. 2014. Climate change 2013: the physical science 

basis: Working Group I contribution to the Fifth assessment report of the 

Intergovernmental Panel on Climate Change. Edited by Thomas Stocker: Cambridge 

University Press.

Inyo County. 2015. County Analysis of Economic Contributions from Wilderness-Hiking, 

Grazing, OHV, Hunting and Fishing.

Isaak, D.J., Young, M.K., Nagel, D.E., Horan, D.L. and Groce, M.C.,. 2015. The cold-water 

climate shield: delineating refugia for preserving salmonid fishes through the 21st 

century. . Global Change Biology: 21(7), pp. 2540-2553.

Isaak, Daniel J., and Bruce E. Rieman. 2013. Stream isotherm shifts from climate change and 

implications for distributions of ectothermic organisms. Global Change Biology 19 

(3):742-751.

Isaak, D.J., S. Wollrab, D. Horan, and G. Chandler. 2012. Climate change effects on stream and 

river temperatures across the northwest US from 1980–2009 and implications for 

salmonid fishes. Climatic Change 113 (2):499-524.

Jackson, Stephen T., and Richard J. Hobbs. 2009. Ecological restoration in the light of ecological 

history. Science (New York, N.Y.) 325 (5940):567-9.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

708

Jenkins, M.J., E. Hebertson, W. Page, and C.A. Jorgensen. 2008. Bark beetles, fuels, fires and 

implications for forest management in the Intermountain West. Forest Ecology and 

Management 254 (1):16-34. doi: 10.1016/j.foreco.2007.09.045.

Jenkins, MJ, WG Page, EG Hebertson, and ME 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 275:23-34. doi: 

10.1016/j.foreco.2012.02.036.

Jepsen, S., C. LaBar, and J. Arnock. 2012. Margaritifera falcata (Gould, 1850) Western pearlshell 

Bivalvia: Margaritiferidae. In Species Profile: Western Pearlshell (Margaritifera falcata), 

edited by The Xerces Society for Invertebrate Conservation: The Xerces Society for 

Invertebrate Conservation.

Jepson Flora Project. 2015. Jepson EFlora. Accessed May 29. 

http://ucjeps.berkeley.edu/IJM.html.

Jernigan, Valarie Blue Bird, Alicia L. Salvatore, Dennis M. Styne, and Marilyn Winkleby. 2012. 

Addressing food insecurity in a Native American reservation using community-based 

participatory research. Health Education Research 27 (4):645-655. doi: 

10.1093/her/cyr089.

Jones, Rachel O, Jeanne C Chambers, David I Board, Dale W Johnson, and Robert R Blank. 

2015. The role of resource limitation in restoration of sagebrush ecosystems dominated 

by cheatgrass (Bromus tectorum). Ecosphere 6 (7):1-21.

Jones, Terry L, and Kathryn Klar. 2007. California prehistory: Colonization, culture, and 

complexity: Rowman Altamira.

Kalinowski, R., M.D. Johnson, and A.C. Rich. 2014a. Habitat relationships of great gray owl prey 

in meadows of the Sierra Nevada Mountains. Wildlife Society Bulletin 38:547-556.

Kane, Van R, James A Lutz, Susan L Roberts, Douglas F Smith, Robert J McGaughey, Nicholas A 

Povak, and Matthew L Brooks. 2013. Landscape-scale effects of fire severity on mixedconifer and red fir forest structure in Yosemite National Park. Forest Ecology and 

Management 287:17-31.

Kane, Van R, Malcolm P North, James A Lutz, Derek J Churchill, Susan L Roberts, Douglas F 

Smith, Robert J McGaughey, Jonathan T Kane, and Matthew L Brooks. 2014. Assessing 

fire effects on forest spatial structure using a fusion of Landsat and airborne LiDAR data 

in Yosemite National Park. Remote Sensing of Environment 151:89-101.

Kattelmann, R., and M. Embury. 1996. Riparian areas and wetlands, Sierra Nevada Ecosystem 

Project. In Final report to Congress, Vol. II, Assessments and scientific basis for 

management options. Davis, CA: University of California, Centers for Water and 

Wildland Resources.

Katz, Jacob, Peter B Moyle, Rebecca M Quiñones, Joshua Israel, and Sabra Purdy. 2013. 

Impending extinction of salmon, steelhead, and trout (Salmonidae) in California. 

Environmental Biology of Fishes 96 (10-11):1169-1186.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

709

Kauffman, J. Boone, and W. C. Krueger. 1984. Livestock Impacts on Riparian Ecosystems and 

Streamside Management Implications... A Review. Journal of Range Management 37 

(5):430-438. doi: 10.2307/3899631.

Keane, J.J. 2014. California spotted owl: Scientific considerations for forest planning. In Chapter 

7.2 in Science synthesis to support sociological resilience in the Sierra Nevada and 

Southern Cascade Range: USDA Forest Service.

Keane, R. E., D. Tomback, C. Aubrey, A. Bower, E. Campbell, M. Jenkins, M. Manning, S. 

McKinney, M. Murray, D. Perkins, D. Reinhart, C. Ryan, A. Schoettle, and S. C. 2012. A 

Range-wide restoration strategy for whitebark pine (Pinus albicaulis). RMRS-GTR-279.

Fort Collins, CO: U.S. Dept. of Agriculture, Forest Service, Rocky Mountain Research 

Station.

Keeley, Jon E. 2006. Fire management impacts on invasive plants in the western United States. 

Conservation biology : the journal of the Society for Conservation Biology 20 (2):375-

84.

Kelley, R. 2015. Regional summary of BMP effectiveness matrix, Inyo National Forest. Vallejo, 

CA: USDA Forest Service, Pacific Southwest Regional Office.

Kershner, JM. 2014. A climate change vulnerability assessment for focal resources of the Sierra 

Nevada. EcoAdapt, Bainbridge Island, Washington, USA.

Kilgore, B. M., and R. W. Sando. 1975. Crown-fire potential in a sequoia forest after prescribed 

burning. Forest Science 21:83-87.

Kindlmann, Pavel, and Francoise Burel. 2008. Connectivity measures: a review. Landscape 

ecology 23 (8):879-890.

Knapp, E. E., M. P. North, M. Benech, and B. L. Estes. 2012. The variable-density thinning study 

at Stanislaus-Tuolumne Experimental Forest. In Managing Sierra Nevada forests. General 

Technical Report, edited by M. P. North.

Knapp, EE, and MW Ritchie. 2016. Response of understory vegetation to salvage logging 

following a high-severity wildfire. Ecosphere 7 (11). doi: 10.1002/ecs2.1550.

Knapp, Eric, Jamie Lyderson, Malcolm North, and Brandon Collins. 2017. Efficacy of variable 

density thinning and prescribed fire for restoring forest heterogeneity to mixed-conifer 

forest in the central Sierra Nevada, CA. Forest Ecology and Management 406:228-241. 

doi: 10.1016/j.foreco.2017.08.028.

Knapp, R. A. 2017. Against the Odds: Recovering Endangered Mountain Yellow-legged Frogs in 

the Sierra Nevada. California/Nevada Amphibian Populations Task Force 2017 Meeting:

14.

Knapp, R. A., and K. R. Matthews. 2000a. Nonnative fish introductions and the decline of the 

mountain yellow-legged frog from within protected areas. Conservation Biology 14 

(2):428-438. doi: 10.1046/j.1523-1739.2000.99099.x.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

710

Knapp, R. A., and V. T. Vredenburg. 1996. Spawning by California golden trout: Characteristics 

of spawning fish, seasonal and daily timing, redd characteristics, and microhabitat 

preferences. Transactions of the American Fisheries Society 125 (4):519-531. doi: 

10.1577/1548-8659(1996)125<0519:sbcgtc>2.3.co;2.

Knapp, RA, and Kathleen R Matthews. 2000b. Effects on nonnative fishes on wilderness lake 

ecosystems in the Sierra Nevada and recommendations for reducing impacts.

Knapp, Roland A. 2005. Effects of nonnative fish and habitat characteristics on lentic 

herpetofauna in Yosemite National Park, USA. Biological Conservation 121 (2):265-279.

Knapp, Roland A., Daniel M. Boiano, and Vance T. Vredenburg. 2007. Removal of nonnative fish 

results in population expansion of a declining amphibian (mountain yellow-legged frog, 

Rana mucosa). Biological Conservation 135 (1):11-20. doi: 

http://doi.org/10.1016/j.biocon.2006.09.013.

Knapp, Roland A., and Kathleen R. Matthews. 2000c. Non-Native Fish Introductions and the 

Decline of the Mountain Yellow-Legged Frog from within Protected Areas 

Introducciones de Peces No-nativos y Disminuciones de la Rana de Montaña de Patas 

Amarillas Dentro de Áreas Protegidas. Conservation Biology 14 (2):428-438. doi: 

10.1046/j.1523-1739.2000.99099.x.

Knowles, Noah, and Daniel R Cayan. 2002. Potential effects of global warming on the 

Sacramento/San Joaquin watershed and the San Francisco estuary. Geophysical Research 

Letters 29 (18).

Kondolf, G. M., R. Kattelmann, M. Embury, and D. C. Erman. 1996. Status of riparian habitat. 

In: Sierra Nevada Ecosystem Project: Final report to Congress, vol. II, Assessments and 

scientific basis for management options. Pages 1009-1030 in University of California, 

Centers for Water and Wildland Resources, Davis, CA.

Kopp, Christopher W, and Elsa E Cleland. 2014. Shifts in plant species elevational range limits 

and abundances observed over nearly five decades in a western North America mountain 

range. Journal of Vegetation Science 25 (1):135-146.

Krasnow, KD, and SL Stephens. 2015. Evolving paradigms of aspen ecology and management: 

impacts of stand condition and fire severity on vegetation dynamics. Ecosphere 6 (1). doi: 

10.1890/ES14-00354.1.

Kroeber, Alfred Louis. 1925. Handbook of the Indians of California. Vol. 78: Courier 

Corporation.

Kurcera, T. E., W. J. Zielinski, and R. H. Barrett. 1996. Current distribution of the American 

marten, Martes americana, in California. California Fish and Game 81:96-103.

Lake, Frank K. 2011. Working with American Indian tribes on wildland fires: protecting cultural 

heritage sites in northwestern California. Fire Management Today 71 (3):14-21.

Lake, Frank K. 2013. Historical and cultural fires, tribal management and research issue in 

Northern California: Trails, fires and tribulations.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

711

Lake, Frank K, and Jonathan W Long. 2014a. Chapter 4.2-Fire and tribal cultural resources. In 

Science synthesis to support socioecological resilience in the Sierra Nevada and southern 

Cascade Range, edited by Long et al.

Lake, Frank K, and Jonathan W Long. 2014b. Fire and tribal cultural resources. In Science 

synthesis to support socioecological resilience in the Sierra Nevada and southern Cascade 

Range. Albany, CA: USDA Forest Service.

Landscape Fire and Resource Management Planning Tools Data version LF_1.3.0 

Landres, P., S. Boutcher, L. Merigliano, and others. 2005. Monitoring selected conditions related 

to wilderness character: a national framework. USDA Forest Service Rocky Mountain 

Research Station General Technical Report. Fort Collins, CO.

Landres, P. B., P. Morgan, and F. J. Swanson. 1999a. Overview of the use of natural variability 

concepts in managing ecological systems. Ecological Applications 9:1179-1188.

Landres, Peter B, Penelope Morgan, and Frederick J Swanson. 1999b. Overview of the use of 

natural variability concepts in managing ecological systems. Ecological Applications 9 

(4):1179-1188.

Larson, Andrew J, Kyle C Stover, and Christopher R Keyes. 2012. Effects of restoration thinning 

on spatial heterogeneity in mixed-conifer forest. Canadian Journal of Forest Research 42 

(8):1505-1517.

Latham, P., and J. Tappeiner. 2002. Response of old-growth conifers to reduction in stand density 

in western Oregon forests. Tree physiology 22 (2-3):137-146. doi: 10.1093/treephys/22.2-

3.137.

Lawler, Joshua J, Hugh D Safford, and Evan H Girvetz. 2012. Martens and fishers in a changing 

climate. Edited by K. B. Aubry, Biology and Conservation of Martens, Sables, and 

Fishers: a New Synthesis. Ithaca, NY: Cornell University Press.

Lee, D.E., and M.L. Bond. 2015. Occupancy of California spotted owl sites following a large fire 

in the Sierra Nevada, California. The Condor 117:228-236.

Lee, D.E., M.L. Bond, M.I. Borchert, and R. Tanner. 2013. Influence of fire and salvage logging 

on site occupancy of spotted owls in the San Bernardino and San Jacinto Mountains of 

Southern California. The Journal of Wildlife Management 77 (7):1327-1341.

Lee, D.E., M.L. Bond, and R.B. Siegel. 2012. Dynamics of breeding-season site occupancy of the 

California spotted owl in burned forests. The Condor 114 (4):792-802.

Lenihan, J. M., D. Bachelet, R. P. Neilson, and R. Drapek. 2008. Response of vegetation 

distribution, ecosystem productivity, and fire to climate change scenarios for California. 

Climatic Change 87:S215-S230.

Lenihan, J. M., R. Drapek, D. Bachelet, and R. P. Neilson. 2003. Climate change effects on 

vegetation distribution, carbon, and fire in California. Ecological Applications 13:1667-

1681.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

712

Lentz, David C., and Mark A. Clifford. 2014. A synopsis of recent history of California’s inland 

trout management programs: litigation and legislation. California Fish and Game 100 

(4):727-739.

Levine, C.R., C.V. Cogbill, B.M. Collins, and others. 2017. Evaluating a new method for 

reconstructing forest conditions from General Land Office survey records. Ecological 

Applications 27 (5):1498-1513. doi: 10.1002/eap.1543/full.

Lindenmayer, David B, and Joern Fischer. 2013. Habitat fragmentation and landscape change: an 

ecological and conservation synthesis: Island Press.

Liu, X. X., L. G. Huey, R. J. Yokelson, and others. 2017. Airborne measurements of western US 

wildfire emissions: Comparison with prescribed burning and air quality implications. 

Journal of Geophysical Research-Atmospheres 122 (11):6108-6129. doi: 

10.1002/2016jd026315.

Loarie, Scott R, Benjamin E Carter, Katharine Hayhoe, Sean McMahon, Richard Moe, Charles A 

Knight, and David D Ackerly. 2008. Climate change and the future of California's 

endemic flora. PloS one 3 (6):e2502.

Loffland, H.L., R.B. Siegel, R.D. Burnett, B.R. Campos, T. Mark, and Stermer. C. 2014. Point 

Reyes Station, CA.

Logan, Jesse A, Jacques Regniere, and James A Powell. 2003. Assessing the impacts of global 

warming on forest pest dynamics. Frontiers in Ecology and the Environment 1 (3):130-

137.

Long, J.W., L. Quinn-Davidson, and C.N. Skinner. 2014a. Chapter 1.2 Integrative approaches: 

Promoting socioecological resilience. In Science Synthesis to Support Socioecological 

Resilience in the Sierra Nevada and Southern Cascades, PSW-GTR-247, edited by J. W. 

Long, L. N. Quinn-Davidson and C. N. Skinner. Albany, CA: Pacific Southwest Research 

Station, USDA Forest Service.

Long, Jonathan, Leland Tarnay, and Malcolm North. 2017. Aligning smoke management with 

ecological and health management goals. Journal of Forestry 115:11. doi: 

https://doi.org/10.5849/jof.16-042.

Long, Jonathan W, Lenya Quinn-Davidson, and Carl N Skinner. 2014b. Science synthesis to 

support socioecological resilience in the Sierra Nevada and southern Cascade Range 

PSW-GTR-247, edited by J. W. Long, L. N. Quinn-Davidson and C. N. Skinner. Albany, 

CA: Pacific Southwest Research Station, USDA Forest Service.

Long, Jonathan W, Lenya Quinn-Davidson, and Carl N Skinner. 2014c. Science synthesis to 

support socioecological resilience in the Sierra Nevada and southern Cascade Range 

PSW-GTR-247, edited by J. W. Long, L. N. Quinn-Davidson and C. N. Skinner. Albany, 

CA: Pacific Southwest Research Station, USDA Forest Service.

Lubow, B. C. 2016. Memorandum 6 June 2016: Statistical analysis for 2015 horse and burro 

surveys in Bi-State sage-grouse area, Nevada and California. Centerville, VA: IIF Data 

Solutions, Inc.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

713

Lubow, B. C., and J. I. Ransom. 2007. Aerial population estimates of wild horses (Equus 

caballus) in the Adobe Town and Salt Wells Creek Herd Management Areas using an 

integrated simultaneous double-count and sightability bias correction technique. Edited 

by United States Geological Survey United States Department of the Interior.

Lubow, B. C., and J. I. Ransom. 2016. Practical Bias Correction in Aerial Surveys of Large 

Mammals: Validation of Hybrid Double-Observer with Sightability Method against 

Known Abundance of Feral Horse (Equus caballus) Populations. Plos One 11 (5). doi: 

10.1371/journal.pone.0154902.

Luce, Charles H, and Zachary A Holden. 2009. Declining annual streamflow distributions in the 

Pacific Northwest United States, 1948–2006. Geophysical Research Letters 36 (16).

Lydersen, Jamie M, Malcolm P North, Eric E Knapp, and Brandon M Collins. 2013. Quantifying 

spatial patterns of tree groups and gaps in mixed-conifer forests: reference conditions and 

long-term changes following fire suppression and logging. Forest Ecology and 

Management 304:370-382.

Lydersen, Jamie, and Malcolm North. 2012. Topographic variation in structure of mixed-conifer 

forests under an active-fire regime. Ecosystems 15 (7):1134-1146.

MacKenzie, Martin. 2014. Mountain Pine beetle is the best thing to happen to the whitebark pine 

on June Mountain. The Forest Biology Observer.

Magilligan, F. J., and P. F. McDowell. 1997. Stream channel adjustments following elimination of 

cattle grazing. Journal of the American Water Resources Association 33 (4):867-878. doi: 

10.1111/j.1752-1688.1997.tb04111.x.

Mahler, B. 2012. Tracking American Participation in Outdoor Recreation. In Outdoor recreation 

trends and futures: a technical document supporting the Forest Service 2010 RPA 

Assessment. Asheville, NC: USDA Forest Service Southern Research Station.

Mallek, C., H. D. Safford, and S. Sawyer. 2012. A summary of current trends and probable future 

trends in climate and climate-driven processes in the Sierra and Sequoia National Forests 

and the neighboring Sierra Nevada. Vallejo, CA: USDA Forest Service, Pacific 

Southwest Region Ecology Program.

Mallek, Chris, Hugh Safford, Joshua Viers, and Jay Miller. 2013. Modern departures in fire 

severity and area vary by forest type, Sierra Nevada and southern Cascades, California, 

USA. Ecosphere 4 (12):1-28.

Maloney, P. 2011. Incidence and distribution of white pine blister rust in the high-elevation 

forests of California. Forest Pathology 41: 308-316.

Manley, P.N., J.A. Fites-Kaufman, M.G. Barbour, M.D. Schlesinger, and D.M. Rizzo. 2000. 

Biological integrity. In Lake Tahoe watershed assessment, edited by D. D. Murphy and C. 

M. Knopp. Albany, CA: USDA Forest Service, Pacific Southwest Research Station.

Manley, PN, GE Brogan, C Cook, ME Flores, DG Fullmer, S Husare, TM Jimerson, LM Lux, 

ME McCain, and JA Rose. 1995. Sustaining ecosystems: a conceptual framework. San 

Francisco, CA: USDA Forest Service, Pacific Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

714

Mason, Larry, Germaine White, Gary Morishima, Ernesto Alvarado, Louise Andrew, Fred Clark, 

Mike Durglo, Jim Durglo, John Eneas, and Jim Erickson. 2012. Listening and learning 

from traditional knowledge and Western science: a dialogue on contemporary challenges 

of forest health and wildfire. Journal of Forestry 110 (4):187-193.

Mathewson, H.A., H.L. Loffland, M.L. Morrison, L. Vormwald, and C. Cocimano. 2007. 2007 

annual report and preliminary demographic analysis for willow flycatcher monitoring in 

the central Sierra Nevada, in partial fulfillment of cost share agreement 06-CR-11052007. 

Texas A&M University and USDA Forest Service, Tahoe National Forest.

Maurer, J. 2006. 2005 Great gray owl survey in Yosemite National Park. Yosemite National Park.

Mayer, K. E., and W. F. Laudenslayer Jr. 1988. A guide to wildlife habitats of California. State of 

Department of Fish and Game.

McAvoy, Leo, Paul Shirilla, and Joseph Flood. 2004a. American Indian gathering and recreation 

uses of National Forest, Proceedings of the 2004 Northeastern Recreation Research 

Symposium.

McAvoy, Leo, Paul Shirilla, and Joseph Flood. 2004b. American Indian gathering and recreation 

uses of national forests. In Proceedings of the 2004 Northeastern Recreation Research 

Symposium.

McCreedy, Chris. 2005. Mono Basin Willow Flycatcher Project: 2005 Progress Report. In Point 

Reyes Bird Observatory (Contrib. 1298). Stinson Beach, CA: Point Reyes Bird 

Observatory (Point Blue Conservation Science).

McCreedy, C., and R. Burnett. 2011. Recommendations to the Inyo National Forest to Sustain the 

Lower Rush Creek Willow Flycatcher (Empidonax traillii) Population. PRBO 

Contribution No. 1749. PRBO Conservation Science. Petaluma, CA.

McDonald, Dan, Tom McDonald, and Leo H McAvoy. 2000. Tribal wilderness research needs 

and issues in the United States and Canada. Wilderness science in a time of change 

conference. Vol. 2: Wilderness within the context of larger systems, Missoula, MT, 1999 

May 23–27.

McDowell, Nate, William T. Pockman, Craig D. Allen, David D. Breshears, Neil Cobb, Thomas 

Kolb, Jennifer Plaut, John Sperry, Adam West, David G. Williams, and Enrico A. Yepez. 

2008. Mechanisms of plant survival and mortality during drought: why do some plants 

survive while others succumb to drought? The New Phytologist 178 (4):719-39.

McDowell, NG, AP Williams, C Xu, WT Pockman, LT Dickman, S Sevanto, R Pangle, J 

Limousin, J Plaut, DS Mackay, J Ogee, JC Domec, CD Allen, RA Fisher, X Jiang, JD 

Muss, DD Breshears, SA Rauscher, and C Koven. 2016. Multi-scale predictions of 

massive conifer mortality due to chronic temperature rise (vol 6, pg 295, 2016). Nature 

Climate Change 6 (11):1048-1048. doi: 10.1038/NCLIMATE3143.

McGinnis, Thomas W, Jon E Keeley, Scott L Stephens, and Gary B Roller. 2010. Fuel buildup 

and potential fire behavior after stand-replacing fires, logging fire-killed trees and 

herbicide shrub removal in Sierra Nevada forests. Forest Ecology and Management 260 

(1):22-35.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

715

McIver, James, Mark Brunson, Steve Bunting, Jeanne Chambers, Paul Doescher, James Grace, 

April Hulet, Dale Johnson, Steve Knick, and Richard Miller. 2014. A synopsis of shortterm response to alternative restoration treatments in sagebrush-steppe: the SageSTEP 

Project. Rangeland Ecology & Management 67 (5):584-598.

McKelvey, K. S., C. N. Skinner, C. R. Chang, and Others. 1996. An overview of fire in the Sierra 

Nevada. In: Final report to Congress, vol. II, Assessments and scientific basis for 

management options. Pages 1033-1040. University of California, Centers for Water and 

Wildland Resources, Davis, CA.

Mckelvey, Kevin S, and James D Johnston. 1992. Historical perspectives on forests of the Sierra 

Nevada and the transverse ranges of southern California: Forest conditions at the turn of 

the century. In The California Spotted Owl: A Technical Assessment of its Current Status, 

edited by J. Verner, K.S. McKelvey, B.R. Noon, J.R. Gutierrez, G.I. Gould Jr and T.W. 

Beck. Albany, CA: USDA Forest Service, Pacific Southwest Research.

Menke, J. 1996. Volume I, Chapter 7: Rangelands, In: Sierra Nevada Ecosystem Project final 

report to Congress: Status of the Sierra Nevada. Davis, CA: University of California, 

Davis.

Merriam, K., C. A. Vallejo, Usda, and Service Pacific. 2013. Natural Range of Variation in 

Hardwood Vegetation in the Sierra Nevada, California over the Holocene Epoch.

Metcalfe, M., T. Koehler, A. Brough, and V. Emly. 2013. DRAFT Ecosystem services in the 

bioregion – A summary for forest plan revision. Working Paper. Vallejo, CA: U.S. 

Department of Agriculture, Forest Service, Pacific Southwest Region.

Metzger, J. P., and H. Décamps. 1997. The structural connectivity threshold: an hypothesis in 

conservation biology at the landscape scale. Acta Oecologica 18:1-12.

Meyer, M., B.M. Bulaon, M. MacKenzie, and H.D. Safford. 2014a. Mortality Monitoring in the 

Inyo National Forest 2013 Report. Vallejo, California: USDA Forest Service.

Meyer, M., B.M. Bulaon, M. MacKenzie, and H.D. Safford. 2014b. Whitebark pine (Pinus 

albicaulis) mortality monitoring in the Inyo National Forest 2013 Report. U.S. 

Department of Agriculture, Forest Service, Pacific Southwest Region.

Meyer, M. D. 2013. Natural range of variation (NRV) for red fir forests in the bioregional 

assessment area. Unpublished report. USDA Forest Service, Pacific Southwest Region. 

Vallejo, CA.

Meyer, M. D. 2013b. Natural range of variation (NRV) for subalpine forests in the bioregional 

assessment area. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.

Meyer, M. D. 2015a. Forest fire severity patterns of resource objective wildfires in the southern 

Sierra Nevada. Journal of Forestry 113:49-56.

Meyer, M. D. 2015b. Natural range of variation (NRV) for red fir forests in the bioregional 

assessment area. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.

Meyer, M. D. 2015c. Natural range of variation (NRV) for subalpine forests in the bioregional 

assessment area. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

716

Meyer, M. D., B. Estes, B. Bulaon, and M. MacKenzie. 2010. Reference Conditions in 

Contemporary Sierra Nevada Red Fir Forests with an Active Fire Regime. In Investigator 

Annual Report: Department of Interior, National Park Service.

Meyer, M. D., H. Safford, and S. Sawyer. 2012. A summary of current trends and probable future 

trends in climate and climate-driven processes in the Sierra National Forest and the 

neighboring Sierra Nevada. Forest Service, Pacific Southwest Region. Vallejo, CA.

Meyer, Marc D, Susan L Roberts, Robin Wills, Matthew Brooks, and Eric M Winford. 2015. 

Principles of effective USA federal fire management plans. Fire Ecology 11 (2):59-83.

Meyer, Marc D, and Hugh D Safford. 2011. Giant sequoia regeneration in groves exposed to 

wildfire and retention harvest. Fire Ecology 7 (2):2-16.

Meyer, MD, B Bulaon, M MacKenzie, and HD Safford. 2016. Mortality, structure, and 

regeneration in whitebark pine stands impacted by mountain pine beetle in the southern 

Sierra Nevada. Canadian Journal of Forest Research 46 (4):572-581. doi: 10.1139/cjfr2015-0464.

Miles, S.R., and C.B Goudey. 1998. Ecological subregions of California: section and subsection 

descriptions. In Technical Paper. San Francisco, CA: Meyer, M. D. 2015c. Natural range 

of variation (NRV) for subalpine forests in the bioregional assessment area. USDA Forest 

Service, Pacific Southwest Region. Vallejo, CA.

Millar, Constance I, Nathan L Stephenson, and Scott L Stephens. 2007. Climate change and 

forests of the future: managing in the face of uncertainty. Ecological applications 17 

(8):2145-2151.

Millar, Constance I., and Nathan L. Stephenson. 2015. Temperate forest health in an era of 

emerging megadisturbance. Science (New York, N.Y.) 349 (6250):823-6.

Miller, C, and GH Aplet. 2016. Progress in Wilderness Fire Science: Embracing Complexity. 

Journal of Forestry 114 (3):373-383. doi: 10.5849/jof.15-008.

Miller, C., and D. L. Urban. 1999. Forest pattern, fire, and climatic change in the Sierra Nevada. 

Ecosystems 2: 76-87.

Miller, J. D., B. M. Collins, J. A. Lutz, S. L. Stephens, J. W. van Wagtendonk, and D. A. Yasuda. 

2012. Differences in wildfires among ecoregions and land management agencies in the 

Sierra Nevada region, California, USA. Ecosphere 3. USDA, Forest Service, Pacific 

Southwest Region. Vallejo, CA.

Miller, J. D., E. E. Knapp, C. H. Key, C. N. Skinner, C. J. Isbell, R. M. Creasy, and J. W. 

Sherlock. 2009. Calibration and validation of the relative differenced Normalized Burn 

Ratio (RdNBR) to three measures of fire severity in the Sierra Nevada and Klamath 

Mountains, California, USA. Remote Sensing of Environment 113 (3):645-656. doi: 

10.1016/j.rse.2008.11.009.

Miller, J. D., and H. Safford. 2012. Trends in wildfire severity 1984-2010 in the Sierra Nevada, 

Modoc Plateau and southern Cascades, California, USA. Fire Ecology 8 (3):41-57.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

717

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.

Miller, JD, and HD Safford. 2017. Corroborating evidence of a pre-Euro-American low-to 

moderate-severity fire regime in yellow pine-mixed conifer forests of the Sierra Nevada, 

California, USA. Fire Ecology 13(1):58-90. doi: 10.4996/fireecology.1301058.

Miller, R.R. 1973. Two new fishes, Gila bicolor snyderi and Catostomus fumeiventris, from the

Owens River Basin, California. Occasional Papers of the Museum of Zoology,

University of Michigan. Ann Arbor, Michigan. 667:1-19.

Miller, Richard F, Jeanne C Chambers, and Mike Pellant. 2014. A field guide for selecting the 

most appropriate treatment in sagebrush and pinon-juniper ecosystems in the Great 

Basin: Evaluating resilience to disturbance and resistance to invasive annual grasses, and 

predicting vegetation response. Fort Collins, CO: USDA Forest Service, Rocky Mountain 

Research Station.

Miller, Richard F, Jaime Ratchford, Bruce A Roundy, Robin J Tausch, April Hulet, and Jeanne 

Chambers. 2014. Response of conifer-encroached shrublands in the Great Basin to 

prescribed fire and mechanical treatments. Rangeland Ecology & Management 67 

(5):468-481.

Monleon, VJ, and HE Lintz. 2015. Evidence of Tree Species' Range Shifts in a Complex 

Landscape. Plos One 10 (1). doi: 10.1371/journal.pone.0118069.

Moore, Jonathan W., David B. Herbst, Walter N. Heady, and Stephanie M. Carlson. 2012. Stream 

community and ecosystem responses to the boom and bust of an invading snail. 

Biological Invasions 14 (11):2435-2446. doi: 10.1007/s10530-012-0240-y.

Moratto, M. J. 1984. California Archaeology. Orlando, FL: Academic Press, Inc.

Morgan, P., G.H. Aplet, J.B. Haufler, H.C. Humphries, M.M. Moore, and W.D. Wilson. 1994. 

Historical range of variability: a useful tool for evaluating ecosystem change. Journal of 

Sustainable Forestry 2 (1-2):87-111.

Moritz, Craig, James L Patton, Chris J Conroy, Juan L Parra, Gary C White, and Steven R 

Beissinger. 2008. Impact of a century of climate change on small-mammal communities 

in Yosemite National Park, USA. Science 322 (5899):261-264.

Moritz, Max A., and Scott L. Stephens. 2008. Fire and sustainability: considerations for 

California’s altered future climate. Climatic Change 87 (1):265-271. doi: 

10.1007/s10584-007-9361-1.

Morris, Daniel, and Margaret A Walls. 2009. Climate change and outdoor recreation resources.

Washington, DC. Resources for the Future.

Morrison, M. L., K. A. With, I. C. Timossi, W. M. Block, and K. A. Milne. 1987. Foraging 

behavior of bark-foraging birds in the Sierra-Nevada. Condor 89 (1):201-204. doi: 

10.2307/1368782.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

718

Mortenson, L.A., A.N. Gray, and D.C. Shaw. 2015. A forest health inventory assessment of red fir 

(Abies magnifica) in upper montane California. Ecoscience 22 (1):47-58. doi: 

10.1080/11956860.2015.1047142.

Moyle, Peter B. 2002. Inland fishes of California: revised and expanded. Univ of California 

Press. Berkeley, CA.

Moyle, Peter B, Jacob VE Katz, and Rebecca M Quiñones. 2011. Rapid decline of California’s 

native inland fishes: a status assessment. Biological Conservation 144 (10):2414-2423.

Moyle, Peter B., and Paul J. Randall. 1998. Evaluating the Biotic Integrity of Watersheds in the 

Sierra Nevada, California. Conservation Biology 12 (6):1318-1326. doi: 10.1111/j.1523-

1739.1998.97161.x.

National Association of Recreation Resource Planners. 2009. Principles of Recreation Resource 

Planning. Marienville, PA.

Neary, D.G., K.C. Ryan, L.F. DeBano, J.D. Landsburg, and J.K. Brown. 2005. Wildland fire in 

ecosystems: Effects of fire on soil and water. In General Tech Report. Ogdon, UT: USDA 

Forest Service. Rocky Mountain Research Station.

Nelson, D.D. 2016. Histopathology Report regarding Nelson' bighorn: Letter from Danielle 

Nelson, Pathologist and Necropsy Section Head, Washington Animal Disease Diagnostic 

Lab, Washington State University, to Dr. Peregrine Wolff, veterinarian with the Nevada 

Dept. of Wildlife. On file with US Forest Service, Pacific Southwest Region, Vallejo, CA.

Nielsen-Pincus, Max. 2010. The Employment and Economic Impacts of Forest and Watershed 

Restoration in Oregon. Edited by Cassandra Moseley: Ecosystem Workforce Program 

University of Oregon.

Noonan-Wright, Erin K., Tonja S. Opperman, Mark A. Finney, G. Thomas Zimmerman, Robert 

C. Seli, Lisa M. Elenz, David E. Calkin, and John R. Fiedler. 2011. Developing the US 

Wildland Fire Decision Support System. Journal of Combustion 2011. doi: 

10.1155/2011/168473.

North American Bird Conservation Initiative. 2011. The State of the Birds 2011 Report on Public 

Lands and Waters. U.S. Department of Interior. Washington, D.C.

North, M., J.Q. Chen, B. Oakley, B. Song, M. Rudnicki, A. Gray, and J. Innes. 2004. Forest stand 

structure and pattern of old-growth western hemlock/Douglas-fir and mixed-conifer 

forests. Forest Science 50 (3):299-311.

North, M, BM Collins, and S Stephens. 2012. Using Fire to Increase the Scale, Benefits, and 

Future Maintenance of Fuels Treatments. Journal of Forestry 110 (7):392-401. doi: 

10.5849/jof.12-021.

North, M. 2012a. Managing Sierra Nevada Forests. Albany, CA: USDA Forest Service.

North, M. 2012b. Managing Sierra Nevada forests. In General Technical Report. Albany, CA: 

U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

719

North, M. 2014. Forest ecology. In Science synthesis to support socioecological resilience in the 

Sierra Nevada and southern Cascade Range, edited by J.W. Long, L.N. Quinn-Davidson 

and C.N. Skinner. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Research Station.

North, M., B. M. Collins, H. D. Safford, and N. L. Stephenson. 2012. Montane Forests. Edited by 

H. A. Mooney and E. S. Zavaleta. Vol. 110, Ecosystems of California. Berkeley CA.

Univ. California Press.

North, M., J. Innes, and H. Zald. 2007. Comparison of thinning and prescribed fire restoration 

treatments to Sierran mixed-conifer historic conditions. Canadian Journal of Forest 

Research-Revue Canadienne De Recherche Forestiere 37:331-342.

North, Malcolm, April Brough, Jonathan Long, Brandon Collins, Phil Bowden, Don Yasuda, Jay 

Miller, and Neil Sugihara. 2015. Constraints on mechanized treatment significantly limit 

mechanical fuels reduction extent in the Sierra Nevada. Journal of Forestry 113 (1):40-

48.

North, Malcolm P, and Matthew D Hurteau. 2011. High-severity wildfire effects on carbon stocks 

and emissions in fuels treated and untreated forest. Forest Ecology and Management 261 

(6):1115-1120.

North, Malcolm P, Kip M. Van de Water, Scott L. Stephens, and Brandon M. Collins. 2009. 

Climate, rain shadow, and human-use influences on fire regimes in the eastern Sierra 

Nevada, California, USA. Fire Ecology 5(3): 17-31.

North, M., P. A. Stine, K. L. O’Hara, W. J. Zielinski, and S. L. Stephens. 2009. An ecosystems 

management strategy for Sierra mixed-conifer forests, with addendum. General technical 

report PSW-GTR-220. U.S. Department of Agriculture, Forest Service, Pacific Southwest 

Research Station, Albany, California, USA.

Noss, Reed F, Jerry F Franklin, William L Baker, Tania Schoennagel, and Peter B Moyle. 2006. 

Managing fire-prone forests in the western United States. Frontiers in Ecology and the 

Environment 4 (9):481-487.

Null, S. E., J. H. Viers, M. L. Deas, S. K. Tanaka, and J. F. Mount. 2013. Stream temperature 

sensitivity to climate warming in California’s Sierra Nevada: impacts to coldwater 

habitat. Climatic Change (116):149-170.

Null, Sarah, J.H. Viers, M. Deas, S. Tanaka, and J. Mount. 2010. Stream temperature sensitivity 

to climate warming in California's Sierra Nevada. Climatic Change 116(1):149-170.

Nydick, K., and C. Sydoriak. 2011a. Alternative futures for fire management under a changing 

climate. Park Science 28 (1):44‒47.

Nydick, K., and C. Sydoriak. 2011b. A strategic framework for science in support of management 

in the southern Sierra Nevada, California. Park Science 28(1):41‒43.

Oles, K. M., D. A. Weixelman, D. F. Lile, K. W. Tate, L. K. Snell, and L. M. Roche. 2017. 

Riparian Meadow Response to Modern Conservation Grazing Management. 

Environmental Management 60 (3):383-395. doi: 10.1007/s00267-017-0897-1.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

720

Oliver, W. W. 1995. Is self-thinning in ponderosa pine ruled by Dendroctonus bark beetles? In: 

comp. Forest health through silviculture: Proceedings of the National Silviculture 

Workshop, May, Mescalero, New Mexico Gen. Tech. Rep. RM-GTR-267. Department of 

Rocky Mountain Forest and Range Experiment Station: 213-218. Fort Collins, CO.

Olson, D. 2015. Personal Communication with Deanna Olson. Corvallis, OR, November 27, 

2015.

Outdoor Foundation. 2014. 2014 Outdoor recreation participation report. The Outdoor 

Foundation. Washington, D.C.

Outdoor Industry Association, Western Governors' Association, and Moto. 2012. Outdoor 

Recreation Economy: A Snapshot of the Economic Impact of Outdoor Recreation in the 

West.

Panek, Jeanne, David Saah, Annie Esperanza, Andrzej Bytnerowicz, Witold Fraczek, and Ricardo 

Cisneros. 2013. Ozone distribution in remote ecologically vulnerable terrain of the 

southern Sierra Nevada, CA. Environmental pollution (Barking, Essex: 1987) 182:343-

56.

Parisien, M. A., D.R. Junor, and V.G. Kafka. 2007. Comparing landscape-based decision rules for 

placement of fuel treatments in the boreal mixedwood of western Canada International 

Journal of Wildland Fire 16:664-672.

Parisien, M. A., C. Miller, A.A. Ager, and M.A. Finney. 2010. Use of artificial landscapes to 

isolate controls on burn probability. Landscape Ecology 25:79-93.

Parisien, M. A., S. Snetsinger, J.A. Greenberg, C.R. Nelson, T. Schoennagel, S.Z. Dobrowski, and 

M.A. Moritz. 2012. Spatial variability in wildfire probability across the western United 

States International Journal of Wildland Fire 21:313-327.

Parker, Patricia L, and Thomas F King. 1998. Guidelines for evaluating and documenting 

traditional cultural properties. National Register Bulletin 38. U.S. Department of the 

Interior, National Park Service, National Register, History and Education National 

Register of Historic Places. Washington, D.C.

Parks, SA, C Miller, JT Abatzoglou, LM Holsinger, MA Parisien, and SZ Dobrowski. 2016. How 

will climate change affect wildland fire severity in the western US? Environmental 

Research Letters. 11 pp. doi: 10.1088/1748-9326/11/3/035002.

Parmesan, Camille. 2006. Ecological and evolutionary responses to recent climate change. Annu. 

Rev. Ecol. Evol. Syst. 37:637-669. doi: 10.1146/annurev.ecolsys.37.091305.110100.

Parmesan, Camille, and Gary Yohe. 2003. A globally coherent fingerprint of climate change 

impacts across natural systems. Nature 421 (6918):37-42. 

Parrotta, John A, and Ronald L Trosper. 2011. Traditional Forest-Related Knowledge: Sustaining 

Communities, Ecosystems and Biocultural Diversity. World Forest Series vol. 12. 

Springer Science + Business Media. Springer Dordrecht, Heidelberg, London, and New 

York.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

721

Southern Sierra Partnership. 2010. Framework for cooperative conservation and climate 

adaptation for the southern Sierra Nevada and Tehachapi Mountains, California, USA. 

Edited by Audubon California The Nature Conservancy, Sequoia Riverlands Trust, Sierra 

Business Council. Available at: 

http://www.southernsierrapartnership.org/uploads/2/3/7/6/23766303/ssp_framework_vol_

2_appendix.pdf

Perkins, Judy L. 2015. Fire enhances whitebark pine seedling establishment, survival, and 

growth. Fire Ecol 11 (2):84-99.

Peterson, D.L., C.I. Millar, L.A. Joyce, M.J. Furniss, J.E. Halofsky, R.P. Neilson, and T.L. 

Morelli. 2011. Responding to climate change in national forests: a guidebook for 

developing adaptation options. In Gen. Tech. Rep. PNW-GTR-855. Portland, OR: USDA 

Forest Service, Pacific Northwest Research Station.

Peterson, DW, EK Dodson, and RJ Harrod. 2015. Post-fire logging reduces surface woody fuels 

up to four decades following wildfire. Forest Ecology and Management 338:84-91. doi: 

10.1016/j.foreco.2014.11.016.

Pettit, Neil E, and Robert J Naiman. 2007. Fire in the riparian zone: characteristics and ecological 

consequences. Ecosystems 10 (5):673-687.

Piirto, DD, and RR Rogers. 2002. An ecological basis for managing giant sequoia ecosystems. 

Environmental Management 30 (1):110-128. doi: 10.1007/s00267-001-2537-y.

Pimentel, David, Michael McNair, Louise Buck, Marcia Pimentel, and Jeremy Kamil. 1997. The 

Value of Forests to World Food Security. Human Ecology 25 (1):91-120. doi: 

10.1023/a:1021987920278.

Pinter, N., and E.A. Keller. 1991. Hydrology of Fish Slough. In Biotic inventory and ecosystem 

characterization for Fish Slough, Inyo and Mono Counties, California, edited by W.R. 

Ferren and F.W. Davis. Santa Barbara, California. University of California, Santa 

Barbara. Prepared for the Resources Agency, Department of Fish and Game, Award No. 

FG-83890.

Podolak, K., D. Edelson, S. Kruse, B. Aylward, M. Zimring, and N. Wobbrock. 2015. Estimating 

the water supply benefits from forest restoration in the Northern Sierra Nevada. 

Unpublished report. The Nature Conservancy. San Francisco, CA: 20.

Pollard, S.J.T., G.J. Davies, F. Coley, and M. Lemon. 2008. Better environmental decision 

making — Recent progress and future trends. Science of the Total Environment 400 (1–

3): 20-31. doi: http://doi.org/10.1016/j.scitotenv.2008.07.022.

Pond, P.D. 2007. Taking charge of the wild: Keeping an eye on trail use can be difficult with 

unmanaged recreation. Parks and Recreation 42 (6).

Ponisio, L.C., K. Wilkin, L.K. M'Gonigle, K. Kulhanek, L. Cook, R. Thorp, T. Griswold, and C.

Kremen. 2016. Pyrodiversity begets plant-pollinator community diversity. Global Change 

Biology 22 (5):1794-1808. doi: 10.1111/gcb.13236.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

722

Potter, C. 2004. Rehabilitation of a desert fish refuge: Efforts to promote tui chub recovery at

Mule Spring Pond in the Owens Valley, California. In Report prepared for California

Department of Fish and Game, Region VI. Bishop, California.

Potter, Donald A. 1998. Forested communities of the upper montane in the central and southern 

Sierra Nevada PSW-GTR-169. U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Region. Albany, CA.

Potyondy, John P, and Theodore W Geier. 2011. Watershed condition classification technical 

guide. FS-978. United States Department of Agriculture, Forest Service, Washington, 

DC.

Powell, Douglas R., and Harold E. Klieforth. 1991. Weather and Climate. In, Hall, C.A. ed.,

Natural History of the White-Inyo Range Eastern California. 18-21. Berkeley, CA.

University of California Press.

Preisler, H. K., S.C. Chen, F. Fujioka, J.W. Benoit, and A.L. Westerling. 2008. Meteorological 

model applications for estimating probabilities of wildland fires. International Journal of 

Wildland Fire 17: 305-316.

Preisler, H.K., J. Eidenshink, S. Howard, and R.E. Burgan. 2015. Forecasting distribution of 

numbers of large fires. In, Keane, R.E., J. Matt, R. parson, and K. Riley, eds., 

Proceedings of the large wildland fires conference RMRS-P-73. Missoula, MT. USDA 

Forest Service, Rocky Mountain Research Station. 

Preisler, HK, NE Grulke, Z Heath, and SL Smith. 2017. Analysis and out-year forecast of beetle, 

borer, and drought-induced tree mortality in California. Forest Ecology and Management 

399:166-178. doi: 10.1016/j.foreco.2017.05.039.

Primus, T., G. Wright, and P. Fisher. 2005. Accidental discharge of brodifacoum baits in a tidal 

marine environment: A case study. Bulletin of Environmental Contamination and 

Toxicology 74 (5):913-919. doi: 10.1007/s00128-005-0668-1.

Purdy, Sarah E., Peter B. Moyle, and Kenneth W. Tate. 2012. Montane meadows in the Sierra 

Nevada: comparing terrestrial and aquatic assessment methods. Environmental 

Monitoring and Assessment 184 (11):6967-6986. doi: 10.1007/s10661-011-2473-0.

Pyke, David A, Scott E Shaff, Andrew I Lindgren, Eugene W Schupp, Paul S Doescher, Jeanne C 

Chambers, Jeffrey S Burnham, and Manuela M Huso. 2014. Region-wide ecological 

responses of arid Wyoming big sagebrush communities to fuel treatments. Rangeland 

Ecology & Management 67 (5):455-467.

Quinn-Davidson, Lenya N, and J Morgan Varner. 2012. Impediments to prescribed fire across 

agency, landscape and manager: an example from northern California. International 

Journal of Wildland Fire 21 (3):210-218.

Quiñones, Rebecca M, and P.B. Moyle. 2015. California’s freshwater fishes: status and 

management. Fishes in Mediterranean Environments. 20p.

Rabinowitz, Deborah. 1981. Seven forms of Rarity. In The biological aspects of rare plant 

conservation, edited by Hugh Synge. New York, NY. Wiley.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

723

Rachowicz, Lara J., Roland A. Knapp, Jess A. T. Morgan, Mary J. Stice, Vance T. Vredenburg,

John M. Parker, and Cheryl J. Briggs. 2006. Emerging infectious disease as a proximate 

cause of amphibian mass mortality. Ecology 87 (7):1671-1683. doi: 10.1890/0012-

9658(2006)87[1671:eidaap]2.0.co;2.

Raish, Carol, Armando González-Cabán, and Carol J. Condie. 2005. The importance of 

traditional fire use and management practices for contemporary land managers in the 

American Southwest. Global Environmental Change Part B: Environmental Hazards 6 

(2):115-122. doi: http://doi.org/10.1016/j.hazards.2005.10.004.

Rambo, Thomas, Timothy Schowalter, and Malcolm North. 2014. Canopy arthropod responses to 

thinning and burning treatments in old-growth mixed-conifer forest in the Sierra Nevada, 

California. Forest Ecology and Management 326:91-100.

Rapacciuolo, G, SP Maher, AC Schneider, TT Hammond, MD Jabis, RE Walsh, KJ Iknayan, GK 

Walden, MF Oldfather, DD Ackerly, and SR Beissinger. 2014. Beyond a warming 

fingerprint: individualistic biogeographic responses to heterogeneous climate change in 

California. Global Change Biology 20 (9):2841-2855. doi: 10.1111/gcb.12638.

Raphael, Martin G, and Marshall White. 1984. Use of snags by cavity-nesting birds in the Sierra 

Nevada. Wildlife monographs: 3-66.

Rau, Benjamin M, Robin Tausch, Alicia Reiner, Dale W Johnson, Jeanne C Chambers, Robert R 

Blank, and Annmarrie Lucchesi. 2010. Influence of prescribed fire on ecosystem 

biomass, carbon, and nitrogen in a pinyon juniper woodland. Rangeland Ecology & 

Management 63 (2):197-202.

Reeder, Natalie MM, Allan P Pessier, and Vance T Vredenburg. 2012. A reservoir species for the 

emerging amphibian pathogen Batrachochytrium dendrobatidis thrives in a landscape 

decimated by disease. PLoS One 7 (3):e33567.

Reeves, M. 2016. R5 Rangeland Vegetation Production and Performance Assessment Final 

Report. Unpublished. USDA Forest Service Rocky Mountain Research Station, Missoula, 

MT.

Reiner, A., M.R. Gallagher, N. Skowronski, M. Dickison, and C. Ewell. 2016. Interactions of the 

2015 Cabin Fire and recent wildfires on the Sequoia National Forest. USDA Forest 

Service, Adaptive Management Services Enterprise Team (AMSET). Washington, D.C.

Reiner, Alicia, Matthew Dickenson, Jennifer Anderson, Brandon Smith, Cally Davidson, Scott 

Dailey, and Carol Ewell. 2017. Fire Behavior in Tree Mortality Summary Report Sequoia 

National Forest and Giant Sequoia National Monument 2017 Pier Fire. USDA Forest 

Service Enterprise Program Fire Behavior Assessment Team.

Centers for Water and Wildland Centers. 1996. Sierra Nevada Ecosystem Project Final Report to 

Congress: Assessment summaries and management strategies. Davis, CA: Centers for 

Water and Wildland Resources, University of California.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

724

Rich, T. D., C. J. Beardmore, H. Berlanga, P. J. Blancher, M. S. W. Bradstreet, G. S. Butcher, D. 

W. Demarest, E. H. Dunn, W. C. Hunter, E. E. Iñigo-Elias, J. A. Kennedy, A. M. Martell, 

A. O. Panjabi, D. N. Pashley, K. V. Rosenberg, C. M. Rustay, J. S. Wendt, T. C. Will. 

2004. Partners in Flight North American Landbird Conservation Plan. Cornell Lab of 

Ornithology. Ithaca, NY.

Richards, C. 2015a. Personal Conversation with Los Angeles Department of Water and Power 

and Southern California Edison concerning employees located in Inyo County. February 

2015. Copy available at US Forest Service, Vallejo, CA.

Richards, C. 2015b. Personal Conversation with Mammoth Lakes Tourism concerning visitation. 

February 2015. Copy available at US Forest Service, Vallejo, CA.

Rieman, Bruce E, Daniel Isaak, Susan Adams, Dona Horan, David Nagel, Charles Luce, and 

Deborah Myers. 2007. Anticipated climate warming effects on bull trout habitats and 

populations across the interior Columbia River basin. Transactions of the American 

Fisheries Society 136 (6):1552-1565.

Ritchie, Martin W, and Eric E Knapp. 2014. Establishment of a long-term fire salvage study in an 

interior ponderosa pine forest. Journal of Forestry 112 (5):395-400.

Ritchie, Martin W, Eric E Knapp, and Carl N Skinner. 2013. Snag longevity and surface fuel 

accumulation following post-fire logging in a ponderosa pine dominated forest. Forest 

Ecology and Management 287:113-122.

Ritchie, MW, BM Wing, and TA Hamilton. 2008. Stability of the large tree component in treated 

and untreated late-seral interior ponderosa pine stands. Canadian Journal of Forest 

Research-Revue Canadienne De Recherche Forestiere 38 (5):919-923. doi: 10.1139/X07-

242.

Roberts, Nina S., Deborah J. Chavez, Benjamin M. Lara, and Emilyn A Sheffield. 2009. Serving 

culturally diverse visitors to forests in California: a resource guide. In Gen. Tech. Rep. 

PSW-GTR-222. Albany, CA: U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Research Station.

Roberts, S.L., J.W. van Wagtendonk, A.K. Miles, and D.A. Kelt. 2011. Effects of fire on spotted 

owl site occupancy in a late-successional forest. Biological Conservation 111:610-619.

Robeson, SM. 2015. Revisiting the recent California drought as an extreme value. Geophysical 

Research Letters 42 (16):6771-6779. doi: 10.1002/2015GL064593.

Roche, L., D. Weixelman, D. Lile, M. Freitas, K. Oles, A. Jackson, A. Yost. 2015. Meadow 

conditions on national forest grazing allotments. Davis, CA: University of California, 

Davis, Rangeland Watershed Laboratory.

http://rangelandwatersheds.ucdavis.edu/main/projects/sierra_nevada_meadows_lit.html.

Root, Terry L., Jeff T. Price, Kimberly R. Hall, Stephen H. Schneider, Cynthia Rosenzweig, and J. 

Alan Pounds. 2003. Fingerprints of global warming on wild animals and plants. Nature 

421 (6918):57-60.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

725

Rosenberg, K.V., J.A. Kennedy, R. Dettmers, R.P. Ford, D. Reynolds, J.D. Alexander, C.J. 

Beardmore, P.J. Blancher, R.E. Bogart, G.S. Butcher, A.F. Camfield, A. Couturier, D.W. 

Demarest, W.E. Easton, J.J. Giocomo, R.H. Keller, A.E. Mini, A.O. Panjabi, D.N. 

Pashley, T.D. Rich, J.M. Ruth, H. Stabins, J. Stanton, and T. Will. 2016. Partners in Flight 

Landbird Conservation Plan: 2016 Revision for Canada and Continental United States. 

Partners in Flight Science Committee. Cornell Lab of Ornithology. Ithaca, NY.

Roundy, Bruce A, Richard F Miller, Robin J Tausch, Kert Young, April Hulet, Ben Rau, Brad 

Jessop, Jeanne C Chambers, and Dennis Eggett. 2014. Understory cover responses to 

pinon–juniper treatments across tree dominance gradients in the Great Basin. Rangeland 

Ecology & Management 67 (5):482-494.

Rowley, W. D. 1985. U.S. Forest Service Grazing and Rangelands: a History. College Station, 

TX: Texas A&M University.

Rudnick, D. A., S. J. Ryan, P. Beier, S. A. Cushman, F. Dieffenbach, C. W. Epps, L. R. Gerber, J. 

Hartter, J. S. Jenness, J. Kintsch, and A. M. Merenlender. 2012. The role of landscape 

connectivity in planning and implementing conservation and restoration priorities. Issues 

in Ecology. Report No. 16. Ecological Society of America. Washington, DC.

Rueda, D., D. J. Campbell, P. Fisher, F. Cinninghame, and J. B. Ponder. 2016. Biologically 

significant residual persistence of brodifacoum in reptiles following invasive rodent 

eradication, Galapagos Islands, Ecuador. Conservation Evidence 13:38.

Runcie, Julia M., Alexandra P. Few, David W. German, John D. Wehausen, and Thomas R. 

Stephenson. 2015. 2014-2015 Annual Report of the Sierra Nevada Bighorn Sheep 

Recovery Program. California Department of Fish and Wildlife. Sacramento, CA.

Rundel, Philip W. 2011. The diversity and biogeography of the alpine flora of the Sierra Nevada, 

California. Madroño 58 (3):153-184.

Sada, D., and K.F. Pohlmann. 2002. Spring inventory and monitoring protocols. Conference 

Proceedings: Spring-fed wetlands: Important scientific and cultural resources of the 

Intermountain Region, May 7-9, 2002, Las Vegas, NV. Las Vegas, NV. DHS Publication

No. 41210. Retrieved (2015) from Desert Research Institute web site: 

http://wetlands.dri.edu

Safford, H. D. 2013. Natural range of variation (NRV) for yellow pine and mixed conifer forests 

in the bioregional assessment area, including the Sierra Nevada, southern Cascades, and 

Modoc and Inyo National Forests. Vallejo, CA: USDA Forest Service.

Safford, H.D., M. Coppoletta, B.E. Estes, S.E. Gross, K.E. Merriam, M.D. Meyer, M. Slaton, and 

H. Stone. 2013a. Natural range of variation (NRV) for terrestrial ecosystems in the 

bioregional assessment area, including the Sierra Nevada, southern Cascades, and Modoc 

and Inyo National Forests. USDA Forest Service, Pacific Southwest Region.

Safford, H.D., M. Coppoletta, B.E. Estes, S.E. Gross, K.E. Merriam, M.D. Meyer, M. Slaton, and 

H. Stone. 2013b. Natural range of variation (NRV) for terrestrial ecosystems in the 

bioregional assessment area, including the Sierra Nevada, southern Cascades, and Modoc 

and Inyo National Forests. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

726

Safford, H.D., M. Coppoletta, B.E. Estes, S.E. Gross, K.E. Merriam, M.D. Meyer, M. Slaton, and 

H. Stone. 2013c. Natural range of variation (NRV) for terrestrial ecosystems in the 

bioregional assessment area, including the Sierra Nevada, southern Cascades, and Modoc 

and Inyo National Forests. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.

Safford, H.D., M.P. North, and M.D. Meyer. 2012. Climate change and the relevance of historical 

forest conditions. In Managing Sierra Nevada forests, edited by M. P. North. Albany, CA: 

USDA Forest Service, Pacific Southwest Research Station.

Safford, H.D., and J.T. Stevens. 2017. Natural range of variation for yellow pine and mixedconifer forests in the Sierra Nevada, Southern Cascades, and Modoc and Inyo National 

Forests, California, USA. In U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Research Station, General Technical Report. Albany, CA: U.S. Department of 

Agriculture, Forest Service, Pacific Southwest Research Station.

Safford, HD, JD Miller, and BM Collins. 2015. Differences in land ownership, fire management 

objectives and source data matter: a reply to Hanson and Odion (2014). International 

Journal of Wildland Fire 24 (2):286-293. doi: 10.1071/WF14013.

Safford, HD, M North, and MD Meyer. 2012. Climate change and the relevance of historical 

forest conditions. In: North, Malcolm, ed. 2012. Managing Sierra Nevada forests. Gen. 

Tech. Rep. PSW-GTR-237. Albany, CA: U.S. Department of Agriculture, Forest Service, 

Pacific Southwest Research Station. pp. 23-45.

Safford, Hugh D, Gregory D Hayward, Nicole E Heller, and John A Wiens. 2012. Historical 

Ecology, Climate Change, and Resource Management: Can the Past Still Inform the 

Future? In: Wiens, J., G. Hayward, H. Safford, and C. Giffen, eds., Historical 

environmental variation in conservation and natural resource management: 46-62. WileyBlackwell. Hoboken, NJ.

Safford, Hugh D, Jay Miller, David Schmidt, Brent Roath, and Annette Parsons. 2008. BAER soil 

burn severity maps do not measure fire effects to vegetation: a comment on Odion and 

Hanson (2006). Ecosystems 11 (1):1-11.

Safford, Hugh D, and Kip M Van de Water. 2014. Using fire return interval departure (FRID) 

analysis to map spatial and temporal changes in fire frequency on national forest lands in 

California es. Pap. PSW-RP-266. Albany, CA. USDA, Forest Service, Pacific Southwest 

Research Station. 

Saracco, James F, Rodney B Siegel, and Robert L Wilkerson. 2011. Occupancy modeling of 

Black-backed Woodpeckers on burned Sierra Nevada forests. Ecosphere 2 (3):1-17.

Savage, M. 1994. Anthropogenic and natural disturbance and patterns of mortality in a mixed 

conifer forest in California. Canadian Journal of Forest Research 24:1149-1159.

Sawyer, S. 2013. Natural range of variation of non-meadow riparian habitat in the Bioregional 

Assessment area. Vallejo, CA: U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

727

Schindler, Daniel E., Roland A. Knapp, and Peter R. Leavitt. 2001. Alteration of Nutrient Cycles 

and Algal Production Resulting from Fish Introductions intoMountain Lakes. Ecosystems 

4 (4):308-321. doi: 10.1007/s10021-001-0013-4.

Schmidt, David A., Alan H. Taylor, and Carl N. Skinner. 2008. The influence of fuels treatment 

and landscape arrangement on simulated fire behavior, Southern Cascade range, 

California. Forest Ecology and Management 255 (8–9):3170-3184. doi: 

http://doi.org/10.1016/j.foreco.2008.01.023.

Schmidt, Lars, Marco G Hille, and Scott L Stephens. 2006. Restoring northern Sierra Nevada 

mixed conifer forest composition and structure with prescribed fires of varying 

intensities. Fire Ecology 2 (2):20-33.

Schwartz, M.D., K.R. Nydick, J.H. Thorne, and A.J. Holguin. 2013. Southern Sierra ecoregional 

fire management exercise based on modeling plausible future scenarios: vegetation 

climate vulnerability section. Report in preparation for Sequoia and Kings Canyon 

National Parks and Sequoia National Forest. California Cooperative Ecosystem Studies 

Unit, National Park Service, Task Agreement No. J8C07100024. Berkeley, CA.

Schwartz, M.W., J. Thorne, and A. Holguin. 2013. A natural resource condition assessment for 

Sequoia and Kings Canyon National Parks. Appendix 20A: Biodiversity. In Natural 

Resource Report. Fort Collins, CO. US Department of the Interior, National Park Service, 

Natural Resource Stewardship and Science.

Schwartz, Mark W, Nathalie Butt, Christopher R Dolanc, Andrew Holguin, Max A Moritz, 

Malcolm P North, Hugh D Safford, Nathan L Stephenson, James H Thorne, and Phillip J 

van Mantgem. 2015. Increasing elevation of fire in the Sierra Nevada and implications 

for forest change. Ecosphere 6 (7):1-10.

Scott, J., J. Gilberston-Day, P. Bowden, A. Brough, and D. Helmbrecht. 2015. Southern Sierra 

Nevada wildfire risk assessment. Unpublished report. U.S. Department of Agriculture, 

Forest Service, Pacific Southwest Region. Vallejo, CA.

Scott, Michael L., Susan K. Skagen, and Michael F. Merigliano. 2003. Relating Geomorphic 

Change and Grazing to Avian Communities in Riparian Forests Relación entre el Cambio 

Geomórfico y el Pastoreo con las Comunidades de Aves en Bosques Riparios. 

Conservation Biology 17 (1):284-296. doi: 10.1046/j.1523-1739.2003.00466.x.

Seamans, M.E., J. Corcoran, and A. Rex. 2004. Southernmost record of a spotted owl x barred 

owl hybrid in the Sierra Nevada. Western Birds 35:173-174.

Seamans, M.E., and R.J. Gutierrez. 2007. The Condor. Habitat selection in a changing 

environment: the relationship between habitat alteration and spotted owl territory 

occupancy and breeding dispersal 109 (3):566-576.

Serra-Diaz, J.M., J. Franklin, W.W. Dillon, A.D. Syphard, F.W. Davis, and R.K. Meentemeyer. 

2016. California forests show early indications of both range shifts and local persistence 

under climate change. Global Ecology and Biogeography 25 (2):164-175. doi: 

10.1111/geb.12396.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

728

Shaffer, M. L. 1981. Minimum population sizes for species conservation. Bioscience 31 (2):131-

134. doi: 10.2307/1308256.

Show, S.B., and EI Kotok. 1924. The role of fire in the California pine forests. USDA Bulletin 

number 1294. Washington, D.C. U.S. Department of Agriculture, National Agricultural 

Library.

Siegel, R. B., R. L. Wilkerson, M. W. Tingley, and C. A. Howell. 2014. Roost sites of the blackbacked woodpecker in burned forest. Western Birds 45:296–303.

Siegel, R.B., P. Pyle, J.H. Thorne, A.J. Holguin, C.A. Howell, S. Stock, and M.W. Tingley. 2014. 

Vulnerability of birds to climate change in California's Sierra Nevada. Avian 

Conservation and Ecology 9 (1):58.

Siegel, Rodney B, Morgan W Tingley, Robert L Wilkerson, Christine A Howell, Matthew 

Johnson, and Peter Pyle. 2015. Age structure of Black-backed Woodpecker populations in 

burned forests. The Auk 133 (1):69-78.

Sierra Business Council. 2012. Eastern Sierra Innovation and Prosperity. An Industry Cluster 

Approach to Economic Sustainability in California’s Inyo and Mono Counties. Bishop, 

CA. Sierra Business Council.

Sierra Nevada Alliance. 2010. Sierra climate change toolkit: planning ahead to protect Sierra 

natural resources and rural communities, third edition. South Lake Tahoe, CA. Sierra 

Nevada Alliance.

Skovlin, J.M. 1984. Impacts of grazing on wetlands and riparian habitat: A review of our 

knowledge. In Developing strategies for rangeland management: a report prepared by the 

committee on developing strategies for rangeland management. Boulder, CO: National 

Research Council/National Academy of Sciences.

Slaton, M. 2013. Inyo National Forest Assessment Topic Paper. Chapter 1: Terrestrial, Aquatic 

and Riparian Ecosystems. Unpublished report. USDA Forest Service, Pacific Southwest 

Region, Inyo National Forest. Bishop CA.

Slaton, M., and H. Stone. 2015a. Natural range of variation of pinyon-juniper in the Bioregional 

Assessment Area. Unpublished report. USDA Forest Service, Pacific Southwest Region, 

Inyo National Forest. Vallejo, CA.

Slaton, M., and H. Stone. 2015b. Natural range of variation of sagebrush in the Bioregional 

Assessment Area. USDA Forest Service, Pacific Southwest Region. Vallejo, CA.

Slaton, M.R., S. Gross, and M. Meyer. 2014. Whitebark pine: R5 Spatial Stratification for 

Monitoring. Internal Report. Vallejo, CA: Department of Agriculture, Forest Service, 

Pacific Southwest Region (Region 5).

Slaton, MR. 2015. The roles of disturbance, topography and climate in determining the leading 

and rear edges of population range limits. Journal of Biogeography 42 (2):255-266. doi: 

10.1111/jbi.12406.

Smith, S. 2007. Bark beetles and vegetation management in California. USDA Forest Service, 

Pacific Southwest Region, Forest Health Protection. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

729

Smith, S. L., and D.R. Cluck. 2011. Marking guidelines for fire-injured trees in California. 

Susanville, CA: USDA Forest Service, Pacific Southwest Region, Forest Health 

Protection.

Sierra Nevada Ecosystem Project (SNEP). 1996. Sierra Nevada Ecosystem Project. In Final 

report to Congress. Davis, CA: University of California, Centers for Water and Wildland 

Resources.

Spencer, W., S. Sawyer, H. Rosmos, W. Zielinski, C. Thompson, and S. Britting. 2016. Southern 

Sierra Nevada fisher conservation strategy. Unpublished report. San Diego, CA. 

Conservation Biology Institute.

Spencer, W.D., R.H. Barrett, and W.J. Zieliski. 1983. Marten habitat preferences in the northern 

Sierra Nevada. Journal of Wildlife Management 47 (4):1181-1186. doi: 10.2307/3808189.

Spencer, W.D., S.C. Sawyer, H.L. Romsos, W.J. Zielinski, R.A. Sweitzer, C.M. Thompson, K.L. 

Purcell, D.L. Clifford, L. Cline, H.D. Safford, S.A. Britting, and J.M. Tucker. 2015. 

Southern Sierra Nevada fisher conservation assessment. San Diego, CA. Conservation 

Biology Institute.

Spier, R. F.G. 1978. Monache and Foot Hill Yokuts. Edited by Robert F. Heizer, Handbook of 

North American Indians: California-Volume 8. Washington DC. Smithsonian Institution.

Spies, Thomas A. 2004. Ecological concepts and diversity of old-growth forests. Journal of 

Forestry 102 (3):14-20.

Steel, Z. L., H.D. Safford, and J.H. Viers. 2015. The fire frequency-severity relationship and the 

legacy of fire suppression in California forests. Ecosphere 6 (8).

Steger, G.N., L.R. Werner, and T.E. Munton. 2006. First documented record of the barred owl in 

the southern Sierra Nevada. Western Birds 37:106-109.

Stephens, S. J., C. McGuire, and L. Sims. 2004. Conservation assessment and strategy for the 

California golden trout (Oncorhynchus mykiss aguabonita) in Tulare County, California. 

California Golden Trout Working Group: California Department of Fish and Game San 

Joaquin Valley and South Sierra Region and USDA Forest Service, Pacific Southwest 

Region. Available USDA Forest Service, Pacific Southwest Region, Vallejo, CA.

Stephens, S. L., R.E. Martin, and N.E. Clinton. 2007. Prehistoric fire area and emissions from 

California's forests, woodlands, shrublands, and grasslands. Forest Ecology and 

Management 251:205-216.

Stephens, S.L., S.W. Bigelow, R.D. Burnett, B.M. Collins, C.V. Gallagher, J.J. Keane, D.A. Kelt, 

M.P. North, L.J. Roberts, P.A. Stine, and D.H. Van Vuren. 2014. California spotted owl, 

songbird, and small mammal responses to landscape fuel treatments. Bioscience 64:893-

906.

Stephens, S.L., B.M. Collins, C.J. Fettig, M.A. Finney, C.A. Hoffman, E.E. Knapp, M.P. North, 

H. Safford, and R.B. Wayman. 2018. Drought, wildfire, and tree mortality in forests 

adapted to frequent fire. Bioscience bix146:12. doi: https://doi.org/10.1093/biosci/bix146.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

730

Stephens, Scott L, Brandon M Collins, and Gary Roller. 2012. Fuel treatment longevity in a 

Sierra Nevada mixed conifer forest. Forest Ecology and Management 285:204-212.

Stephens, Scott L, Jamie M Lydersen, Brandon M Collins, Danny L Fry, and Marc D Meyer. 

2015. Historical and current landscape-scale ponderosa pine and mixed conifer forest 

structure in the Southern Sierra Nevada. Ecosphere 6 (5):1-63.

Stephens, Scott L, Constance I Millar, and Brandon M Collins. 2010. Operational approaches to 

managing forests of the future in Mediterranean regions within a context of changing 

climates. Environmental Research Letters 5 (2):024003.

Stephens, Scott L, and Jason J Moghaddas. 2005. Experimental fuel treatment impacts on forest 

structure, potential fire behavior, and predicted tree mortality in a California mixed 

conifer forest. Forest Ecology and Management 215 (1):21-36.

Stephens, Scott L, and Lawrence W Ruth. 2005. Federal forest-fire policy in the United States. 

Ecological applications 15 (2):532-542.

Stephens, SL, JD Miller, BM Collins, MP North, JJ Keane, and SL Roberts. 2016. Wildfire 

impacts on California spotted owl nesting habitat in the Sierra Nevada. Ecosphere 7 (11). 

doi: 10.1002/ecs2.1478.

Stephenson, Thomas R., John D. Wehausen, Alexandra P. Few, David W. German, Dennis F. 

Jensen, Derek Spitz, Kathleen Knox, Becky M. Pierce, Jeffrey L. Davis, Jeff Ostergard, 

and Jonathan Fusaro. 2012. 2010-2011 Annual Report of the Sierra Nevada Bighorn 

Sheep Recovery Program: A Decade in Review. California Department of Fish and 

Game. Sacramento, CA.

Stevens, JT, HD Safford, MP North, JS Fried, AN Gray, PM Brown, CR Dolanc, SZ Dobrowski, 

DA Falk, CA Farris, JF Franklin, PZ Fule, RK Hagmann, EE Knapp, JD Miller, DF 

Smith, TW Swetnam, and AH Taylor. 2016. Average Stand Age from Forest Inventory 

Plots Does Not Describe Historical Fire Regimes in Ponderosa Pine and Mixed-Conifer 

Forests of Western North America. Plos One 11 (5). doi: 10.1371/journal.pone.0147688.

Stralberg, Diana, Dennis Jongsomjit, Christine A. Howell, Mark A. Snyder, John D. Alexander, 

John A. Wiens, and Terry L. Root. 2009. Re-Shuffling of Species with Climate 

Disruption: A No-Analog Future for California Birds? PLoS ONE 4 (9):e6825. doi: 

10.1371/journal.pone.0006825.

Strayed, Cheryl. 2012. Wild: From lost to found on the Pacific Crest Trail. Vintage. New York, 

NY.

Stumpff, Linda Moon. 2000. In wilderness there is life: An American Indian perspective on 

theory and action for wildlands. Wilderness science in a time of change conference. Vol 

2: Wilderness within the context of larger systems, Missoula, MT. U.S. Department of 

Agriculture, Forest Service, Rocky Mountain Research Station.

Sugihara, N.G., J.W. Van Wagtendonk, J. Fites-Kaufman, and A.E. Thode. 2006. Fire in 

California’s Ecosystems. Edited by N.G. Sugihara, J.W. van Wagtendonk, K.E. Shaffer, J. 

Fites-Kaufman and A.E. Thode, Fire as an ecological process. Berkeley, CA: University 

of California Press.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

731

Sulak, A., and L. Huntsinger. 2002. The importance of federal grazing allotments to central 

Sierran oak woodland permittees: a first approximation. Proceedings of the Fifth 

Symposium on Oak Woodlands: Oaks in California's Challenging Landscape. Gen. Tech. 

Rep. PSW-GTR-184.

Swanson, Mark E, Jerry F Franklin, Robert L Beschta, Charles M Crisafulli, Dominick A 

DellaSala, Richard L Hutto, David B Lindenmayer, and Frederick J Swanson. 2010. The 

forgotten stage of forest succession: early-successional ecosystems on forest sites. 

Frontiers in Ecology and the Environment 9 (2):117-125.

Swetnam, T. W. 1993. Fire history and climate change in giant sequoia groves. Science (New 

York, N.Y.) 262 (5135):885-9.

Sydoriak, C., J.A. Panek, J.J. Battles, and K.R. Nydick. 2013a. A natural resource condition 

assessment for Sequoia and Kings Canyon National Parks. In National Resources Report. 

Fort Collins, CO.

Sydoriak, C., J.A. Panek, J.J. Battles, and K.R. Nydick. 2013b. A natural resource condition 

assessment for Sequoia and Kings Canyon National Parks. In National Resources Report 

Fort Collins, CO.

Tarnay, Leland W, and James A Lutz. 2011. Sustainable fire: Preserving carbon stocks and 

protecting air quality as Sierra Nevada forests warm. Park Science 28 (1):48.

Tate, K. 2005. Confirmation of Riparian Friendly Grazing Project Results and Development of 

Achievable, Site Specific Reference Conditions for Grazed Riparian Areas, Final Report 

for SW03-037. Davis, California: University of California, Davis.

Tempel, D.J., R.J. Gutierrez, S.A. Whitmore, M.J. Reetz, R.E. Stoelting, W.J. Berigan, M.E. 

Seamans, and M.Z. Peery. 2014a. Effects of forest management on California spotted 

owls: implications for reducing wildfire risk in fire-prone forests. Ecological Applications 

24 (8):2089-2106.

Tempel, D.J., M.Z. Peery, and R.J. Gutierrez. 2014. Using integrated population models to 

improve conservation monitoring: California spotted owls as a case study. Ecological 

modelling:86-95.

Tepley, Alan, Jonathan Thompson, Howard Epstein, and Kristina Anderson-Teixeira. 2017. 

Vulnerability to forest loss through altered post-fire recovery dynamics in a warming 

climate in the Klamath Mountains. Global Change Biology:1-16. doi: DOI: 

10.1111/gcb.13704.

Thompson, Matthew P, Phil Bowden, April Brough, Joe H Scott, Julie Gilbertson-Day, Alan 

Taylor, Jennifer Anderson, and Jessica R Haas. 2016. Application of wildfire risk 

assessment results to wildfire response planning in the southern Sierra Nevada, 

California, USA. Forests 7 (3):64.

Thompson, Matthew P, David E Calkin, Mark A Finney, Krista M Gebert, and Michael S Hand. 

2013. A risk-based approach to wildland fire budgetary planning. Forest Science 59 

(1):63-77.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

732

Thompson, Matthew P., and Dave E. Calkin. 2011. Uncertainty and risk in wildland fire 

management: a review. Journal of environmental management 92 (8):1895-909.

Thorne, J.H., H. Choe, R.M. Boynton, J. Bjorkman, W. Albright, K. Nydick, A.L. Flint, L.E. 

Flint, and M.W. Schwartz. 2017. The impact of vegetation change uncertainty on 

California's vegetation and adaptive management. Ecosphere 8 (12):e02021.

Timbrook, J., J.R. Johnson, and D.D. Earle. 1993. Vegetation burning by the Chumash. Edited by 

Thomas C. Blackburn and M. Kat Anderson, Before the wilderness: Environmental 

management by native Californians: Ballena Press, Menlo Park, California.

Timmons, Rebecca S, L. deBano, and K.C. Ryan. 2012. Implications of fire management on 

cultural resources [Chapter 9]. In: Ryan, Kevin C.; Jones, Ann Trinkle; Koerner, 

Cassandra L.; Lee, Kristine M., tech. eds. Wildland fire in ecosystems: effects of fire on 

cultural resources and archaeology. Gen. Tech. Rep. RMRS-GTR-42-vol. 3. Fort Collins, 

CO: U.S. Department of Agriculture, Forest Service, Rocky Mountain Research Station. 

p. 171-191.

Tingley, Morgan W., William B. Monahan, Steven R. Beissinger, and Craig Moritz. 2009. Birds 

track their Grinnellian niche through a century of climate change. Proceedings of the 

National Academy of Sciences 106 (Supplement 2):19637-19643. doi: 

10.1073/pnas.0901562106.

Tingley, MW, V Ruiz-Gutierrez, RL Wilkerson, CA Howell, and RB Siegel. 2016. Pyrodiversity 

promotes avian diversity over the decade following forest fire. Proceedings of the Royal 

Society B-Biological Sciences 283 (1840). doi: 10.1098/rspb.2016.1703.

Tingley, MW, RL Wilkerson, ML Bond, CA Howell, and RB Siegel. 2014. Variation in homerange size of Black-backed Woodpeckers. Condor 116 (3):325-340. doi: 

10.1650/CONDOR-13-140.1.

Toupal, Rebecca. 2003. Cultural landscapes as a methodology for understanding natural resource 

management impacts in the western United States. Conservation ecology 7 (1):12.

Tucker, J. K. 2018. Personal communication, via email, between Leeann Murphy and Patti 

Krueger, Inyo National Forest and Regional 5, Regional Office, respectively, and Jody 

Tucker, Sierra Nevada Carnivore Monitoring Program Leader, Sequoia National Forest, 

US Forest Service. January 19, 2018.

Turner, J. W. 2015. Environmental influences on movements and distribution of a wild horse 

(Equus caballus) population in western Nevada, USA: a 25-year study. Journal of Natural 

History 49 (39-40):2437-2464. doi: 10.1080/00222933.2015.1024778.

Turner, J. W., and M. L. Morrison. 2001. Influence of predation by mountain lions on numbers 

and survivorship of a feral horse population. Southwestern Naturalist 46 (2):183-190. doi: 

10.2307/3672527.

Turner, M. G. 1989. Landscape ecology: the effect of pattern on process. Annual Review of 

Ecology and Systematics: 171-197.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

733

Turner, Nancy J., and Katherine L. Turner. 2008. Where our women used to get the food: 

cumulative effects and loss of ethnobotanical knowledge and practice; case study from 

coastal British Columbia. This paper was submitted for the Special Issue on Ethnobotany, 

inspired by the Ethnobotany Symposium organized by Alain Cuerrier, Montreal Botanical 

Garden, and held in Montreal at the 2006 annual meeting of the Canadian Botanical 

Association. Botany 86 (2):103-115. doi: 10.1139/b07-020.

United States Census Bureau. 2015. 2010 Geographic Terms and Concepts. United States Census 

Bureau. Available at: https://www.census.gov/geo/reference/terms.html.

United States Department of Agriculture. 2003. Department Regulation 4300-4 Civil Rights 

Impact Analysis. Washington, D.C. United States Department of Agriculture.

United States Department of Agriculture, Forest Service. 1982. Comprehensive management plan 

for the Pacific Crest National Scenic Trail. Portland, Oregon.

United States Department of Agriculture, Forest Service. 1986. Forest Service Handbook 1709.11 

- Civil Rights Handbook, Chapter 30 - Civil Rights Impact Analysis. Washington, D.C.

United States Department of Agriculture, Forest Service. 1988a. Inyo National Forest Land and 

Resource Management Plan: U.S. Dept. of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 1988b. Inyo National Forest Land and 

Resources Management Plan: Final Environmental Impact Statement and Record of 

Decision. San Francisco, CA. U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Region.

United States Department of Agriculture, Forest Service. 1988c. Sequoia National Forest (N.F.), 

Land and Resource(s) Management Plan (LRMP): Environmental Impact Statement.

United States Department of Agriculture, Forest Service. 1992. Sierra National Forest Land and 

Resource(s) Management Plan (LRMP) Final Environmental Impact Statement and ROD.

Environmental Impact Statement. San Francisco, CA.

United States Department of Agriculture, Forest Service. 1995a. Decision Notice and Finding of 

No Significant Impact: Forest Plan Amendment #6 - Forestwide Range Utilization 

Standards. Inyo National Forest. Bishop, CA.

United States Department of Agriculture, Forest Service. 1995b. Landscape aesthetics: A 

handbook for scenery management. In Agriculture Handbook Number 701. Washington, 

DC. United States Department of Agriculture, Forest Service.

United States Department of Agriculture. 1997. Department Regulation 5600-002 Environmental 

Justice. Washington, D.C. United States Department of Agriculture.

United States Department of Agriculture, Forest Service. 2000. Landbird strategic plan. 

Washington D.C.: U.S. Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2001a. Investigating water quality in the 

Pacific Southwest Region, Best Management Practices Evaluation Program: A User’s 

Guide. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

734

United States Department of Agriculture, Forest Service. 2001b. Record of Decision: Sierra 

Nevada Forest Plan Amendment: Environmental Impact Statement. Vallejo, CA: U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Region.

United States Department of Agriculture, Forest Service. 2001c. Sierra Nevada Forest Plan 

Amendment: Final Environmental Impact Statement, Vol. 1–6. USDA Forest Service 

Pacific Southwest Region, Vallejo, Calif.

United States Department of Agriculture, Forest Service. 2004a. National Report on Sustainable 

Forests-2003. Washington, DC: USDA Forest Service.

United States Department of Agriculture, Forest Service. 2004b. Sierra Nevada Forest Plan 

Amendment. Record of Decision. Vallejo, CA: USDA Forest Service, Pacific Southwest 

Region.

United States Department of Agriculture, Forest Service. 2004c. Sierra Nevada Forest Plan 

Amendment: Final Supplemental Environmental Impact Statement and Record of 

Decision. Vallejo, CA: Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2004d. Sierra Nevada Forest Plan 

Amendment: Final Supplemental Environmental Impact Statement and Record of 

Decision. Vallejo, CA: Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2006. United States Department of 

Agriculture Forest Service Master National Visitor Use Monitoring. Washington, DC. 

United States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2008. Policies on American Indians and 

Alaska Natives. Departmental Regulation 1340-007. Washington D.C. U.S. Department 

of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2011a. National Report on Sustainable 

Forests-2010. Washington D.C. U.S. Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2011b. National visitor use monitoring 

master report. Bishop, CA: U.S. Department of Agriculture, Forest Service, Inyo National 

Forest.

United States Department of Agriculture, Forest Service. 2011c. Nationwide Aerial Application of 

Fire Retardant on National Forest System Land. Washington, DC. United States 

Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2011d. Watershed Condition 

Framework: A Framework for Assessing and Tracking Changes to Watershed Condition.

Washington, DC. United States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2011e. Western bark beetle strategy. 

Washington, DC. United States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2011f. Ecological Restoration Strategy. 

Vallejo, CA: USDA Forest Service, Pacific Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

735

United States Department of Agriculture, Forest Service. 2012a. Forest health monitoring risk 

maps. Washington, DC. United States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2012b. National Best Management 

Practices for water Quality Management on National Forest System Lands. Washington, 

DC. United States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2012c. Sage-Grouse Interim 

Management Policy. Bishop, California: U.S. Department of Agriculture, Forest Service, 

Inyo National Forest.

United States Department of Agriculture, Forest Service. 2013a. Final Inyo National Forest 

assessment. Vallejo, CA: USDA Forest Service, Pacific Southwest Region. 

United States Department of Agriculture, Forest Service. 2013b. Final Sequoia National Forest 

assessment. Vallejo, CA: USDA Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2013c. Final Sierra National Forest 

assessment. Vallejo, CA: USDA Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2013d. Final Sierra Nevada bio-regional 

assessment. Vallejo, CA. USDA Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2013e. Snapshot bioregional assessment 

from Living Assessment wikispaces website. Vallejo, CA, accessed April 9.

United States Department of Agriculture, Forest Service. 2013f. Snapshot Inyo National Forest 

assessment from Living Assessment wikispaces website. USDA Forest Service, accessed 

September 2. 

https://livingassessment.wikispaces.com/Inyo+NF+September+2%2C+2013+Snapshot+P

ages.

United States Department of Agriculture, Forest Service. 2013g. Snapshot Sequoia National 

Forest assessment from Living Assessment wikispaces website. Vallejo, CA, accessed 

August 2. 

https://livingassessment.wikispaces.com/Sequoia+NF+August+2%2C+2013+Snapshot+P

ages.

United States Department of Agriculture, Forest Service. 2013h. Snapshot Sierra National Forest 

assessment from Living Assessment wikispaces website. USDA Forest Service, Pacific 

Southwest Region, accessed July 2. 

https://livingassessment.wikispaces.com/Sierra+NF+July+2%2C+2013+Snapshot+Pages.

United States Department of Agriculture, Forest Service. 2013i. Regional Forester Sensitive 

Species Lists 2013 (Animal Species and Plant Species). Vallejo, CA. United States 

Department of Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2014a. Final Sierra National Forest 

Assessment. In Management Bulletin Vallejo, CA: U.S. Department of Agriculture, 

Forest Service, Pacific Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

736

United States Department of Agriculture, Forest Service. 2014b. Final Sierra Nevada BioRegional Assessment. Management Bulletin R5-MB-268. Vallejo, CA. United States 

Department of Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2014c. Inyo, Sequoia, and Sierra 

National Forests Need to change analysis-Supplement. Vallejo, CA: U.S. Department of 

Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2014d. Preliminary need to change. 

Vallejo, CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2014e. Sequoia National Forest 

Assessment. Vallejo, CA: U.S. Department of Agriculture, Forest Service, Pacific 

Southwest Region.

United States Department of Agriculture, Forest Service. 2014f. The estimated economic 

contributions of National Forests and Grasslands. PowerPoint at the Western Forest 

Mensurationists and Economists Meeting. 

United States Department of Agriculture, Forest Service. 2014g. Updated need to change. Vallejo, 

CA: U.S. Department of Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2015a. Aerial mortality surveys. edited 

by Pacific Southwest Region USDA Forest Service. Vallejo, CA: USDA Forest Service, 

Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2015b. All service receipts (ASR) final 

payment detail report PNF (ASR-10-03).

United States Department of Agriculture, Forest Service. 2015c. Draft Interim Recommendations 

for the Management of California Spotted Owl Habitat on National Forest System Lands 

Vallejo, CA. United States Department of Agriculture, Forest Service, Pacific Southwest 

Region.

United States Department of Agriculture, Forest Service. 2015d. Strategic Plan: FY 2010-2015. 

Washington, DC: U.S. Department of Agriculture.

United States Department of Agriculture, Forest Service. 2015e. The Rising Cost of Wildfire 

Operations: Effects on the Forest Service's Non-Fire Work. Washington, D.C. United 

States Department of Agriculture, Forest Service.

United States Department of Agriculture, Forest Service. 2015f. USDA FS Economic 

contributions model Inyo National Forest. January 2015. Vallejo, CA. United States 

Department of Agriculture, Forest Service, Pacific Southwest Region.

United States Department of Agriculture, Forest Service. 2015g. Region 5 Ecological Restoration 

Leadership Intent. Vallejo, CA. United States Department of Agriculture, Forest Service, 

Pacific Southwest Region.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

737

United States Department of Agriculture, Forest Service. 2016. Cut and Sold Reports, 2010-2014. 

United States Department of Agriculture, Forest Service, Forest Management. 

Washington, DC. Available at: http://www.fs.fed.us/forestmanagement/products/soldharvest/cut-sold.shtml.

United States Department of Agriculture, Forest Service. 2017a. Biological Assessment for 

Revision of the Inyo National Forest Land Management Plan: Federally designated 

threatened and endangered species and their designated critical habitat and candidate 

species. Vallejo, CA. United States Department of Agriculture, Forest Service, Pacific 

Southwest Region.

United States Department of Agriculture, Forest Service. 2017b. Biological Evaluation for Region 

5 Sensitive Species, Wildlife Fish and Invertebrate Species: Revision of the Inyo National 

Forest Land Management Plan. Vallejo, CA.

United States Department of Agriculture, Forest Service. 2017c. Biological Evaluation for 

Sensitive Plants: Inyo National Forest Revised Forest Plan. Bishop, CA.

United States Department of Agriculture, Forest Service. 2017d. National Allotment NEPA 

Schedule 2017-2018: Rescissions Act P.L. 104-19, Sec. 504(a) and 2004 Interior 

Appropriations Act P.L. 108-108, Sec. 325. edited by Forest Service United States 

Department of Agriculture. Washington D. C.

United States Department of Agriculture, Forest Service. 2017e. R5 rangeland analysis and 

planning guide R5-EM-TP-004, March 1997 supplement. Vallejo, California.

United States Department of Agriculture, Forest Service. 2018a. Rationales for animal species 

considered for designation as species of conservation concern. Vallejo, CA: Southwest 

Pacific Regional Office.

United States Department of Agriculture, Forest Service. 2018b. Rationales for plant species 

considered for designation as species of conservation concern. Vallejo, California: Pacific 

Southwest Regional Office.

United States Department of Agriculture and Environmental Protection Agency. 2015. Pollinator 

research action plan. Washington, DC. United States Department of Agriculture, Forest 

Service and Environmental Protection Agency.

United States Department of Agriculture, Forest Service, Humboldt-Toiyabe National Forest, and 

Bureau of Land Management United States Department of the Interior, Carson City 

District. 2015. Greater sage-grouse Bi-state distinct population segment forest plan 

amendment: final environmental impact statement. Sparks, NV Carson City, NV.

United States Department of Agriculture and United States Department of the Interior. 2015. 

Pollinator friendly best management practices for federal lands. Washington, DC. United 

States Department of Agriculture and United States Department of the Interior.

United States Department of Agriculture, Forest Service, Pacific Southwest Region. 1994. Record 

of decision and Inyo National Forest plan amendment #4 and Sequoia National Forest 

plan amendment. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

738

United States Department of Agriculture, Forest Service, Pacific Southwest Region, Inyo 

National Forest. 2009a. Inyo National Forest Motorized Travel Management Final 

Environmental Impact Statement R5-MB-198. Bishop, CA. USDA FS, Region 5, Inyo 

NF.

United States Department of Agriculture, Forest Service, Pacific Southwest Region, Inyo 

National Forest. 2009b. Inyo National Forest Travel Management Final Environmental 

Impact Statement Record of Decision R5-MB-198a. Bishop, CA. USDA FS, Region 5, 

Inyo NF.

United States Department of Agriculture, Forest Service, and United States Department of the 

Interior, Fish and Wildlife Service. 2015. Conservation agreement for Abronia alpina 

(Ramshaw Meadows abronia), Tulare County, CA. Bishop, CA. U.S. Department of 

Agriculture, Forest Service, Inyo National Forest and U.S. Department of Interior, U.S. 

Fish and Wildlife Service, Sacramento Office.

United States Department of the Interior, Bureau of Land Management. 2015a. Riparian area 

management: Proper functioning condition assessment for lotic areas. Technical 

Reference 1737-15. Denver, CO. United States Department of Interior, Bureau of Land 

Management, National Operations Center.

United States Department of Interior, Fish and Wildlife Service. 2008. Birds of Conservation 

Concern 2008. Arlington, VA. United States Department of Interior, Fish and Wildlife 

Service, Division of Migratory Bird Management.

United States Department of Interior, Fish and Wildlife Service. 2013. Endangered and threatened 

wildlife and plants; threatened status for the Bi-State distinct population segment of 

greater sage-grouse with special rule. Washington D. C. Federal Register.

United States Department of Interior, Fish and Wildlife Service. 2015b. Endangered and 

threatened wildlife and plants; withdrawal of the proposed rule to list the bi-state distinct 

population segment of greater sage-grouse and designate critical habitat; proposed rule. 

50 CFR Part 17. Washington D. C. Federal Register.

United States Department of the Interior, Bureau of Land Management. 2010. Discussion paperNWCG GIS data layer standard: Fire cultural sites and fire cultural surveys. Washington, 

DC. United States Department of the Interior, Bureau of Land Management.

United States Department of the Interior, Bureau of Land Management. 2017. Wild horse and 

burro program, Facts and Statistics: 2017 HA and HMA Dataset. Washington, DC. United 

States Department of the Interior, Bureau of Land Management. Available at: 

https://www.blm.gov/programs/wild-horse-and-burro/about-the-program.

United States Department of the Interior, Fish and Wildlife Service. 1967. Native Fish and 

Wildlife: Endangered Species. Federal Register 32 (48):4001.

United States Department of the Interior, Fish and Wildlife Service. 1970. United States list of 

endangered native fish and wildlife. Federal Register 35:16047-16048.

United States Department of the Interior, Fish and Wildlife Service. 1975. Threatened Status for 

Three Species of Trout. Federal Register 40 (137):29863-29864.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

739

United States Department of the Interior, Fish and Wildlife Service. 1985. Endangered Status and 

Critical Habitat Designation for the Owens Tui Chub. Federal Register 50 (150):31592-

31597.

United States Department of the Interior, Fish and Wildlife Service. 1995a. Lahontan cutthroat 

trout (Oncorhynchus clarki henshawi) Recovery Plan. Portland, Oregon. United States 

Department of the Interior, Fish and Wildlife Service.

United States Department of the Interior, Fish and Wildlife Service. 1995b. Lahontan cutthroat 

trout (Oncorhynchus clarki henshawi) Recovery PlanLahontan cutthroat trout 

(Oncorhynchus clarki henshawi) Recovery Plan. Portland, Oregon. United States 

Department of the Interior, Fish and Wildlife Service.

United States Department of the Interior, Fish and Wildlife Service. 1998. Owens Basin Wetland 

and Aquatic Species Recovery Plan Inyo and Mono Counties, California. Portland, 

Oregon. United States Department of the Interior, Fish and Wildlife Service.

United States Department of the Interior, Fish and Wildlife Service. 1999. Emergency Rule To 

List the Sierra Nevada Distinct Population Segment of California Bighorn Sheep as 

Endangered. Federal Register 64 (75):19300-19309.

United States Department of the Interior, Fish and Wildlife Service. 2000. Final Rule To List the

Sierra Nevada Distinct Population Segment of the California Bighorn Sheep as 

Endangered. Federal Register 65 (1):20-30.

United States Department of the Interior, Fish and Wildlife Service. 2003. 12-Month Finding for a 

Petition To List the Sierra Nevada Distinct Population Segment of the Mountain Yellowlegged Frog (Rana muscosa). Federal Register 68 (11):2283-2303.

United States Department of the Interior, Fish and Wildlife Service. 2004. Revised Recovery Plan 

for the Paiute cutthroat trout (Oncorhynchus clarki seleniris). Portland, Oregon. United 

States Department of the Interior, Fish and Wildlife Service.

United States Department of the Interior, Fish and Wildlife Service. 2007. National Bald Eagle 

Management Guidelines. Washington, DC. United States Department of the Interior, Fish 

and Wildlife Service.

United States Department of the Interior, Fish and Wildlife Service. 2007. Recovery Plan for the 

Sierra Nevada Bighorn Sheep. Sacramento, California. United States Department of the 

Interior, Fish and Wildlife Service, California/Nevada Operations Office.

United States Department of the Interior, Fish and Wildlife Service. 2008a. Final Rule, 

Designation of Critical Habitat for the Sierra Nevada Bighorn Sheep (Ovis canadensis 

sierrae) and Taxonomic Revision; Final Rule. Federal Register 73 (151):45534-45604.

United States Department of the Interior, Fish and Wildlife Service. 2008b. Sierra Nevada 

Bighorn Sheep Ovis canadensis californiana (=Ovis canadensis sierrae) 5-Year Review: 

Summary and Evaluation. Ventura, California. United States Department of the Interior, 

Fish and Wildlife Service, Ventura Fish and Wildlife Office.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

740

United States Department of the Interior, Fish and Wildlife Service. 2011. 12-Month Finding on a 

Petition To List Pinus albicaulis as Endangered or Threatened With Critical Habitat. 

Federal Register 76 (138):42631-42654.

United States Department of the Interior, Fish and Wildlife Service. 2013. Paiute Cutthroat Trout 

(Oncorhynchus clarkii seleniris) 5-Year Review: Summary and Evaluation. Reno, 

Nevada. United States Department of the Interior, Fish and Wildlife Service, Nevada Fish 

and Wildlife Office.

United States Department of the Interior, Fish and Wildlife Service. 2014. Endangered Species 

Status for Sierra Nevada Yellow-Legged Frog and Northern Distinct Population Segment 

of the Mountain Yellow-Legged Frog, and Threatened Species Status for Yosemite Toad; 

Final Rule Federal Register 79 (82):24256-24310.

United States Department of the Interior, Fish and Wildlife Service. 2015. Withdrawal of the 

Proposed Rule To List the Bi-State Distinct Population Segment of Greater Sage-Grouse 

and Designate Critical Habitat; Proposed Rule. Federal Register 80 (78):22827-22866.

United States Department of the Interior, Fish and Wildlife Service. 2016a. Designation of 

Critical Habitat for the Sierra Nevada Yellow-Legged Frog, the Northern DPS of the 

Mountain Yellow-Legged Frog, and the Yosemite Toad; Final Rule. Federal Register 81 

(166):59046-59119.

United States Department of the Interior, Fish and Wildlife Service. 2016b. U.S. Fish and Wildlife 

Service Species Assessment and Listing Priority Assignment Form: Pinus albicaulis.

Washington, DC. Federal Register 81 (232):87263.

Vaillant, N. 2009. Characterizing fire severity patterns in three wildland fire use incidents in the 

southern Sierra Nevada. For the Sequoia National Forest. Washington, DC. United States 

Department of Agriculture, Forest Service, Adaptive Management Services Enterprise 

Team.

Vaillant, Nicole M, Erin K Noonan-Wright, Alicia L Reiner, Carol M Ewell, Benjamin M Rau, 

Josephine A Fites-Kaufman, and Scott N Dailey. 2015. Fuel accumulation and forest 

structure change following hazardous fuel reduction treatments throughout California. 

International Journal of Wildland Fire 24 (3):361-371.

Vaillant, Nicole M, Alicia L Reiner, and Erin K Noonan-Wright. 2013. Prescribed fire effects on 

field-derived and simulated forest carbon stocks over time. Forest Ecology and 

Management 310:711-719.

Van de Water, Kip M, and Hugh D Safford. 2011. A summary of fire frequency estimates for 

California vegetation before Euro-American settlement. Fire Ecology 7 (3):26-58.

Van Mantgem, Phillip J, Nathan L Stephenson, John C Byrne, Lori D Daniels, Jerry F Franklin, 

Peter Z Fulé, Mark E Harmon, Andrew J Larson, Jeremy M Smith, and Alan H Taylor. 

2009. Widespread increase of tree mortality rates in the western United States. Science 

323 (5913):521-524.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

741

Van Mantgem, Phillip J, Nathan L Stephenson, Eric Knapp, John Battles, and Jon E Keeley. 2011. 

Long-term effects of prescribed fire on mixed conifer forest structure in the Sierra 

Nevada, California. Forest Ecology and Management 261 (6):989-994.

van Wagtendonk, JW, and J. Fites-Kaufman. 2006. Sierra Nevada bioregion. Edited by N.G. 

Sugihara, J.W. van Wagtendonk, KE Shaffer, J Fites-Kaufman and AE Thode, Fire in 

California’s Ecosystems. Berkeley, CA: University of California Press: Berkeley, CA.

Van Zuuk, K. 2014. Region 5 Draft Pollinator Best Management Practices. Vallejo, CA. United 

States Department of Agriculture, Forest Service, Pacific Southwest Region.

Vannote, R.L., and G. W. Minshall. 1982. Fluvial processes and local lithology controlling 

abundance, structure, and composition of mussel beds. Proceedings of the National 

Academy of Science 79(13): 4103-4107.

Verner, J., and K.L. Purcell. 1988. Subalpine conifer. California Wildlife Habitat Relationship. 

California Wildlife Habitat Relationships System. California Department of Fish and 

Game, California Interagency Wildlife Task Group. Available at:

https://www.wildlife.ca.gov/Data/CWHR/Wildlife-Habitats.

Viegas, Domingos X, Jorge R Raposo, David A Davim, and Carlos G Rossa. 2012. Study of the 

jump fire produced by the interaction of two oblique fire fronts. Part 1. Analytical model 

and validation with no-slope laboratory experiments. International Journal of Wildland 

Fire 21 (7):843-856.

Viers, JH, SE Purdy, RA Peek, A Fryjoff-Hung, NR Santos, JVE Katz, JD Emmons, DV Dolan, 

and SM Yarnell. 2013. Montane meadows in the Sierra Nevada: Changing hydroclimatic 

conditions and concepts for vulnerability assessment. Center for Watershed Sciences 

Technical Report. Davis, California. UC Davis, Center for Watershed Sciences.

Viers, Joshua H, and David E Rheinheimer. 2011. Freshwater conservation options for a changing 

climate in California’s Sierra Nevada. Marine and Freshwater Research 62 (3):266-278.

Vogel, Howard J. 2001. The Clash of Stories at Chimney Rock: A Narrative Approach to Cultural 

Conflict Over Native American Sacred Sites on Public Land. Santa Clara Law Review 

41:757.

Voggesser, Garrit, Kathy Lynn, John Daigle, Frank K. Lake, and Darren Ranco. 2013. Cultural 

impacts to tribes from climate change influences on forests. Climatic Change 120 

(3):615-626. doi: 10.1007/s10584-013-0733-4.

Vose, J.M., J.S. Clark, C.H. Luce, and T. Patel-Weynand. 2016. Effects of drought on forests and 

rangelands in the United States: A comprehensive science systhesis GTR WO-93b. 

United States Department of Agriculture, Forest Service. Washington D. C.

Vose, JM, JS Clark, and CH Luce. 2016. Introduction to drought and US forests: Impacts and 

potential management responses. Forest Ecology and Management 380:296-298. doi: 

10.1016/j.foreco.2016.09.030.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

742

Vose, JM, CF Miniat, CH Luce, H Asbjornsen, PV Caldwell, JL Campbell, GE Grant, DJ Isaak, 

SP Loheide, and G Sun. 2016. Ecohydrological implications of drought for forests in the 

United States. Forest Ecology and Management 380:335-345. doi: 

10.1016/j.foreco.2016.03.025.

Vredenburg, V. T., R. Bingham, R. Knapp, J. A. T. Morgan, C. Moritz, and D. Wake. 2007. 

Concordant molecular and phenotypic data delineate new taxonomy and conservation 

priorities for the endangered mountain yellow-legged frog. Journal of Zoology 271 

(4):361-374. doi: 10.1111/j.1469-7998.2006.00258.x.

Wallin, Kimberly F, Thomas E Kolb, Kjerstin R Skov, and Michael Wagner. 2008. Forest 

management treatments, tree resistance, and bark beetle resource utilization in ponderosa 

pine forests of northern Arizona. Forest Ecology and Management 255 (8):3263-3269.

Watson, A.M., R. Matt, T. Waters, K. Gunderson, Carver S., and B. Davis. 2009. Mapping 

tradeoffs in values at risk at the interface between wilderness and non-wilderness lands. 

In, Gonzalez-Duban, A., tech. coord. Proceedings of the Third International Symposium 

on fire economics, planning, and policy: Common problems and approaches. Gen. Tech. 

Rep. PSW-GTR-227. Albany, CA. U.S. Department of Agriculture, Forest Service, 

Pacific Southwest Research Station. p. 375-387.

Watson, Alan, Roian Matt, Katie Knotek, Daniel Williams, and Laurie Yung. 2011. Traditional 

wisdom: protecting relationships with wilderness as a cultural landscape. Ecology and 

Society 16 (1).

Watts Jr, Clifton E, and Cherie LeBlanc Fisher. 2010. Proceedings of the 2009 Northeastern 

Recreation Research Symposium. Gen. Tech. Rep. NRS-P-66. Newtown Square, PA.

U.S. Department of Agriculture, Forest Service, Northern Research Station. 276 p.

Wayman, Rebecca Bewley, and Malcolm North. 2007. Initial response of a mixed-conifer 

understory plant community to burning and thinning restoration treatments. Forest 

Ecology and Management 239 (1):32-44.

Webb, K., C. Craft, and E. Elswick. 2008. The evaluation of the freshwater western pearl mussel, 

Margaritifera falcata (Gould, 1850), as a bioindicator through the analysis of metal 

partitioning and bioaccumulation. Northwest Science 82:163-173.

Webster, Karen M, and Charles B Halpern. 2010. Long-term vegetation responses to 

reintroduction and repeated use of fire in mixed-conifer forests of the Sierra Nevada. 

Ecosphere 1 (5):1-27.

Wehausen, John D. 1996. Effects of Mountain Lion Predation on Bighorn Sheep in the Sierra 

Nevada and Granite Mountains of California. Wildlife Society Bulletin 24 (3):471-479.

Wehausen, John D., Vernon C. Bleich, and Rob R. Ramey II. 2005. Correct Nomenclature for 

Sierra Nevada Bighorn Sheep. California Fish and Game 91 (1):216-218.

Weixelman, D.A. , and D.J. Cooper. 2009. Assessing Proper Functioning Condition for Fen Areas 

in the Sierra Nevada and Southern Cascade Ranges in California, A User Guide, R5-TP028. edited by Pacific Southwest Region 5 USDA Forest Service. Vallejo, CA.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

743

Welch, John R. 2012. Chapter 8: Effects of fire on intangible cultural resources: Moving toward a 

landscape approach. In, Ryan, K.C., A. T. Jones, C. L. Koerner, and K. M. Lee, eds.,

Wildland fire in ecosystems: effects of fire on cultural resources and archaeology Gen. 

Tech. Rep. RMRS-GTR-42-vol. 3. Fort Collins, CO. U.S. Department of Agriculture, 

Forest Service, Rocky Mountain Research Station.

Welch, KR, HD Safford, and TP Young. 2016. Predicting conifer establishment post wildfire in 

mixed conifer forests of the North American Mediterranean-climate zone. Ecosphere 7 

(12). doi: 10.1002/ecs2.1609.

Weller, M.W. 1996. Birds of rangeland wetlands. In, Krausman, P.R., ed., Rangeland wildlife. 71-

82. Denver, CO. The Society of Range Management.

Wenger, Seth J., Daniel J. Isaak, Jason B. Dunham, Kurt D. Fausch, Charles H. Luce, Helen M. 

Neville, Bruce E. Rieman, Michael K. Young, David E. Nagel, Dona L. Horan, and 

Gwynne L. Chandler. 2011. Role of climate and invasive species in structuring trout 

distributions in the interior Columbia River Basin, USA. Canadian Journal of Fisheries 

and Aquatic Sciences 68 (6):988-1008. doi: 10.1139/f2011-034.

Wenger, Seth J., Daniel J. Isaak, Charles H. Luce, Helen M. Neville, Kurt D. Fausch, Jason B. 

Dunham, Daniel C. Dauwalter, Michael K. Young, Marketa M. Elsner, Bruce E. Rieman, 

Alan F. Hamlet, and Jack E. Williams. 2011. Flow regime, temperature, and biotic 

interactions drive differential declines of trout species under climate change. Proceedings 

of the National Academy of Sciences 108 (34):14175-14180. doi: 

10.1073/pnas.1103097108.

Werth, Paul A, Brian E Potter, Craig B Clements, Mark Finney, Scott L Goodrick, Martin E 

Alexander, Miguel G Cruz, Jason A Forthofer, and Sara S McAllister. 2011. Synthesis of 

knowledge of extreme fire behavior: volume I for fire managers Gen. Tech. Rep. PNWGTR-854. Portland, OR. U.S. Department of Agriculture, Forest Service, Pacific 

Northwest Research Station. 144 pp.

Westerling, A. L. 2015. Personal communication between Dr. Westerling and Dr. Fites-Kaufman 

regarding statistical differences in fire-climate trend models using two (VCC 1 vs VCC2 

and 3) versus three (VCC VCC2, VCC3) vegetation condition class categories as input 

variables.

Westerling, A. L., B.P. Bryant, H.K. Preisler, T.P. Holmes, H.G. Hidalgo, T. Das, and S.R. 

Shrestha. 2011. Climate change and growth scenarios for California wildfire. Climatic 

Change 109:445-463.

Westerling, A. L., H. G. Hidalgo, D. R. Cayan, and T. W. Swetnam. 2006. Warming and earlier 

spring increase western U.S. forest wildfire activity. Science (New York, N.Y.) 313 

(5789):940-3.

Westerling, A.L., H.G. Hidalgo, D.R. Cayan, and T.W. Swenam. 2006. Warming and earlier 

spring increase western U.S. forest wildfire activity. Science 313:940-943.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

744

Westerling, A.L., and A. Keyser. 2016a. Changing fire, fuels and climate in the Sierra Nevada. 

Add-on high fire severity analysis. Draft report under USFS Cooperative Agreement: 

Modeling Potential Fire Impacts with Landscape Vegetation Scenarios and Changing 

Climate for the Sierra Nevada and Other Areas in the Western U.S. Merced, CA. 

University of California Merced.

Westerling, A.L., and A. Keyser. 2016b. Modeling Potential Fire Impacts with Landscape 

Vegetation Scenarios and Changing Climate for the Sierra Nevada and Other Areas in the 

Western U.S. In Changing fire, fuels and climate in the Sierra Nevada. Merced, CA.

University of California Merced.

Westerling, A.L., J. Milostan, and A.R. Keyser. 2015. Changing fire, fuels and climate in the 

Sierra Nevada. In Modeling Potential Fire Impacts with Landscape Vegetation Scenarios 

and Changing Climate for the Sierra Nevada and Other Areas in the Western U.S.: 

University of California Merced.

Westerling, AL, and BP Bryant. 2008. Climate change and wildfire in California. Climatic 

Change 87 (1):231-249.

Westerling, Anthony, and Benjamin Bryant. 2006. Climate change and wildfire in and around 

California: Fire modeling and loss modeling. A Report From: California Climate Change 

Center White Paper. California Energy Commission: CEC-500-2005-190-SF

Westerling, Anthony L, Alexander Gershunov, Timothy J Brown, Daniel R Cayan, and Michael D 

Dettinger. 2003. Climate and wildfire in the western United States. Bulletin of the 

American Meteorological Society 84 (5):595-604.

White, A. M., P. N. Manley, G. L. Tarbill, T. W. Richardson, R. E. Russell, H. D. Safford, and S. 

Z. Dobrowski. 2016. Avian community responses to post-fire forest structure: 

implications for fire management in mixed conifer forests. Animal Conservation 19

(3):256-264. doi: 10.1111/acv.12237.

Wiedinmyer, Christine, and Matthew D Hurteau. 2010. Prescribed fire as a means of reducing 

forest carbon emissions in the western United States. Environmental science & 

technology 44 (6):1926-1932.

Wiens, D., and M. R. Slaton. 2012. The mechanism of background extinction. Biological Journal 

of the Linnean Society 105 (2):255-268. doi: 10.1111/j.1095-8312.2011.01819.x.

Wiens, John A, Gregory D Hayward, D Hugh, and Catherine Giffen. 2012. Historical 

environmental variation in conservation and natural resource management. NY, NY. John 

Wiley & Sons.

Wills, R. 2006. Central Valley Bioregion. Southeastern deserts bioregion. Edited by N.G. 

Sugihara, J.W. van Wagtendonk, K.E. Shaffer, J. Fites-Kaufman and A.E. Thode, Fire in 

California’s Ecosystems. Berkeley, CA: University of California Press.

Wimberly, Michael C., Mark A. Cochrane, Adam D. Baer, and Kari Pabst. 2009. Assessing fuel 

treatment effectiveness using satellite imagery and spatial statistics. Ecological 

applications 19 (6):1377-84.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

745

Winter, P.L., J.W. Long, F.K. Lake, and S. Charnley. 2014. Broader context for social, economic, 

and cultural components. Chap. 9.1. In Science synthesis to support socioecological 

resilience in the Sierra Nevada and southern Cascade Range, edited by Jonathan W. Long, 

Lenya Quinn-Davidson and Carl N. Skinner. Albany, CA: U.S. Department of 

Agriculture, Forest Service, Pacific Southwest Research Station.

Winward, A. H. 2000. Monitoring the Vegetation Resources in Riparian Areas RMRS-GTR-47.

USDA Forest Service, Rocky Mountain Research Station. Ogden, UT.

Wisdom, Michael J, and Jeanne C Chambers. 2009. A landscape approach for ecologically based 

management of Great Basin shrublands. Restoration Ecology 17 (5):740-749.

Wolf, EC, and DJ Cooper. 2015. Fens of the Sierra Nevada, California, USA: patterns of 

distribution and vegetation. Mires and Peat 15 (08):1-22.

Wright, A. N. , R. J. Hijmans, M. W. Schwartz, and H. B. Shaffer. 2013. California Amphibian 

and Reptile Species of Future Concern: Conservation and Climate Change. In Final 

Report to the California Department of Fish and Wildlife Nongame Wildlife Program, 

Task 12, Contract No. P0685904: University California, Davis.

Wu, J.X., H.L. Loffland, R.B. Siegel, and C. Stermer. 2016. A Conservation Strategy for Great 

Gray Owls (Strix nebulosa) in California, Interim Version 1.0. Point Reyes Station, CA.

The Institute for Bird Populations and California Partners in Flight.

Wyman, W. 1945. The wild horse of the West. Lincoln, NE: University of Nebraska Press.

Yablon, Marcia. 2004. Property Rights and Sacred Sites: Federal Regulatory Responses to 

American Indian Religious Claims on Public Land. The Yale Law Journal 113 (7):1623-

1662. doi: 10.2307/4135775.

Young, Charles A., Marisa I. Escobar-Arias, Martha Fernandes, Brian Joyce, Michael Kiparsky, 

Jeffrey F. Mount, Vishal K. Mehta, David Purkey, Joshua H. Viers, and David Yates. 

2009. Modeling the Hydrology of Climate Change in California’s Sierra Nevada for 

Subwatershed Scale Adaptation. Journal of the American Water Resources Association 45 

(6):1409-1423. doi: 10.1111/j.1752-1688.2009.00375.x.

Young, DJN, JT Stevens, JM Earles, J Moore, A Ellis, AL Jirka, and AM Latimer. 2017. Longterm climate and competition explain forest mortality patterns under extreme drought. 

Ecology Letters 20 (1):78-86. doi: 10.1111/ele.12711.

Zeanah, David W. 2002. Central Place Foraging and Prehistoric Pinyon Utilization in the Great 

Basin. In Beyond Foraging and Collecting: Evolutionary Change in Hunter-Gatherer 

Settlement Systems, edited by Ben Fitzhugh and Junko Habu, 231-256. Boston, MA.

Springer US.

Zedeño, M. Nieves, Diane Austin, and Richard Stoffle. 1997. Landmark and Landscape: A 

Contextual Approach to the Management of American Indian Resources. Culture & 

Agriculture 19 (3):123-129. doi: 10.1525/cag.1997.19.3.123.
References

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

746

Zeiner, D. C., W. F. Laudenslayer, K. E. Mayer, and M. White. 1990. California’s Wildlife, 

Volume I: Amphibians and Reptiles, Volume II: Birds, Volume III: Mammals. California 

Statewide Wildlife Habitat Relationship System. Department of Fish and Game, The 

Resources Agency. Sacramento, California. 732 pages.

Zielinski, William J. 2014. The forest carnivores: marten and fisher. Chapter 7.1. In Science 

synthesis to support socioecological resilience in the Sierra Nevada and southern Cascade 

Range (Vol2), edited by J. W. Long, L. Quinn-Davidson and C. N. Skinner. Albany, CA: 

U.S. Department of Agriculture, Forest Service, Pacific Southwest Research Station.

Zielinski, William J., Richard L. Truex, Fredrick V. Schlexer, Lori A. Campbell, and Carlos 

Carroll. 2005. Historical and contemporary distributions of carnivores in forests of the 

Sierra Nevada, California, USA. Journal of Biogeography 32 (8):1385-1407. doi: 

10.1111/j.1365-2699.2005.01234.x.
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

747

Index

A

air quality, ii, iii, 21, 27, 33, 41, 44, 145, 147

emissions, xiii, xvii, 64, 79, 83, 88, 111, 131, 136, 

145, 147, 148, 149, 150, 151, 152, 153, 154, 

155, 156, 157, 158, 159, 224, 228, 233, 236, 

655, 657, 707, 712, 719, 729, 744

smoke, 148, 150, 152, 153, 154, 156

smoke and recreation, 148, 151, 153, 154, 155, 

157

visibility in wilderness, 148, 151, 153, 154, 156, 

157

Apache fritillary, 351

aquatic and riparian ecosystems, ii, iii, iv, vii, 22, 28, 

35, 42, 45, 66, 79, 206, 247, 258, 264, 270, 272, 

273, 278, 281, 295, 296, 297, 326, 327, 389, 390, 

391, 392, 395, 426, 427, 430, 444, 445, 448, 450, 

526, 576, 651, 655, 666, 709, 728

biodiversity, 208, 287, 300, 302, 307, 310, 312, 

313, 626, 629, 645, 651, 659, 667, 705, 727

connectivity, 286, 300, 302, 306, 309, 311, 313

habitat sustainability, 286, 297, 299, 301, 305, 309, 

311, 313

resilience to climate change, 23, 29, 36, 42, 45, 

287, 300, 302, 308, 310, 312, 313

riparian vegetation, 287, 300, 303, 308, 310, 312, 

313, 363

at-risk species, ii, iii, iv, vii, viii, 23, 27, 29, 34, 36, 42, 

45, 68, 70, 206, 211, 314, 326, 444, 450, 458, 646, 

651

B

bald eagle, 345, 373, 695, 739

best available scientific information, v, 77

bighorn sheep

Nelson desert bighorn sheep, 24, 30, 38, 42, 46, 

331, 334, 339, 340, 342, 367, 371, 389

Sierra Nevada bighorn sheep, xv, 24, 30, 38, 42, 46, 

68, 316, 331, 337, 338, 339, 355, 357, 366, 367, 

368, 370, 371, 372, 386, 388, 692, 698, 725, 

730, 739, 742

black toad, 273, 282, 302, 363, 364, 392, 409, 410, 

417, 437, 438

butterflies, 350, 382

C

California golden trout, 289, 290, 297, 363, 392, 393, 

408, 409, 411, 414, 439, 440, 598, 710, 729

California spotted owl, 23, 28, 30, 32, 34, 38, 46, 57, 

345, 376, 701, 715, 736

candidate plant species determination, 473

candidate species, vii, 316, 447, 450

whitebark pine, 458

carbon stocks, sequestration, and stability, 206, 215, 

223, 224, 228, 233, 235, 238, 241

cave pseudoscorpion, 353, 383

climate change

climate adaptation, xiv, 21, 22, 27, 33, 41, 44, 45, 

63, 79, 246, 247, 250, 251, 252, 256, 257, 258, 

300, 302, 310, 459, 465, 721

climate trends, xiii, 81, 82, 84, 91, 93, 95, 97, 172, 

173, 176, 240

climate vulnerability, 245, 246, 247, 248, 249, 252, 

254, 256, 333, 385, 576, 727

resilience to climate change, 11, 23, 29, 36, 42, 45, 

269, 274, 283, 287, 300, 302, 303, 308, 310, 

312, 313, 420, 465, 475

comment periods, 9, 10, 12, 647

complex early seral forest, 16, 28, 34, 40, 41, 45, 66, 

204, 207, 208, 212, 216, 218, 225, 228, 229, 230, 

231, 234, 237, 239, 243, 244, 334, 340, 353

connectivity, 65, 69, 207, 208, 212, 216, 224, 228, 

233, 236, 238, 241, 302, 306, 311, 679, 709

conservation watersheds, xiv, xv, 16, 35, 36, 56, 58, 

59, 66, 68, 69, 95, 274, 275, 276, 277, 278, 281, 

284, 285, 287, 289, 303, 304, 305, 306, 307, 308, 

313, 361, 364, 365, 374, 381, 419, 422, 427, 429, 

432, 437, 470, 489, 491, 497, 501, 516, 517, 543, 

609, 610, 619, 632

critical aquatic refuges, 17, 23, 29, 36, 42, 45, 56, 270, 

272, 278, 281, 284, 289, 470, 489, 491, 501

E

ecological integrity, i, ii, iii, iv, vi, 7, 22, 27, 33, 41, 44, 

58, 59, 160, 326, 608, 618

ecological zones, xiii, xiv, xv, xvii, 82, 84, 87, 88, 90, 

92, 160, 161, 165, 167, 171, 172, 182, 187, 207, 

215, 240, 336, 337, 340, 351, 353, 359, 373, 374, 

376, 380, 459, 519, 591, 594, 606, 608, 611, 618, 

619, 651

alpine, 176, 177, 191, 195, 200, 203, 204, 220, 222, 

224, 227, 233, 240, 356, 371

dry mixed conifer, xiv, 161, 166, 171, 172, 173, 

182, 190, 198, 202, 212, 213, 215, 216, 219, 

222, 248, 334, 376, 463, 586, 591, 594

eastside shrublands, xiv, 161, 172, 178, 181, 182, 

185, 187, 189, 191, 195, 196, 199, 200, 203, 

204, 205, 207, 222, 223, 224, 227, 230, 233, 

240, 335, 360, 375

Jeffrey pine, 174, 334

Jeffrey pine and dry mixed conifer, 105, 165, 166, 

213, 215, 221, 222, 227, 244, 334

lodgepole pine, 101, 161, 175, 182, 190, 213, 215, 

222, 235, 334, 335

mountain mahogany, 161, 172, 178, 179, 181, 182, 

200, 205, 212, 215, 221, 222, 233, 322, 335, 

343, 360, 450, 463
Index

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

748

pinyon-juniper, 165, 215, 471

red fir, 175, 185, 190, 191, 212, 215, 220, 222, 249, 

334, 344, 346, 358, 708, 715, 716

sagebrush, 165, 215, 471

Sierra Nevada montane zone, xiv, 161, 166, 172, 

176, 181, 183, 187, 189, 190, 193, 199, 202, 

203, 209, 215, 216, 222, 223, 227, 230, 232, 

234, 237, 240, 243, 334, 359, 360, 372, 373, 

374, 378, 685

subalpine, 191, 195, 200, 203, 204, 222, 224, 227, 

233, 240, 356

subalpine woodland and forest, 176, 177, 195, 

203, 213, 222, 224, 227, 333, 341, 715, 716

woodlands, xiv, 178, 182, 185, 189, 191, 195, 196, 

200, 203, 204, 205, 222, 224, 227, 233, 240, 

335, 360

xeric shrub-black brush, 167

economics, xii, 627, 628, 630, 631, 634, 636

ecosystem sustainability, xiv, 161, 211, 220, 221, 226, 

231, 232, 235, 237, 240, 244, 679, 680

F

federally listed species, 328, 330, 391, 396

determinations, 388, 443

Lahontan cutthroat trout, 402, 426

mountain yellow-legged frog, 316, 396, 421, 709, 

739

Owens tui chub, 404, 432, 739

Paiute cutthroat trout, 316, 403, 429, 740

Sierra Nevada yellow-legged frog, 317, 396, 421

Yosemite toad, 24, 30, 38, 43, 46, 307, 316, 399, 

423, 425, 694, 700, 740

fire management

Cohesive Fire Strategy, 25, 32, 57

community wildfire protection zone, 26, 32

fire-adapted communities, 129, 131, 134, 136

general wildfire protection zone, 26, 32

managing wildfire to meet resource objectives, ii, 

iii, 21, 27, 33, 41, 44

safe and effective fire fighting, 130, 132, 135, 136

strategic fire management zones, ii, iii, 21, 25, 32, 

40, 44, 120, 122, 124, 126, 132

wildfire as a tool, 128, 131, 133, 135

wildfire maintenance zone, 26, 33, 40, 56, 124, 

127, 309, 368, 424, 460, 531, 532, 533, 542, 544

wildfire restoration zone, 26, 33, 56, 63, 124, 368, 

424, 428, 460, 469, 531, 542

wildfire risk management, 113, 141

wildland fire, 32, 40, 44, 57, 111, 112, 118, 124, 

127, 137, 142, 143, 184, 276, 305, 369, 409, 

411, 412, 424, 432, 438, 460, 583, 584, 692, 

699, 710, 720, 722, 731, 732, 740

fire regimes, 206, 212, 215, 220, 223, 226, 232, 235, 

238, 240, 716, 730

fire trends, v, 81, 90, 105, 110, 149, 156, 165, 183, 

187, 192, 195, 198, 199, 201, 215, 220, 223, 224, 

225, 227, 228, 234, 236, 237, 238, 241, 248, 251, 

253, 254, 256, 262, 264, 272, 273, 274, 303, 312, 

332, 354, 357, 359, 361, 390, 416, 419, 420, 508, 

537, 591, 592, 594

forest plan

contents defined, i, 4

current plan, ii, 21

need for changing the plan, i, 6

forest products, x, 13, 53, 74, 216, 462, 485, 576, 583, 

584, 585, 586, 587, 588, 589, 590, 591, 592, 593, 

594, 624, 638, 658, 666, 667, 675

area restored, x, 587, 589, 591, 592, 594

special forest products, x, 587, 588

suitability for timber production, 584, 585

treatment costs, 590

G

great gray owl, i, 18, 23, 30, 38, 42, 46, 346, 378, 745

H

habitat diversity, 22, 28, 34, 42, 45

heritage resources, 517

I

insects and pathogens, v, 98, 104, 160, 164, 173, 212, 

216, 220, 241, 247, 248, 664

bark beetles, v, 101, 702

defoliators, v, 102

dwarf mistletoes and root diseases, v, 102

expected trends, 104

nonnative insects and diseases, v, 104

interdisciplinary team members, 663

invasive species, 21, 378, 416

Inyo Mountains slender salamander, 392, 409, 437, 

438, 439

issues, i, 10

J

Jeffrey pine, 98, 171, 174, 182, 212, 334, 586

John Muir Trail, xviii, 561, 567, 571

K

Kern Plateau salamander, 339, 392, 409, 411, 437, 

438

keystone species, 208, 209, 210, 217, 219, 226, 230, 

232, 234, 237, 239, 243, 256, 294
Index

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

749

L

Lahontan cutthroat trout, 402, 426

livestock grazing, iii, x, 38, 62, 74, 263, 268, 298, 414, 

595, 606, 607, 613, 617, 618, 619, 703

rangeland ecosystems, x, xi, 597, 613

rangeland vegetation, 606, 608, 618

suitable lands, 601

M

management areas, v, xiii, xvi, 8, 16, 25, 31, 32, 35, 

39, 43, 46, 55, 56, 57, 61, 62, 73, 96, 113, 122, 124, 

126, 192, 274, 289, 303, 305, 313, 354, 370, 431, 

436, 475, 491, 537, 547, 557, 558, 559, 562, 565, 

566, 568, 569, 571, 609, 610, 613, 614, 615, 617, 

619, 633, 713

Mono Basin National Forest Scenic Area, 40

Mono Lake checkerspot, 351, 382

Mount Pinos sooty grouse, 348

mountain yellow-legged frog, 316, 396, 709, 739

N

National Register of Historic Places, xvi, 517, 518, 521, 

523, 525, 581, 689, 720

national visitor use monitoring, xv, 476, 484, 485, 

486, 528, 657, 658, 734

Nevada Enhancement Act, ii, xvii, 19, 20

O

old forests, 22, 65, 164, 207, 208, 209, 212, 216, 224, 

229, 233, 236, 238, 242, 244, 254

Owens tui chub, 404, 432, 739

Owens Valley springsnail, 392

P

Pacific Crest National Scenic Trail, 7, 16, 25, 31, 39, 

43, 46, 56, 73, 476, 555, 559, 560, 571, 657, 733

Pacific fisher, i, 18, 24, 343, 372

Paiute cutthroat trout, 316, 403, 429, 740

partnerships, 18, 514

piaga (Pandora moth), 18

planning rule, i, 3

preferred alternative, ii, 31

priority watersheds, 36

public participation, i, 5, 8, 49, 662

R

recreation

recreation management zones, 39

renewable energy, xvi, 563, 564, 570, 571

riparian conservation areas, 28, 35, 299, 304, 351, 

409, 610, 686

S

sage-grouse, 23, 29, 37, 42, 347, 375

San Emigdio blue, 351, 382

scenery management system, 19

scenery resources, viii, 508, 510

scenic integrity objectives, 508, 512

scenic stability and character, 511

Sierra marten, i, 18, 24, 344, 373

Sierra Nevada yellow-legged frog, 317, 396

Sierra sulphur, 351, 382

social conditions, xii, 75, 81, 639, 650, 666

Civil Rights, 2, xii, 640, 647, 656, 733

environmental justice, xii, 641, 648, 657, 700, 733

values, xii, 75, 578, 640, 645, 650, 659, 691, 695, 

705

species of conservation concern, i, vii, 17, 95, 247, 

318, 319, 325, 328, 331, 339, 408, 411, 437, 440, 

447, 451, 461, 609, 663, 667, 696

Apache fritillary, 351

aquatic species, 392, 443

aquatic wildlife outcomes, 443

bald eagle, 345, 373, 695, 739

bighorn sheep, 24, 30, 38, 42, 46, 342, 371

black toad, 410, 437

butterflies, 350, 382

California golden trout, 392, 411, 439, 729

California spotted owl, 23, 28, 30, 32, 34, 38, 46, 

57, 345, 376, 701, 715, 736

cave pseudoscorpion, 353, 383

great gray owl, i, 18, 23, 30, 38, 42, 46, 346, 378, 

745

greater sage-grouse, 347, 375

Inyo Mountains slender salamander, 410, 437

Kern Plateau salamander, 411, 437, 438

mammals and birds, xv, 339, 340

Mono Lake checkerspot, 351, 382

Mount Pinos sooty grouse, 348

Owens Valley springsnail, 413, 440

Pacific fisher, i, 18, 24, 343, 372

plant determinations and outcomes, 473

Ramshaw Meadows Abronia, 462

San Emigdio blue, 351, 382

Sierra marten, i, 18, 24, 344, 373

Sierra sulphur, 351, 382

square dotted blue, 352, 382

terrestrial invertebrates, xv, 350, 351

terrestrial wildlife outcomes, 389

western pearlshell mussel, 413

willow flycatcher, i, 18, 24, 43, 316, 348, 381, 714

spotted owl, 23, 28, 30, 32, 34, 38, 46, 57, 345, 376, 

701, 715, 736

square dotted blue, 352, 382

sustainable recreation, viii, 476, 528, 538

access, x, 480, 489, 492, 498, 501, 502, 574, 578, 

579, 580, 581, 582, 673, 674

facilities and level of development, 483, 490, 493, 

499, 502, 503
Index

Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

750

recreation settings and opportunities, ix, 478, 487, 

491, 494, 501, 502, 538

visitor use, x, 477, 484, 490, 494, 499, 502, 503, 

560, 567, 570

T

terrestrial ecosystems, ii, iii, iv, v, vi, 22, 27, 33, 41, 

44, 64, 65, 66, 79, 81, 82, 84, 89, 99, 107, 108, 109, 

160, 264, 270, 278, 279, 326, 327, 332, 334, 444, 

445, 448, 450, 465, 576, 651, 659, 665, 666, 668

Tribal consultation, 10

Tribal relations, i, x, 18, 219, 223, 518, 547, 571, 575, 

588, 650, 652, 658, 662, 664, 665, 670

Tribal resources, x, 574, 578, 579, 580, 581, 582

Tribal uses, 571

Tribal uses and biocultural diversity, 211, 219, 223, 

226, 231, 235, 237, 240, 244

V

vegetation types, 172, 182

hardwood, xiv, 169

visual management system, 24, 61

W

water quality, vii, 67, 68, 258, 260, 261, 263, 264, 267, 

268, 270, 272, 275, 278, 281, 283, 286, 288, 672

impaired waters, xiv, 265, 268, 283

water quantity, vii, 67, 258, 260, 262, 265, 268, 270, 

273, 276, 279, 281, 284, 286, 288

watersheds

condition, vii, xiv, 25, 31, 35, 67, 68, 258, 259, 260, 

262, 263, 266, 267, 269, 271, 273, 274, 275, 

276, 277, 278, 279, 282, 284, 285, 286, 288, 

289, 297, 304, 306, 308, 311, 326, 414, 432, 

469, 497, 576, 602, 604, 609, 688, 734

condition class, xiv, 267

conservation watersheds, xiv, xv, 16, 35, 36, 58, 

59, 66, 68, 69, 95, 274, 275, 276, 277, 278, 281, 

284, 285, 287, 289, 303, 304, 305, 306, 307, 

308, 313, 361, 364, 365, 374, 381, 419, 422, 

427, 429, 432, 437, 470, 489, 491, 497, 501, 

516, 517, 543, 610, 619, 632

functioning at risk, 261, 263, 267, 288, 289, 291, 

604

functioning properly, 261, 267, 288, 289, 468

impaired function, 261, 267, 289

western pearlshell, 392, 413, 440, 705, 708

whitebark pine, xv, 70, 98, 101, 177, 191, 195, 203, 

204, 246, 249, 252, 254, 256, 317, 325, 358, 359, 

445, 446, 447, 450, 451, 458, 459, 460, 461, 473, 

652, 709, 713, 715, 716, 721, 728

wild and scenic rivers, 19, 549

eligible and suitable rivers, ix, 552

wild horse and burro management, 612

land suitability, 615

wilderness

designated wilderness, ii, viii, ix, 24, 56, 526, 527, 

529, 530, 531, 534

recommended wilderness, ii, iii, iv, ix, x, 12, 30, 39, 

43, 46, 56, 60, 71, 72, 73, 533, 535, 536, 537, 

574, 578, 579, 580, 581, 582, 610, 619, 664

natural resource management, ix, 541

recreation and access, ix, 538

special uses, ix, 535, 536, 539, 541, 545

wildlife, fish and plants

migratory birds, vii, 324

stressors and threats, xv, 336, 337, 340, 351, 409, 

412

terrestrial wildlife habitat, 333, 335, 356, 362, 363

willow flycatcher, i, 18, 24, 43, 316, 348, 381, 714

Y

Yosemite toad, 24, 30, 38, 43, 46, 307, 316, 399, 423, 

425, 694, 700, 740
Final Environmental Impact Statement

for Revision of the Inyo National Forest Land Management Plan – Vol. 1

751