United States Department of Agriculture

1st 48 Roadside Fuelbreak 

Collaborative Project

Draft Decision Notice & Finding of No Significant Impact

Forest 

Service

Pacific Southwest 

Region

Six Rivers 

National Forest

R5-MB-313

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

Prescott.

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USDA is an equal opportunity provider, employer, and lender.
Draft Decision Notice & Finding of No Significant Impact – i

1st 48 Roadside Fuelbreak Collaborative Project

Draft Decision Notice & Finding of No Significant Impact

Trinity County, California

Responsible Official: Merv George Jr., Forest Supervisor

Six Rivers National Forest

1330 Bayshore Way

Eureka, CA 95501

(707) 441-3534

mgeorge@fs.fed.us

For Information Contact: Dan Dill, District Ranger

Mad River Ranger District

741 State Highway 36

Bridgeville, CA 95526

(707) 574-6233

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

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

Table of Contents

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

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

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

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

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

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

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

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

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

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

Tribal Consultation ...............................................................................................................................9

Scoping ...............................................................................................................................................10

Alternative Considered in Detail, but not Selected.................................................................................10

Finding of No Significant Impact ...............................................................................................................11

Context ...................................................................................................................................................11

Intensity ..................................................................................................................................................11

Implementation Date ..............................................................................................................................29
iv – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

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Draft Decision Notice

Draft Decision Notice & Finding of No Significant Impact – 1

Draft Decision Notice

Introduction

In 2013, the Trinity County Collaborative (TCC)1 brought forward a “proof-of-concept” proposal seeking 

collaboration with leadership on the Six Rivers National Forest (SRNF or forest), to take immediate action 

to establish a network of linear roadside shaded fuelbreaks on national forest lands to facilitate safe 

evacuation, firefighter access and landscape fire management. This draft Decision Notice and Finding of No 

Significant Impact (DN and FONSI) documents my selection to implement Alternative 2, representing the 

TCC’s proposal, as disclosed in the 1st 48 Roadside Fuelbreak Collaborative Project (1st 48 Project) Final 

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

Alternative 2 developed in detail to meet the purpose and need and respond to public issues, and Alternative 

1 (No Action), as a comparison of what could happen without management (final EA pp. 17-44).

The 1st 48 Project was designed in compliance with the standards and guidelines (S&Gs) per the 1995 

Six Rivers Land and Resources Management Plan (LRMP or forest plan), the 1999 Shasta-Trinity 

National Forest’s Late Successional Reserve Assessment (LSRA), the 2011 Recovery Plan for the 

Northern Spotted Owl (Recovery Plan), the 2012 Northern Spotted Owl Critical Habitat Rule (Critical 

Habitat Rule), the 1994 Aquatic Conservation Strategy (ACS), and other federal, state, and local laws and 

requirements (final EA pp. 7-13).

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

California, in T2S, R8E, Sec. 6, 7, 8, 18, 19, 20, 21, 28, 29, 30, 31, 32 and 33; and T2S, R7E, Sec. 11, 12 

and 13, Humboldt Baseline and Meridian. The 1st 48 Project is near the community of Ruth, ranging from 

2,700 feet in elevation to 5,800 feet at the top of South Fork Mountain (final EA p. 4).

Purpose and Need

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

that allow for safer evacuation during wildfires; allow greater, faster wildland firefighter response and 

suppression; and reduce the risk of roadside fire starts traveling into high-value landscape-level forest 

resources (final EA pp. 5-6).

Decision

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

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

Proposed Action), as described in Chapter 2 pp. 17-42 of the final EA. My decision authorizes thin from 

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

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

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

below, hazardous fuels reduction, prescribed jackpot and underburning on approximately 821 acres of 

National Forest System (NFS) lands over the next 15 years, and decommissioning a segment of Forest 

Service Road (FSR) 2S54.

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

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

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

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

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

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

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

My decision will establish roadside fuelbreak networks (both tree shaded and unshaded where open 

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

. All 

proposed treatments would occur at varying widths on FSRs open to the public, from a minimum of 25 

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

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

2S53) and one (1) motorized trail (Jeep Trail 8E20). All treatments will reduce hazardous surface and 

ladder fuels and breakup intermingled tree crown fuels, while maintaining sufficient tree shade to curb 

brush response (final EA pp. 2, 18).

The 1st 48 Project will thin suppressed, intermediate and co-dominant trees (see final EA Table 4) 

using cable- and ground-based mechanical methods (such as tractor and masticator). Hazardous fuels 

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

brush masticated, followed by machine (dozer or small excavator equipped with a brush rake) and handpiling debris, manually lopping and scattering surface and small ladder fuels, prescribed jackpot burning 

and underburning in oak woodlands to stimulate oak regeneration.

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

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

perimeter of the plantations, hazardous fuels reduction (HFR) treatments would be implemented to 

establish a 150-foot flank or buffer intersecting with the roadway (final EA p. 18).

Specifically, my decision authorizes:

o 461 acres of mechanical thin from below and mechanical, manual and jackpot burning HFR

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

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

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

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

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

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

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

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

Draft Decision Notice & Finding of No Significant Impact – 3

o 37 acres of mechanical thin from below, manual and phased underburning HFR in oak 

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

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

underburning to the oak woodland units.

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

no live tree overstory.

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

o Decommissioning FSR 2S54 (classified Maintenance Level (ML) 2 road open to the public), 

which includes removing drainage structures, restoring natural drainage patterns and placement 

of an earth mound barrier at the entrance to prevent motorized use and the promotion of passive 

restoration of the travelway, and managing in a maintenance-free condition for the long term.

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

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

previous ground disturbance within units or existing roadside turnouts.

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

roads will be barricaded post operations, once the thin from below and HFR treatment 

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

will involve activities to achieve hydrologically maintenance-free conditions.

Permits, Licenses and Authorizations Needed to Implement the Decision

In accordance with 40 CFR 1502.25 (b), the EA is to list all federal permits, licenses, or other entitlements 

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

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

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

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

Mitigation and Monitoring

I recognize there may be short-term disturbances to the human environment from the use of machinery, 

presence of field crews and associated increased traffic, noise and smoke from prescribed burning when

operations are underway. My decision requires application of project design features (PDFs) and 

mitigation measures aimed at reducing, minimizing, or eliminating impacts to various natural and cultural 

resources, and ensuring the project is in compliance with the resource protection standards and guidelines 

(S&GS) of the SRNF LRMP; the Record of Decision for amendments to the survey and manage, 

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

Land Management planning documents within the range of the northern spotted owl (USFS et al. 2001),

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

Bonnie, W.WA No. C08-1067-JCC); US Forest Service Region 5 Soil Management Handbook (FSH 
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4 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

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

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

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

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

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

decisions, 2) establish a baseline for various measures prior to implementation and mitigations, and 3) verify 

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

implementation of management actions to ensure that mitigation measures are implemented effectively.

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

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

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

spectrum of techniques and methods may be used including:

o Formal joint management and collaborative field reviews

o Site-specific observations by on-site resource specialists

o Field assistance trips by other technical specialists

o On-going accomplishment reporting processes

o Discussions with other agencies and various public users

o Interdisciplinary team reviews of monitoring results.

Implementation and effectiveness monitoring for cumulative watershed effects will be accomplished 

through the BMP Effectiveness Evaluation Process. The objective is for BMP implementation to be at 100 

percent. Results for any BMP below 85 percent trigger a review of the activity area before implementation 

of further projects. Implementation monitoring is achieved by selecting a representative number of 

treatment units each year from a sample pool of completed stands or project areas. A complete listing of 

BMPs is included in Appendix C of the final EA.

Wildlife monitoring will occur by conducting northern spotted owl (NSO) surveys in compliance with 

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

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

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

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

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

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

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

Reasons for the Decision

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

consultation, public comments, resource reports, the No Action Alternative (Alternative 1) and the 

potential effects and outcomes (final EA pp. 17-18). My decision to implement Alternative 2 signifies a 
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Draft Decision Notice & Finding of No Significant Impact – 5

step toward aiding the protection of dispersed private properties, residents and the at-risk community of 

Ruth3. It also provides an opportunity to demonstrate TCC’s “proof-of-concept” in alignment with the 

National Cohesive Wildland Fire Management Strategy (Cohesive Strategy) and the Six Rivers LRMP, as 

disclosed in the 1st 48 Project final EA.

I believe Alternative 2 will effectively capitalize on the benefits that roads and trails provide in 

rapidly deploying firefighters, making the most of suppression tactics. By establishing crown separation 

in the forest canopy and lowering fuel concentrations, firefighters will have defensible space from which 

the flame front can be contained. My highest priority is to serve local residents living in and around the 

town of Ruth, by establishing safe evacuation routes so they can get to safety during a wildfire.

My decision will address high tree densities and associated intertwined tree crowns, which promote a 

route for active crown fire, particularly during wind-driven events. Thinning from below will act to 

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

response of understory brush species. I believe that retaining adequate tree shade will minimize the loss of 

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

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

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

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

There are 88 acres of 1st 48 Project units within the burned area of the Ruth Fire. Fire effects are variable 

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

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

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

forest (Sugihara et al. 2006). The dramatic reduction in wildfire burn acreages over the last 80 years 

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

vertically. Given this increased conifer density, future wildfires could become larger and more destructive 

than in the past. In the prolonged absence of fire, aggravated by other disturbance factors, these fireadapted forests and grasslands have undergone dramatic changes in species composition and structure. 

Intermediate canopy layers and higher ground fuel loadings have developed, which allow ground fires to 

reach the crown more easily, making fires more difficult to control (final EA pp. 49-55).

Young plantations now occupy most of the harvested old-growth sites within the project area. Earlyand mid-seral stages of Douglas-fir are more susceptible to mortality by wildfire than older late-seral 

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

whereby crowns become fully engulfed in flames. While thick, corky bark on the lower bole and roots of 

older trees protects the cambium from heat damage, and tall trees have their foliage concentrated on the 

upper bole, which makes it difficult for fire to reach the crown, trees are typically not free of lower 

branches until they are more than 100 years old (Hermann et al. 1990).

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

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

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

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

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

For example, the existing basal area within the Douglas-fir series in the project area ranges from 71 

square feet per acre to 545 square feet per acre, with an average of 229 square feet per acre. Typical average 

post-thinning target basal areas aimed at promoting healthy conditions for early-mature Douglas-fir stands 

ranges from 120 square feet per acre to 160 square feet per acre. Currently, approximately 85 percent of 

Douglas-fir-dominated stands feature basal areas greater than 160 square feet per acre. My concerns are these 

tree densities will promote tree mortality contributing to fuel concentrations, likely to fuel high intensity fire 

behavior and severity at a large scale, similar to the Ruth Fire (final EA p. 51). I have concluded Alternative 2 

offers an important advantage over not taking action, by establishing fuelbreak networks and lowering 

hazardous fuels to lessen the impacts of wildfires on communities and the environment.

One of the most threatened species is the California black oak (Quercus Kelloggii), which is vulnerable 

to being overtopped and crowded out by Douglas-fir. One of the biggest deficits on the landscape is the old 

upland oak woodland (final EA p. 50). Therefore, my decision will implement thinning around these remnant 

oak trees being over topped and shaded out by faster growing Douglas-fir, which will enable them to receive 

more sunlight to promote the growth of fuller crowns, increasing their health and resistance to disturbance.

Relevant Issues

I considered the following relevant issues associated with implementing the 1st 48 Project. I made my 

decision with the greatest good in mind.

Wildlife Habitat Quality

I understand the reduction of forest ladder and select crown fuels may lower habitat quality for the NSO 

(Strix occidentalis caurina). I considered the analysis of predicted changes under Alternative 2 on nesting, 

roosting, foraging, and dispersal habitats within NSO core and home ranges. The changes in NSO habitat 

were analyzed and compared to the suggested levels of habitat as described by the USFWS (USDI Fish 

and Wildlife Service 2009), published research, and professional judgement. Based on my review, I find 

Alternative 2 contributes to fulfilling the goals and objectives of the USFWS’s Recovery Plan (final EA

pp. 61-85).

The California Coast Range (Klamath West) is considered a “fire-prone” area because of its frequent fire 

return intervals and existing vegetation condition that likely elevates the potential of fire. Within fire-prone 

areas, resource agencies planning vegetation management in critical habitat for the NSO are encouraged to 

ameliorate current threats of on-going habitat loss from uncharacteristic fires and vegetation change that are 

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

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

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

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

1994, and larger, landscape-level managed late-successional areas. The network of reserves is intended to 

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

and help ensure that late-successional species diversity will be conserved.
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Draft Decision Notice & Finding of No Significant Impact – 7

In 1999, the Shasta-Trinity National Forest (STNF) completed a forest-wide LSR assessment (August 

26, 1999) to determine their sustainability and provide information to decision makers for managing LSRs 

to meet forest plan goals and objectives. The South Fork LSR encompasses 80,451 acres, with the majority 

located on the STNF. Of that, 1,057 acres are situated and administered by the SRNF. The 1st 48 Project

will manage 73 acres (49 acres of thin from below) within the South Fork LSR, as it was identified as a 

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

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

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

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

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

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

Northwest Forest Plan (NWFP) S&Gs (USDA REO letter, October 18, 2009). I find my decision is 

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

reducing risk (potential loss due to wildfire) in younger white fir stands adjacent to FSR 2S23, and along 

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

My decision to implement the 1st 48 Project will expedite conservation and restoration of spotted owl 

sites and high-value spotted owl habitat using fuels techniques to enhance structural complexity and 

biological diversity, as recommended by the Recovery Plan and Critical Habitat Rule. Alternative 2 will 

apply thinning from below to accelerate diameter and height growth, while retaining a minimum 60 

percent forest canopy closure in all suitable habitat for the NSO. No pre-dominant or dominant trees will 

be cut, and large snags and downed logs will be maintained. Stands selected for treatment in the project 

area are predominantly 80 years old or less (final EA p. 61).

My review of the wildlife analysis indicates four (4) of the ACs in the 1st 48 Project area overlap the 

Kelsey Peak Project planning area. The cumulative effects analysis considered habitat effects of these four 

(4) NSO ACs within their entire home ranges. The maximum acres treated within an AC for these two (2) 

projects combined is 19 percent of nesting/roosting and 36 percent of foraging habitat. Current habitat 

function has been or will be maintained in all treated areas. The wildlife analysis indicates approximately 

98 percent of the available nesting/roosting and 90 percent foraging habitat within the Upper Mad River 

Watershed will be left untreated and available as alternative habitat for the use by NSOs.

As I understand it, all treatment areas in the action areas will remain suitable immediately post 

project, as treatments were designed to maintain and restore habitat function in low- to moderate-quality 

habitat in all project units. Post-treatment monitoring was conducted by the US Forest Service (Forest 

Service or USFS) in coordination with the USFWS on the Kelsey Peak Project, as well as on projects 

elsewhere on the forest (final EA pp. 91-94). These previously implemented projects applied treatments

similar to the 1st 48 Project. Monitoring indicates canopy closure requirements were exceeded for all the 

units and pre-dominant trees, snags, and downed logs were retained, as specified (final EA p. 93). 

Therefore, I conclude the 1st 48 Project, even in light of cumulative effects, will have beneficial effects on 

future habitat conditions and create more alternative habitats for owls to use across the landscape.
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8 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Soil Erosion

I recognize tree removal and associated operations (i.e., skidding, temporary road use and expansion of 

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

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

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

Act §303(d) impaired 1992) (final EA pp. 95, 101-102). However, even so, my concern is for events such as 

the Ruth Fire in 2011, which consumed forest vegetation leaving soils barren and vulnerable to erosion and 

displacement resulting in substantial disruptions to the watershed conditions and hydrological function.

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

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

along streams and low-intensity thinning from below and HFR are spatially limited to 130 acres, or 16 

percent of the project area units. I am authorizing jackpot burning and underburning, but it is limited to 

low to moderate intensity to retain sufficient surface duff and litter cover (final EA pp 40-41, 102).

My review of the soils analysis, which was based on the Region 5 Soil Erosion Hazard Rating (EHR) 

System (USDA Forest Service 1990) as a method to rate the risk of soil erosion for all soil types in the 

project area, indicates none of the soils in the project area have a high EHR, with 50 to 70 percent soil 

cover on their respective average slope gradients. Most of the soils do not even have a high EHR when 

bare, due to the surface loams being very porous (>2 in/hr. infiltration rate), which is typical of loamy and 

most fine-loamy forest soils. It is expected there will be areas of bare soils after ground-based operations 

are complete (existing temporary roads and landings), typically less than 10 percent of the unit area. My 

decision requires that in any areas rendered bare on greater than one-fifth of an acre will be monitored for 

vegetation recovery, and will be actively mulched and/or seeded if any evidence of substantial erosion is 

discovered and/or if natural revegetation is not timely.

I find my decision to implement the 1st 48 Project will maintain at least 50 percent cover of duff and 

fine litter for soil productivity (with perhaps more needed for erosion prevention as determined for the 

project), in compliance with SRNF LRMP S&Gs. Furthermore, treatment intensity is much less than 

historic clearcut practices. A living forest canopy that continually adds litterfall to the forest floor will 

compensate in the short-term to cover small areas that may burn hot or otherwise where more cover is 

inadvertently removed than desired. A healthy productive forest is the best case for self-maintaining 

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

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

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

been aggressive, so current cover levels are adequate in extent (>50%) (final EA pp. 113-122).

The 1st 48 Project will lower erosion rates associated with FSR 2S54, an ML 2 road that is 1.95-miles 

long, by decommissioning it from where it intersects with FSR 2S02. Activities will include barricading 

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

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

the long term. The combination of barricading and water dispersion treatments are designed to stop water 

from concentrating on the travelway surface, reduce the potential for stream diversions (i.e., prevent water 
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Draft Decision Notice & Finding of No Significant Impact – 9

from flowing down the road or trail), and reduce the potential for erosion and associated off-site sediment 

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

soil resources, as roadside fuelbreak treatments are designed to aid wildfire containment and control to 

decrease the probability for large-scale, high-intensity fire behavior to protect soils, down woody debris 

and nutrient cycling in the long term (final EA p. 120).

Best Available Science

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

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

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

the assumptions underpinning the basis for the findings.

Public Involvement

Collaboration

Since 2012, the TCC, spurred by the encouragement of USDA Secretary Tom Vilsack, helped to develop

the strategy and landscape-scale (742,000 acres) Trinity Community Protection and Landscape 

Restoration Project, spanning the STNF and SRNF along with interspersed private timberlands, ranches,

and six (6) isolated rural communities. This project set the stage for using prescribed fire as a primary tool

to help protect communities, watersheds and habitats in the near future, fulfilling the goals of the

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

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

Restoration Partnership (Joint Chiefs).

In 2013, the TCC working group approached SRNF leadership, submitting a proposal as a “proof of 

concept” to begin to incrementally achieve the goals of the larger landscape TCC project. In 2016, the 

Forest Service and TCC working group met in the field to discuss the bounds of the project area and 

potential treatment methodology within mutual zones of agreement. The TCC working group participated 

in interdisciplinary team (IDT) meetings and discussions beginning in 2017. On-going informal 

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

conversations about refining the proposal and progress updates (final EA p. 13).

Tribal Consultation

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

Preservation Act (NHPA; 36 CFR 800.2(c)(2)) with the Bear River Band of Rohnerville Rancheria, Round 

Valley Indian Tribes: A Sovereign Nation of Confederated Tribes, the Wiyot Tribe, the Lassic Band of 

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

understands that the local tribes continue to play an important role in this and other undertakings on the 

forest. Tribal knowledge of the area and potential concerns about natural and cultural resources management 
Draft Decision Notice

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

within their ancestral territory is an important part of the project design and analysis. A comment submitted 

stated, “We hope that the proposed 1st 48 Project and the joint participants be allocated the revenue and 

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

severity fires, waterways that are healthy and able to sustain our local wildlife” (final EA pp. 13-14).

Scoping

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

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

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

Municipal Watershed District, the USFWS, US Congressional Representative Jared Huffman, County Board 

of Supervisors for Humboldt and Trinity counties, American Forest Resource Council, Environmental 

Protection Information Center (EPIC), Conservation Congress and Journey’s End, to name a few.

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

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

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

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

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

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

Alternative Considered in Detail, but not Selected

In addition to the Selected Alternative (Alternative 2), I considered the No Action Alternative (Alternative

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

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

Alternative 2 is not implemented. Although under Alternative 1, unavoidable short-term impacts from 

implementing thinning from below and HFR will not occur at this time, and the lack of action could result 

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

I did not choose the No Action Alternative because it does not meet the Purpose and Need to 

implement the Six Rivers LRMP or the “proof-of-concept” proposal submitted by the TCC. The No

Action Alternative will not meet the Purpose and Need to establish strategically placed, roadside

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

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

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

overtopped by conifers and water availability becomes more limited from inter-tree competition. 

Alternative 1 will tend to maintain forest conditions prone to high-intensity fire behavior; challenging for 

fire suppression crews to manage safely (final EA pp. 49-56). Under the No Action Alternative, point 

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

For these reasons, I choose not to select Alternative 1.
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 11

Finding of No Significant Impact

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

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

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

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

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

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

intensity. I considered the following evaluation of 1st 48 Project’s context and intensity 

summarized below.

Context

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

(human, national), the affected region, the affected interests, and the locality. Significance varies 

with the setting. In the case of a site-specific action, significance usually depends upon the effects 

in the locale, rather than in the world as a whole. Both short- and long-term effects are relevant.

The 1st 48 Project’s context is limited to 821 acres around the community of Ruth within the 

wildland-urban interface (WUI), two 6th-field watersheds, and the South Fork Late-Successional 

Reserve (LSR) encompassing 80,451 acres, of which 73 acres lie within the project area on the 

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

while benefits will be long lasting.

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

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

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

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

Intensity

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

summarizes the findings of intensity relative to those factors:

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

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

Fire, Fuels and Vegetation.

I find there will be positive response to thinning from below from implementing the 1st 48 Project, 

since suppressed, intermediate and select co-dominant trees will be removed to allow upper 

canopy trees (healthy dominant and pre-dominant) to expand into the additional growing space to 
Finding of No Significant Impact

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

achieve desired shaded-fuelbreak conditions. Thinning from below acts to increase the residual 

size of trees left in a stand (Agee and Skinner 2005, Smith et al. 1997; final EA pp. 56-57).

I believe reducing stand density at this time will also allow these forested stands to quickly 

develop more resilience to disturbances, such as wind, heavy snow and ice, bark beetle infestations

and fire processes. Thinning, whether from below or throughout the diameter classes (with the 

exception of pre-dominant and dominant trees), increases spacing and reduces stand densities, 

resulting in less inter-tree competition, which increases individual tree vigor, resulting in stands 

that are more resilient to insects, disease, wildland fire, and drought (Agee and Skinner 2005, 

Fettig et al. 2007, Hessburg et al. 2016, van Mantgem et al. 2009, Vernon 2017; final EA p. 57).

As the 1st 48 Project will reduce ladder fuels, canopy base heights will be increased, meaning 

there will be less low-lying tree limbs to carry fire on the ground up into their crowns. Canopy 

densities will be decreased through thinning activities; and to a potentially noticeable extent, a 

reduction in fuel ladders will also occur. As a result, the 1st 48 Project will help to reduce flame 

lengths, resistance to control, and the potential for a ground fire to transition into a crown fire

(final EA pp. 54-57).

One of the most threatened species is the California black oak (Quercus kelloggii), which is 

vulnerable to being overtopped and crowded out by Douglas-fir. One of the biggest deficits on the 

landscape is the old upland oak woodland (CR). Thinning around these remnant oak trees being 

over topped and shaded out by faster growing Douglas-fir, would enable them to receive more 

sunlight promoting the growth of fuller crowns, which would increase their health and resistance 

to disturbance (final EA pp. 50-51, 58).

Invasive Plant Species.

The policies from Forest Service Manual (FSM) 2900 (Invasive Species Management) that guide 

management of invasive species on National Forest System (NFS) lands require that land 

management activities not foster the introduction and spread of invasive species, apply to the 1st

48 Project. Project design features (PDFs) and mitigation measures described in Chapter 2 of the 

final EA will reduce the risk of introduction and spread of invasive non-native plant species from 

high to low. Isolated populations will also be eradicated (final EA pp. 138-142; Botany Weed 

Risk Assessment).

Soil Resources.

The 1st 48 Project is consistent with the SRNF land and resource management plan (LRMP or forest 

plan) and associated standards and guidelines (S&G), including soil quality standards (SQS) for 

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

Implementing project-specific mitigation measures will minimize effects to help ensure compliance 

with the LRMP provisions to maintain long-term soil productivity within this project area.

My review of the soils analysis indicates current existing detrimental effects of past actions 

are minimal in spatial extent. The 1st 48 Project by itself will not produce significant amounts of 

adverse direct or indirect soil impacts, using 15 percent of the area in detrimental soil conditions 
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 13

collectively as the threshold used to determine if soil impacts are significant, per current 

management direction. There are no reasonably foreseeable future actions, which will produce 

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

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

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

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

Clean Air Act of 1970.

The Clean Air Act of 1970 and its amendments provide for the protection and enhancement of the 

nation’s air resources. My decision to implement the 1st 48 Project will not exceed the federal and 

state ambient air quality standards to protect public health. Jackpot burning and underburning in 

the oak woodlands will be implemented seasonally. As each entry may be implemented over 

several seasons and will be small in size, and handpiles will be covered with Kraft waxed paper to 

minimize smoke production during burning, I am confident the project design and mitigation 

measures will effectively address public health and safety concerns. In addition, a burn plan will 

be developed that identifies specific tactics to reduce smoke emissions, including identifying 

sensitive smoke receptors and when favorable wind directions will promote smoke dispersal prior 

to scheduling burn ignition (final EA p. 45).

Clean Water Act.

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

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

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

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

compliance with the Clean Water Act; Porter-Cologne Water Quality Control Act; applicable water 

quality control plans, including the North Coast Regional Water Quality Control Board 

(NCRWQCB) Basin Plan; and the NCRWQCB waiver of waste discharge requirements. A waiver 

application will be filed after the Decision Notice is signed (final EA pp. 13, 98).

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

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

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

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

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

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

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

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

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

total maximum daily load (TMDL) target for sediment in the Upper Mad subarea was set at 173 
Finding of No Significant Impact

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

tons, a reduction of 26 percent for the Upper Mad watershed. The Environmental Protection 

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

Upper Mad watershed, management-related sediment must be reduced by 68 percent over time. 

The 1st 48 Project will minimize, and in some areas, reduce management-related sediment and 

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

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

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

retention, stream temperature will not be affected. The 1st 48 Project will not construct new 

permanent (system) roads or temporary roads. For the project as a whole, there are 141 acres of 

riparian reserves deemed equipment exclusion zones. The streams coming off South Fork 

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

vegetation (final EA pp. 95-96, 101-102).

Wildland-Urban Interface.

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

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

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

wildfires that burned into areas where hazardous fuels reduction treatments had previously been 

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

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

indicate that 90 percent of treatments have helped reduce wildfire intensity, allowing better 

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

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

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

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

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

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

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

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

critical areas.

Caves.

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

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

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

resource from implementing the 1st 48 Project (final EA pp. 102-104; Geology Report).
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 15

Wetlands and Floodplains.

No floodplains associated with Executive Order 11988 or wetlands per Executive Order 11990 

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

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

Parklands and Prime Farmlands.

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

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

EA p. 146).

Research Natural Areas.

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

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

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

Wilderness Areas.

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

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

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

Wild and Scenic Rivers.

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

Wild and Scenic Rivers Act of 1968, designated by the Secretary of the Interior, on January 19, 

1981, within the project area. Therefore, there will be no effect to these resources from 

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

Northern Spotted Owl Critical Habitat.

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

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

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

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

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

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

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

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

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

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

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

California Coast Subunits 1 and 2 of the Critical Habitat Rule. There are 12 units to be treated for 

hazardous fuel reduction (HFR; 152 acres), four (4) units to be oak woodland restoration (37 

acres), eight (8) units of plantation thins (108 acres) and 61 units (461 acres) of fuelbreak 

construction that would occur in NSO critical habitat units (CHU). A total of 784 acres of NSO 
Finding of No Significant Impact

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

nesting/roosting/foraging/ dispersal habitat and 37 acres of non-habitat would be treated between 

the two subunits of CHU (final EA pp. 59, 62-64).

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

USFWS Level 1 Team on the Kelsey Peak Project, as well as on similar projects elsewhere on the 

forest. All the units exceeded canopy-closure requirements, and protected pre-dominant trees, 

snags, and downed logs. The units are still functional habitat and should respond well to the 

treatments. The Level 1 Team agreed these types of treatments will have a beneficial effect on the 

future habitat conditions of the area and create more alternative habitats for owls to use as 

additional treatments occur on the landscape (final biological assessment (BA)).

Late Successional Reserves.

A very small portion of the 1st 48 Project is located within the South Fork Late-Successional Reserve 

(LSR; RC-330). The entire South Fork LSR is 80,451 acres, with the majority located on the ShastaTrinity National Forest (STNF). Of that, only 1,057 acres are on the SRNF, with the 1st 48 Project

affecting 73 acres on the westernmost boundary of the entire LSR. The South Fork LSR is a land 

allocation established in the Northwest Forest Plan (NWFP), incorporated into both the SRNF and 

STNF LRMPs, managed to protect and enhance late-successional forest ecosystems through 

prescribed understory fire and thinning. General management direction for LSR lands is found on 

pages IV-34 to IV-39 of the SRNF LRMP (USDA Forest Service 1995). The STNF included the 

South Fork LSR in the 1999 Forest-Wide Late-Successional Reserve Assessment (LRSA; USDA 

Forest Service 1999), which identifies general current conditions, general desired conditions, and 

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

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

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

Southwest Regional Ecosystem Office (REO) related to hazard reduction thinning activities 

proposed in LSRs to reduce the risk of large-scale disturbance. The REO had reviewed the LRSA 

for the STNF and concluded that fuel treatments proposed in the LSRs that thin suppressed, 

intermediate and some co-dominant trees are consistent with the S&Gs under the NWFP (USDA 

REO letter, October 18, 2009).

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

give firefighters a good chance of keeping exterior wildfire from entering, or conversely, interior 

wildfire from exiting the area. Under the LSRA and LRMP direction, proposed fuels treatments

are aimed at reducing risk (i.e., potential loss due to wildfire) in 59 acres of younger white fir 

stands adjacent to FSR 2S23 and along the ridgetop within the South Fork LSR. The trees 

targeted for removal in the early mature white fir stands have a diameter range of 14 to 24 inches, 

and are less than 120- to 150-years old. Some trees in this age class are larger than 24-inch dbh

(diameter at breast height) and may be removed to meet crown spacing objectives.

Additionally, there are approximately 14 acres of Douglas-fir or ponderosa pine-dominated 

stands within the LSR that are early- and mid-mature or late-mature stands, which have had 
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 17

previous entries of individual tree harvest. The trees targeted for removal in these stands are 

similar to the white fir stands in terms of age and diameter range. In the patches of mid-mature 

and remnant late-mature seral forest, trees range from 70 to 120 years in age, with diameters 

ranging from 12- to 32-inch dbh. However, the 1st 48 Project targets removal of trees with underdeveloped crowns, which are typically suppressed and/or intermediate trees less than 150 years 

old, while retaining trees with the fullest crowns characteristic of co-dominant, dominant and predominant trees with late-seral characteristics (final EA pp. 57-58, 203-206).

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

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

Retention management area and 234 acres within Partial Retention management area, while the 

remainder of the project area occurs within the Modification VQO classification. The majority of 

the project area has experienced substantial alterations in visual quality from road and log landing 

construction and even-age timber harvest management. The 1st 48 Project will retain variable 

forest canopy closure at or over 60 percent, limit new landing construction to existing flat 

openings, and involve no new road construction. The removal of boundary flagging and placing 

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

S&Gs. Thin from below treatments will blend well with adjacent untreated forest lands to 

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

from wildfire (final EA p. 46).

Jeep Trail 8E20 (aka Wiregrass) is a special vehicle designation trail (i.e., four-wheel-drive 

non-highway legal vehicle wider than 50 inches/all-wheeled vehicles 50-inches wide or less) that 

is 1.29 miles long, located in T2S R8E. The Forest Service’s national resource management 

(NRM) database indicates the trail was added to the NFST (NFS trails) by the Lower Trinity/Mad 

River Motorized Travel Management Record of Decision in April 2010. This trail is displayed on 

the revised motor vehicle use map (MVUM) for that area.

My decision to implement the 1st 48 Project will allow the existing footprint of Jeep Trail 

8E20 to be graded and temporarily closed to public use during logging operations to ensure 

public safety. Other than the short-term disruption in public use, grading and constructing 

waterbars will be visually evident in the short-term, likely only one season. Although these 

impacts are unavoidable, in the long term, this action will contribute to protecting scenic quality 

for the long term (final EA pp. 45-46).

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

highly controversial.

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

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

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

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

Mad River. The reservoir has a storage capacity of about 48,030 acre-feet and was designed to 
Finding of No Significant Impact

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

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

percent of the total annual runoff for the watershed.

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

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

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

flow for the month of August from 1953 to 1961 ranged from 2 to 8 cubic feet per second (cfs), 

with an average of 4 cfs.

Currently, the HBMWD manages the release of water from Ruth Reservoir to meet domestic 

and industrial water needs, as well as instream flow requirements for the protection of listed fish 

species (HBMWD 2004; final EA p. 101).

My review of the analysis for watershed resources indicates the extent, duration and intensity 

of treatment activities under Alternative 2 are not sufficient to adversely affect in-stream flows. 

Evapotranspiration rates will not be further altered, nor will sufficient ground compaction occur to 

alter rates of surface runoff. This indicates to me the 1st 48 Project will not result in changes to 

spatial and temporal hydrology, due to the limited magnitude of the treatments and the very small 

and localized spatial extent of the treatments. Therefore, the timing, magnitude, and duration of 

flows will not be altered by treatment activities. I find instream flows and fluvial processes will

continue to occur at the rates under which the stream system evolved and aquatic habitat diversity, 

channel stability, and water quality will continue to be moderate to high (final EA pp. 95-102).

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

involve unique or unknown risks.

Asbestos Airborne Toxic Control Measure for Surface Application.

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

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

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

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

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

percent without concern. No ultramafic bedrock or naturally occurring asbestos exists within the 

project area. The SRNF has samples and tests for presence of Naturally Occurring Asbestos as 

close as 10 miles from the project area. Two of the 42 samples within a 20-mile radius from the 

project area contained asbestos at 0.5 percent in small serpentenite outcrops. The project area 

contains no similar outcrops. No ultramafic bedrock and therefore, no naturally occurring 

asbestos occur in the project area. No groundwater resources will be developed or are existing 

within the project area. The 1st 48 Project applies low-intensity mechanical, manual and 

prescribed burning treatment methods. The treatment prescriptions and mitigation measures 

incorporated have been applied on numerous projects across the SRNF with predictable effects 

and outcomes (final EA pp. 104-105; Geology Report).
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 19

Executive Order 12898, Environmental Justice.

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

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

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

proposal.

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

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

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

and adverse manner, by government programs and activities affecting human health or the 

environment. There would be no discernable differences between the Proposed Action and No 

Action Alternatives regarding effects on minorities or the civil rights of any American citizen.

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

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

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

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

or ameliorate adverse effects to these populations were identified (final EA pp. 14-15).

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

or enhancement of long-term productivity.

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

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

change the human environment after final maintenance of fuelbreaks have concluded, as 

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

minimize disturbance to nearby neighbors and natural resources.

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

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

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

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

oak-dominated stands (aiding acorn production, native herbs and forbs) and produce commercial 

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

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

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

Irreversible or Irretrievable Commitments of Resources.

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

commitment of resources resulting from implementation. Irretrievable commitment applies to 

losses that are temporary, such as use of renewable natural resources. The production lost will be 

irretrievable, but the action will not be irreversible. Vegetation removed as commodity 

byproducts is considered an irretrievable impact. Forest conditions will return, as tree growth 

over one or more decades will feature increased canopy closure and development of healthy, 
Finding of No Significant Impact

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

sustainable stand densities resilient to natural processes serving Endangered Species Act (ESA) 

wildlife habitat and soil resources (final EA pp. 56-57, 92, 113-122).

Vegetation.

Tree removal authorized by my decision is considered an irretrievable impact, as it will “extract” 

timber, an outcome of thinning commercially valuable trees. However, forested conditions will

return as tree growth accelerates over one or more decades, with increased diameter and canopy 

growth associated with higher commercial value. In the long term, my decision will also promote 

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

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

Soils.

Current existing detrimental effects of past actions are minimal in spatial area. The 1st 48 Project will 

not produce significant amounts of adverse direct or indirect soil impacts, as 15 percent of the area in 

detrimental soil conditions collectively will not exceed the threshold for significance, per current 

management direction. There are no reasonably foreseeable future actions, which could contribute to 

significant impairment of soil quality or productivity. I find since there are no additive significant 

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

cumulative effects to soil resources.

The 1st 48 Project design is consistent with the SRNF forest plan and SQS for soil productivity 

in compliance with NFMA. Standards and guidelines and SQS indicators were used as the context 

to describe and analyze the extent and magnitude of expected soil impacts, spatially and temporally. 

I believe my requirement to implement project-specific design features and mitigation measures,

along with monitoring, will ensure compliance with these LRMP provisions to long-term soil 

productivity (final EA pp. 117-120).

Adverse Environmental Effects that cannot be Avoided.

Soil Resources.

I recognize the 1st 48 Project will involve adverse environmental effects to soil resources that 

cannot be wholly avoided or mitigated. While no new temporary roads will be constructed the 

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

the most impactful due to severe compaction, causing reduced infiltration and soil runoff. 

However, my decision requires drainage features be constructed to control runoff and avoid 

adverse impacts, in compliance with best management practices (BMPs). Additionally, my 

decision applies PDFs and mitigation measures stipulating rehabilitation of these sites via decompaction by “ripping” (i.e., furrowing using conventional rock-rippers common on logging 

equipment) or “dibbling” (i.e., working the ground with an excavator bucket, also called “potato 

patch”). This will be followed by re-contouring to the approximate original terrain in cases where 

the feature was “constructed” by blading topsoil to create a favorable grade or bench (constructed 

using cut and fill).
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 21

The new landings are mostly roadside on gentle grade, so little blading should be necessary to 

make them usable, and thus little to no recontouring is expected; however, some form of 

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

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

vegetation. In most cases, old access roads and landings are in favorable locations to be reutilized, which will minimize new disturbance and cumulative effects. Even with rehabilitation 

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

to slowly recover naturally over time.

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

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

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

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

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

compaction risk, namely Kistirn (SMU 260), Hugo (SMU 265-266) and Hecker (SMU 250-256), 

which intersect with many of the ground-based units. Thus, it is conservatively assumed that skidtrail compaction will be detrimental. My decision requires these equipment trails, in combination 

with temporary roads and landings, be limited to less than15percent of the unit area. If equipment 

trails are deeply rutted, they may be decompacted by ripping, if necessary to promote natural 

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

Energy Requirements of Alternatives.

Under the Proposed Action, various amounts of fossil fuels and human labor will be expended. 

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

have an adverse effect upon continued availability of these resources.

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

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

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

temporary or by breaking it down into small component parts.

Vegetation.

I find the 1st 48 Project differs from past actions, in that historic timber harvest (pre-1990s) 

consisted of clearcut or shelterwood logging, broadcast burning, and planting with Douglas-fir 

seedlings. The actions I am authorizing will not detract or stall these stands in structure 

development to mid-mature/late-mature, and understory re-initiation and will not alter the current 

distribution of seral or development stages (also called structural stages) within the analysis area.

The 1st 48 Project will employ thinning from below (Tappeiner et al. 2007) in early and 

early/mid-mature Douglas-fir/black oak stands ranging in age from 70 to 80 years, early mature 

white fir stands, and young Douglas-fir or ponderosa pine plantations. These stands are generally 

single-layered and consist of even-aged patches of varying age. As I understand it, a positive 
Finding of No Significant Impact

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

response to thinning from below is expected, since subordinate trees (i.e., suppressed, 

intermediate and select co-dominant trees) will be removed to allow trees of the upper canopy 

(which have more fully developed crowns) to utilize the additional growing space and increase in 

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

My decision will retain all dominant trees and pre-dominant trees, including those with 

defects. Most co-dominant trees will also be retained. The codominant conifers that will be cut 

are those without sufficient growing space in the canopy for further crown development, and 

those adjacent to dominant and predominant conifers and hardwoods or pockets of smaller 

diameter hardwoods to increase their ability to survive.

The thinning from below prescription will not alter existing seral stage condition, and will in 

fact, increase growth on the remaining trees to accelerate development of trees into late-seral size 

classes. This will promote an increase in the acres of late-seral stands as an incremental step 

toward achieving the minimum Douglas-fir Recommended Management Range (RMR) threshold.

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

Beaverslide and the 2013 Kelsey Peak Timber Sale and Fuelbreak Project. Other foreseeable 

actions within the analysis area are additional HFR projects and shaded-fuelbreak construction 

and maintenance. In terms of past, proposed, ongoing, and foreseeable actions, the 1st 48 Project

will have no cumulative effects to the vegetation structural stages within the south zone of the 

forest, which is the entire Mad River Ranger District. The current distribution has been molded 

by past activities, which removed older forest types and from past wildfires. This project will

improve the distribution of structural stages over the long term for species needing older forest 

habitats for part or all of their life cycle (final EA pp. 56-58, 184-185, 206-207).

Fire and Fuels.

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

through competition from Douglas-fir. Fire suppression since the early 1900s means that these 

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

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

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

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

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

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

losing them to a stand-replacing fire. My decision will lower stand densities aiding in forest 

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

Watershed Resources.

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

designated a Priority Watershed under watershed condition framework (WCF). The project is 

small in acreage and widely dispersed across the landscape along open roads in narrow 300-foot-
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 23

strips, existing roadside plantations and oak woodland stands. I find thinning to establish shaded 

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

sufficient shade from solar radiation to prevent increases in water temperature.

My decision restricts tree thinning (ladder and crown fuels) prescriptions to the outer portion 

of the riparian reserves to retain tree root systems that hold soil and stream channels in place, 

acting to minimize soil erosion and the potential for increased sedimentation to protect water 

quality. Alternative 2 incorporates design features and mitigation measures that will retain large 

woody debris, limiting thinning of trees to 6-inch dbh using only manual methods within inner 

riparian reserve buffers to maintain suitable stream habitat conditions and mitigate introduction 

and spread of invasive and non-native weeds due to open range and other operational vectors

(final EA pp. 97-98).

Soil Resources.

Current existing detrimental effects of past actions are minimal in extent area. The Proposed Action 

alternative by itself would not produce significant amounts of adverse direct or indirect soil impacts, 

using 15 percent of the area in detrimental soil conditions collectively as the threshold used to 

determine if soil impacts are significant, per current management direction. There are no reasonably 

foreseeable future actions, which would produce significant impairment of soil quality or 

productivity. Thus there are no additive significant effects of past, present, and foreseeable future 

actions expected, and therefore by definition no significant cumulative effects for soil resources.

The Proposed Action is design consistent with the regulatory framework outlined above. 

Forest Plan S&Gs and SQS are intended to comply with NFMA, maintaining soil productivity. 

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

extent and magnitude of expected soil impacts, spatially and temporally. Implementing projectspecific PDFs are intended to help ensure compliance with these LRMP provisions, and it is thus 

deduced that long-term soil productivity is maintained within this project area (final EA p. 122).

Geologic Resources.

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

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

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

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

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

in landslide activity. Concentrated flow from skid trails will not occur due to application of skid trial 

remediation. I considered if S&Gs, BMPs, PDFs and mitigation measures are applied, the negative 

effects to slope stability should be minimal or absent, as compared to the likelihood that extensive 

landslide reactivation could be triggered by a hot, large scale wildfire (final EA pp. 104-105).

Invasive Plant Species.

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

mitigation measures required under Alternative 2 will reduce the risk of introduction and spread, 
Finding of No Significant Impact

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

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

Botany Weed Risk Assessment).

8. The degree to which the action may adversely affect districts, sites, highways, structures, or 

objects listed in or eligible for listing in the National Register of Historic Places or may 

cause loss or destruction of significant scientific, cultural, or historical resources.

To comply with the regulatory framework protecting cultural resources, pre-field research was 

conducted consisting of examination of previous archaeological surveys in the planning area, site 

records, maps, and GIS data. The data indicated that seven (7) of the surveys, conducted between 

1978 and 2012, included the Area of Potential Effect (APE), defined as the project’s treatment units. 

The surveys resulted in the identification of 10 archaeological sites, none located within the APE. 

Two (2) archaeological sites were identified during surveys conducted within the project’s APE 

between October 2016 and August 2017. These surveys were recorded in a cultural resources 

inventory report (CRIR) on file in the Heritage Department of the SRNF Supervisor’s Office. 

Standard resource protection measures, as defined in the Programmatic Agreement among the USDA 

Forest Service, Pacific Southwest Region (Region 5), California State Historic Preservation Officer, 

Nevada State Historic Preservation Officer, and the Advisory Council on Historic Preservation 

Regarding the Processes for Compliance with Section 106 of the National Historic Preservation Act 

for Management of Historic Properties by the National Forests of the Pacific Southwest Region (R5 

PA), would be applied to fully protect archaeological sites within the APE (final EA pp. 122-124).

9. The degree to which the action may adversely affect an endangered or threatened species or its 

habitat that has been determined to be critical under the Endangered Species Act of 1973 (ESA).

The Endangered Species Act (ESA) of 1973 (16 USC 1531 et seq.) requires any action authorized 

by a federal agency to not jeopardize the continued existence of a threatened or endangered species, 

or result in the destruction or adverse modification of the critical habitat of such species. Section 7 

of the ESA, as amended, requires the responsible federal agency to consult with the USFWS and 

the National Marine Fisheries Service (NMFS) concerning endangered and threatened species under 

their jurisdiction as follows:

Threatened and Endangered Wildlife Resources.

The 2011 Recovery Plan for the Northern Spotted Owl (Recovery Plan) recognizes the importance of 

maintaining and restoring habitat for the recovery and long-term survival of the spotted owl. The 

Recovery Plan relies on federal lands to provide the major contribution for recovery (USDI Fish and 

Wildlife Service 2011). The 1st 48 Project was designed to meet the objectives of this Recovery Plan.

The SRNF definition of suitable nesting/roosting NSO habitat includes mid-mature (starting 

at 21-inch dbh), late-mature and old-growth seral stages. The definition of NSO nesting/roosting 

habitat used for this project was based on the definition found in the SRNF LRMP and field 

verified by wildlife biologists with extensive experience with the species. The LRMP definition 

was based on extensive published literature and represents the best available science for SRNF
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 25

habitat types. All potential habitat was considered during project evaluation, and all high-quality 

habitat (no matter what seral stage) was dropped from treatment. Low-quality habitats were 

evaluated for habitat improvement measures.

Because the SRNF strives towards recovery of the spotted owl, all activity centers (ACs) 

receive the same level of protection and are not prioritized, with some ACs getting less protection 

as allowed by the Recovery Plan. This exceeds the requirement of Recovery Action 10 in the 

Recovery Plan. In addition, the USFWS requires a 70-acre nest grove protection zone.

As part of the wildlife analysis, in 2017 and 2018, NSO protocol surveys were conducted in all 

suitable habitats in the 1st 48 Project area in accordance with the Critical Habitat Rule protocol. In 

addition, NSO surveys were conducted within the planning area in the early and mid-1990s. There 

are three 100-acre LSRs located in association with ACs 290, 239 and 236; however, the LSR 

coincides with the actual nest grove (which is based on the owl’s location) for the AC. Therefore, 

no treatment would occur within these 100-acre LSRs.

My review of the wildlife analysis indicates the 1st 48 Project will restore and accelerate 

development of important habitat characteristic for the spotted owl by treating plantations and 

overstocked stands that, if treated, will increase the available habitats and help reduce interspecies competition between the barred owl and the spotted owl. The 1st 48 Project was designed 

to ensure no adverse impacts to listed species will occur. Informal consultation with the USFWS 

was initiated through the interagency Level 1 process. The Level 1 team determined that the 

project will not likely to adversely affect the NSO or designated NSO Critical Habitat. The 

USFWS concurred with this determination (final EA pp. 61-85; final BA).

Threatened and Endangered Botanical Resources.

No federally listed plant species are known to occur, nor does suitable habitat exist in the project 

area (final EA pp. 46, 124; biological assessment/biological evaluation (BA/BE)).

Threatened and Endangered Aquatic Species.

Three (3) species of threatened and endangered (TE) salmonids are found in the Mad River 

watershed. Northern California steelhead trout (Oncorhynchus mykiss) are found in the mainstem 

Mad River up to Matthews Dam with Critical Habitat being designated up to County Line Creek. 

Chinook (California Coastal ESU; O. tshawytscha) and coho (Southern Oregon/Northern 

California ESU, O. kisutch) are found in the in mainstem Mad River up to “Bug Creek Falls,”

approximately 27 miles downstream from Matthews Dam. As the roadside treatment areas are 

located upstream of the Ruth Lake Dam, threatened, endangered and Forest Service Sensitive 

(TES) anadromous fish species cannot reach the project area. Therefore, my decision will have no 

effect on anadromous TE species and their habitats (final EA pp. 46-47).
Finding of No Significant Impact

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

10. Whether the action threatens a violation of federal, state, or local law or requirements 

imposed for the protection of the environment.

Aquatic Conservation Strategy.

The 1st 48 Project was developed in alignment with the Aquatic Conservation Strategy (ACS) 

reflected in the Record of Decision (ROD) and S&Gs of the NWFP (USDA and USDI 1994) as 

incorporated into the SRNF (USDA Forest Service 1995) and KNF (USDA Forest Service 2010)

LRMPs. The project will fulfill specific objectives regarding the forest goals in the management 

of aquatic and riparian resources (USDA Forest Service 1995 p. IV-107), and to be consistent 

with the nine (9) ACS objectives and the May 22, 2007 ACS guidance memorandum. 

Implementation of the Proposed Action will not retard or prevent attainment of ACS objectives at 

the hydrologic unit code (HUC) 6th and larger scales in the short term. Rather, it will promote 

attainment of ACS objectives in the long term. Cumulative watershed effects (CWE) will remain 

below the threshold for adverse watershed effects (final EA pp. 98-102).

Forest Service Sensitive Wildlife Species.

All Forest Service Sensitive wildlife species known or thought to occur in the project area, based 

on habitat and range, were evaluated for this project. It was determined that the project will not

impact certain Forest Service Sensitive species, based on the lack of habitat, lack of detections 

during surveys, or the fact that habitat will not be impacted. Species that will not be affected by 

this project include the bald eagle (Haliaeetus leucocephalus), Townsend’s big-eared bat 

(Corynorthinus townsendii), fringed myotis (Myotis thysanodes), California wolverine (Gulo gulo 

luteus), Humboldt marten (Martes caurina), pallid bat (Antrozous pallidus), western bumblebee 

(Bombus occidentalis), western pond turtle (Clemmys marmorata), foothill yellow-legged frog 

(Rana boylii) southern torrent salamander (Rhyacotriton variegatus), and northern red-legged 

frog (Rana aurora aurora) (final EA pp. 86-89).

Pacific Fisher (Martes pennanti pacifica, also a Federal Candidate Species).

In northern California, fishers occupy mid-elevation, multi-storied mature and old-growth conifer, 

mixed conifer, and mixed-conifer hardwood forests with contiguous canopy cover. Fishers 

typically select closed canopies (>50%), but would use areas of low- to moderate-canopy cover 

(25 to 40%), if there is sufficient understory (Lofroth et al. 2010). They do not occur in highelevation alpine or subalpine habitats.

My decision will maintain characteristics for denning, so habitats will continue to provide 

denning habitat immediately post-project. All riparian reserves will be buffered on both sides of 

stream channels and canopy closure will be maintained at 60 percent or greater. Little to no true 

riparian habitat exists within the units given the lack of riparian-vegetation-associated ephemeral 

and intermittent stream courses within the project area. However, in the long term, project 

implementation has the potential to improve riparian habitat conditions through the release of 

conifer and hardwoods/shrubs from thinning, generating a secondary canopy.
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 27

Of the 13,686 acres of fisher denning habitat within the action area, approximately 290 acres 

of low- and moderate-quality denning habitat will be treated. However, no high-quality habitat 

will be treated. Approximately 2 percent of the denning habitat within the action area will be 

treated (98% of the denning habitat in the action area will not receive any treatment).

In 2016, surveys were conducted in the 1st 48 Project area using camera stations. Fisher were 

detected in three (3) areas. Although no den sites have been located, limited operating periods 

(LOPs) will be imposed for all noise- and smoke-generating activities within 0.25 miles of fisher 

suitable habitat around the detection sites (final EA pp 84-86).

Northern Goshawk (Accipiter gentilis).

Goshawks are known to use mature forest habitats for nesting and foraging. Nesting stands are 

typically in dense pockets of large trees, often on north-facing, bench slopes near water. Foraging 

habitats are often more open to allow for the aerial ambush foraging strategy of the goshawk.

Goshawks occupy similar habitat to that of the NSO. There are approximately 13,686 acres of 

suitable goshawk habitat in the 1st 48 Project area. Surveys were conducted in the 1st 48 Project

area in 2017. No goshawks were detected.

Suitable habitat for the goshawk occurs in the planning area. No pre-dominant trees (potential 

nest trees) or dominant trees will be removed. Current canopy closure will be maintained. 

Removal of understory vegetation may improve foraging conditions for the goshawk. If nesting 

goshawks were subsequently found within 0.25 miles of any treatment units, LOPs will be 

imposed. The project may impact individual northern goshawk, but will not cause a trend towards 

listing (final EA pp. 88-94).

Foothill yellow-legged frog (Rana boylii).

The foothill yellow-legged frog is found in or near rocky streams or rivers in a variety of habitats. 

In California, breeding and egg laying usually wait until the end of spring flooding, and may 

commence anytime from mid-March to mid-June, depending on the occurrence of spring rains. 

These frogs are diurnal with adults often basking on exposed rock surfaces near streams. When 

disturbed, they dive into the water and take refuge under submerged rocks or sediments.

There is suitable habitat for foothill yellow-legged frogs in the planning area. In August 2017, 

tadpoles and adult frogs were observed in Littlefield Creek at the low-water crossing at milepost 

0.4 on 2S53 (K. Kenfield personal observation). If water is not present during operations, 

commercial log hauling may proceed. If water is present, a temporary low-water crossing will be 

constructed. Currently non-commercial vehicles drive through the low-water ford. Installation of 

the temporary vented ford (two or more 36-inch pipes laid over geotextile cloth on the streambed 

with fill on top) will cause disturbance to an approximate 30 foot by 10 foot reach of stream. My 

decision will install a vented ford to eliminate vehicles entering the water during operations. The 

project may impact individuals, but will not cause a trend towards listing (final EA pp. 88-94).
Finding of No Significant Impact

28 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

Management Indicator Species and Migratory Bird Species.

Under NFMA, the Forest Service is directed to “provide for diversity of plant and animal 

communities based on the suitability and capability of the specific land area in order to meet 

overall multiple-use objectives” (PL 94-588 §6 (g)(3)(B)). The 1982 regulations implementing 

NFMA require that “Fish and wildlife habitat shall be managed to maintain viable populations of 

existing native and desired non-native vertebrate species in the planning area” (36 CFR 219.19).

Management indicator species (MIS) is a concept used by the agency to serve as a barometer for 

species viability at the forest level. Population changes of MIS are believed to indicate the effects 

of management activities.

The SRNF LRMP uses MIS to assess potential effects of project activities on the various habitats 

and habitat assemblages with which these species are associated. Forty-one (41) fish and wildlife 

species have been selected as MIS or assemblages for a variety of habitats that are potentially 

affected by resource management activities on the Forest (USDA Forest Service 1995 p. IV-97).

Due to the scope, size, and intent of this project, there are no concerns of negative cumulative 

effects for MIS, migratory bird species (MBS), or other wildlife species. Direct, indirect and 

cumulative effects to MIS and MBS were addressed based on their potential to occur within the 

project area based on habitat suitability, survey results, or incidental sighting records.

The 1st 48 Project will not adversely impact MIS. Although shaded-fuelbreak construction 

will degrade habitat for species, such as the Pacific wren and ruffed grouse, through the removal 

of brush and understory trees, the majority of the project will improve/restore habitat conditions 

for all MIS by thinning young, homogeneous stands, accelerating the development of multistoried conditions and other late-successional habitat characteristics. In addition, development of 

strategic fuelbreaks will help protect existing habitat from stand-replacing fire.

The crossing of Littlefield Creek by Forest Service road (FSR) 2S02 is thought to be 

perennial due to increased flow from the Ruth Fire (from reduced transpiration due to canopy 

removal). Resident rainbow trout and foothill yellow legged frog were found in the stream at the 

crossing. If the stream is flowing at the time needed for commercial haul, a temporary pipe array 

will be installed consisting of two (2) or more culverts, geotextile fabric, and clean gravel (i.e., no 

fine sediments). Installation of the temporary vented ford (two or more 36-inch pipes laid over 

geotextile cloth on the streambed with fill on top) will cause disturbance to an approximate 30-

foot by 10-foot reach of stream (final EA pp. 88-94).

Survey and Manage Wildlife Species.

No wildlife survey and manage (S&M) species occur within the 1st 48 Project; therefore, no preproject surveys were conducted. The 1st 48 Project will be in compliance with the Record of 

Decision for amendments to the survey and manage, protection buffer, and other mitigation 

measure standards and guidelines in Forest Service and Bureau of Land Management planning 

documents within the range of the northern spotted owl (USDA and USDI 2001), the April 25, 2013 

9th Circuit Court Order in Conservation Northwest (and others) v. Sherman (No. 11-35729), and the 
Finding of No Significant Impact

Draft Decision Notice & Finding of No Significant Impact – 29

February 18, 2014 District Court Order in Conservation Northwest (and others) v. Robert Bonnie 

(and others) (W. WA No. C08-1067-JCC) (final EA pp. 91-94).

Implementation Date

Implementation of this project is expected to take place from 2018 to 2033. Fuelbreak corridors 

will be maintained up to 15 years, as needed to maintain desired fuelbreak conditions.

MERV GEORGE JR. Date

Forest Supervisor

Six Rivers National Forest
Finding of No Significant Impact

30 – 1st 48 Roadside Fuelbreak Collaborative Project – Mad River Ranger District

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