United States Department of Agriculture

Somes Bar Integrated Fire 

Management Project

Decision Notice & Finding of No Significant Impact

Forest 

Service

Pacific Southwest 

Region

Six Rivers 

National Forest

R5-MB-312

July 2018
Cover photo: Low intensity prescribed fire returns to a white oak stand near Orleans, California, during 

the 2014 Klamath River Prescribed Fire Training Exchange (TREX), after over a hundred years of fire 

exclusion. Photo courtesy of Will Harling, Mid Klamath Watershed Council.

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Decision Notice & Finding of No Significant Impact – i

Somes Bar Integrated Fire Management Project

Decision Notice & Finding of No Significant Impact

Siskiyou County, California

Responsible Official: Elizabeth A. Berger, Acting Forest Supervisor

Six Rivers National Forest

1330 Bayshore Way

Eureka, CA 95501-3834

(707) 441-3534

eaberger@fs.fed.us

For Information Contact: Nolan C. Colegrove Sr., District Ranger

Lower Trinity, Orleans and Ukonom Ranger Districts

PO Box 410

1 Ishi Pishi Road

Orleans, CA 95556

(530) 627-3291 (Orleans)

ncolegrove@fs.fed.us
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iii – Somes Bar Integrated Fire Management Project

Table of Contents 

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

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

Purpose and Need...................................................................................................................................... 2

Decision .................................................................................................................................................... 2

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

Mitigation and Monitoring .................................................................................................................... 4

Reasons for the Decision....................................................................................................................... 5

Relevant Issues .................................................................................................................................... 12

Public Involvement ................................................................................................................................. 18

Collaboration ....................................................................................................................................... 18

Tribal Consultation ............................................................................................................................. 19

Scoping Period .................................................................................................................................... 19

Comment Period on the Draft EA ....................................................................................................... 20

Objection Period on the Draft Decision Notice, Finding of No Significant Impact & Final EA ........ 20

Alternatives Considered in Detail, but not Selected ............................................................................... 21

Alternative 1 (No Action) ................................................................................................................... 21

Alternative 3 ........................................................................................................................................ 23

Finding of No Significant Impact ............................................................................................................ 25

Context .................................................................................................................................................... 25

Intensity ................................................................................................................................................... 25

Implementation Date ............................................................................................................................... 40

Figures 

Figure 1. High stand densities in a mechanical treatment unit. .................................................................... 7

Figure 2. Conifer encroachment in black oak stands. ................................................................................... 8

Figure 3. Treatment unit with commercial timber as a by-product. ............................................................ 12

Figure 4. WKRP utilized a collaborative process to develop overlay assessments to better prioritize 

manual, mechanical and prescribed burning treatment methods and locations. ................................. 18

Tables 

Table 1. Alternative 2 treatment summary.................................................................................................... 2

Table 2. Alternative 3 treatment summary.................................................................................................. 23
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Decision Notice

Decision Notice & Finding of No Significant Impact – 1

Decision Notice

Introduction

The Somes Bar Integrated Fire Management Project (Somes Bar Project) exemplifies participatory 

planning where all contributors share responsibilities for each other’s safety and well-being, and for 

preserving the nation’s natural resources and our cultural legacy for future generations (Harling and Tripp 

2014). With this vision in mind, dedicated Forest Service and community collaborators organized to form

the Western Klamath Restoration Partnership (WKRP)1 in 2013. The WKRP convened workshops and 

field trips over several years, coming to agreement in principle and practice on a wide range of 

stewardship treatments across the landscape (final EA p. 2).

The Somes Bar Integrated Fire Management Project Decision Notice and Finding of No Significant 

Impact (DN and FONSI) documents my selection to implement Alternative 2, as disclosed in the Somes 

Bar Integrated Fire Management Project Final Environmental Assessment (Somes Bar Project final EA). 

The Somes Bar Project final EA discloses the environmental effects of Alternative 2, developed in detail 

to meet the Purpose and Need and respond to public issues; Alternative 1 (No Action), as a comparison of 

what could happen without management; and Alternative 3, considered in response to a public comment.

The Somes Bar Project (Alternative 2 in the final EA) was designed by the WKRP to benefit diverse 

community interests and reinstate fire processes to restore natural and cultural resources holistically, 

recognizing Karuk Aboriginal Territory values are at the forefront. For the Karuk Tribe, cultural resources 

are synonymous with natural resources, and the management, protection, preservation, and accessibility to 

these resources are vital for perpetuating traditional practices (final EA pp. 12-15, 39-43).

The land management treatments were designed in alignment with the Klamath and Six Rivers 

national forests’ land and resource management plans (SRNF and KNF LRMPs or forest plans; USDA 

Forest Service 1995 and 2010, respectively) and records of decision (ROD(s)), and informed by the 

Karuk Tribe Eco-Cultural Resource Management Plan (Karuk Tribe 2010), Katimiin Memorandum of 

Understanding (MOU; Karuk Tribe and USDA Forest Service 2017), and the Orleans/Somes Bar 

Community Wildfire Protection Plan (CWPP; CWPP 2012, final EA pp. 16-20, 80-93).

The Somes Bar Project encompasses 5,570 acres of National Forest System (NFS) lands administered 

by the Orleans/Ukonom Ranger District (RD) on the Six Rivers National Forest (SRNF or forest) in 

T11N, R6E, Sec. 5-6; T12N, R6E, Sec. 2-4, 9-11, 14-16, 19-21, and 29-33; T14N, R6E, Sec. 34-35; and 

T13N, R6E, Sec. 3-5, 8-9, 17, 20-22, 27-29, and 32-33; Humboldt Base and Meridian, Siskiyou County, 

California (final EA pp. 3-7).

 1 Western Klamath Restoration Partnership (WKRP): The WKRP formed to build trust and a shared vision for restoring fire 

resilience at the landscape scale. Members include representatives from the US Forest Service, Karuk Tribe, Mid Klamath Watershed 

Council, Orleans-Somes Bar Fire Safe Council, Salmon River Restoration Council, The Nature Conservancy Fire Learning Network, 

Klamath Forest Alliance, Environmental Protection Information Center, University of California Berkeley, Bureau of Indian Affairs, 

National Oceanic and Atmospheric Administration, Environmental Protection Agency, and US Fish and Wildlife Service.
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2 – Somes Bar Integrated Fire Management Project

Purpose and Need 

The purpose for the Somes Bar Project is to demonstrate how prescribed fire restores and maintains 

resilient ecosystems, communities, and economies to revitalize balanced human relationships with our 

dynamic landscape (final EA pp. 8-15). The project will reinstate the use of traditional ecological 

knowledge (TEK) fire integrated with emergent restorative fire practices at the landscape scale, thereby:

o Reestablishing frequent fire cycles, behavior and patterns simulating resilient, spatially

heterogeneous forest and riparian habitats and self-sustaining populations of culturally

important Karuk focal species and traditions.

o Promote shared values, encourage widespread personal ownership and local technical

skills leading to healthy communities and economies, capable of well-coordinated land

stewardship regardless of ownership or administrative boundaries.

This project responds to the following needs: 

o Restoring and Maintaining Resilient Landscapes,

o Restoring and Maintaining Resilient Communities, and

o Restoring and Maintaining Resilient Economies.

Decision 

Based on a review of the analysis disclosed in the April 2018 Somes Bar Project final EA, the project 

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

2 (final EA pp. 15-16, 38-94, 413-432; Appendices C and D). My decision authorizes the implementation 

of 250,822 linear feet of strategic fire control features positioned alongside roads and mountain ridges, 

and 5,570 acres of landscape-scale integrated vegetative, fuels reduction and restorative prescribed 

burning treatments. A maximum of 160 landings (30 newly constructed), long-term and incidental 

temporary handlines, and 11 miles of temporary road access (0.6 miles of new construction) may be 

required to facilitate operations, as summarized in Table 1 (final EA pp. 15-16). 

Table 1. Alternative 2 treatment summary. 

Integrated Fire Management Treatments Area and/or Length

Strategic Fire Control Features Feet

Ridgetop Shaded Fuelbreak 105,524

Handline 145,298

Treatments –Total Acres Acres

Manual, Prescribed Burn 2,658

Mastication, Manual, Prescribed Burn 187

Mechanical – cable system, Manual, Prescribed Burn 176

Mechanical – ground-based, Manual, Prescribed Burn 1,058

Prescribed Burn 1,491

Total 5,570
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Decision Notice & Finding of No Significant Impact – 3

Integrated Fire Management Treatments Area and/or Length

Landings – Mechanical and Mastication units only Number Acres

Existing Landing 130 63

New Landing 30 13

Total 160 76

Temporary Use Road – Access to Mechanical and Mastication units Miles

Existing Mastication Access Road 2.3

Existing Temp Roads 8.1

New Temp Road 0.6

Total 11.0

Level 1 Roads to be Used – Provides access to Mechanical, Manual and Prescribed Fire units Miles

13N12A 0.9

13N14A 1.2

13N14C 0.2

13N14D 0.5

13N14E 0.5

13N18A 0.3

13N18E 0.5

14N15 0.5

Total 4.7

Legacy Road Sediment Source Restoration – Route Number Miles

9400 0.09

9100 0.35

9101 0.13

9102 0.22

9103 0.19

9402 0.11

Total 1.09

Alternative 2 is designed to phase the application of strategically placed manual, mechanical, and 

prescribed burning treatments around private inholdings to establish defensible space, safe escape 

egress/access routes for residents, and roadside and ridgetop fuelbreaks to aid fire control and allow for 

frequent burning to promote traditional cultural properties (TCPs; final EA pp. 39-67). Once initial 

phased entries 1 through 3 are complete, carefully planned prescribed burning will continue for up to 15 

years (final EA p. 55). These prescribed burns, ignited from the established fuelbreaks and allowed to

slowly creep downslope, are the primary method to achieve ecological balance of key cultural and 

ecological elements, and wildland-urban interface (WUI) property and life protection.

Permits, Licenses and Authorizations Needed to Implement the Decision

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

that must be obtained to implement the action alternatives. A waiver application will be filed with the North 

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

decision document is signed (Appendix B of the final EA). A burn permit from the North Coast Unified Air 

Quality Management District (NCUAQMD) will be acquired before initiating any prescribed burning.
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4 – Somes Bar Integrated Fire Management Project

Mitigation and Monitoring

There may be short-term disturbances to the human environment from the use of machinery, presence of 

field crews and associated increased traffic, as well as noise and smoke from prescribed burning while 

operations are underway. This decision requires project design features (PDFs) to reduce, minimize or 

eliminate impacts to various natural and cultural resources, and ensure the project is in compliance with 

the SRNF’s LRMP resource protection standards and guidelines (S&GS); the Record of Decision for 

amendments to the survey and manage, protection buffer, and other mitigation measure standards and 

guidelines in Forest Service and Bureau of Land Management planning documents within the range of 

the northern spotted owl (USFS et al. 2001), based on the district court’s remedy order issued on 

February 18, 2014 (Conservation Northwest v. Bonnie, W.WA No. C08-1067-JCC); US Forest Service 

Region 5 Soil Management Handbook (FSH 2509.18); Six Rivers National Forest Best Management 

Practices (BMP) for Invasive Plant Species and Aquatic Organisms (2014); and national, regional, and 

state water quality BMPs (final EA pp. 285-300).

My decision requires monitoring as described in the final EA (pp. 94-95). Monitoring is important for 

tracking project implementation to ensure activities are executed as planned, as well as for measuring the 

effectiveness of required mitigation measures to minimize impacts. Monitoring and evaluation are 

separate, sequential activities that provide information to determine whether projects are meeting forest 

plan direction. The overarching goal of monitoring the Somes Bar Project is to evaluate the effectiveness 

of treatments in achieving the desired condition and function, including the reintroduction of fire as a step 

towards restoring and maintaining resilient ecosystems, communities, and economies to revitalize and 

balance our human relationship with our dynamic landscape. The objective of the Somes Bar 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.

The WKRP is dedicated to shared-learning; therefore, I wholeheartedly endorse the Somes Bar 

Project’s multi-party monitoring (MPM) strategy, where the partnership and the community can learn 

together about—and from—the project. The monitoring effort will be led by a MPM team of diverse 

participants that may include representatives from the Karuk Tribe, Forest Service, Klamath Forest 

Alliance/Environmental Protection Information Center (KFA/EPIC), Salmon River Restoration Council, 

Mid Klamath Watershed Council (MKWC), local K-12 students, Humboldt State University or other 

university students, and community volunteers. My decision requires the MPM team to meet annually to 

consider and recommend monitoring priorities.

Implementation and effectiveness monitoring for cumulative watershed effects will be accomplished

through the BMP Effectiveness Evaluation Process. The objective is for 100 percent BMP

implementation—results below 85 percent trigger a review of the activity area before further project 

implementation. Implementation monitoring is achieved by selecting a representative number of treatment 

units each year from a sample pool of completed stands or project areas (final EA pp. 94-95).

Wildlife monitoring will include northern spotted owl (NSO) surveys using the most current, US Fish 

and Wildlife Service- (USFWS) approved protocol throughout the project area. Updated surveys will be 
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Decision Notice & Finding of No Significant Impact – 5

maintained throughout the life of the project or additional limited operating periods (LOPs) will be 

implemented on activities within 0.25 miles of NSO nesting/roosting habitat without up-to-date surveys 

(final EA pp. 88-89).

Reasons for the Decision

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

consultation, public comments, resource reports, and the alternatives and their potential effects and 

outcomes, as disclosed in the Somes Bar Project final EA. My decision to select Alternative 2 represents 

a step toward restoring and revitalizing our landscapes, while preparing communities to live cooperatively 

with wildfire and frequent, restorative fire (final EA p. 20).

I commend the WKRP’s innovative, collaborative design of the Somes Bar Project, developed to 

manage and improve the landscape as a whole integrating traditional ecological knowledge (TEK)—for the 

collective benefit of all people, animals and plants—rather than single-species management. I am confident 

the Somes Bar Project will bring us one-step forward on our long journey to adopt change on the SRNF.

The day treatments are applied on the ground will be a precedent-setting triumph for all participants, an 

outcome of those willing to work hard and embrace land management challenges holistically (final EA pp. 

7-8).

I embrace the WKRP vision “establish and maintain resilient ecosystems, communities, and economies 

guided by cultural and contemporary knowledge through a truly collaborative process that effectuates the 

revitalization of continual human relationships with our dynamic landscape” (final EA p. 8). The Somes Bar 

Project is an example of how we can come together with our communities to work out our differences 

coming to agreements and understandings without bias.

I am grateful to the many individuals and groups willing to come together, even though they had 

diverse views, to develop the Somes Bar Project, as a groundbreaking, relevant community-based 

solution. I am confident that the collaborative efforts of this project will continue through the 

implementation phase and well into the future.

Restoring and Maintaining Resilient Landscapes

The Somes Bar Project responds to the Purpose and Need to treat fuels and alter forest structure to allow 

frequent prescribed fires to restore and maintain the landscape at relatively self-limiting small scales, 

historic topographic position, and when seasonally appropriate (final EA pp. 9-11). Alternative 2 will 

most effectively promote resilient heterogeneity by creating small openings and retention areas to alter 

vegetative patterns across all NFS lands within the project areas (final EA pp. 10, 47-53, 171, 172, 257,

273). The establishment of strategic fuelbreaks and firelines, which allow for the safe application of 

frequent, restorative prescribed burning and aid in the control of wildfires, are wise decisions recognizing 

the threat to human life. Risk is not acceptable.

The Somes Bar Project final EA and supporting project record indicates the combination of phased 

mechanical, manual and prescribed burning pre-treatments will provide many benefits, allowing fire to be 

used as a tool in the future to restore and maintain resilient landscapes (final EA pp. 98-101), including:
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6 – Somes Bar Integrated Fire Management Project

o Improved forest health, structural complexity, and native tree and plant species diversity

(final EA pp. 167-172).

o A tribal initiative designed to promote Karuk cultural environmental management 

practices for select TEK focal species within and surrounding the Katimiin Cultural 

Management Area. This is the first step toward restoring the landscape to its ancestral 

state to begin to formulate a story of human re-emergence in accepting the people’s 

collective responsibility in a contemporary future (final EA pp. 111-114, 121-131).

Forest health, structural complexity, native tree and plant species diversity.

The fuels analysis indicates predicted flame lengths over the life of the project will be reduced by 

treatments, from 18.3 feet under current conditions in plantations, to 4.7 to 5.3 feet after treatment; and 

from 7.3 feet in non-plantations to 5.4 to 6.1 feet after treatment (final EA pp. 98, 149-154). This indicates 

that the Somes Bar Project will aid in preserving ecological integrity, despite historic fire occurrence 

records and predicted probability of wildfire ignitions (final EA pp. 132-138). The treatment of these

project areas will allow for the safe reintroduction of prescribed burning. My decision will enable the 

reintroduction of fire as a cultural environmental management practice.

The Somes Bar Project promises to mitigate, if not remediate, the era of wildland fire exclusion and 

past management practices. The landscape and residents are currently at-risk from wildfire torching with 

the potential transition to large-scale crown-fire events. The findings in the fuels analysis indicate flamelengths reduced by half and fire type altered with active management, suggesting surface fires will not 

readily transition to crown fires (final EA pp. 98, 149-154). This is more in alignment with natural 

ecological processes and the need for community health and safety.

I considered the analysis of vegetation, which used stand density index (SDI) as a measure of inter-tree 

competition. The results of predictive modeling indicate the current condition of SDI within the Somes Bar 

Project area is estimated at 80 percent in plantations and non-plantations. At this level, trees in the stand 

compete heavily for light and resources, resulting in stressed trees and increased rates of mortality (Figure 1).

Thickets of dead and dying trees contribute to flammability and torching during wildfires from 

increased surface fuel loading. This stage of stand development often lasts a century or longer (Oliver and 

Larson 1996). The Somes Bar Project will reduce SDI approximately 40 percent over 15 years (final EA 

pp. 98-101), improving forest health and resilience by reducing inter-tree competition for water, light, and 

other resources. The increased tree vigor will allow trees and stands to be more resistant to disturbance 

agents, such as drought, disease and insects (Fettig et al. 2007, Vernon 2017), including the western pine 

beetle, which has been detected in the project area. Lower densities and increased vigor provide trees a 

better chance of surviving an insect outbreak, compared to trees that are stressed (Fettig et al. 2010, 2007; 

final EA pp. 99, 101).
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Decision Notice & Finding of No Significant Impact – 7

The vegetation analysis indicates that basal area modeling, which is the cross-sectional area of a tree 

determined from the diameter at breast height (dbh) or 41⁄2 feet above ground level, was used to predict 

risk of tree mortality. This cross-sectional area of all stems of a species or all stems in a stand provided an

estimate of the tree densities in forest stands. My understanding is that the higher the tree densities and 

associated basal area, the greater the risk of tree mortality from environmental stressors (e.g., limited 

water, light and nutrients). Once stand densities of a given species reach a certain threshold, the likelihood 

of mortality increases significantly. Stand density modeling used to inform the analysis indicates there is a 

high risk of tree mortality (81 to 92 percent basal area) under current conditions. The Somes Bar Project

is predicted to lower these percentages to 49 percent risk of mortality in plantations and up to 70 percent 

in non-plantations. Without action, stand health will continue to decline, as modeling indicates there will 

be a gradual increase in basal area mortality over the next 50 years. Increased mortality is a valuable 

indicator—and a threat to stand resiliency—recognizing it contributes to severe fire behavior, and

increases susceptibility of our forest resources and habitats to insect outbreaks and the spread of 

pathogens and disease, such as sudden oak death. The modeling results indicate this stand trajectory could 

eventually lead to widespread stand replacement of most native and TEK focal species. For these reasons, 

I support the Somes Bar Project, as it is predicted to reduce average basal area mortality by 40 to 50 

percent through the life of the project (final EA pp. 99, 101, 149-154, 167-172).

Certain species of trees are of particular interest to the WKRP collaborative and the Karuk Tribe, 

including deciduous hardwoods, such as California black oak and Oregon white oak; evergreen hardwoods,

such as large acorn-producing tanoaks, large nut-producing giant golden chinquapin, and large madrones; as 

Figure 1. High stand densities in a mechanical treatment unit.
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8 – Somes Bar Integrated Fire Management Project

well as sugar and ponderosa pines. The majority 

of these tree species are considered early seral 

trees that are either fire-dependent or enhanced 

by fire. These trees also have a lower tolerance 

for dense stand conditions compared to 

Douglas-fir and white fir, which crowd, overtop, 

and eventually kill many of these important tree 

species in the absence of fire processes (Hunter 

and Barbour 2001). There is extensive cultural, 

archeological, and scientific evidence that 

healthy, mature individuals of these tree species 

were present in much higher numbers within the 

project area than they are today (Figure 2), prior 

to the occupation of these lands by Europeans, 

the subsequent establishment of the NFS, and 

fire suppression policy (Taylor and Skinner 

2003, North et al. 2007, Crawford et al. 2015; 

final EA pp. 113-119).

The Somes Bar Project will directly 

benefit trees of interest to the collaborative. In 

plantations, larger hardwoods, both singlestemmed and larger stems in clumps, will be 

favored for retention and conifers thinned around them to enhance hardwood growth. In non-plantation

stands, hardwoods over 24-inch dbh are usually the oldest trees in the stand; however, these trees, once 

the dominant or co-dominant trees in the stands prior to fire exclusion, are now outcompeted by conifers. 

Through thinning, these remnant trees will receive more light and grow fuller crowns. This in turn will 

allow hardwoods to persist in these stands, and thus continue to provide valuable structural habitat and 

diversity, maintain and support a healthy mixed-severity fire regime, increase their health and resistance 

to disturbance, as well as increase acorn production in true oaks, tanoak, and chinquapin (Devine and 

Harrington 2006, Engber et al. 2011; final EA pp. 132-135).

The effects within burn units will likely achieve patch-style dynamics according to burn plan 

prescription constraints. Various research supports this restorative type treatment, indicating “... a 

reasonable start is to put forest and woodland landscapes on a path to successional patterns and 

disturbance dynamics that reflect the natural disturbance regimes of regional and local landscapes and 

allow the future climate to adapt them” (Swetnam et al. 1999, Keane et al. 2009, Wiens et al. 2012).

With this in mind, the combination of increasing structural and vegetative species diversity, reducing 

SDI, lowering risk of tree mortality and stimulating healthy plant response is a positive step toward

fulfilling the need to restore and maintain resilient landscapes (final EA p. 151).

Figure 2. Conifer encroachment in black oak stands.
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Decision Notice & Finding of No Significant Impact – 9

Realizing a tribal initiative designed to promote Karuk cultural environmental management practices.

I support the benefits of the Somes Bar Project to restore cultural vegetation characteristics and the strong 

desire of the WKRP and its partners, including the Karuk Tribe, to make change happen across the entire 

WKRP planning area and beyond. Cultural vegetation characteristics, a special category of tribal 

archaeological data that provide evidence of human management, are defined as vegetation assemblages 

indicative of historic human use, management, or occupation. They are indicators that provide historically 

relevant information, which may justify their designation as a site, property, or as a feature in determining 

the eligibility of a larger district.

Vegetation with evidence of management include huckleberries, sugar pines and tanoaks. A high-quality

tanoak grove is made up of mature, well-spaced trees that require fire and the removal of younger trees to 

ensure the heath, vitality and productivity of the main trees. Huckleberries need to be managed to produce 

useful berries for people and animals. Both of these—tanoaks and huckleberries—become unproductive if 

left unmanaged. Sugar pines, often found in strategic places on ridges, were managed as ignition sources. 

They are also commonly found in conjunction with other plants that thrive in areas well managed by fire, 

such as tanoak, hazel and beargrass (final EA pp. 12-13, 42, 104-105, 116, 120-121, 128, 171-172).

While much of the land within the Somes Bar Project area is administered by the Forest Service—all 

of it is within Karuk Aboriginal Territory. Therefore, there is a statutory obligation to engage in §106 of 

the National Historic Preservation Act (NHPA) and tribal consultation processes for projects on this land

(final EA pp. 5, 18-19, 119-123). Government-to-government tribal consultation has been ongoing 

between the Karuk Tribe and the forest since the project’s inception in 2013. The Karuk Resources 

Advisory Board, who provided a letter of support, and the Karuk Department of Natural Resources have 

been fully involved in all aspects of project design and planning.

The Somes Bar Project will serve the broader vision of restoring cultural burning practices for those

living along the Klamath River, its tributaries, and other ancestral landscapes. It is time to follow up on 

our cultural responsibilities to this place by blending the tenets of TEK, as an indigenous science, with 

Euro-American models of science to protect the Karuk people from further loss of cultural identity. This 

project provides a rare opportunity for us, as collaborators, to become responsible stewards of the land 

enhancing focal species, integrating TEK, and fostering strong relationships with other tribal groups. 

There are already informal discussions underway to take the collaborative processes and considerations of 

the Somes Bar Project to the regional, national and international levels. As we continue to build a social 

license increasing the scope and scale of fire use for a more resilient landscape, we are also moving closer 

to a revitalized cultural environment, one in which ceremonial burning is fully restored.

Restoring and Maintaining Resilient Communities

The careful placement of fuelbreaks, combined with fuels reduction across the landscape, will reduce

vegetative fuel hazards around private properties and critical ingress/egress routes to safeguard life, health 

and property. These features will also improve the safety and effectiveness of fire management, both 

planned and unplanned ignitions (final EA pp. 11-12).
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10 – Somes Bar Integrated Fire Management Project

My concern is for the likelihood of human-caused ignitions during the hot, dry summer months,

particularly within the WUI. The project area is generally low elevation, with very warm summers and 

seasonal easterly prevailing winds. In addition, the lightning frequency in the Somes Bar Project area is 

almost twice as high as the rest of the forest combined, particularly in the higher elevation terrain of the 

Marble Mountain Wilderness, just east of the project area. Wildfires have a tendency to spread up canyons

and upslope towards ridgetops, making it difficult and dangerous for direct attack methods performed by 

fire suppression crews (final EA pp. 25-35, 132).

My decision acknowledges residents living in and around the four project areas that rely on 

collaborative fuels reduction efforts as a preventative measure, recognizing the personal and family 

hardships that can occur because of high-intensity wildfire. Since May 2001, the Orleans/Somes Bar Fire 

Safe Council has been acting on the direction of the National Fire Plan (USDA Forest Service 2000a), which 

instructs federal land management agencies to work closely with communities to protect people and 

resources in the WUI. In 2001, the Western Governors’ Association published A Collaborative Approach for 

Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Strategy (10-Year Strategy) for 

reducing wildland fire risks to communities and the environment (final EA pp. 17, 20-21, 27-28, 38-39).

My selection of Alternative 2 will be beneficial to these communities by reducing hazardous fuels 

around isolated private land parcels, as well as connecting and enhancing project area perimeter and 

interior roadside fuelbreak networks. These fuelbreak corridors will be created—and regularly

maintained—by treating surface, ladder and crown fuels. Recent fire seasons illustrate the risks and costs 

of inaction to life, property, firefighter and public safety. Over time, as fuel treatments and maintenance 

are implemented, fire suppression effectiveness should increase and the associated cost of fighting fire 

within the project area should decrease, as ecological resilience is restored.

Restoring and Maintaining Resilient Economies

The Somes Bar Project will provide for traditional and local food sources, forestry and fire management 

training, local living-wage jobs, and commercial forest by-products to promote local economic vitality

(final EA pp. 12-15).

Traditional and local food sources.

The Karuk Tribe has practiced World Renewal Ceremonies around Panamnik and Katimiin since time 

immemorial. These ceremonial centers are located, respectively, near the communities of Orleans and 

Somes Bar. The ceremonies themselves have been passed down for generations, and are a key part of the 

social fabric of these communities. They connect families and guide spiritual, hunting, gathering, and 

land-management activities. The whole landscape needs to be considered to understand the links between 

village sites, gathering places, spiritual trails, and places that have been managed in accordance with 

ancestral principles, use and responsibility. Tribal people continue to have a close relationship with the 

land and hold sacred many resources across the landscape. This relationship between the people and the 

land, as well as the sacred duty to take care of it for all animals and plants, has endured through countless 
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generations. People still gather, hunt, fish, prune, burn, and carry on their cultural practices throughout the 

Karuk Aboriginal Territory (final EA pp. 39-43, 104-105, 112-114).

The concept of TCPs and their consideration within historic preservation law has provided a deeper 

understanding of what needs to be identified and protected. Traditional cultural properties tie the practices of 

a living community with ancestral use. Vegetation and landscape features, the setting, and the feeling of a 

place may all be concrete elements in the designation of a TCP. This brings to the fore a broader 

understanding of historic preservation law that considers historic activities within a given area that link to 

contemporary practices. These contemporary practices include active management of sites that have been 

used for countless generations and are still used by people today. The Purpose and Need of the Somes Bar 

Project opens up the possibility that management actions will benefit and revitalize these sites. In this way, 

the NHPA can be employed to preserve the living culture of the Karuk people (final EA pp. 124-131).

Forestry and fire management training, local living-wage jobs.

In 2008, The Nature Conservancy’s Fire Learning Network (FLN) designed a novel program to provide 

training and learning opportunities for wildland fire professionals, while at the same time furthering the 

long-term objectives of FLN landscapes. These two- to three-week events, known as prescribed fire 

training exchanges (TREX), give trainees a concentrated dose of prescribed fire experience, as well as 

exposure to new people, places and techniques. The TREX program acts to build local capacity, while 

providing high-quality training opportunities for local, state, private and federal fire professionals, 

students, and managers from around the United States and from other countries.

The economics analysis indicates that combining local, tribal, and federal resources needed to 

implement fire management actions, as described in the Somes Bar Project, has the potential to provide

75 to 100 training opportunities. The implementation of mechanical and manual treatment activities will 

create up to 20 full-time equivalents (FTE) local living-wage jobs. The WKRP and the Somes Bar 

Project, not including the Klamath TREX or Forest Service employees, have already contributed over 

$1.4 million to the local economy to conduct outreach, field surveys, project development and 

environmental analysis for the Somes Bar Project draft and final EAs. Portions of these funds have gone 

to local contractors, with the majority invested in the local workforce. From 2016 to 2017, the number of 

FTE positions increased over 200 percent (final EA pp. 99, 281-282).

My decision to authorize the Somes Bar Project will provide socio-economic stability, particularly 

critical to those living in Orleans, Somes Bar and other nearby areas. An inadvertent outcome of the 

boom-and-bust nature of logging and mining industries has contributed to unemployment and a cycle of 

poverty, further aggravated by historic even-age forestry management practices that disrupted ecological 

cycles, compromising the services provided by industrial and traditional/cultural systems. With the 

decline in big game, salmon and other foods from the land, people are compelled to purchase foods in 

grocery stores or rely on government commodities and subsidies. This financial deficit can make or break 

a family business or promote poor diet and health (final EA pp. 12, 13, 99-100).
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12 – Somes Bar Integrated Fire Management Project

In making my selection, it is important to consider what these jobs mean to our rural economic, 

cultural and social well-being. The Forest Service has an obligation to provide local jobs, while securing 

any available fiscal sources to optimize implementation of critical restoration treatments.

Commercial forest by-products.

The Forest Service has a role to play in providing a wood supply for local manufacturers and businesses—

the management of vegetation and fuels will contribute commercially valuable timber by-products (Figure 

3), consistent with the Klamath and SRNF LRMPs, and other federal, state, and local laws and 

requirements. The Somes Bar Project responds to the Purpose and Need to provide commercial timber

harvesting as a tool to achieve desired vegetative and fuels conditions, as well as employment 

opportunities. While it was a challenge to balance economic feasibility, while conserving natural resources

and protecting cultural values, my decision supports forestry-related economic activity and employment 

opportunities by generating approximately 6 million board feet (MMBF) of commercially valuable timber

and unquantifiable amounts of species of interest for food gathering and sale (final EA pp. 99-100).

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, reference scientific sources that informed the analysis, as well 

as the assumptions underpinning the basis for the findings (final EA p. 103).

Relevant Issues

With the greatest good in mind, I considered the following relevant issues associated with implementing 

the Somes Bar Project (final EA pp. 22-23).

Threats to Native and Traditional Ecological Knowledge Plants

As the Responsible Official, I am dedicated to protecting historic properties in a spirit of stewardship for 

the inspiration and benefit of present and future generations (NHPA (16 USC 470-1(3)). Based upon a 

Figure 3. Treatment unit with commercial timber as a by-product.
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review of the Somes Bar Project record, I am satisfied Alternative 2 will provide immediate and 

foreseeable benefits, while minimizing adverse effects (final EA p. 81).

For the purposes of NHPA §106 analysis (outlined at 36 CFR 800), the project’s area of potential effect

(APE) was identified as the external boundaries of the four (4) project areas at Ti Bar, Patterson, Rodgers 

Creek, and Donahue Flat. This APE also corresponds in NEPA terms to the area of direct effects. Although 

the projects mechanical treatments involve varying levels of ground disturbance and can affect cultural 

resources through compaction, movement, breakage, or total destruction of artifacts, features, site stratigraphy 

(subsurface cultural deposits), or the entire site, the final EA documents no significant impacts to cultural 

resources in the NEPA framework and no adverse effects in the NHPA framework (final EA p. 117-118, 121). 

Rather, the Somes Bar Project aims to enhance these areas. Information regarding sensitive cultural resources 

and all locational data will be protected from public disclosure and will not be subject to the Freedom of 

Information Act (FOIA). Relevant federal statutes include the 2008 Farm Bill, the FOIA identification of 

exemptions (5 USC 552 (b) (3)), and NHPA confidentiality (16 USC 470 hh; final EA p. 122).

Karuk identity, and cultural use flora and fauna remain at risk due to uncharacteristic high-intensity 

wildfire and the lack of a managed fire regime based on TEK principles. If removing some trees will be 

beneficial to a site (e.g., restoring an acorn processing site where conifers have encroached upon a mature oak 

stand), the forest heritage program manager may allow timber harvest when it has been determined that work 

can be conducted without causing significant impacts to the site. All work within site boundaries will be 

monitored and directed by Forest Service archaeologists and/or tribal representatives.

The introduction and spread of invasive plants is associated with equipment used for road 

maintenance, landing development, and thinning, particularly in proximity to known Himalayan 

blackberry and other aggressive plant species. Invasive species have high dispersal capabilities, relatively 

long-lived seed banks, high tolerance for disturbance, few herbivores, and the ability to reproduce via 

seed and rhizomes—all attributes that provide a competitive advantage that leads to displacement of 

native plant communities. Most problematic is the occurrence of Himalayan blackberry in continuous 

thickets along the relatively lower sections of Forest Service routes intersecting with State Highway 96.

The Somes Bar Project incorporates design features to reduce the risk of invasive plant introduction 

and spread, including equipment cleaning prior to operating in the four project areas, avoiding developing 

new landings and staging equipment areas where there is a risk of contact with invasive plants, and 

managing the progression of work. My decision will prioritize road maintenance and mechanical 

treatments first for select units that are relatively “invasive-plant free” to minimize the potential for 

spreading seeds. The Somes Bar Project will also eradicate satellite occurrences with relatively few 

individuals (e.g., Himalayan blackberry and Dyer’s woad). Combined, current threats to TEK plant 

species should be reduced (final EA pp. 100, 111, 259-260).
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14 – Somes Bar Integrated Fire Management Project

Human Disturbance

Noise

Operational noise, presence of field crews, and smoke generated from prescribed burning during Somes Bar 

Project implementation may periodically disturb neighbors. During collaborative events, residents expressed 

that they chose to live in these isolated private land parcels surrounded by forestlands, because they highly 

value and cherish solitude, quiet, outdoor recreation, and the scenic beauty and bounty provided by nature.

Although the analysis indicates amplified noise disturbance within the project areas during implementation, 

particularly where there are no barriers to the source, such as segments along State Highway 96, these noise 

levels are reduced by increasing distance, air density, wind, and obstructions (e.g., trees, rock outcrops and 

natural landscape features). On windy days under the forest canopy or near streams, ambient noise tends to 

screen noise from machinery and traffic (final EA pp. 265-281).

Noise disturbances from timber harvesting and chainsaws during implementation of the Somes Bar 

Project will be seasonal and focused along transport or log-truck haul routes. Traditional tractor logging 

generates sounds from many sources throughout the harvest area, usually for the duration of the harvest 

period. However, sounds from heavy equipment operating in the forest are often dampened or attenuated by 

the surrounding trees and soft ground surface. On even terrain, noise level is generally reduced by one-half 

when the distance is doubled between the noise source and the receptor. Initial entries will involve tree felling 

with a line of sight noise measurement of 65 A-weighted decibels (dBA) at a distance of 150 feet; skidding 

and stacking logs, 65 dBA; and loading, 58 to 65 dBA. The dBA varies depending on the size of logs and the 

equipment used—is a heel boom or a loader equipped with log forks used, or is other equipment needed for 

operations, such as a Caterpillar D6 or D7 bulldozer or a log skidder (final EA pp. 267-268).

Cable yarding, which will be used on less than 2 percent of the Somes Bar Project, is a fairly quiet 

operation; however, communication from the logging area to the landing is necessary. Loggers do this with 

pre-designated signals from a device on the belt of the choker setter/hook tender that emits sounds on the 

yarder called a “talkie tooter”, generally in repeated short blasts (documented blasts of 135 to 140 decibels 

(db) at the source). These sounds, which can be carried 1 to 3 kilometers (0.6 to 1.9 miles) with wind 

increasing that distance, will likely be heard by nearby residents (final EA p. 268).

That said, all substantial noise levels resulting from operations will be temporary and infrequent, 

limited to daylight hours and weekdays. Operations will disturb anyone living right next to national forest 

lands being treated, the degree depending on the individual’s sensitivity and life preferences. While the 

presence of field crews and equipment is not necessarily a welcome change to those who enjoy solitude, I 

am committed to notifying and coordinating with neighbors prior to operations to help relieve impacts. It is 

my hope that despite these short-term disturbances, everyone recognizes the benefits of preserving and 

protecting NFS lands around their communities (final EA pp. 273-282).

Smoke

Prescribed burning will be implemented seasonally, over 15 years. Smoke from prescribed burning may 

impact nearby residents and visitors, reducing visibility and contributing to a smell of burning wood and 

other vegetation. While these impacts may occur, mitigation elements will address public concerns, such as
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Decision Notice & Finding of No Significant Impact – 15

contract language to maintain roadway openings or road monitors to address safety concerns. In addition, 

burn plans will also include language on how to reduce smoke emissions, identify sensitive smoke 

receptors, or indicate favorable wind directions for smoke transport.

In recent years, it has been observed that smoke from large wildfires has become trapped in river 

valleys and remained for long periods. In fact, smoke production can be so excessive that it can linger for 

months. Many environmental factors can contribute to this condition; however, there is a direct 

correlation between high levels of smoke production and high concentrations of fuel loading.

Although smoke production from prescribed fires is very temporary in nature and light in duration 

compared to wildfire smoke lasting hours or days, it can still be a nuisance to those in close proximity. 

Smoke management techniques will be utilized to minimize emissions from these burns as much as 

possible. These techniques may include only burning concentrations of fuels in an area as an initial action, 

isolating fuels that may smolder for long periods, mosaic burning in areas of non-continuous fuels and/or 

mechanical removal of fuels (USDA Forest Service 2001; final EA pp. 148, 280-281).

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

nation’s air resources. To protect public health, the implementation of the Somes Bar Project will not 

exceed federal and state ambient air quality standards, and as mentioned above, prescribed burning will 

be implemented seasonally, over 15 years. While smoke impacts from prescribed burns are unavoidable, I 

am committed to notifying and coordinating with neighbors prior to operations and am dedicated to doing 

everything I can to address public health and safety (final EA pp. 80-81).

Visuals

The Somes Bar Project will alter forest vegetation by implementing mechanical, manual and prescribed 

burning treatments across 5,570 acres. However, since the Forest Service began implementing 

clearcutting practices, and building roads and log landings, residents in and around the project area have 

been living with visibly altered scenic quality. As an outcome of my decision, the greatest change to 

scenic integrity will occur where trees are removed along roads and along private land boundaries, where

operational slash and freshly cut tree stumps will likely draw the attention of residents and motorists that 

drive by in the short term. While logging slash and charred and smoldering debris from prescribed 

burning will be visible, vegetative regrowth and wood decomposition will overtop this debris and cut 

surfaces will darken to become less evident. The design of the prescriptions will retain variable forest 

structure and complex mosaic patterns to blend with other natural forest patches and openings. This 

alteration will mimic current scenic integrity, so treatments remain visually subordinate within the Retention 

and Partial Retention Visual Quality Objective (VQO) classes (final EA pp. 265-266, 268-278).

Habitat Disturbance

The removal of select crown fuels (co-dominant conifer trees), along with ladder and surface fuels 

reduction treatments, including prescribed burning, may act to simplify forest stand structure in the short 

term, impacting habitat quality and TEK focal species (final EA pp. 172-216).
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16 – Somes Bar Integrated Fire Management Project

Northern Spotted Owl

Under Alternative 2, the predicted changes to nesting, roosting, foraging, and dispersal habitats within 

northern spotted owl (NSO; Strix occidentalis caurina) core and home ranges were analyzed and 

compared to the suggested levels of habitat described by the USFWS (2009), published research, and 

professional judgement. Alternative 2 fulfills the goals and objectives of the USFWS’s 2011 Revised 

Recovery Plan for the Northern Spotted Owl (2011 Recovery Plan; final EA pp. 178-183).

The California Coast Range (Klamath West) is considered “fire-prone” because of its frequent firereturn intervals and existing vegetation condition that likely elevates the potential of fire. Within fireprone areas, resource agencies planning vegetation management in NSO Critical habitat are encouraged to 

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

largely related to past fire exclusion (USDI Fish and Wildlife Service 2012; final EA pp. 183-184).

The Somes Bar Project will expedite conservation and restoration of NSO sites and high-value NSO

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

recommended by the 2011 Recovery Plan and 2012 NSO Critical Habitat Rule. Alternative 2 will apply 

variable thinning to accelerate diameter and height growth, while retaining a minimum 40 percent canopy 

cover in NSO foraging habitat. No pre-dominant trees (i.e., large diameter, older trees) will be cut; and 

large snags and downed logs will be maintained (final EA pp. 191-198).

Fisher

In general, fisher dispersal is affected by the reduction in fisher habitat and the distance between patches 

of habitat (Weir and Corbould 2010). The Somes Bar Project will maintain all potential suitable habitat 

for this species within a 7th-field watershed. Ten of the watersheds analyzed met the criteria of possibly 

containing or contributing to a fisher home range. These ten watersheds are likely to contain enough 

habitat and could contribute to a fisher home range after treatments (final EA pp. 200-201).

Roosevelt Elk

Over the last 100 years, fire suppression has simplified Roosevelt elk calving and wintering habitats. The 

level of habitat alteration authorized by my decision will have beneficial effects for this species with 

treatments that promote a mosaic of habitat types across the landscape, encouraging mixed-severity fire that 

reduces conifer encroachment in hardwoods, and increases perennial grass and structural diversity providing 

hiding cover for calving and calves during the reproductive period. Without the influence of naturally 

occurring mixed-severity fire, oak woodland habitat will be encroached upon and replaced by conifer 

species. The treatments will also reduce the risk of hiding cover loss by high-severity fires in the watershed.

Commercial treatments are limited to 146 acres within riparian reserves. These preserved riparian reserve

habitats will continue to serve as corridors and networks within the project areas, providing connectivity to 

patches of secure cover and calving habitats. The analysis indicates implementing the Somes Bar Project will 

provide adequate security cover and improve wintering habitat for Roosevelt elk (final EA pp. 173, 175).

Pacific Giant Salamander

Under Alternative 2, the risk of disturbance to Pacific giant salamander will be low following criteria

developed for the species and the amount of habitat treated. The available research on movement and habitat 
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use has the species highly associated with the inner 80 feet of riparian reserves, where there will be no 

mechanical treatment in stream tributaries within the four project areas. Within fish-bearing stream reaches 

(320-foot riparian reserve widths), no mechanical treatment will occur within 240 feet. The impacts of fall 

prescribed fires, designed to be ignited upslope and allowed to back down into the inner 80 feet of riparian 

reserves, will occur at temporal and spatial extents considered minimal for any single season. Prescribed fire 

within the Klamath River floodplain and associated riparian habitat will likely not impact the species, as 

most larvae will have achieved metamorphic climax and begun dispersing into tributaries, and adults will 

have moved earlier in the summer post-breeding activities. For adult Pacific giant salamanders moving or 

dispersing during winter rains, habitat modifications may be at a moderate risk in areas where large woody 

material (LWM) has not been retained on the landscape (final EA pp. 176, 178).

Willow

Willow is a TEK focal species managed for basket-making material. The direct and indirect effects on 

willow (Salix spp.) habitat due to Somes Bar Project implementation is low for 100 percent of the 7th-field 

watersheds in the analysis area. According to the analysis, most of the effects are the result of fuels 

treatments in riparian reserves. The primary habitat is along the Klamath River corridor and falls within 

the treatment polygons. The river corridor has isolated pockets of suitable willow habitat. Field surveys 

indicate alder is also prevalent (final EA p. 173).

Soil Erosion

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

Service Strategic Plan for FY 2015-2020, June 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 analysis indicates the Somes Bar Project will result in very low to no risk of 

sediment delivery, based on integration of minimization design and mitigation measures. Proximity of ground 

disturbance to riparian reserves is an important factor controlling sediment delivery (Rashin et al. 2006). 

Mechanical fuel-reduction treatment methods and associated connected actions implemented within riparian 

reserves have potential to cause measurable ground disturbance, which could impact water quality by altering 

background sedimentation rates in the short term (final EA pp. 241-246).

However, the analysis clarifies that because the project is spread across three 6th-field watersheds, and 

at most encompasses roughly 13 percent of the Reynolds-Klamath River watershed, it is very unlikely that 

enough vegetation will be removed to cause detectable changes in peak flows in the analysis area. For raindominated zones—below 2,500 feet in elevation in the project area—changes in peak flow can only be 

detected when 29 percent of the area is harvested (Grant et al. 2008). For areas where rain-on-snow events 

can occur—above 2,500 feet in elevation in the project area—the detection level for peak flow increases is 

19 percent, including harvested acres and roaded areas. The magnitude of observed changes in peak flows 

from management activities diminished with increased watershed area (ibid; final EA p. 234).
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18 – Somes Bar Integrated Fire Management Project

Public Involvement 

Collaboration

Collaboration was initiated by the WKRP in February 2012, and included 21 open forums with 

landowners, public stakeholders and regulatory agencies through June 2017, to develop the Somes Bar 

Project (Appendix A of the final EA). In 2013, the WKRP convened workshops utilizing an Open 

Standards process (Figure 4) for conservation planning of the entire Middle Klamath sub-basin. The 

Somes Bar Project is the first phase in realizing landscape and National Cohesive Wildland Fire 

Management Strategy2 (Cohesive Strategy) goals, in accordance with TEK3 and customs, as a framework 

for living with fire in the western Klamath Mountains of northern California (final EA p. 25).

2 National Cohesive Wildland Fire Management Strategy: The Federal Land Assistance, Management and Enhancement Act of 

2009 (FLAME Act) states, in part, “Not later than one year after the date of the enactment, the Secretary of the Interior and 

Secretary of Agriculture shall submit to Congress a report that contains a cohesive wildfire management strategy.” The Act 

directs that a cohesive strategy be developed addressing seven topic areas ranging from how to allocate fire budgets at the federal 

level to assessing threats to communities, and prioritizing hazardous fuels project funds. The Act is the catalyst for bringing fire 

leadership at all levels and agencies together and prompting a new approach to how wildland fire is managed 

(www.forestsandrangelands.gov/strategy/documents/strategy/CSPhaseIIINationalStrategyApr2014.pdf). 3 Traditional Ecological Knowledge (TEK): Cumulative body of knowledge, practice, and belief, evolving by adaptive processes 

and handed down through generations by cultural transmission, about the relationship of living beings (including humans) with one 

another and with their environment (Berkes et al. 2000).

Figure 4. WKRP utilized a collaborative process to develop overlay 

assessments to better prioritize manual, mechanical and 

prescribed burning treatment methods and locations.
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Decision Notice & Finding of No Significant Impact – 19

Tribal Consultation

On January 6, 2017, the Forest Service initiated formal consultation with the Karuk Tribe, a WKRP 

participant. The 11,950-acre Katimiin Cultural Management Area (CMA 8) lies within the Rogers Creek 

and Donahue project areas. The 2017 MOU between the tribe and the Forest Service provides a platform 

for both parties to work together to meet mutually beneficial goals and objectives to manage Katimiin, 

which is of indescribable importance to the Karuk people. Through meaningful consultation, the Karuk 

Tribe has led the way in designing the WKRP Somes Bar Project in a way that goes beyond simple 

protection of historic properties, to a focus of proposing land management activities that will benefit 

cultural sites and revitalize traditional practices.

The NHPA (16 USC §470 et seq.), intended to preserve the cultural and historical legacy of the United 

States for the benefit of future generations, requires that federal agencies consult with any Indian tribe that 

attaches religious and cultural significance to historic properties that may be affected by an undertaking. 

The law, as amended in 1992, clarifies that historic properties of religious and cultural importance to Indian 

tribes may be eligible for listing in the National Register. Section 106 regulations (36 CFR 800) require

that federal agencies and State Historic Preservation Officers (SHPO) engage Indian tribes in timely and 

meaningful consultation to resolve adverse effects of an undertaking (final EA pp. 21-22, 121-123).

Scoping Period

The Council on Environmental Quality (CEQ) defines scoping as an early and open process to determine

the scope of issues to be addressed and to identify potential significant issues related to a project (40 CFR 

1501.7). Beginning in February 2017, the Somes Bar Project was listed on the Klamath National Forest’s

(KNF) Schedule of Proposed Actions (SOPA), as the Ukonom Ranger District is part of the KNF

administered by the SRNF.

The 30-day scoping period for the Somes Bar Project—February 21, 2017 through March 23, 2017—

was initiated with the distribution of a scoping letter and map to 114 individuals and groups disclosing

information and seeking public comment on the project, along with an invitation to attend a public 

meeting on March 1, 2017. The notification was distributed to the Karuk Tribe, federal and state agencies, 

local government officials, businesses, interest groups, adjacent landowners, and interested individuals.

Sixteen (16) commenters submitted 56 comments during the scoping period (Appendix B of the final 

EA). The interdisciplinary team (IDT) considered public comments received during the scoping period to 

refine the Somes Bar Project and as the basis to explore Alternative 3 (final EA pp. 95-97). The following 

relevant issues were identified, representing minor and/or non-variable consequences, which will be 

avoided, or partially or fully mitigated by design criteria and operating procedures (final EA pp. 80-96 

and throughout Chapter 3):

o Threats to Native and Traditional Ecological Knowledge Plants. Prescribed burning in 

the spring and ground disturbance from log skidding, sorting and loading may damage 

native plant species, while increasing solar radiation favoring the spread of invasive weeds.
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20 – Somes Bar Integrated Fire Management Project

o Human Disturbance. Operational noise, presence of field crews, and smoke generated 

from prescribed burning may periodically disturb neighbors.

o Habitat Disturbance. The removal of select crown fuels (co-dominant conifer trees), 

along with ladder fuels and surface fuels reduction treatments, including prescribed

burning, may act to simplify forest stand structure in the short term, impacting habitat 

quality and TEK focal species.

o Soil Erosion. Tree harvest and associated logging operations (e.g., skidding, temporary 

road and landing construction), coupled with phased initial and maintenance prescribed 

burning, may increase sedimentation downstream.

Comment Period on the Draft EA

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

publication of the opportunity to comment in the Eureka Times-Standard. Additional notification was 

posted on the KNF’s website and on the SRNF’s social media sites (Facebook and Twitter). The Forest 

Service received comments from 12 individuals or agencies during the comment period, including 

comments from KFA, EPIC, NCRWQCB, Conservation Congress, Klamath Siskiyou Wildlands Center, 

MKWC and California Wilderness Coalition (final EA p. 23). A compilation of public comments received 

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

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

Impact & Final EA

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

means of administrative review. On April 21, 2018, the legal notice commencing an Opportunity to 

Object was published in the newspaper of record (Eureka Times-Standard), initiating the 45-day objection 

filing period pursuant to 36 CFR 218 Subparts A and B, ending June 5, 2018. Following publication of 

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

On June 1, 2018, an objection letter was submitted by Conservation Congress (unreadable due to a 

corrupt file format) and resubmitted in readable format on June 10, 2018. On June 22, 2018, the Objection 

Reviewing Officer provided a written response to issues raised in the objection letter, as required by 36 

CFR 218.32(b). The Objection Reviewing Officer found the Forest Supervisor’s rationale for this project 

is clear, and the reasons for the project are logical and responsive to direction contained in the SRNF 

LRMP. The Objection Reviewing Officer instructed the Responsible Official to proceed with issuance of 

this Decision Notice upon completion of further examination and consideration of any necessary 

information and clarifications that would strengthen the project record associated with the economic 

analysis, old growth retention in the 5th-field watershed, effects of climate change and the identification of 

temporary roads in the project area. On June 28, 2018, Conservation Congress requested clarifications 

and any information completed and added to the project record. On July 25, 2018, additional analysis and 
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Decision Notice & Finding of No Significant Impact – 21

a disclosure were added to the project record. This additional information was emailed to Conservation 

Congress as requested.

Two objection letters indicating support for the Somes Bar Project were received during the Objection 

Period—from MKWC, on June 4, 2018, and from EPIC and KFA, on June 5, 2018. On July 23, 2018, the 

Objection Reviewing Officer provided a written response indicating there will be no further review by 

any other Forest Service or US Department of Agriculture official as per 36 CFR 218.11(b)(2).

Alternatives Considered in Detail, but not Selected

I considered a range of alternatives in the analysis process; however, the Selected Alternative (Alternative 

2) best meets the Purpose and Need for the Somes Bar Project. The following alternatives were considered 

in detail, but not selected:

Alternative 1 (No Action)

In addition to the Selected Alternative, I considered the No Action Alternative (Alternative 1) as a baseline 

for comparison (final EA pp. 35-38). The environmental analysis and disclosure of the No Action 

Alternative provides an indication of what could happen if Alternative 2 was not selected. I did not choose 

the No Action Alternative because it does not meet the Purpose and Need to implement the SRNF or KNF 

LRMPs or the collaborative recommendations developed by the WKRP.

Although under Alternative 1 no hazardous fuels reduction or pre-treatment of vegetative fuels would

occur, avoiding potential risks and effects associated with taking action, the lack of action could result in 

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

shrub and invasive weed encroachment, high stocking reforestation forestry practices between 1950 and 

1994, and considerable investment in fire suppression technologies that effectively excluded fire across the 

landscape has made the use of prescribed fire in overgrown forest vegetation more complicated as a safe 

management tool without first implementing some type of fuels reduction pre-treatments.

Despite differences in European and Native American cultures, core values, jurisdictional authorities

and disjointed funding mechanisms respective of fire programs, all participants adamantly agree there are 

commonalities to be recognized in living with fire. The WKRP reached an agreement in principle for 

promoting frequent fire in that, if enough land is treated with prescribed fire more regularly at a lower 

intensity as the Karuk once did, there will be less flammable vegetative fuels to burn when lightning or 

human-caused fires do strike (final EA pp. 149-152).

Prior to fire suppression, indigenous burning and uninhibited lightning-ignited wildfires were an 

inseparable part of this forest ecosystem, consuming flashy fuels on a regular cycle. These wildfire 

events, coupled by frequent fire use by the Karuk, were mechanisms for environmental change and 

continuous renewal of healthy, heterogeneous wildlife habitats and plant communities. Karuk culture is 

directly reliant and dependent on mixed fire-severity regimes (Lake 2007). While fire is a central 

component of Karuk management and culture, increased fire severity and frequency pose particular and 
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22 – Somes Bar Integrated Fire Management Project

unique risks to specific Karuk tribal foods and cultural use species on the one hand, and to broader tribal 

programmatic goals and activities on the other (Lake et al. 2010; final EA p. 282).

Every fire interval removed from this fire-adapted landscape has resulted in a fire deficit, compounding 

threats to values at risk. Today, the amount of vegetative fuels buildup across forests and grasslands do not 

allow for safe application of fire as a restorative management tool. Rather, burning of overgrown vegetative 

fuels will likely promote volatile active crown-fire behavior that is difficult for fire crews to contain. Fire 

modeling of current conditions within the project area shows the potential of high fire hazard (the hazard 

ranges from low to high, but there is a significant percentage of moderate to high; final EA pp. 149-152).

Recent fire activity, occurring under conditions similar to those within the project area, have resulted 

in large wildfires that demonstrate negative stand-replacing fire effects. The benefits of the Somes Bar 

Project should be viewed in the context of, and in comparison to, wildfire effects. Fire behavior modeling 

indicates without action, it is likely the next wildfire event will burn across the land at an 

uncharacteristically high intensity. In 2014’s Happy Camp Complex Fire, as in the 2008 fires, several areas 

burned at sufficient temperatures to kill all vegetation and prevent any significant regeneration. This danger 

is especially acute due to the overall lack of fire across the WKRP planning area—over the last century, 

few areas have seen five (5) fires and large areas have seen no fire at all (Harling and Tripp 2014). This 

sets the stage for uncharacteristically high-intensity fires, rather than the traditional practice of introducing 

frequent, designed, and regular fires at low intensity. As is well established, both the costs and the direct 

effects to cultural resources from wildfire suppression are far higher than prescribed fires in the same area

(final EA pp. 25-35, 105-106, 126-128).

Focal and indicator species provide direct and culturally specific information about the overall health 

of the landscape. The policy of fire exclusion has resulted in great damage to the landscape—many 

resources, left to grow unmanaged, are choked with brush. Black oak woodlands, a key component of the 

landscape in dire threat, are easily overtopped and out-competed by Douglas-fir, reducing habitat for focal 

species such as Roosevelt elk. Because of these factors, the overall landscape is on a trajectory leading to 

uncharacteristically high-intensity wildfire, loss of local focal species populations, and ecosystem 

collapse (final EA pp. 105, 114).

In 2017, national forests in southern California experienced extreme fire behavior, impacting families 

and communities. These large, uncharacteristically high-intensity fires demonstrate the need to take action

using a variety of mechanisms—mechanical, manual and prescribed fire—to promote more fire-resilient

ecosystems. Between 2005 and 2015, more than 355,000 acres burned across the forest—more than 21⁄2 

times greater than historic trends. Although there is social debate over why this is occurring, reducing the 

amount of flammable fuels and improving forest resiliency is a wise approach and an incremental step to 

managing a fire deficit that would otherwise be deferred, setting the stage for a more hazardous future.

For these reasons, I found that the No Action Alternative will not meet the Purpose and Need to restore 

and maintain resilient landscapes or communities. Without action, fire behavior will not be modified to aid 

suppression, expedite the need to establish strategically placed fuelbreaks, or reduce potential flame 

lengths to four (4) feet or less around private lands and the community of Somes Bar, at risk of wildfire.
Decision Notice

Decision Notice & Finding of No Significant Impact – 23

Without active forest management, the vigor and growth rates of seedlings, saplings and small trees in 

overstocked plantations and young natural stands will stagnate or decline as water availability becomes 

more limited from inter-tree competition. The No Action Alternative will tend to maintain uniform 

structure and species composition at the landscape scale (final EA pp. 98-99). 

Under the No Action Alternative, opportunities to serve communities, tribal interests, create jobs and 

support businesses via the availability of natural resources would not be fulfilled. Consequently, I find the No 

Action Alternative does not respond to the need to restore and maintain resilient communities or economies. 

Alternative 3

In response to public comment, I considered an alternative where protecting the NSO was the driving 

force underlying treatment design (final EA pp. 95-97). Alternative 3 would limit removal of 18-inch dbh 

or greater crown fuels (intermediate and dominant trees) in natural stands, and would avoid all 

mechanical treatments in cable units and within riparian reserves included under Alternative 2. Vegetative 

fuel hazards would occur along roughly 50 percent of the critical ingress/egress routes to private land 

inholdings. Table 2 presents a treatment summary of Alternative 3. 

Table 2. Alternative 3 treatment summary. 

Treatment Methods Acres

Manual, Prescribed Burn 502

Mastication / Manual, Prescribed Burn 154

Mechanical – Ground-based / Manual, Prescribed Burn 496

Prescribed Burn 133

Grand Total 1,286

Although these treatments are within the framework of consideration for Alternative 3, implementation 

would require a high equipment mobilization costs as the 496 acres of mechanical treatments are scattered 

throughout the four (4) project areas, with limited acreage in the Ti Bar and Rogers Creek areas. 

Without perimeter containment (control lines/firelines) and pre-treatment of hazardous fuels across the 

landscape, the reintroduction of prescribed restorative fire could not be safely employed. More importantly, 

hazardous fuels would not be treated around most private land inholdings within the project areas (final 

EA p. 96). 
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24 – Somes Bar Integrated Fire Management Project

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Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 25

Finding of No Significant Impact

Based on the site-specific analysis summarized in the Somes Bar Integrated Fire Management Project 

Final Environmental Assessment (Somes Bar Project final EA) and the associated project file, I have 

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

significantly affect the quality of the human environment; therefore, an environmental impact statement 

(EIS) is not required. Under the 1978 regulations written by the Council on Environmental Quality (CEQ; 

40 CFR 1500-1508), significance is evaluated for both context and intensity. The evaluation of context 

and intensity is summarized below.

Context

The significance of an action must be analyzed in several contexts, such as society as a whole, 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 on the effects in the locale, rather than in the world as 

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

The Somes Bar Project context is of limited scope and duration. The potential effects will be confined 

to 5,570 acres with project completion occurring over the next 15 years. Any adverse effects will be 

limited and short-term, while benefits will be long lasting. Even in a local context, the Somes Bar Project

will not pose significant short- or long-term effects. Resource protection measures will minimize and 

avoid adverse impacts to the extent that all impacts are within levels allowable under the Six Rivers and 

Klamath national forests’ land and resource management plans (SRNF and KNF LRMPs or forest plans), 

consistent with all standards and guidelines (S&Gs).

Intensity

Intensity refers to the severity of impact, which is evaluated based on 10 factors. The following 

summarizes the findings of intensity relative to those factors:

1. Impacts may be both beneficial and adverse. A significant effect may exist even if, on balance, effects 

are believed to be beneficial.

The Western Klamath Restoration Partnership (WKRP) aims to transform the fire exclusion paradigm to 

one of holistic landscape management in alignment with the National Cohesive Wildland Fire Management 

Strategy (Cohesive Strategy). The Somes Bar Project seamlessly integrates, in practice, principles 

underlying the Cohesive Strategy and Karuk traditions passed down and preserved over generations.

The Somes Bar Project will reduce ladder fuels, increase canopy base heights, and decrease canopy 

densities through thinning activities. In combination, these activities will help reduce rates of spread, 

flame length, fireline intensity, resistance to control and the potential for ground fires to transition into 

crown fires (final EA p. 152). The reduction in these fire behavior indicators will occur over time and 
Finding of No Significant Impact

26 – Somes Bar Integrated Fire Management Project

multiple entries as the fuel models transition following thinning and burning to increase stand resiliency 

to large-scale crown fires (final EA pp. 160-166).

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

vulnerable to being overtopped and crowded out by Douglas-fir. The oaks that remain are old and serve as 

indicators of an ancestral state. In addition, one of the biggest deficits on the landscape is the old upland oak 

woodland (CR). The Somes Bar Project will directly benefit these traditional ecological knowledge (TEK) 

species of interest (e.g., California black oak, Oregon white oak, golden chinquapin, hazel, large tanoaks). In 

plantations, larger hardwoods, both single stemmed and larger stems in clumps, will be favored for retention 

and conifers thinned out around them to enhance hardwood growth while reducing stand densities. In natural 

stands, hardwoods over 24-inch dbh are usually the oldest trees in the stand. Although these trees may no 

longer be dominant or co-dominant in the canopy, they were once the dominant or co-dominant trees in the 

stands before fire exclusion. Thinning around these remnant trees, many of which are being overtopped and 

shaded out by faster growing Douglas-fir, will enable the remnant trees of interest to receive more light and 

grow fuller crowns, which will increase their health and resistance to disturbance, as well as enhance acorn

production in true oaks, tanoaks, and chinquapins (final EA pp. 42, 47, 105, 126-127, 157, 163, 170).

The main negative effect of prescribed burning is the incidental torching of small-diameter trees. Tree 

mortality may be most visible along roadways and near private property. Fire-killed leaves and needles are 

short-term visual indicators of mortality; however, in a one-year period following entry, leaves and needles 

fall to the ground lessening the visual effect (final EA p. 154). The Somes Bar Project will implement pretreatment thinning activities prior to understory burning to limit incidental mortality of preferred retention 

leave trees (final EA p. 148), minimizing unintended impacts to soils and visual integrity.

The North Coast Regional Water Quality Control Board’s (NCRWQCB) Basin Plan indicates state 

controllable water quality factors shall not cause further degradation of water quality when it has already been 

established as degraded, and efforts to restore the impaired beneficial uses of these watersheds must be made. 

The project design and mitigation measures will act to minimize delivery of management-related sediment 

and improve the long-term sediment regime for the project area to protect water quality. The watershed 

analysis indicates stream temperature and dissolved oxygen will not be altered as a result of implementing the 

Somes Bar Project. The project design delineates extensive riparian reserve buffers and residual canopy cover 

at 60 percent in the outer 80 feet of the acres treated mechanically (146 acres) to protect stream temperatures 

and reduce the risk of sedimentation and turbidity. Current dissolved oxygen concentrations are within the 

range of natural concentration levels and will not be altered by the proposed activities (final EA p. 234).

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

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

activities not foster the introduction and spread of invasive species, apply to the Somes Bar Project. The 

direct effects of the Somes Bar Project pertaining to invasive plant species are primarily associated with 

introduction and spread of invasive plants from equipment used for road maintenance, landing 

development and thinning (final EA p. 216). Project design features (PDFs) for the Somes Bar Project will

reduce the risk of invasive plant introduction and spread via 1) equipment cleaning prior to operating in the 

four project areas; 2) avoiding development of landings and staging equipment where there is a risk of 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 27

contact with invasive plants; and 3) employing progression of work that prioritizes road maintenance and 

mechanical treatments (including mastication) first to those units in settings that are relatively “invasiveplant free,” such as upper reaches of the project areas, before operating in the units and/or settings where 

invasive plant cover and diversity is high, such as along State Highway 96 and on US Forest Service 

(Forest Service or USFS) routes within one (1) mile of the highway (final EA pp. 262-263).

Indirect effects of the Somes Bar Project pertain to the types of actions occurring adjacent to invasive 

plant occurrences, such as reducing canopy or shrub cover by mechanical thinning or manual fuels 

treatments, thereby enhancing the growing conditions of relatively shade-intolerant invasive species and 

reducing competition. These indirect effects could result in invasive species like Himalayan blackberry 

expanding from the road edge into the forest. Project design features to reduce the risk of indirect effects 

and thus substantiate the Finding of No Significant Impact (FONSI) for this element, include treatment of 

relatively small and discrete occurrences of invasive species, maintenance of a native vegetation around 

invasive plant occurrences to reduce down or upslope spread, and in certain riparian area reaches, focal 

treatment of blackberry by manual removal, piling and burning (final EA pp. 264-265).

2. The degree of effects on public health or safety.

Clean Air Act of 1970

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

nation’s air resources. The implementation of the Somes Bar Project will not exceed federal and state 

ambient air quality standards to protect public health. Prescribed burning will be implemented seasonally, 

phased over 15 years. As each entry may be implemented over several seasons, smoke disturbance may 

impact nearby residents and visitors by lowering visibility and from the smoke smell in the short-term. 

While these impacts are unavoidable, mitigation elements will address public health and safety concerns. 

The project design incorporates operational provisions to maintain roadway openings, along with 

requiring road monitors, to ensure safe motorized access to private land inholdings during operations. 

Additionally, burn plans will be developed identifying 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 pp. 154, 268, 280).

Clean Water Act

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

(USDA Forest Service 2015). Management activities on NFS lands must be planned and implemented to 

protect the hydrologic functions of forest watersheds, including the volume, timing, and quality of 

streamflow. The alternatives, as proposed, will comply with the Clean Water Act, Porter-Cologne Water 

Quality Control Act, applicable water quality control plans, and the NCRWQCB waiver of waste 

discharge requirements. A waiver application will be filed after the Decision Notice is (final EA p. 234).

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, 

applicable to timber and fuel treatment projects. The water quality standards in the NCRWQCB Basin 
Finding of No Significant Impact

28 – Somes Bar Integrated Fire Management Project

Plan that most closely apply to the Somes Bar Project are sediment, turbidity, temperature and dissolved 

oxygen (final EA p. 234).

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. The 

standard for turbidity states, “turbidity shall not be increased more than 20 percent above naturally occurring 

background levels”. Effort was made to reduce the risk of sedimentation and turbidity from the Somes Bar 

Project through design features and BMPs. The NCRWQCB Basin Plan states that controllable waterquality factors shall not cause further degradation of water quality when it has already been established as 

degraded, and efforts to restore the impaired beneficial uses of these watersheds must be made. The waterquality analysis of the Somes Bar Project focused on minimizing delivery of management-related sediment 

and improving the long-term sediment regime for the project area (final EA pp. 228, 230-231, 233, 449).

Relative to water temperature, the NCRWQCB Basin Plan states that water temperature of receiving 

water bodies shall not be altered and at no time shall the temperature of any cold water be increased by more 

than 5°F. Similarly, dissolved oxygen concentrations shall not fall below 6.0 mg/l (milligrams per liter).

Stream temperature and dissolved oxygen will not be altered as a result of the Somes Bar Project. 

Extensive riparian reserve buffers and 60 percent residual canopy cover in the outer 80 feet of 

mechanically treated units (146 acres total) will protect stream temperatures (final EA p. 222). Current 

dissolved oxygen concentrations are in the range of natural concentrations and will not be altered.

Because the Somes Bar Project is spread across three 6th-field watersheds, and at most encompasses 

13 percent of the Reynolds-Klamath River watershed, it is very unlikely that enough vegetation will be 

removed to cause detectable changes in peak flows in the analysis area. For rain-dominated zones (below 

2,500 feet in elevation in the project area), changes in peak flow can only be detected where 29 percent of 

the area is harvested (Grant et al. 2008). For areas where rain-on-snow events can occur (above 2,500 feet 

in elevation in the project area), the detection level for peak flow increases is 19 percent, including 

harvested acres and the area in roads. The magnitude of observed changes in peak flows from 

management activities diminished with increased watershed area (ibid; final EA p. 221).

Wildland-Urban Interface

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

(WUI), as the Somes Bar Project is designed to allow for efficient wildfire containment and control (final 

EA pp. 16, 19-20). 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 reported in the database have helped to reduce wildfire intensity, allowing better 

control by firefighters. In most 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 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 29

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).

3. Unique characteristics of the geographic area such as proximity to historic or cultural resources, 

park lands, prime farmlands, wetlands, wild and scenic rivers, or ecologically critical areas.

Katimiin Cultural Management Area

The Katimiin Cultural Management Area (CMA) lies within Rogers Creek and Donahue project areas, 

encompassing 2,306 acres within the Somes Bar Project area. A memorandum of understanding (MOU; 

Karuk Tribe, SRNF and KNF 2017) provided a platform for both parties to collaboratively develop the Somes 

Bar Project to achieve mutually beneficial goals and objectives for land management, recognizing the land’s

indescribable importance to the Karuk (final EA p. 6). The Somes Bar Project fulfills the intent of the MOU 

to work together to mutually coordinate planning and implementation efforts as partners, in and adjacent to 

the Katimiin CMA in a manner consistent with Karuk customs, culture and federal land management 

direction (final EA pp. 122, 156, 174).

Wetlands and Floodplains

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

within the project area. Therefore, the Somes Bar Project will constitute a “no effect” undertaking, as 

none exist or will be affected (final EA p. 289, 434).

Parklands and Prime Farmlands

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

Service will notify and coordinate with a local grape grower to coordinate the timing of prescribed 

burning to mitigate smoke tainting of commercial grape products (final EA p. 80).

Wild and Scenic Rivers

The Klamath River, which lies adjacent to the project areas, flowing north to south, was designated a 

Recreational River within the National Wild and Scenic Rivers System in 1981 (KNF LRMP 4-156). 

Three designated segments have been identified for potential reclassification per the 1986 amendment to 

the Wild and Scenic River Act (WSRA). The closest segment is from Ti Bar to the mouth of the Salmon 

River, portions of which overlap the project areas near the Klamath River. All Somes Bar Project

activities are consistent with the KNF standards and guidelines (S&Gs) for Recreational River 

management (final EA p. 267). Most recreational activities are concentrated along the Klamath River or 

are associated with the Marble Mountain Wilderness to the east, outside the project area (final EA p. 290).

Northern Spotted Owl Critical Habitat

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 (USDI Fish and 

Wildlife Service 2012). Within fire-prone areas, resource agencies planning vegetation management in 

critical habitat for the northern spotted owl (NSO) are encouraged to ameliorate current threats of ongoing habitat loss from uncharacteristic fires and vegetation change that are largely related to past fire 
Finding of No Significant Impact

30 – Somes Bar Integrated Fire Management Project

exclusion (USDI Fish and Wildlife Service 2012). Designed collaboratively, the Somes Bar Project is 

aimed at maintaining and enhancing the characteristics of older forests, providing large habitat blocks and 

associated interior forest conditions, including mosaics of interior habitats and edges to provide for the 

diversity of NSO prey (final EA pp. 181, 184, 191, 194-195, 198).

Special Habitat Management Area

Special Habitat Management Area (KNF Management Area 5) consists of special provisions for peregrine 

falcon, bald eagle and late-successional reserves (LSR), including a provision for peregrine falcon eyries. 

Although the Somes Bar Project proposes fuels reduction treatments within the Special Habitat 

Management Area; there are no known peregrine falcon eyries located within 0.5 miles of the project

areas (final EA p. 174). Therefore, the proposed treatment is consistent with the management of this area 

and will not be analyzed further for this project.

Bald eagles were delisted under the Endangered Species Act (ESA), but the eagle is included in the 

Forest Service Sensitive species list. Forest plan provisions for the Special Habitat Management Area 

around bald eagle nests will be followed. Effects of the Somes Bar Project on bald eagles are disclosed 

under discussions of Forest Service Sensitive species (final EA pp. 90, 174, 178, 199, 206).

Approximately 49 acres of the Somes Bar Project are proposed for treatment within LSR Ten Bear 

RC349. The KNF Forest-Wide LSR Assessment (LSRA 1999) determined that this area of the LSR was 

deficient in late-successional habitat. Portions of the LSR were harvested prior to designation; therefore, 

extensive stands of dense plantations exist that not only create a fuels hazard, they also do not provide 

suitable habitat for late-successional species, such as the NSO. Plantations and young natural stands are evenaged and lack the horizontal and vertical diversity components associated with late-mature stands. Young 

stands have the potential to achieve rapid diameter and height growth with thinning treatments. Silvicultural 

prescriptions can be applied to younger stands to accelerate their development toward late seral conditions. 

These treatments could increase the amount of late seral vegetation sooner than will occur naturally. The 

LSRA indicated the proposed area needs extensive fuels treatments to protect the LSR, as well as extensive 

habitat restoration. Planned treatments outside but adjacent to the Ten Bear LSR will reduce fuel loading risk 

and provide additional protection to late-seral stands (final EA pp. 177-178).

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

controversial.

The term controversial in this context refers to cases where substantial scientific dispute exists as to the size, 

nature, or effects of a major federal action on some human environmental factor, rather than to public 

opposition of a proposed action. The Conservation Congress refers to a study conducted by fire ecologists at 

the Missoula Fire Lab indicating, “Even extensive fuel treatments may not reduce the amount of area burned 

over the long-term and furthermore, reduction of area burned may actually be an undesirable outcome”. The 

commenter shares a new study soon to be published based a review of 1,500 wildfires occurring between 

1984 and 2014, indicating, “actively managed forests had the highest level of fire severity”.

The premise underlying the Somes Bar Project is to prepare land for the return of frequent, restorative 

lower intensity fire as the Karuk once did, so there would be less flammable vegetative fuels to burn when 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 31

lightning or human-caused fires do strike. Unlike the aforementioned fuel treatment studies, the underlying 

premise of the Purpose and Need is if enough land is treated with prescribed fire more regularly as a tool to 

regulate vegetative growth and composition, fuel concentrations would be decreased and cultural natural 

resources revitalized (final EA pp. 15, 18, 38-42, 45, 111-112, 126, 148). The WKRP recognizes an 

individual action is not sufficient to alter fire behavior, particularly those wind-driven wildfire events 

igniting during 90th-percentile weather conditions (final EA p. 153).

However, there are numerous scientific publications supporting findings that, “Maintaining managed 

ecosystems within the bounds of the historical range of variation for key ecosystem patterns or processes 

has traditionally been seen as the best hope for preserving species and landscapes and ensuring long-term 

ecological sustainability” (Egan and Howell 2001, Landres et al. 1999; see Scoping Comment #46). 

Another publication states, “A management strategy that includes methods for increasing forest 

heterogeneity at multiple scales will improve habitat quality and landscape connectivity” (North et al. 

2009). Some studies and models suggest, “... a crown fire entering a stand is rarely sustained (i.e., 

sustained only under extreme weather conditions), if understory fuels are too sparse to generate sufficient 

radiant and convective heat” (Agee and Skinner 2005; Stephens and Moghaddas 2005). Various research 

supports this restorative type treatment by summarizing, “... a reasonable start is to put forest and 

woodland landscapes on a path to successional patterns and disturbance dynamics that reflect the natural 

disturbance regimes of regional and local landscapes, and allow the future climate to adapt them” 

(Swetnam et al. 1999, Keane et al. 2009, Wiens et al. 2012).

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

unique or unknown risks.

The Somes Bar Project was designed to achieve objectives identified in the SRNF and KNF Forest Plans. 

Project design features and resource protection measures will minimize the potential for adverse effects. 

Traditional ecological knowledge and years of local experience with these types of projects minimize the 

chance of highly uncertain effects or effects that involve unique or unknown risks.

The 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.

Executive Order 12898, Environmental Justice

This federal order requires an assessment of whether there would be disproportionate effects to minority 

or low-income populations. Although there are minorities and low-income populations living in the North 

Coast California area, they will benefit from the proposal (final EA pp. 80-94).

Environmental Justice ensures 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 

will be no discernable differences between the Somes Bar Project and No Action Alternative regarding 

effects on minorities or the civil rights of any American citizen.
Finding of No Significant Impact

32 – Somes Bar Integrated Fire Management Project

The Somes Bar Project will not have disproportionately high and adverse human health effects, high 

or adverse environmental effects, substantial environmental hazards, or effects to differential patterns of 

consumption of natural resources. Extensive scoping did not reveal any issues or concerns associated with 

the principles of Environmental Justice. No mitigation measures to offset or ameliorate adverse effects to 

these populations have been identified (final EA p. 98-101).

Relationships between Local, Short-Term Uses of the Human Environment and Maintenance or 

Enhancement of Long-Term Productivity

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

burning and logging/hauling operations. Long-term effects should not appreciably change the human 

environment after final entry fuel reduction operations have concluded, as proposed treatment

prescriptions are low-intensity, and planned for phased entries to minimize disturbance to nearby 

neighbors and natural resources (final EA p. 100).

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

community members rely on natural resources for substance food gathering and jobs. These communities 

are directly influenced by forest-management job opportunities and supply of natural resources from 

forest ecosystems. The burning activities will promote production of food and fiber resources for 

subsistence gatherers contributing to the local economy. Implementation of the Somes Bar Project will 

not cause unavoidable or other indirect social/economic adverse effects (final EA p. 99).

The Klamath Prescribed Fire Training Exchange (TREX) is an annual two-week training in the use of 

prescribed burning in the Western Klamath Mountains to reduce the future danger of wildfires. The TREX 

event builds local capacity, while providing high-quality training opportunities for local, state, private and 

federal fire professionals, students, and managers from around the country and from other countries. With 

combined funding and resources from tribal, local, and federal partners, the TREX events help bring in 

more participants to deliver good fire to a larger landscape. Every year, the Klamath TREX advances the 

training of firefighters from around the region, the nation and even the world to share best practices and 

knowledge about how to implement prescribed fire. This training event blends traditional native burning 

with western science to restore fire processes directly around communities where it is needed most (final 

EA p. 131).

Each year, since its inception, the Klamath TREX has had approximately 50 training opportunities

and 100 participants, and created six (6) full-time-equivalent (FTE) jobs. The implementation of the 

Somes Bar Project over a 15-year period will potentially increase paid training job opportunities 

equivalent to at least 20 FTE.

The SRNF has had an active fuels treatment program for many years. Prescribed fires are 

implemented using measures that will ensure good air quality for local residents. Effects on the human 

environment from smoke and prescribed burns are predictable; past experience shows impacts to humans 

are negligible when management measures are in place.

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

represents a decision in principle about a future consideration.
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 33

Due to the routine nature of the Somes Bar Project, no precedent will be set for future decisions with 

significant effects. A decision to proceed does not represent a decision in principle about a future 

consideration.

Irreversible or Irretrievable Commitments of Resources

Irreversible commitment of resources refers to a loss of non-renewable resources, such as mineral 

extraction, heritage (or cultural) resources, or to those factors which are renewable only over long time 

spans, such as soil productivity. Under the No Action Alternative, there would be no irreversible or 

irretrievable commitment of resources.

Irretrievable commitment applies to losses that are temporary, such as the use of renewable natural 

resources. The production lost would be irretrievable, but the action would not be irreversible. Vegetation 

removed as commodity byproducts for the Somes Bar Project 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, sustainable stand densities resilient to natural processes serving TEK focal and 

indicator species, ESA wildlife habitat, and human and cultural values (final EA pp. 26, 122, 175).

Adverse Environmental Effects that cannot be Avoided

The Somes Bar Project involves adverse environmental effects to soil resources that cannot be wholly 

avoided or mitigated. There will be measurable negative effects in specific areas (e.g., temporary roads, 

landings, some skid trails); however, these are not expected to be long term or extensive enough to be 

significant at unit-scale. The aerial extent of these impacts is expected to comply with applicable

standards (less than 15 percent of the area), and thus impacts are not considered to constitute a 

“substantial and permanent impairment” of soil productivity with respect to National Forest Management 

Act of 1976 (NFMA) and Forest Service Region 5 Soil Quality Standards (R5 SQS). Project design 

features are developed in site-specific fashion and are intended to ensure compliance with the various 

elements of soil management direction. Physical soil impacts will be limited in aerial extent, and thus are 

considered acceptable for the project, in accordance with soil management direction.

Implementation of the Somes Bar Project will cause no other known unavoidable or other indirect 

adverse effects, other than the effects already stated (final EA pp. 67, 92-93, 230, 232, 242, 244, 246).

Energy Requirements of Alternatives

The implementation of the Somes Bar Project will require the use of various amounts of fossil fuels.

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.

The Somes Bar Project will not result in significant cumulative adverse impacts when considered in 

combination with other past, current, or reasonably foreseeable actions. Cumulative effects to sensitive 
Finding of No Significant Impact

34 – Somes Bar Integrated Fire Management Project

resources were discussed in the final EA (final EA Chapter 3 in resource-specific cumulative effects and 

Appendix F). Based on the effects to soils, water quality, riparian areas, wildlife, fish, botany, and fuels 

addressed in the final EA, and the biological assessments/evaluations addressing this project, there will be 

no significant cumulative adverse effects that could result from implementation of the Somes Bar Project.

When considering past, present, and foreseeable future actions (e.g., mechanical and manual cutting, 

prescribed burning, etc.), the Somes Bar Project will increase the amount of ground disturbance and 

subject the land to prescribed fire. Past and present projects that are in and around the current project 

footprint include the Roots and Shoots Cultural Burn (Roots and Shoots), Orleans Community Fuels 

Reduction (OCFR), and Katimiin Thin projects. The only known future project is the Six Rivers Aquatic 

Restoration Project (Aquatic Restoration Project), which is under development.

Cultural Resources

Mitigation measures have been or will be implemented to keep ground-disturbing activities out of cultural 

resource site boundaries. Fuels reduction pre-treatments have been or will be implemented to minimize 

fire effects on archaeological sites and traditional cultural properties (TCPs) during prescribed burns

(final EA pp. 81-82). As such, the potential cumulative effects on cultural resources and TCPs are not 

considered adverse. In fact, on-going and future collaborative-based ecological restoration projects will

benefit cultural resources across the larger landscape (final EA p. 130-131).

Fire and Fuels

In consideration of additional projects within the project area boundaries, as well as those just outside of 

the project boundaries, this project is a direct compliment to other efforts. The recognition that fire danger 

exists well beyond the project boundaries (as well as on private inholdings) is addressed by providing for 

a connectivity of fuels reduction treatments (final EA pp. 32-35). Working across jurisdictional 

boundaries achieves the greater goal of the WKRP, as well as aiming to achieve goals within the 

Cohesive Strategy (final EA p. 155).

By initially developing strategic fire control features of private property thinning, ridgeline fuelbreak 

construction and careful assessment of high fuel loading condition, we should be able to return fire 

successfully to the project areas. Once first-entry treatments of fire have occurred, second and third entry 

treatments may occur at larger scales, due to previous reductions in fuel loading and decreased tree 

densities, as well as the placement of multiple established control lines (final EA pp. 38-39, 131, 153).

Soils

The Somes Bar Project will have adverse environmental effects to soil resources that cannot be wholly 

avoided or mitigated. There will be measurable negative effects in specific areas (e.g., new temporary 

roads, landings, some skid trails); however, these are not expected to be long term or extensive enough to 

be significant at unit-scale. The aerial extent of these impacts is expected to comply with applicable 

standards (less than 15 percent of the area), and thus impacts are not considered to constitute a “substantial 

and permanent impairment” of soil productivity with respect to NFMA and R5 SQS. Project design 

features are developed in site-specific fashion and are intended to ensure compliance with the various 

elements of soil management direction. In addition, applicable BMPs for water quality management (final 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 35

EA Appendix B) are integrated into the project to safeguard against potential adverse impacts to soils. 

Implementation and effectiveness monitoring of BMPs would occur on an annual basis. Physical soil 

impacts will be limited in aerial extent, and thus are considered acceptable for this project, in accordance 

with soil management direction (final EA p. 246).

Invasive Plants

The Somes Bar Project does have the potential to increase the risk of invasive plant introduction and 

spread. Actions that increase the risk include using heavy equipment and staging equipment at sites with 

invasive plants, reducing canopy cover proximal to occurrences of invasive plants, creating landings and 

using existing landings where invasive plants are already exist, and prescribed burning that removes 

native vegetation (i.e., forbs, shrubs, small trees) that provides competition and functions as a barrier to 

movement of invasive plants. There are settings within the project areas specifically associated with State 

Highway 96 and the Klamath River, as well as along the lower stretches of access roads closest to State 

Highway 96, that are already very compromised in terms of invasive plant cover and the array of species 

present. Without aggressive actions, such as the use of herbicides, the proposed actions in these settings 

are not likely to change the current condition and the risk of spread is considered high, even if no actions 

were proposed in these areas.

The Somes Bar Project incorporates prescriptions and design features to reduce the introduction and 

spread of invasive plant species from a high risk to low risk where occurrences are small and discrete, and 

moderate risk where occurrences are modest in size or located in riparian areas. Examples of risk 

reduction actions include establishing a progression of work for implementation that treats areas not 

infested with invasive plants prior to moving to infested areas, equipment cleaning, using weed-free rock 

material and erosion control material, clearing invasive plants from landings prior to use, and targeting 

removal of isolated plants (final EA pp. 262-263).

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.

The Somes Bar Project will benefit cultural resources. In fact, fuels reduction treatments and the 

reintroduction of cultural burning will improve the state of certain sites, objects, features, or properties. It 

is important to consider traditional principles, practices, use factors, and associated wildlife habitats that 

link the action to the spiritual, living environment, and human responsibility through respect and 

reciprocity, especially concerning food, fiber, medicinal and regalia species. The treatments planned for 

the Somes Bar Project include prescribed burning, hand thinning with chainsaws, mastication, and several 

types of ground-disturbing activities, such as ground and cable-based tree harvesting. These activities 

have the potential to affect cultural resources, including historic properties, archaeological sites, TCPs, 

sacred sites, and traditional-use areas. However, with the application of PDFs and standard protection 

measures, it is anticipated that none of the proposed activities will adversely affect cultural resources. The 

cultural resource surveys have been designed in such a way as to assess current conditions in the area of 
Finding of No Significant Impact

36 – Somes Bar Integrated Fire Management Project

potential effect (APE) to design management prescriptions that will lead to a desired future condition 

more considerate of perpetuating living Karuk culture (final EA p. 124-125).

Through TEK integration, the Somes Bar Project will promote the preservation of a living culture,

while enabling expansion of fire-adapted community concepts. The management practices achieved by 

implementing the Somes Bar Project will lead to the reintroduction of fire, and will start the process of 

landscape recovery from years of neglect, fire exclusion, road building, use of chemical/biological agents 

and logging practices. The reintroduction of management by fire may have indirect beneficial effects over 

a much wider area than the direct APE covered by the analysis. Since the Somes Bar Project takes a 

holistic landscape approach and employs five focal species that together cover the main landscape 

components, it is appropriate to realize that there may be indirect beneficial effects in the context of the 

entire WKRP planning area and beyond.

The actions planned for the Somes Bar Project will enhance the focal species and integrate other TEK 

considerations across that whole area, as well as build relationships with additional tribal groups. Indirect 

effects beyond the scope of the WKRP effort are also underway as many people at regional, national, and 

international scales are expressing interest in the processes and considerations being established and 

undertaken in this demonstration project. A key indirect effect of the Somes Bar Project is the potential for 

enabling the restoration of important ceremonial burning practices on Offield Mountain. By treating large 

areas around residential structures, and building social license for increasing the scope and scale of fire use, 

ceremonial burning can be restored, as well as managed wildfire decisions enabled on adjacent landscapes.

The Somes Bar Project has been implemented in accordance with the requirements of National 

Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA) §106. The implementation 

of this project is designed to avoid and improve cultural resources in TCPs (final EA p. 126-131).

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.

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 US Fish and Wildlife Service 

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

species under their jurisdiction as follows:

Wildlife

The draft wildlife biological assessment (BA) for the Somes Bar Project (Bettaso and Yost 2017/2018) 

contains a detailed analysis of effects and determinations on the following ESA listed species:

Gray wolf

No gray wolf den or rendezvous sites are known to occur within the project area. No critical habitat has 

been designated for the gray wolf. The nearest known den or rendezvous site is more than 70 miles from 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 37

the project area. Therefore, it was determined the Somes Bar Project will have “no effect” on this species

(wildlife final BA p. 4).

Marbled murrelet

Surveys were conducted for the marbled murrelet with no detections. In addition, the project is not 

located within marbled murrelet critical habitat. Therefore, the Somes Bar Project will have “no effect” on 

marbled murrelet or its critical habitat (wildlife final BA p. 3).

Northern spotted owl

During discussions with the Level 1 team, draft data presented to the USFWS has resulted in a tentative 

agreement on the determination of “may affect, not likely to adversely affect” NSO and its critical habitat,

due to the removal of 3.4 acres of low- to moderate-quality nesting/roosting habitat and removal of 7.5

acres of foraging habitat during construction of temporary roads and new landings. Temporary roads and 

landings will remove scattered pockets of nesting, roosting and foraging habitat typically less than 0.25 

acres in size of suitable NSO habitat (wildlife final BA p. 69). No commercial treatment will occur within 

70-plus-acre nest groves or high-quality nesting/roosting habitat (wildlife final BA p. 73). All current NSO 

habitat function will be maintained in the remaining treated areas and ample alternative (non-treated) 

habitat exists in all areas. In the long term, the Somes Bar Project is expected to have beneficial effects 

through restoration and protection of higher quality habitats. The project is consistent with the USFWS’s 

2011 Revised Recovery Plan for the Northern Spotted Owl (2011 Recovery Plan). Limited operating 

periods (LOPs) will be imposed to prevent noise and smoke disturbance during the peak breeding season.

The Somes Bar Project “may affect but is not likely to adversely affect” Critical Habitat for NSO due 

to removal and modification of primary constituent elements, although current functionality of the primary 

constituent elements will be maintained in the proposed treatment units. Temporary roads and landings will

remove scattered pockets of nesting, roosting and foraging habitat. In the long term, the Somes Bar Project

will have a beneficial effect on Critical Habitat through restoration and protection of higher quality 

habitats. The Somes Bar Project is consistent with the 2012 NSO Critical Habitat Rule (wildlife final BA 

pp. 82-83, final EA p. 206).

Botany

There are no occurrences of the federally listed endangered species within the project area (botany final 

BE/BA p. 3). Hence, there will be no effects (direct or indirect) from the Somes Bar Project to this species. 

Under §7 of the ESA, consultation with the USFWS is not required for “no effect” determinations.

Fisheries

The Fish BA/BE (biological assessment/biological evaluation) for the Somes Bar Project (Cyr 2017) 

contains a detailed analysis of effects and determinations on the following ESA-listed species, essential 

fish habitat (EFH), and Sensitive species.

Coho salmon

The Fish BA/BE analysis resulted in a Level 1 agreement on the determination of “may affect, not likely 

to adversely affect” coho salmon and its critical habitat due to a negligible potential for sediment to reach 
Finding of No Significant Impact

38 – Somes Bar Integrated Fire Management Project

occupied habitat through a combination of all actions. More importantly, the Fish BA/BE documenting 

the Somes Bar Project will result in key recovery actions being implemented on 5,570 acres of the MidKlamath population of coho salmon to reduce the risk of high-severity fire.

10. Whether the action threatens a violation of federal, state, or local law or requirements imposed for 

the protection of the environment.

The Somes Bar Project will not violate federal, state, and local laws or requirements for the protection of 

the environment. The action will not threaten a violation of any laws or requirements imposed for the 

protection of the environment. It is consistent with the National Forest Management Act, Endangered 

Species Act, National Environmental Policy Act, National Historic Preservation Act, Archaeological 

Resources Protection Act of 1979, Clean Water Act, Clean Air Act, Wild and Scenic Rivers Act, the 

Federal Highway Safety Act, and the California Porter Cologne Water Quality Act, and Executive Order 

12898. It is consistent with the Record of Decision for Amendments to Forest Service and Bureau of Land 

Management Planning Documents within the Range of the Northern Spotted Owl (April 1994) and the 

Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection 

Buffer, and other Mitigation Measures Standards and Guidelines (January 2001).

Aquatic Conservation Strategy

The Somes Bar Project was developed in alignment with the Aquatic Conservation Strategy (ACS) reflected 

in the Record of Decision (ROD), and S&Gs of the Northwest Forest Plan (NWFP; USDA and USDI 1994) 

as incorporated into the SRNF LRMP (USDA Forest Service 1995) and the KNF LRMP (USDA Forest 

Service 2010). The ACS outlines specific objectives regarding the forest goals in the management of aquatic 

and riparian resources (SRNF IV-107 and KNF 4-25). Project NEPA decisions must be consistent with the 

wording regarding ACS consistency, including consistency with the nine ACS objectives, as ACS 

consistency is described in the 1994 NWFP ROD on page B-10 and in the May 22, 2007 memorandum.

The implementation of the Somes Bar Project will not prevent attainment of ACS objectives at the

Hydrologic Unit Code (HUC) 6th and larger scales in the short-term, and promotes attainment of ACS 

objectives in the long term. Fuel treatments are in accord with recommendations in the Ishi Pishi 

Ecosystem Analysis (1998). Cumulative watershed effects (CWE) will remain below threshold for adverse 

watershed effects. Minimal disturbances are not expected to adversely affect anadromous fish and habitat,

as the implementation of project design features and mitigation measure will lower effects so they are 

negligible. The Somes Bar Project will maintain and help restore many of the HUC 6 sub-watershed 

indicators in the short term, and is expected to improve aquatic habitats and watershed conditions for fish 

populations in the Kennedy-Ti Creek and Irving-Reynolds Creek composite sub-watersheds, and in the 

lower mid-Klamath River in the long term (final EA pp. 227, 449).

Forest Service Sensitive Wildlife Species

The analysis of the Somes Bar Project impacts to Forest Service Sensitive species is required by FSM 

2670 through the preparation of a BE. All Forest Service Sensitive wildlife species known or thought to 

occur in the project area (based on habitat and range), were evaluated. It was determined the Somes Bar 
Finding of No Significant Impact

Decision Notice & Finding of No Significant Impact – 39

Project will have no impact on certain Forest Service Sensitive species, based on either the lack of 

habitat, lack of detections during surveys, or the fact that habitat will not be impacted. In addition, 

surveys and limited operating periods (LOPs) maybe applied as a mitigation to reduce the risk of 

impairing species’ reproduction (wildlife final BA p.80, final EA pp. 199-206).

Species that will not be affected by Somes Bar Project include greater sandhill crane, great gray owl, 

Siskiyou Mountains salamander, cascade frog, northern red-legged frog, Tehama chaparral snail and 

mardon skipper (final EA p. 198).

The Somes Bar Project may impact individuals, but is not likely to result in a trend towards federal 

listing for the following Forest Service sensitive species and/or habitat: bald eagle, northern goshawk, 

fisher, marten, wolverine, pallid bat, Townsend’s big-eared bat, fringed myotis, willow flycatcher, western 

bumblebee, foothill yellow-legged frog, southern torrent salamander, and western pond turtle. The BE 

prepared for the Somes Bar Project contains the affected environment for each species, description of 

indicators to base effects, as well as on the assumptions upon which the analysis was done (wildlife final 

BE pp. 82-83, final EA pp. 178-179).

Forest Service Sensitive Botanical Species

Sensitive species are those for which there is a concern for viability of the species based upon population 

trends or loss of habitat that will reduce the species existing distribution (USDA Forest Service 2005, 

FSM 2670.5). The Somes Bar Project was designed to not lead toward a loss of viability or a trend toward 

federal listing in compliance with KNF and SRNF forest plan direction, and disclosed in the BE (Hoover 

2017a). For Thermopsis robusta, implementation of the Somes Bar Project with the PDFs is not expected 

to have any negative direct or indirect effects to this species. For the other species considered, 

prescriptions that provide for retention of mature forest and their structure (i.e., partial canopy, coarse 

woody debris (CWD), pre-dominant trees, forest floor vegetation mosaics) coupled with PDFs associated 

with recent past, present and future projects are intended to reduce the possibility of direct effects to 

Sensitive species and mitigate significant indirect effects. In light of the inherent uncertainties about some 

Sensitive species, such as the extent of the underground network of fungal mycelia of Phaeocollybia 

olivaceae, the distribution of Sulcaria badia in the forest canopy, and the dormancy and dispersal of 

Cypripedium fasciculatum, the Somes Bar Project may affect individuals of a given sub-population, but is 

not likely to result in a trend toward federal listing or loss of species viability (botany final BE p. 20).

Forest Service Sensitive Aquatic Species

A BE was prepared for the Forest Service aquatic sensitive species located in the analysis area (see 

Region 5 list by Forest dated July 2015; Cyr 2018). The analysis resulted in a “may impact individuals 

but would not lead to a trend towards federal listing” for Upper Klamath Trinity River Chinook salmon, 

Klamath Mountain Province steelhead trout, as well as, Pacific and Klamath River lampreys. The slight 

risk of an insignificant amount of sediment reaching these species’ habitat is far outweighed by reducing 

the risk of high-severity wildfire and the potential impacts that will bring. The Somes Bar Project will

have no effect on western brook lamprey, California floater, pristine springsnail, and chace juga, as they 

are not located within the project boundaries (final EA p. 235).
Finding of No Significant Impact

40 – Somes Bar Integrated Fire Management Project

Magnuson-Stevens Fishery Conservation and Management Act

The Magnuson-Stevens Fishery Conservation and Management Act (MSA), as amended by the 

Sustainable Fisheries Act of 1996 (PL 104-267), requires federal agencies to consult with National 

Oceanic and Atmospheric Administration (NOAA) Fisheries on all actions and proposed actions 

authorized, funded or undertaken by the agency that may adversely affect EFH. All EFH assessments 

must include 1) a description of the Proposed Action; 2) an analysis of the effects, including cumulative 

effects of the Proposed Action on EFH, the managed species and associated species, including life history 

stages potentially affected; 3) the federal agency’s views regarding the effects of the action on the EFH; 

and 4) proposed mitigation, where applicable (50 CFR 600.920(g)(2)).The information prepared under a 

BA for formal or informal consultation under the ESA (50 CFR 402.12) may serve as the EFH 

assessment curtailing the need for separate analysis.

The effects to EFH related to the Somes Bar Project were analyzed using habitat data derived from 

available historical fish species inventories and habitat assessments on record at the Orleans/Ukonom 

Ranger District. The project will have no effect on Chinook or coho salmon EFH (final EA p. 235) and

meets ACS objectives of the Forest Plan.

Implementation Date

Implementation of this project is expected to take place from 2018 to 2033.

ELIZABETH A. BERGER Date

Acting Forest Supervisor

Six Rivers National Forest