Butcherknife/Slate Fuels Reduction Project Environmental Assessment

I. INTRODUCTION 

A. What is this Document About? 

The Forest Service prepared this Environmental Assessment (EA) for the Butcherknife/Slate 

Fuel Reduction Project to disclose pertinent environmental effects predicted to occur should the 

proposal be implemented. In preparing this report, an interdisciplinary team of resource management specialists worked to apply requirements and procedures mandated by the National 

Environmental Policy Act (NEPA, 42 U.S.C. §§ 4321-4347), and its implementing regulations 

(40 Code of Federal Regulations [CFR] Parts 1500 to 1508) and the Healthy Forests Restoration 

Act (HFRA)1

as well as those requirements established by allied Federal environmental laws and 

regulations. 

As its most fundamental function, this EA is intended to concisely present “sufficient evidence 

and analysis for determining whether to prepare an environmental impact statement [EIS] or a 

finding of no significant impact [40 CFR § 1508.9(a)(1)].” To fulfill that purpose, this assessment summarizes information and analysis that was assembled during the environmental review 

of this proposal. Overall, this report aims to provide the reader with an abridged account of the 

magnitude, duration and significance that predicted impacts would have upon salient resource 

values. In turn, the information presented on environmental effects should be adequate to decide 

whether proposed activities would be “significantly affecting the quality of the human environment [NEPA Section 102(2)(C)]” and, therefore, require preparation of an EIS. 

Discussions of four topics required for an EA are included in this report: the need for the proposal, alternatives as required by NEPA section 102(2)(E), the predicted environmental impacts 

of the Proposed Action and alternatives and a listing of agencies and persons consulted (40 CFR 

§ 1508.9(b)). Supplementary information, such as a description of existing conditions, is also 

included in this report to provide context for the environmental review. This EA is organized 

into five chapters, plus ancillary sections and an Analysis File, as follows: 

• Chapter I: Introduction: This chapter summarizes the Forest Service’s proposal and identifies the need compelling the agency’s attention and reasons for proposing action now. In addition, this section provides a brief review of respondent comments and reactions received 

during the earliest stage of project planning and public consultation. The questions or concerns that emerged from these early responses were used as a basis for identifying issues, 

shaping alternatives or identifying resource values that necessitate a thorough effects analysis. Finally, the choices and validations that form the responsible official’s decision frame 

are defined. 

 

1 Healthy Forests Restoration Act (HFRA) - The federal act of 2003 (P.L. 108-148) contains a variety of provisions to expedite 

hazardous fuel reduction projects on specific types of federal land that are at risk of wildland fire. Except for the act’s authorization to 

analyze fewer NEPA alternatives (Sections 104(c) and (d), most of the requirements of Section 104 are consistent with normal NEPA 

practices. Under HFRA, agencies are not expected to develop a full no-action alternative. Rather agencies are directed to evaluate 

the effects of failing to implement the project. 

4
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

• Chapter II: Affected Environment: Within this chapter is an overview of the current setting 

and existing forest environment within which the Proposed Action would occur. This section 

also identifies pertinent resource management direction that bounds the proposal within a 

pre-determined administrative setting, which in turn establishes the results to be achieved. 

• Chapter III: Proposed Action and Alternatives: The agency’s Proposed Action is explained 

here in detail, including the several activities that collectively form the proposal. Alternatives to the Proposed Action are identified as well. Also included here are mitigation measures and other specifications imbedded in the proposal that serve to reduce or avoid 

undesirable effects. 

• Chapter IV: Environmental Consequences: This Chapter summarizes the environmental 

effects of implementing the Proposed Action (and other alternatives). Under each resource 

heading, the No Action Alternative sometimes serves as a reference baseline for evaluation 

and comparison of the impacts presented for the Proposed Action. 

• Chapter V: EA Preparation and Consultation: This Chapter provides a list of preparers as 

well as the agencies and persons consulted during preparation of this environmental assessment. 

• References: This section compiles the sources of information used (literature citations, personal communications, reports, etc.) to prepare this EA.

• Analysis File: The Analysis File contains the documents, reports, data or other records that 

provide the details and support for the analyses summarized in this environmental assessment. For example, individual reports prepared by resource specialists (such as biological 

evaluations) are part of the Analysis File. The Analysis File is available upon request. 

B. National and Local Context for This Proposal 

Beginning in the 1990s, numerous reports of the destructive effects of catastrophic wildfire, 

particularly in the western States, increased the public’s awareness that millions of Federal forest 

and rangeland acres were considered at high risk of large-scale insect or disease epidemics and 

catastrophic fire. “While the increased risk of catastrophic wildland fire is often blamed on longterm drought or expansion of the wildland urban interface in the Western United States, one 

underlying cause is the buildup of forest fuel and changes in vegetation composition over the last 

century [USDA Forest Service and USDI Bureau of Land Management 2004],” primarily due to 

fire suppression and past timber harvesting. 

The severity of the problem was recognized by the U.S. Congress in 2001, which resulted in the 

funding of the National Fire Plan to facilitate efforts to preserve natural resources on public land 

(USDA Forest Service and USDI Bureau of Land Management 2001). In response, the Secretary 

of Agriculture and the Secretary of Interior, along with the western governors and other interested parties, developed A Collaborative Approach for Reducing Wildland Fire Risks to Communities and the Environment: 10-Year Strategy Implementation Plan to expedite hazardous fuel 

reduction projects. 

5
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

These plans, along with the 2001 Federal Wildland Fire Management Policy, were employed 

nationally. Policy makers became concerned as delays were leaving communities and homes at 

risk to wildfire, particularly those most vulnerable in the western States. Protecting communities 

and providing for firefighter and public safety are the first priorities of fire managers, and therefore, are a top priority for increasing options that can help restore low-severity fire2

 to the landscape. In 2002, Josephine County became intimately aware of these risks as the Biscuit Fire 

burned over 470,000 acres in Josephine and Curry Counties. 

In order to further expedite hazardous fuel reduction projects while upholding environmental 

standards, the Healthy Forests Restoration Act on December 3, 2003 ( P.L. 108-148) was signed 

into law. Environmental analysis requirements for HFRA projects direct managers to focus on 

the ecological processes that provide healthy, resilient ecosystems that support healthy human 

community. An ecosystem can be defined as simply a place where things live (Salwasser 1994) 

or in more detailed terms that relate the interaction of organisms and physical environment 

through a flow of energy (Bormann et al. 1994). Ecosystems contain components such as plants, 

vegetative communities and landforms and processes such as nutrient cycling. 

Another provision tied to HFRA provides for extensive pre-decisional public input during planning to minimize lengthy post-decisional appeal processes. Under these current policies, Federal 

agencies are encouraged to work in collaboration with at-risk communities3

 in setting priorities 

on lands in or adjacent to the wildland urban interface.4 Consequentially, beginning in 2002, the 

Wild Rivers Ranger District began community outreach efforts to develop hazardous fuel reduction priorities for National Forest System lands under the Forest Service’s jurisdiction. 

Concurrently, Josephine County officials directed the completion of the Josephine County Integrated Fire Plan (JCIFP). The goals of this community plan included developing “a wide array 

of strategies for fuel reduction and fire suppression that Josephine County residents can accept as 

sensible precautions against catastrophic fire and that the agencies that manage lands in 

Josephine County can incorporate into their current management practices [Program for 

Watershed and Community Health, University of Oregon, November, 2004].” 

The Josephine County Integrated Fire Plan was subsequently adopted in 2004 to help the County 

be successful in implementing fuel reduction projects, fire prevention education campaigns and 

other fire-related programs. The planning approach directly involved the county’s rural fire 

 

2 Low severity fire - Fire intensity and residence time linked to forest structures that limit the behavior of surface and crown fires and 

provide a fair degree of resistance to tree mortality. Fire intensity associated with the rate of above ground fuel consumption and, 

therefore the energy release rate (Albini 1976, Alexander 1982). Depth of burn is directly related to the duration or residence time of 

burning in woody fuels (Anderson 1969, Albini and Reinhardt 1995) and duff (Frandsen 1991, 1991b, Johnson and Miyanishi 2001). 

3 Under HFRA Section 101(1) - an at-risk community is one that is a wildland-urban interface community as defined in the Federal 

Register notice of January 4, 2001, or a group of homes and other structures with basic infrastructure and services (such as utilities 

and collectively maintained transportation routes) in or adjacent to Federally managed land. It has conditions conducive to a largescale fire and faces a significant threat to human life or property as a result of a wildland fire. The development density is usually three 

or more structures per acre, with shared municipal service. Also is defined as a community with a population density of 250 or more 

people per square mile (66 FR 753). 

4 The wildland-urban interface is the 1.5 mile area surrounding an at-risk community. 

6
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

protection districts as a way to reach citizens in the county. The plan assists the county in being 

more competitive for federal funding programs such as the Healthy Forests Restoration Act, the 

National Fire Plan and FEMA's Pre-Disaster Mitigation Program. Most of the Butcherknife/Slate Analysis Area is in the wildland urban interface as defined by JCIFP (Figure 1). 

Figure 1. Wildland urban interface within the analysis area. 

To Grants Pass

To Cave Jct 199

2500

2500

02 01

07 11

18

19

06

35 36

12

13

24

14

31

23

03

34

15

22

10 08

17

20

05

32

27 26 25 30 29

25 30 27 26 29

Slate Creek

Ramsey Creek

Waters Creek

Butcherknife Creek

Clear Creek

Bear Creek

Love Creek

Cove Creek

Cedar Log Creek

020

306

018

744

630

695

163

760

742

285

673

225

224

753

743

235

244

214

314

751

602

716

650

738

696

256

223

693

747

640

694

278

770

161

226

684

670

700

275

660

745

741

746

685

698

772

771

160

748

212

739

162

686

661

678

695

226

686

T360S

T360S

T370S

T370S

R070W

R070W

R080W

R080W

¬

This product is reproduced from information prepared by

the USDA, Forest Service or from other suppliers. The Forest

Service cannot assure the reliability or suitability of this

information for a particular purpose. The data and product accuracy

may vary due to compilation from various sources, including modeling

and interpretation, and may not meet National Map Accuracy Standards.

This information may be updated, corrected or otherwise modified

without notification. For more information contact: 

the Rogue River Siskiyou NF at 541-471-6500

The USDA is an equal opportunity provider and employer.

December 15, 2008

Legend

Rogue River Siskiyou NF

Butcherknife/Slate Project Boundary

Stream

Road

Private

WUI Area

Butcherknife/Slate

Wildland Urban Interface

Various local, state, and federal policies and programs have set precedence for the development 

of community fire plans. Most notably the National Fire Plan (2001) and the Healthy Forest 

Initiative (2003) mandate rural communities to assess risk and develop action plans. Below is a 

list of programs that relate to JCIFP. 

7
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

• Healthy Forests Restoration Act ( 2003) – Federal legislation to promote fuel reduction projects on federal land, community plans and biomass energy production 

• National Fire Plan and 10-Year Comprehensive Strategy (2001) – interagency plan that focuses on firefighting, rehabilitation, hazardous fuel reduction, community assistance and accountability. 

• Oregon Forestland-Urban Fire Protection Act (1997, SB360) – defines and identifies the 

wildland urban interface and provides standard measures of mitigation for homeowners. 

• Oregon Statewide Land Use Planning Goal 7 – directs local government to adopt plans for 

minimizing risk from natural hazards statewide. 

• Federal Emergency Management Agency Disaster Mitigation Act (2000) – specifies criteria 

for state and local hazard mitigation planning. 

• Josephine County Article 76: Wildfire Safety Standards – establishes requirements for development in wildfire hazard areas. 

The Healthy Forests Restoration Act, coupled with the National Fire Plan and JCIFP forms the 

fundamental framework for Federal agencies, State governments and communities to follow 

today. Pursuant to the provisions of Section 102(2) of NEPA (42 U.S.C. § 4332 (2)), the 

Forest Service is analyzing the Butcherknife/Slate proposal as an authorized hazardous 

fuel project under HFRA. Therefore, the Butcherknife/Slate proposal is subject to the 

objection procedure at 36 CFR part 218 in lieu of the appeal process at 36 CFR part 215. 

This project aims to complement strategic multi-governmental “borderless” fuel reduction efforts 

via the application of various time-tested and adaptive prescribed fire and thinning methods (e.g., 

brush and tree density management). The Proposed Action is designed to implement the recommendations as described in the Josephine County Integrated Fire Plan regarding the general 

location and basic method of treatments. 

As the Butcherknife/Slate proposal is located within the Applegate Adaptive Management Area 

(AMA), opportunities exist to learn by experimenting with and planning innovative fuel reduction approaches. The Applegate AMA is a 277,500-acre federally-administered landscape unit in 

southern Oregon designated to encourage the development and testing of technical and social 

approaches to achieve desired ecological, economic and other social objectives. The overarching 

objective is to learn how to conduct ecosystem management5

 in terms of both technical and social questions in a manner consistent with applicable laws. 

Unique from the other nine delineated AMAs in Oregon and Washington, the Applegate AMA 

focuses on the development and testing of forest management practices, including prescribed 

fire, partial cutting and low impact approaches to forest harvest. It is hoped that localized, idiosyncratic approaches that may achieve conservation objectives can be pursued. Adaptive management relies on the experience and ingenuity of resource managers and communities rather 

than on traditionally derived and tightly prescriptive approaches that are generally applied in 

management of forests. 

 

5 Ecosystem management – A strategy or plan to manage ecosystems to provide for all associated organisms, as opposed to a 

strategy or plan for managing individual species. It moves the focus from individual ecosystem parts such as timber, water, range, 

fish, and wilderness, to how the parts fit together and function as a whole (Bormann and others 1994). 

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 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

C. Briefly, What is Proposed? 

Under authorities made available by the Healthy Forest Restoration Act, the Wild Rivers Ranger 

District is proposing to reduce the risk of unnatural, intense wildfires by thinning (commercial 

and precommercial) high density stands, reducing existing and generated fuels, maintaining 

and/or restoring meadows, pine/oak savannahs, black/white oak, ponderosa and sugar pine, etc. 

and conducting various watershed maintenance or improvement projects (riparian and wildlife 

habitat, noxious weed control, etc.) in the upper Butcherknife Creek and Slate Creek watersheds. 

The analysis area encompasses 5,834 acres of National Forest System lands situated west of 

Wonder/Wilderville and north of Selma, Oregon. All proposed vegetation treatment areas are 

within the wildland urban interface (WUI) of the at-risk community of Wonder/Wilderville. 

Fuel reduction activities, including pruning (ladder fuel reduction), understory thinning, piling 

and understory burning, would be conducted in a variety of forest and other vegetation types, 

including selected riparian areas. The treatment activities are proposed for implementation over 

the next 10 to 15-year period. 

There is a critical need for widespread restoration of lower fuel amounts across the West. Yet 

fuels come in all shapes, sizes, and arrangements. There are live and dead fuels, herb and shrub 

fuels, litter, twigs and branches, ladder fuels (small trees), and canopy fuels (larger trees). A fuel 

reduction treatment might address any or all of these fuels, but depending on which are targeted, 

the treatment may not be relevant to either the easier suppression of unwanted wildfires, or the 

ability of the forest to sustain itself in the presence of wildfire (Agee and Skinner 2005). 

A set of “fire-safe principles” has been described by Agee and Skinner (2005) and is reproduced 

in Table 1. Forest vegetation treated using these principles is likely to be more resilient to wildfires. The principles are based on what is currently known about crown fire. 

Table 1. Principles of Fire Resistance for Dry Forests 

Principal Effect Advantage Concern 

Reduce surface 

fuel 

Reduces potential 

flame length 

Control easier, less 

torching 

May not fully achieve 

objectives 

Increase height to 

live crown 

Requires longer flame 

length to begin torching 

Less torching Opens understory; may 

allow surface wind to 

increase 

Decrease crown 

density 

Makes tree-to-tree 

crown fire less 

probable 

Reduces crown fire 

potential 

Surface wind may 

increase and surface fuel 

may be drier 

Keep big trees of 

fire resistant 

species 

Less mortality for same 

fire intensity 

Generally restores 

historic structure 

Less economical; may 

keep trees at risk of 

insect attack 

Note: Torching is the initiation of crown fire 

(adapted from Agee 2002; Hessburg and Agee 2003) 

9
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

Crown fires occur when surface fires create enough energy to preheat and combust live fuels 

well above the ground. There are two stages to the crown fire process: the initiation of crown 

fire activity, known as “torching”, and the process of active crown fire spread, where fire moves 

from tree crown to tree crown (Van Wagner 1977, Agee et al. 2000). 

First, surface fire behavior must be controlled, so that treatments should either reduce such potential behavior or at least not contribute to increased fire behavior. Because such treatments 

often open the understory so that midflame windspeed will increase and fine fuel moisture will 

decline (van Wagtendonk 1996, Weatherspoon 1996), maintaining no change in surface fire 

behavior generally requires a reduction in surface fuels or significant greenup of grasses and low 

shrubs (Agee et al. 2002). 

Second, a reduction in torching potential requires a comparison of potential surface fire flame 

length with a critical flame length, which is a function of canopy base height. At best, a reduction in potential surface fire behavior plus an increase in canopy base height will minimize torching potential. 

Third, reduction in potential active crown fire spread can be accomplished by a reduction in 

canopy bulk density. Where thinning is followed by sufficient treatment of surface fuels, the 

overall reduction in expected fire behavior and fire severity usually outweigh the changes in fire 

weather factors such as wind speed and fuel moisture (Weatherspoon 1996). 

The fourth principle in a fire resilient forest strategy for the short-term is to keep the largest trees 

in the stand if they are present. These are the most fire-resistant trees in the stand, as they have 

the tallest crowns and thickest bark (Peterson and Ryan, 1986). In the longer term (beyond the 

life of this project), provision must be made for sufficient spatial variation in age classes to provide for replacement of the larger trees as they die. 

Proposed activities include mechanically thinning from below overdense managed and natural 

forest stands (which may include commercial log removal), precommercial thinning in sapling/pole stands, slashing, pile and/or broadcast burning within the understory of forest stands, 

erosion control and drainage improvement on forest roads and forest road closures. Mechanical 

thins and slashing operations (both commercial and precommercial) combined with use of fire is 

proposed on approximately 2,500 acres and use of prescribed fire only is proposed on an additional 2,500 acres. 

D. The Need for This Proposal (Why These Areas? Why Now?) 

All of the land use allocations overlapping with proposed treatment stands are already established by the Siskiyou National Forest Land and Resource Management Plan (USDA Forest 

Service 1989b), as updated by Forest amendments and by the Record of Decision (ROD) for 

Amendments to Forest Service and Bureau of Land Management Planning Documents within the 

Range of the Northern Spotted Owl (commonly cited as the Northwest Forest Plan, NFP, 

USDA/USDI 1994b). 

10
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

Moreover, the environmental consequences that were anticipated from implementation of the 

land and resource allocations are described in the Siskiyou National Forest Final Environmental 

Impact Statement for the Land and Resource Management Plan (USDA Forest Service 1989a) 

and the Final Supplemental Environmental Impact Statement on Management of Habitat for 

Late-successional and Old-growth Forest Related Species within the Range of the Northern 

Spotted Owl (USDA/USDI 1994a). Thus, this EA is tiered to those preceding EIS’s and incorporates by reference the discussions of impacts they contain (Reader Note: Any of the documents 

cited above are available at any Rogue River – Siskiyou National Forest office). 

In addition, several other documents, incorporated by reference, contain pertinent information for 

this analysis. The Roads Analysis for the Rogue River-Siskiyou National Forest (2004) discusses the list of opportunities to reduce road maintenance costs and environmental impacts by 

road decommissioning and by reducing road maintenance levels to closed roads (level 1). The 

Applegate Adaptive Management Area Guide (USDA Forest Service and USDI Bureau of Land 

Management 1998) describes the goals and approaches, objectives, setting, and challenges in the 

watershed. Words into Action: A Community Assessment of the Applegate Valley (1994) presents a social and economic overview of the Applegate Valley, including the Slate Creek 

neighborhood. 

The Chaney - Slate Watershed Analysis (1996) contains pertinent scientific information and 

inventories and recommendations for fuel reduction, vegetation, fisheries, and other resources 

associated with the Butcher Knife Slate project area. The Applegate River Watershed Assessment (USDA Forest Service and USDI Bureau of Land Management 1995) recommends the 

restoration of oak woodlands and pine plant series, the use of low intensity fires to restore oak 

woodlands and pine sites, the decrease in density of appropriate forest stands by thinning or 

judicious use of fire, and concentrate management activities in reforestation, young and mid seral 

stands to promote their development into mature/late-successional forest and encourage vegetation species diversity. Finally, the Applegate Adaptive Management Area Ecosystem Health 

Assessment (USDA Forest Service and USDI Bureau of Land Management 1994) gives the rationale and recommendations for density reduction of trees, moving forested landscapes toward 

dominance by larger, older trees, and reducing risk of fire and insect outbreaks. 

Attainment of Land and Resource Management Plan (LRMP, USDA Forest Service 1989b) 

objectives and outcomes are, for most characteristics defined, wholly dependent on the condition 

and succession of forests (or other vegetation assemblages) within the allocation. At the same 

time, individual forest stands within a LRMP allocation nearly always vary greatly in average 

tree age, species composition, number of canopy layers, amount of bole or crown defects and 

basal area (to name just a few key attributes of stand character). Thus, the contribution of each 

stand to the management goal(s), outcome(s) and desired future condition(s) within an allocation 

differs because of a stand’s individual character. Certainly, too, a stand’s contribution may 

change over time in relation to surrounding or internal conditions. The existing conditions of 

forest stands within the analysis area are described next. 

Fire Risk/Fuel Hazard: Since the early to mid 1900's, when wildfires began to be aggressively 

controlled, fire has not played its natural role in local forest stands. Based on a draft fire regime 

map for the Siskiyou National Forest, the Clear Creek, Butcherknife Creek, Ramsey Creek and 

11
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

Slate Creek watersheds are identified as having a combination of Fire Regime I (0-35 years, low 

severity) and Fire Regime IIIA (less than 50 years, mixed severity) areas. (Note: A ‘fire regime’ 

is an assigned categorization of historical wildfire activity. It has two components (1) frequency 

of occurrence (e.g. average number of years between fire occurrences) and (2) ‘severity’ (e.g., 

how significant of an effect did fire have on existing vegetation/soils/etc.). Because of the proximity of the analysis area to the drier valley floor, it is likely that this area experienced fire even 

more frequently than this map indicates (possibly a 15 to 25-year return interval). Regardless, 

historically, this area was likely subject to frequent, generally low intensity, wildfire. 

These frequent, low intensity fires would have consumed down fuel, killed small trees, reduced 

the presence of brush and hardwood tree vegetation, killed the lower branches on trees, stimulated or maintained grass/forbs in meadows and the forest understory, and generally reduced 

forest stand densities by killing individual or clumps of trees. These fires likely tended to maintain forest stands that consisted of large diameter but relatively wide spaced trees (20-50 trees 

per acre) with a relatively open understory with little ladder fuel. Dominant species were probably sugar pine, ponderosa pine and Jeffery pine, with some Douglas-fir, black oak, Pacific madrone and tanoak. Grass/forbs and needle/leaf litter likely dominated surface fuels. Large down 

logs were probably limited in number. Non-serpentine meadows would have tended to be larger 

and the Jeffery pine/oak savannah serpentine meadows might have contained fewer, more widely 

spaced trees and a less continuous shrub layer. Such serpentine meadows were likely better 

habitat than currently for certain dependent plant and animal species. 

According to Siskiyou fire history records since 1970 (38 years), this analysis area has had 16 

wildfires of which 11 (69%) were human-caused and 5 (31%) were lightening fires. All of these 

fires were less than 3 acres apparently because of prompt fire suppression. The largest fire occurred prior to our computer records and was a 162-acre human-caused fire in 1959. This number of fires close to residential areas is a cause for concern regarding people safety. 

Because of wildfire exclusion, these forest stands have undergone ecological succession without 

the benefit of this primary change (disturbance) agent. Un-thinned portions of the proposed 

treatment area and all of the surrounding watersheds have denser vegetation than likely existed in 

these forests prior to European settlement. This increase in the density of vegetation also increases tree-to-tree moisture stress and competition for light. This, in turn, results in lower tree 

vigor and the susceptibility of conifer trees (particularly pines) to bark beetle attacks. The usual 

result is increased tree mortality and higher amounts of standing and down dead fuel. Low 

growing plants such as forbs and grass are decreasing as the tree canopy closes. The amount of 

brush, hardwood trees such as tanoak, and Douglas-fir, as well as the quantity of ground and 

ladder fuel, is very high. In addition, the number of shade intolerant species such as pine or 

black oak is decreasing as a result of increased mortality from overcrowding and insects/disease. 

In turn, this mortality is increasing the amount of standing and down dead wood. 

This unnaturally dense vegetation could fuel a high intensity wildfire that would consume most 

ground fuel, including smaller trees, shrubs, down woody debris, and kill even the large trees. 

Moreover, under hot and windy weather conditions, there is a substantial likelihood that such a 

high intensity surface fire could move into the tree crowns and create a crown fire that would kill 

even the largest trees. Under worst-case burning conditions, such fires could cause 90 to 100 

12
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

percent mortality of all vegetation present. Obviously, successful suppression of such a large 

wildfire would be very difficult, if not impossible to accomplish, and would likely be very costly. 

Such a wildfire would also pose a serious threat to nearby private homes and property as well as 

to resource values within these or adjacent watersheds. Such high intensity wildfires could send 

burning embers hundreds if not thousands of feet out from the edge of the fire. Ignition of new 

fires from these embers could trap Ramsey/Slate Creek residents who have only one route of 

ingress/egress to their property (Slate Creek Road # 3690). If fire should cut off vehicle egress, 

residents would be trapped with their only option being escape on foot. 

Based on observations of current vegetative conditions compared with expected conditions under 

an un-modified fire regime, this project area is considered a Condition Class 3 in that multiple 

fire cycles of 15 to 25 years have been missed. 

Vegetation: This area has a diverse assortment of tree species as well as various low growing 

plants including shrubs, grass, forbs, etc. The primary conifer tree species include Douglas-fir, 

sugar pine, ponderosa pine, Jeffery pine, incense cedar, with occasional representatives of Pacific 

yew, white fir and Port-Orford-cedar. The primary hardwood tree species include Pacific madrone, tanoak, California black oak, canyon live oak, golden chinquapin, California-laurel with 

occasional representatives of Oregon white oak, bigleaf maple and red alder. The primary brush 

species include manzanita, wedge-leaf ceanothus, buckbrush and deerbrush. 

Many stands with low average diameters (less than 12 inches) contain scattered 30”+ diameter 

individuals or clumps of individuals (1-5 trees per acre) from the previous generation. Average, 

current, conifer tree diameter growth rates are slow (generally .07-.12 inches per year) and trees 

per acre excessive (1,000-25,000 stems per acre). The average stand tree diameter (of stems over 

3” DBH) is approximately 9.3 inches diameter at breast height (DBH). Basal area ranges from 

approximately 125-300 sq ft/acre. 

As previously indicated, fire, the primary disturbance agent for this area, has been absent from 

these stands for a significant portion of this century. As a result, these stands have become 

overly dense which has resulted in a significant slowing of tree growth, reduced individual tree 

vigor, and increases in competition-induced mortality and insect/disease problems. Diameter 

growth slows as the tree crowns close and individual tree crowns compete for sunlight. As the 

amount of light available to individual tree crowns decreases, the affected crowns shorten (‘recede’) and less photosynthetic surface (green needles) is available for the tree to produce food. 

As a result, the vigor of the tree further deteriorates in a continuing cycle. The ultimate result is 

that those trees that do not compete well with other trees either die or become more and more 

unhealthy and more susceptible to mortality caused by either disease pathogens or insects because they lack the resources to ‘fight off’ these agents. Certain species such as ponderosa and 

sugar pine and black and white oak have particularly been impacted because they are very susceptible to high-density conditions, which are resulting in the loss of larger (size) examples of 

these species. These species generally do best in more open-grown conditions. 

13
 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

Re-sprouting hardwoods such as tanoak are now more significant components of these stands 

because of the loss of periodic, low intensity, fire. Frequent, low intensity fires would tend to 

suppress development of significant areas of re-sprouting hardwoods (such as tanoak) while 

favoring species less susceptible to fire such as pine. 

Wildlife Habitat: The lack of periodic, low intensity, wildfire has generally resulted in dense 

canopy conditions with a general lack of openings (e.g. low vegetative density conditions). This 

has benefited certain species that prefer closed canopy conditions (such as the northern spotted 

owl) but has negatively affected other species such as the sooty grouse that prefer more open 

stand conditions. This increased density is also affecting historically open areas such as pine/oak 

savannahs where conifer, hardwood, and shrubs encroachment is reducing the size of such areas 

and the abundance of species dependent on such areas. 

The need for this project, therefore, stems from this increased vegetative density, which has 

reduced tree growth rates and vigor, increased mortality of tree species such as sugar and 

ponderosa pine and black and white oak, reduced the numbers of 30-inch and larger diameter trees, reduced the amount of open habitat conditions and species dependent on 

such, and increased fuel loading and ladder fuel. The slow growth rate is not enabling the 

rapid replacement of large diameter trees that succumb to vegetative competition or insect/ 

diseases. Low-density stand conditions which were historically more prevalent in this area are 

not being re-established because of the lack of fire or other stand disturbances. This is resulting 

in the loss of species (both plant and animal) dependent on such conditions. The high vegetative 

density condition increases the potential for this area to experience a high intensity wildfire. The 

proximity of homes in and near this area and the fact that many have only one-way ingress/egress makes treatment of this and adjacent areas a priority. 

E. Are there Significant Issues Related to this Proposal? 

As mandated at 40 CFR § 1500.1(b), Forest Service “NEPA documents must concentrate on the 

issues that are truly significant to the action in question, rather than amassing needless detail.” 

Further, the Federal agency that is conducting an ‘environmental analysis’ must “[i]dentify and 

eliminate from detailed Analysis the issues which are not significant or which have been covered 

by prior environmental review [40 CFR § 1501.7(3)].” 

In late 2007, preliminary information about this fuel reduction/forest restoration proposal was 

distributed locally. As part of this initial phase of environmental analysis, termed “scoping [40 

CFR § 1501.7],” we requested feedback on our proposal, including asking for help in identifying 

concerns, comments and viewpoints on proposed actions and objectives. We initiated scoping 

with a letter (dated November 2) that invited comments to our early concept of the proposed 

action. Shortly thereafter, on December 12, we also published a legal advertisement in the 

Grants Pass Daily Courier to announce the project proposal and to invite feedback. Then, as a 

wrap-up to the scoping process, we sent a news release on January 9, 2008 to local newspapers 

announcing an open invitation to attend a meeting and field tour scheduled for January 24. The 

Daily Courier printed the notice on January 22 for this meeting/field tour. Approximately 32 

people attended this event, which was held as scheduled, and two proposed treatment stands 

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 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

were visited in the afternoon. Because of the scoping completed through the request letter and 

the field tour, a number of replies were received by the end of August, 2008. 

Among the respondents who sent seven written replies to our scoping request, all expressed 

complete support, conditional endorsement or “agreement” with regard to implementing the 

proposal. Nonetheless, most respondents did explain one or several ideas regarding the design of 

the project. For example, the value of providing shade for streams, keeping or creating snags, 

the benefits of revenue from utilization of wood and other resources, the length and location (or 

seasonal use) of roads needed to accomplish the work, and the use of understory burning or particular activity fuel treatments all were topics where one or more commenters offered specific 

perspectives on what should be planned. 

In addition, many respondents shared advice and preferences for the how-to of conducting the 

project. Commenters 1), recommended specific kinds of administrative tools for completing the 

work (for example, “stewardship/community contracting” or use of Healthy Forests Restoration 

Act authorities), 2), preferred particular forestry methods or approaches (e.g., “variable spacing,” 

“low impact” yarding systems, “legacy pine retention,” “mechanical treatment,” leaving 10 percent or more of slash piles unburned for wildlife habitat, etc.) for use in carrying out the project, 

or 3), advocated a particular set of features or results for emphasis within the proposal or a particular allocation (minimizing seasonal restrictions, decreasing road “density,” restricting use of 

helicopter yarding, building roads as needed for resource protection and economic viability, etc.). 

These comments resulted in design and mitigation measures for the Proposed Action. 

In November 2008, a commenter from Grangeville, Idaho, sent us a statement expressing his 

belief that scientists have shown logging commercial-sized trees increases wildfire intensity. In 

his statement, the respondent excerpted quotes from numerous source documents to support his 

assertion and included those references and opinion articles with his statement (see Analysis 

File). We read each of the papers that were sent to us to understand the basis for the presented 

premise. Then, we compiled our thoughts about the excerpted quotes and each of the papers 

offered. Our reactions and comments to the supplied documents and commentaries are summarized in a separate paper, which is included in the Analysis File. 

 

Our conclusion after reading the papers is this: we find the assertion that scientists have shown 

logging commercial-sized trees increases wildfire intensity is unsupported by the information 

reviewed, especially when logging slash and excess woody debris is appropriately treated to 

decrease fuel quantities. No science evidence from peer-reviewed research was presented that 

suggests that proposed treatments or objectives defined for the Butcherknife/Slate project are 

contrary to the science data available regarding fuel treatments in the wildland urban interface. 

Moreover, the quotes presented are not a reflection of the site-specific activities included in the 

Butcherknife/Slate proposal and are inconsistent with the actual mitigation measures included in 

the Proposed Action. Nonetheless, we considered an alternative that would have excluded cutting of commercial-sized trees and then removing them from overdense treatment stands (logging), as discussed briefly in Chapter II under “Are There Alternatives to the Proposed Action?” 

Among all commenters who sent us a response for this proposal, however, none of those submitting comments asserted the existence of an “unresolved conflict concerning alternative uses of 

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 Butcherknife/Slate Fuels Reduction Project Environmental Assessment

available resources [NEPA Section 102(2)(E)].” Similarly, no irreversible or irretrievable commitments of resources were identified as a concern in connection with implementation of the 

proposal. As well, no respondent postulated that long-term productivity would be exchanged for 

short-term use of the environment as a consequence of implementing the proposal. Indeed, no 

conflict was identified between what is proposed and another possible use or result for the forest 

resources in question. Moreover, Forest Service resource specialists did not uncover evidence 

during their field inspections that suggest or expose a significant environmental issue. Therefore, after considering the scoping feedback and our own examinations of proposed treatment 

stands, we do not identify any significant issues linked to the proposal at hand. 

This discussion and results were shared with the Josephine County Stewardship Committee, a 

local body chartered by Josephine County that represents a broad range of environmental groups, 

local industry, local citizens and county planners. They supported the HFRA process for this 

planning effort and our conclusion that only one action alternative needed to be developed. 

The Decision Maker did request that indicators of effects of implementation be included in the 

document to ensure an informed decision can be made. Some of those effects are the acres of 

fuel treatment, the miles of road decommissioned or built, slope stability, detrimental soils effects, watershed effects, impacts to Gentner’s fritillary, clustered lady slippers, Mendocino gentian, stipuled trefoil, invasive plant species, Chinook and coho salmon, the northern spotted owl, 

existing owl core areas and the interactions between the northern spotted owl and barred owl. 

F. Decision Framework 

Joel T. King, District Ranger for the Wild Rivers Ranger District, is the responsible official for 

this project. He will make a finding regarding environmental impacts connected with the Proposed Action and will also decide whether to implement proposed treatments within proposed 

treatment units, based upon this environmental assessment and other pertinent findings. 

The decision to authorize the Butcherknife/Slate Hazardous Fuel Reduction Project has two 

essential components. The primary decision to be made is whether this proposal represents a 

“major Federal action significantly affecting the quality of the human environment [NEPA Section 102(2)(C)].” Should the District Ranger decide the Proposed Action is a “major Federal 

action...,” then impacts must be documented in an EIS. Conversely, should the District Ranger 

determine that the environmental impacts reported here are not sufficient to significantly affect 

the human environment, and therefore that an EIS is not needed (40 CFR §§ 1501.4(b) and (c)), 

then a “finding of no significant impact [FONSI, 40 CFR §§ 1501.4(e) and 1508.13]” would be 

issued and the project could be implemented without further environmental review. 

Secondly, this proposal must be found to be consistent and/or compliant with statutes, regulations, higher-order plans (LRMP, Northwest Forest Plan) and other binding direction relating to 

administration of national forest lands prior to authorizing implementation. This decision 

framework, then, is directly tied to decisions previously analyzed and made legally binding upon 

the agency by the Siskiyou National Forest LRMP (USDA Forest Service 1989b) and the NFP

(USDA/USDI 1994b). 

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