United States Department of Agriculture

Final Environmental Impact Statement

for the Malheur, Umatilla, and Wallowa-Whitman

National Forests Land Management Plans

Volume 3: Chapter 4, Glossary, and References

Forest Service Pacific Northwest Region 2018
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contact the Wallowa-Whitman National Forest at (541) 523-1264.
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Contents of Volume 3

Chapter 4. Public, Governmental and Tribal Involvement; List of Preparers; and Distribution of the 

Environmental Impact Statement............................................................................................................ 1

Public Involvement ..................................................................................................................... 1

Involvement with Native American Tribes and Federal, State, and Local Agencies and 

Governments............................................................................................................................... 5

Tribes....................................................................................................................................... 5

States ....................................................................................................................................... 6

Counties................................................................................................................................... 7

Federal Agencies..................................................................................................................... 8

Consistency with Government Planning and Land-Use Policies............................................ 8

Comment Letters from Native American Tribes and Federal, State, and Local Agencies and 

Governments ......................................................................................................................... 27

Preparers and Contributors...................................................................................................... 233

Distribution of the Final Environmental Impact Statement .................................................... 237

Glossary and Acronyms...................................................................................................................... 239

References........................................................................................................................................... 297

Contents of Volume 1:

Preface

Chapter 1. Introduction and Background

Introduction 

Purpose and Need

The Proposed Action

Decisions to be Made

Environmental and Regulatory Compliance

Other Guidance

Public Involvement

Issues and Key Indicators

Chapter 2. Alternatives, Including the Modified Proposed Action

Developing the Alternatives

Description and Comparison of the Alternatives

Elements Common to the Plan Revision Alternatives

Alternative A: No-action Alternative

Alternative B: The Modified Proposed Action

Alternative C

Alternative D

Alternative E

Alternative E-Modified

Alternative E-Modified Departure

Alternative F

Description of Alternatives Considered but Eliminated from Detailed Study

Comparison of Alternatives
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Contents

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Chapter 3. Affected Environment and Environmental Consequences (first half)

Introduction

Consideration of Climate Change

Significant Issues

Issue 1: Access

Issue 2: Economic and Social Well-being

Issue 3: Livestock Grazing and Grazing Land Vegetation

Issue 4: Old Forest

Issue 5: Preliminary Administratively Recommended Additions to the National Wilderness 

Preservation System

Issue 6: Ecological Resilience

Physical Environment

Soils

Air Quality

Watershed Function, Water Quality, and Water Uses

Index

Contents of Volume 2:

Chapter 3. Affected Environment and Environmental Consequences (continued)

Biological Environment

Aquatic Species Diversity and Viability

Forest Vegetation

Timber and Forest Products

Wildland Fire

Insects and Diseases

Terrestrial Wildlife Species

Plant Species Diversity and Threatened, Endangered, and Sensitive Plants

Nonnative Invasive Species

Social Environment

Tribal and Treaty Resources

Recreation

Special Areas

Scenery Resources

Heritage Program

Geology, Mining, Minerals, and Energy

Index

Contents of Volume 4:

Appendix A: Forest Plan Revision Alternatives in Detail

Appendix B: Laws and Regulations Relevant to Forest Planning

Appendix C: Response to Concern Statements

Appendix D: Wild and Scenic Rivers

Appendix E: Wilderness Evaluation

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Appendix G: Maps
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Chapter 4. Public, Governmental and Tribal

Involvement; List of Preparers; and Distribution 

of the Environmental Impact Statement

The Forest Service facilitated broad public and intergovernmental participation in the plan 

revision process. Below is a summary of Forest Service efforts to consider the interests of the 

public, Tribes, States, counties, and Federal agencies.

Public Involvement

Public involvement is a critical element of the Forest Plan revision process. The interdisciplinary 

team provided a variety of opportunities for people to learn about the Forest Plans and participate 

in the planning process. The team provided informational products including factsheets, 

newsletters, open letters, presentation slides, and annotated maps. Information was shared 

electronically via the project website (fs.usda.gov/goto/BlueMountainsPlanRevision) and also 

through other modes of communication including email, hardcopy mail, news releases, news 

media interviews, public conference calls, webinars, and public meetings. Additionally, Forest 

Service officials held or attended public meetings in Oregon, Washington, and Idaho. During inperson meetings, staff provided verbal, visual, and written information about the Forest Plans. 

Live meetings and conference calls allowed participants to ask questions and hear answers in real

time. Individuals and organizations sought further clarification via emails, letters, and phone 

calls. (Lists of individuals, organizations, officials, and others who contacted the Forest Service 

during the planning process are filed in the planning record.)

The planning interdisciplinary team and staff from the Blue Mountains national forests provided 

the following opportunities for public involvement:

1. Pre-scoping public meetings, workshops, and field trips

2. Scoping: notice of intent in the Federal Register, public meetings, and comment 

period

3. Draft Environmental Impact Statement alternative-development meetings

4. Publication of the Draft Environmental Impact Statement and subsequent public 

meetings during the formal comment period

5. Public “reengagement” meetings following the formal Draft Environmental Impact 

Statement comment period

6. Continuing communications through newsletters and conference calls

7. Publication of the Final Environmental Impact Statement and objection period

Prior to the formal scoping period, the planning interdisciplinary team and staff from the Blue 

Mountains national forests organized numerous public meetings, workshops, and field trips to 

gather input on the planning process. The planning team published its notice of intent to prepare a 

draft environmental impact statement in the Federal Register on March 29, 2010 (FR, Vol. 75, 

No. 59). The notice asked for written public comment on the proposal by May 25, 2010. During 

the scoping comment period, the planning team held additional public meetings in several 

locations in Oregon and Washington. In response, the Forest Service received 4,174 total 

responses to the request for comment, which included 110 unique comment letters and 4,025 
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organized form letters. The content analysis of the comments received is located in the planning

record. Following the scoping period, the Forest Service held alternative-development meetings 

with a variety of organizations: advisory committees, collaborative groups, counties, industry 

representatives, and interest groups. Details are available in the planning record.

Table 418. Forest Service public meetings held before, during, and after the formal scoping period

Year Type of Meeting

No. of 

Meetings Locations

2004 Community Workshops

(vision and desired conditions 

discussions) 

20 La Grande, Enterprise, Baker City, Pendleton, 

Heppner, John Day, Burns, Portland, Oregon;

Dayton and Pasco, Washington

2004 Co-convener Meetings* 5 La Grande and Baker City, Oregon

2005 Community Workshops

(special designations, wild 

and scenic rivers, wilderness 

areas, and management 

areas discussion)

11 La Grande, Enterprise, Baker City, Pendleton, 

Heppner, John Day, Burns, Portland, and 

Milton-Freewater, Oregon; Dayton, and Pasco, 

Washington

2005 Field Trips 3 Malheur, Wallowa-Whitman, Umatilla National 

Forests

2005 Co-convener Meetings 6 La Grande and Baker City, Oregon

2006 Economic Workshops 2 La Grande and Baker City, Oregon

2006 Open Houses

(to discuss strategies to 

achieve desired conditions)

7 La Grande, Enterprise, Pendleton, John Day, 

Burns, Sandy, Oregon and Dayton, Washington

2006 Co-convener Meetings 1 La Grande, Oregon

2008 Co-convener Meetings 2 La Grande, Oregon

2009 Co-convener Meetings 1 La Grande, Oregon

2010 Co-convener Meetings 2 La Grande, Oregon

2010 Public Meetings, Oregon 8 John Day, Burns, Pendleton, Heppner, Baker 

City, La Grande, Joseph, Portland

2010 Public Meetings, Washington 2 Dayton and Pasco

2011 Co-convener Meetings 3 La Grande, Oregon

2012 Co-convener Meetings 1 Baker City, Oregon

2013 Co-convener Meetings 1 Baker City, Oregon

* Co-convener meetings refers to meetings between the Blue Mountains forest plan revision team and representatives of 

the area counties, resource advisory committee members, Tribal representatives, and the State of Oregon.

2014 Public Meetings

In February 2014 the Forest Service published the Blue Mountains Proposed Revised Land 

Management Plan (Draft Forest Plan) and Draft Environmental Impact Statement. From March 

through June 2014, the three National Forests hosted 14 public meetings and a webinar to provide 

information about the documents, explain the formal public comment process, answer questions, 

and listen to public input. The notes taken at these meetings and the materials presented are 

available on the Blue Mountains Forest Plans website1 and also filed in the planning record.

 1 https://www.fs.usda.gov/detail/wallowa-whitman/landmanagement/planning/?cid=stelprdb5247447
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March 17, 2014: John Day Comment Session

March 18, 2014: Burns Comment Session

March 19, 2014: Long Creek Comment Session

March 20, 2014: Enterprise Comment Session

March 25, 2014: Baker City Comment Session

March 26, 2014: La Grande Comment Session

March 27, 2014: Halfway Comment Session

March 31, 2014: Portland Comment Session

April 1, 2014: Pendleton Comment Session

April 2, 2014: Heppner Comment Session

April 3, 2014: Dayton Comment Session

April 4, 2014: Kennewick Comment Session

April 9, 2014: Clarkston Comment Session

April 10, 2014: Ontario Comment Session

May 1, 2014: Unity Comment Session

June 25, 2014: Access and Wilderness Public 

Webinar

2015-2017 Public Involvement Efforts

Following the extended formal comment period in 2014, the interdisciplinary team and Blue 

Mountains national forests worked with communities and stakeholders to identify three topics for 

further discussion: pace and scale of restoration, access and wilderness, and livestock grazing. 

From June 2015 through February 2016, the Forest Service scheduled a series of public listening 

sessions, which were professionally facilitated to ensure that every participant had time to speak, 

listen to others, and propose solutions. Those meetings are listed below. The notes taken at these 

meetings are available on the project website at 

www.fs.usda.gov/goto/BlueMountainsPlanRevision and also filed in the planning record.

June 16, 2015: Access and Wilderness, Burns, OR

July 7, 2015: Access and Wilderness, John Day, 

OR

July 8, 2015: Access and Wilderness, Clarkston, 

WA

July 9, 2015: Access and Wilderness, Walla 

Walla, WA

July 13, 2015: Access and Wilderness, Enterprise, 

OR

July 14, 2015: Livestock Grazing, Burns, OR

July 15, 2015: Access and Wilderness, Richland, 

WA

July 16, 2015: Access and Wilderness, Ukiah, OR

July 21, 2015: Livestock Grazing, Enterprise, OR

July 22, 2015: Access and Wilderness, Pendleton, 

OR

July 23, 2015: Access and Wilderness, Heppner, 

OR

July 28, 2015: Pace and Scale of Restoration, 

Enterprise, OR

Nov. 2, 2015: Access and Wilderness, La Grande, 

OR

Nov. 4, 2015: Livestock Grazing, Heppner, OR

Nov. 9, 2015: Blue Mountains Forest Plans, Baker 

City, OR

Nov. 10, 2015: Technical Pack Goat Meeting, 

Pendleton, OR

Nov. 10, 2015: Livestock Grazing, Ukiah, OR

Nov. 12, 2015: Pace and Scale of Restoration, La 

Grande, OR

Nov. 12, 2015: Technical Forestry Meeting, La 

Grande, OR

Dec. 10, 2015: Pace and Scale of Restoration,

Burns, OR

Dec. 11, 2015: Pace and Scale of Restoration,

John Day, OR

Dec. 14, 2015: Livestock Grazing & Pace and

Scale of Restoration, Clarkston, 

WA

Dec. 15, 2015: Livestock Grazing, North Powder, 

OR

Feb. 4, 2016: Nez Perce Tribe Town Hall 

Meeting, Lapwai, ID
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The input shared during the public listening sessions listed above was helpful to the 

interdisciplinary team. The listening sessions brought additional context to the 2014 formal 

comments and enhanced the team's understanding of how different alternatives may affect diverse 

public interests. In response, during 2016 and 2017, the team developed two modified alternatives 

(E-Modified and E-Modified-Departure) and analyzed each in detail in the final environmental 

impact statement. The modifications in both alternatives respond to substantive public comments, 

listening session input, and revised recommendations by resource specialists. The team also 

continued with the analysis of other alternatives from the draft environmental impact statement.

During 2016 and 2017, the Forest Service consulted with Tribes and engaged with government 

entities at the Federal, State, and County levels. The table below summarizes meetings held in 

2016 and 2017. Additional information is filed in the project record.

Table 419. Meetings held with Tribes, agencies and governments in 2016 and 2017

Entity Number of Meetings

Cooperating Agency Counties 9

Other County Meetings 10

Confederated Tribes of the Umatilla Indian 

Reservation

10

Nez Perce Tribe 9

State of Oregon 4

State of Washington 4

NOAA National Marine Fisheries Service 24

U.S. Fish and Wildlife Service 24

Additionally, the interdisciplinary team continued to communicate with the public regarding the 

modified alternatives and the ongoing plan revision process through a variety of communication 

channels: newsletters, mail, email, website updates, and public conference calls. The newsletters, 

public conference call recordings, and other public information is available on the project website 

at www.fs.usda.gov/goto/BlueMountainsPlanRevision. Below is a list of newsletters issued and 

public conference calls held during 2016 and 2017.

Newsletters

• April 2016: Update on Forest Plans, including an open letter to the friends of the Blue 

Mountains

• June 2016: Update on Forest Plans, including information on Recommended Wilderness, 

Backcountry Areas, Wildlife Corridors & Designated Routes

• March 2017: Timber and Vegetation Management, New Team leader, and Sustainable 

Documents

• July 2017: Livestock Grazing and Grazing-land Vegetation

• Fall 2016: Update on Forest Plans, including topics related to our team leader transition, 

revised timeline, and our cooperation, coordination, and consultation with other 

agencies.
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Public Conference Calls

• April 2016: Update on Forest Plans, including an open letter to the friends of the Blue 

Mountains

• July 2016: Update on Forest Plans, including information on Recommended Wilderness, 

Backcountry Areas, Wildlife Corridors & Designated Routes

• November 2016: Update on Forest Plans, including topics related to our team leader 

transition, revised timeline, and our cooperation, coordination, and 

consultation with other agencies.

• April 2017: Timber and Vegetation Management, New Team leader, and Sustainable 

Documents

• August 2017: Livestock Grazing and Grazing-land Vegetation

Involvement with

Native American Tribes and Federal, State,

and Local Agencies and Governments

The interdisciplinary team has worked with Tribes and government entities at the Federal, State, 

and County levels to inform the revised Forest Plans. This section describes efforts to engage 

with these different entities during the planning process. 

Tribes

Federally recognized Tribes are sovereign nations with whom the United States has governmentto-government relationships. Their long histories with these lands are well documented, and their 

knowledge and experience is helpful to Federal land managers. Therefore, the Forest Service 

seeks the advice and support of Tribal representatives. Through regular consultation, we exchange 

information and build mutual understanding that improves stewardship of the ecological and 

cultural resources that are significant to the Tribes. 

The Forest Service’s legal responsibilities to federally recognized Tribes are identified in treaties 

and clarified in statutes, executive orders, and case law. Tribal-U.S. treaties have legal authority 

under the U.S. Constitution, and the Forest Service has an obligation to uphold the rights 

recognized by those treaties. Tribal treaty rights often include fishing, hunting, gathering roots 

and berries, and pasturing horses and cattle. Executive Order 13175 on Consultation and 

Coordination with Indian Tribal Governments sets forth guidelines for all Federal agencies to (1) 

establish regular and meaningful consultation and collaboration with Tribal officials in the 

development of Federal policies that have Tribal implications, (2) strengthen the U.S. 

government-to-government relationships with Tribes, and (3) reduce the imposition of unfunded 

mandates on Tribes. Federal agencies are directed to consult with Tribes when engaging in 

policymaking or programs that may have implications on Tribal resources. In addition to 

Executive Order 13175, consultation obligations are included in a number of legal statutes, 

including the Federal Land Policy and Management Act and the National Historic Preservation 

Act. USDA Departmental Regulation 1350-002 on Tribal Consultation, Coordination, and 

Collaboration also provides direction.
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In the Blue Mountains planning area, a significant portion of lands ceded by the Tribes in various 

treaties were designated as part of the National Forest System by the Organic Administration Act 

of June 4, 1897. Lands were ceded through the treaties of 1855 by the Confederated Tribes of the 

Umatilla Indian Reservation, the Confederated Tribes of the Warm Springs Reservation, the Nez 

Perce Tribe of Idaho, and the Confederated Tribes and Bands of the Yakama Indian Nation of the 

Yakama Reservation. The Klamath Tribes, via the Treaty with the Klamath Nation of 1870, ceded 

lands extending into the Malheur National Forest. These treaties are known for their specific 

language recognizing certain reserved rights of the Tribes in aboriginal use areas. Other federally 

recognized Tribes with interests in the management of the Blue Mountains national forests

include the Burns Paiute Tribe, the Shoshone-Paiute Tribes of the Duck Valley Reservation, the 

Fort McDermitt Paiute and Shoshone Tribes, the Fort Bidwell Indian Community of Paiute 

Indians, and the Chief Joseph Band of the of the Nez Perce (now part of the Confederated Tribes 

of the Colville Reservation).

The following Tribes submitted formal comments in response to the February 2014 publication of 

the draft environmental impact statement and Draft Forest Plan: 

• Confederated Tribes of the Umatilla Indian Reservation, 

• Nez Perce Tribe of Idaho, and 

• Shoshone-Bannock Tribes of the Fort Hall Indian Reservation. 

The Forest Service has met its consultation requirements with qualified and interested Tribes at 

the government-to-government and staff-to-staff levels. (Details of Forest Service 

communications and meeting with the Tribes regarding this project are available in the planning 

record.) Tribal officials have been invited to participate in Forest Plan development since the 

beginning of the planning effort in 2003. As part of the planning process, forest supervisors, staff, 

and planning team members met with tribal staff, committees, and leadership, as well as tribal 

members who attended public meetings. The planning team carefully considered and addressed 

the formal comments submitted by the Tribes in response to the draft Environmental Impact 

Statement. Forest Service officials also continue to meet annually with tribal staff and officials to 

consult on national forest “programs of work,” which have included the forest plan revision effort 

since 2004. Further, Forest Service officials reviewed relevant tribal planning and land-use 

policies, in accordance with 36 CFR 219.7(c) of the 1982 Planning Rule, and found no 

inconsistencies with the revised Forest Plans. Please see the table under “Government Planning 

and Land-Use Policies.”

As a result of the efforts summarized above, this Environmental Impact Statement and the revised 

Forest Plans incorporate Tribal input. To ensure successful implementation, the planning team 

recommends that the national forests continue to work with the Tribes at the site-specific and 

project levels.

States

The planning area for the revised Forest Plans includes parts of Oregon and Washington State. 

State agencies with interests in the revised Forest Plans include, but are not limited to, the Oregon 

Department of Fish and Wildlife, Washington Department of Fish and Wildlife, Oregon 

Department of Forestry, and Washington Department of Natural Resources. 

Forest supervisors and members of the planning team worked with State officials during the 

development of the revised Forest Plans. For example, the Forest Service met with State officials 

to discuss adjacent state and private lands in the planning area. (Meeting details are available in 

the project record.) These meetings and discussions strengthened management direction that will 
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help the national forests to be better neighbors in terms of providing wildlife habitat and also 

improving forest resiliency in the face of natural disturbances. The team also carefully considered 

the formal comments submitted by the States in response to the draft Environmental Impact 

Statement. Additionally, Forest Service officials reviewed relevant state planning and land-use 

policies, in accordance with 36 CFR 219.7(c) of the 1982 Planning Rule, and found no 

inconsistencies with the revised Forest Plans. Please see the table under “Government Planning 

and Land-Use Policies.”

State input is incorporated in the Final Environmental Impact Statement and revised Forest Plans. 

The planning team recommends that the national forests continue to work with state agencies at 

the site-specific and project levels to ensure successful implementation.

Counties

The Forest Service began working with neighboring counties in 2003 on the plan revision 

process. The counties provided valuable early input in the development of the proposed action 

and public engagement process. The counties met frequently with the Forest Service during the 

pre-scoping, scoping, and alternative-development phases of the project, including public 

meetings in which county officials actively participated. 

During the alternative-development phase, the counties signed memoranda of understanding 

conferring “cooperating agency” status in the plan revision process. In that capacity, the counties 

provided information and assisted with the development of alternatives (specifically Alternative 

D) for the 2014 draft Environmental Impact Statement. The following counties have current 

memoranda of understanding:

• Oregon counties – Grant, Harney, Morrow, Umatilla, Union, Wallowa, Wheeler

• Washington counties – Asotin, Columbia, Garfield, Walla Walla

Individual counties that submitted formal comment letters in response to the 2014 draft 

Environmental Impact Statement include: Baker, Columbia, Grant, Harney, Morrow, Umatilla, 

Union, Wallowa, and Wheeler. Additionally, the Eastern Oregon Counties Association, consisting 

of 11 county governments, submitted a consolidated formal comment letter in 2014. Comments 

addressed issues related to the pace and scale of restoration, timber volumes, access, grazing, the 

draft’s social and economic analysis, wilderness, and a host of other comments on the preferred 

alternative. The Forest Service has addressed these comments in the response to concern 

statements.

Following the formal comment period in 2014 and associated public meetings, the Forest Service 

met with county officials to identify topics for further public discussion. During 2015 and 2016, 

the Forest Service scheduled a series of 24 public listening sessions that were hosted or attended 

by county officials. In response to public and county input, the planning team decided to analyze 

two modified alternatives in the environmental impact statement. To continue the cooperating 

agency process and exchange information regarding the modified alternatives, forest supervisors 

and the planning team continued to meet frequently with cooperating agency counties as a group 

during 2016 and 2017. During this period, forest supervisors and team members also met, upon 

request, with individual counties as well as county natural resource advisory committees. 

(Meeting details are available in the project record.) 

As part of the planning process, Forest Service officials reviewed relevant county planning and 

land-use policies, in accordance with 36 CFR 219.7(c) of the 1982 Planning Rule. For a list of 

documents reviewed, please see the table under “Government Planning and Land-Use Policies” 
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below. The Forest Service found no inconsistencies between the revised Forest Plans and county 

documents – with the exception of the Baker County Natural Resources Plan. The results of this 

review can be found in the Government Planning and Land-Use Policies section.

As a result of these efforts, this Environmental Impact Statement and the revised Forest Plans 

incorporate county input. The planning team recommends that the national forests continue to 

work closely with neighboring counties to address site-specific and project-level interests.

Federal Agencies

A number of Federal agencies have interests within, or adjacent to, the Planning Area. These 

agencies include, but are not limited to, the U.S. Fish and Wildlife Service, National Marine 

Fisheries Service, Environmental Protection Agency, and Bureau of Land Management. 

The planning team carefully considered and addressed the formal comments submitted by other 

Federal agencies in response to the draft Environmental Impact Statement. The Forest Service 

also worked with Federal officials during the development of the revised Forest Plans. For 

example, under the Endangered Species Act the Forest Service is required to engage in a formal 

consultation process with the U.S. Fish and Wildlife Service and National Marine Fisheries 

Service. Moreover, the Forest Service reviewed the relevant planning and land-use policies of 

other Federal agencies to ensure consistency and compliance in the revised Forest Plans. The 

national forests will continue to operate in accordance with existing federal law, regulation, and 

policy.

Consistency with

Government Planning and Land-Use Policies

The Forest Service carefully considered the comments provided by other government entities. 

Additionally, as indicated in the sections above, the Forest Service reviewed the planning and 

land use policies of other government entities consistent with 36 CFR 219.7(c) of the 1982 

Planning Rule:

The responsible line officer shall review the planning and land use policies of other 

Federal agencies, State and local governments, and Indian tribes. The results of this 

review shall be displayed in the environmental impact statement for the plan (40 CFR 

1502.16(c), 1506.2). The review shall include:

1. Consideration of the objectives of other Federal, State and local governments, and Indians 

tribes, as expressed in their plans and policies;

2. An assessment of the interrelated impacts of these plans and policies;

3. A determination of how each Forest Service plan should deal with the impacts identified; and

4. Where conflicts with Forest Service planning are identified, consideration of alternatives for 

their resolution.

The following section summarizes government planning and land use policies reviewed by the 

Forest Service. Additional documentation is available in the project record.

Washington State Dept. of Natural Resources (WDNR)

20-Year Forest Health Strategic Plan for Eastern Washington

Goals stated in the plan include: 1, Conduct 1.25 million acres of scientifically sound, landscapescale, cross-boundary management and restoration treatments in priority watersheds to increase 
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forest and watershed resilience by 2037. 2, Reduce risk of uncharacteristic wildfire and other 

disturbances to help protect lives, communities, property, ecosystems, assets and working forests. 

3, Enhance economic development through implementation of forest restoration and management 

strategies that maintain and attract private sector investments and employment in rural 

communities. 4, Plan and implement coordinated, landscape-scale forest restoration and 

management treatments in a manner that integrates landowner objectives and responsibilities. 5,

Develop and implement a forest health resilience monitoring program that establishes criteria, 

tools, and processes to monitor forest and watershed conditions, assess progress, and reassess 

strategies over time.

Washington State Dept. of Fish and Wildlife (WDFW)

Blue Mountains Wildlife Area Complex Management Plan

The Blue Mountains Wildlife Area Complex Management Plan includes the following goals and 

objectives: 1, To have healthy and diverse fish and wildlife populations and habitats through 

protecting, restoring and enhancing fish and wildlife populations and their habitats. Through 

ensuring WDFW activities, programs, facilities and lands are consistent with local, state, and 

federal regulations that protect and recover fish, wildlife, and their habitats. Lastly, to minimize 

adverse interactions between humans and wildlife. 2, To have sustainable fish and wildlife-related 

opportunities through providing sustainable fish and wildlife-related recreational and commercial 

opportunities compatible with maintaining healthy fish and wildlife populations and habitats, and 

through working with Tribal governments to ensure fish and wildlife management objectives are 

achieved. 3, To have operational excellence and professional service through providing sound 

operational management of WDFW lands, facilities and access sites, and to reconnect with those 

interested in Washington’s fish and wildlife.

Washington State Wildlife Action Plan

The Washington State Wildlife Action Plan will look to: 1, Identify and safeguard wildlife and 

natural habitats important to many of our family traditions and for future generations. 2, Conserve 

all wildlife and the habitats they live in, starting with the animals and places most in need of help. 

3, Assure that the natural habitats needed by wildlife are healthy enough to provide clean water 

and air for both wildlife and people.

Washington State Department of Recreation and Conservation

Recreation and Conservation Plan (2018-2022)

The conservation plan provides strategic direction to provide outdoor recreation and conservation 

for Washington State residents, and how to achieve conservation goals along with local, regional, 

state, and federal agencies, together with tribal governments, and private and non-profit partners. 

The conservation plan is delivered via the Washington State Recreation and Conservation Office 

website (https://www.rco.wa.gov/StateRecPlans/). The State Plan includes “Strategic Direction,” 

a “Vision 2040” statement, and “Priorities and Recommendations” for the five priority areas that 

include: Sustain Our Legacy: Sustain and grow the legacy of parks, trails, and conservation 

lands. Improve Equity: Improve Equity of parks, trails, and conservation lands. Get Youth 

Outside: Meet the needs of youth. Address Changing Demographics: Plan for culturally 

relevant parks and trails to meet changing demographics. Assert as a Vital Public Service: 

Assert recreation and conservation as a vital public service.
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A final section, Unifying Strategy, offers goals and recommendations based on research and 

findings presented within the 2018-2022 Recreation and Conservation Plan to address statewide 

priorities over the next five years. 

In addition to these core topics, the State Plan includes individual, resource area specific plans 

that include: State Trails Plan, State Athletic Facilities Plan, Nonhighway and Off-road Vehicle 

Plan, Recreational Boating Plan, and a Recreation and Conservation Land Acquisition and 

Development Strategy. Each of the plans contain goal statements and provides recommendations 

that support achieving plan goals and that support regional planning and coordination. 

Washington State Department of Historic Preservation

Washington State Historic Preservation Plan (2014-2019)

The 3-Part preservation plan provides an overview and planning process, the Washington State 

historic preservation plan, and a resource overview and historic preservation trends. Part 2, 

Washington State Historic Preservation Plan, provides three primary goals (outlined below), each 

with a subset of accompanying strategies and actions. The three primary goals are: Goal 1. 

Enhance communities by actively engaging historic preservation with other forces shaping our 

environment. Goal 2. Engage a broad spectrum of the public in preservation; Improve access to 

information. Goal 3. Strengthen policies and planning processes to enhance informed and crossdisciplinary decision-making for managing cultural and historic resources.

The preservation plan further identifies opportunities under Goal 3 to “establish policies and 

provide tools to improve protection of cultural and historic resources.” Specifically, the 

preservation plan identifies the U.S. Forest Service in a supporting role to support these 

protection efforts through an increased understanding of Resource Advisory Committee (RAC) 

funding and its potential application to support survey and inventory work.

State of Oregon

Executive Order 13443: Facilitation of Hunting and Wildlife Conservation

The State encourages the Forest Service to address President Bush’s Executive Order in the 

Revised Forest Plans when discussing forest management actions that may affect hunting and 

fishing opportunities on the Blue Mountains National Forests.

Department of Land Conservation and Development, Statewide Planning Goals

Statewide planning goals include: 1, The Citizen Involvement goal encourages active citizen 

participation in all aspects of planning. 2, The Land Use Planning goal will establish a land use 

planning process and policy framework as a basis for all decision and actions related to use of 

land and to assure an adequate factual base for such decisions and actions. 3, The Forest Lands 

goal is to conserve forest lands by maintaining the forest land base and to protect the state’s forest 

economy by making possible economically efficient forest practices that assure the continuous 

growing and harvesting of forest tree species as the leading use on forest land consistent with 

sound management of soil, air, water, and fish and wildlife resources and to provide for 

recreational opportunities and agriculture. 4, The goal for Air, Water, and Land Resources Quality 

is to maintain and improve the quality of the air, water and land resources of the state. 5, The 

Energy Conservation goal is to conserve energy. 
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Department of Forestry, Forestry Program for Oregon

The Forestry Program for Oregon includes the following goals: Goal 1, Promote a fair legal 

system, effective and adequately funded government, leading-edge research and education, and 

publicly supported environmental, economic, and social policies. Goal 2, Ensure that Oregon’s 

forests make a significant contribution towards meeting the nation’s wood product needs and 

provide diverse social and economic outputs and benefits valued by the public in a fair, balanced, 

and efficient manner. Goal 3, Protect and improve the productive capacity of Oregon’s forests. 

Goal 4, Protect and improve the physical and biological quality of the soil and water resources of 

Oregon’s forests. Goal 5, Conserve diverse native plant and animal populations and protect and 

improve their habitats in Oregon’s forests. Goal 6, Protect and improve the health and resiliency 

of Oregon’s dynamic forest ecosystems, watersheds, and airsheds. Goal 7, Improve carbon 

sequestration and storage and reduce carbon emissions in Oregon’s forests and forest products.

Department of Forestry, Eastern Region Long-Range Forest Management Plan

The comprehensive plan includes the following goals and objectives: 1, The management goal for 

air quality is to contribute to maintaining air quality that meets National Ambient Air Quality 

Standards and Prevention of Significant Deterioration Standards established by the 

Environmental Protection Agency under the federal Clean Air Act. 2, The goals for fire 

management are to suppress wildfires and minimize the risk of their occurrence in the interest of 

conserving forest resources and protecting public safety, and to mitigate the effects of excluding 

natural fires from the forest ecosystem. 3, The goal for forest health is to maintain or restore 

diverse, productive, resilient, and sustainable forest ecosystems. 4, The overall management goal 

for timber is to maximize long-term revenues to the Common School fund and to produce income 

for counties, schools, and local taxing districts through a cost-effective, sustainable, and 

environmentally sound timber program.

Oregon Department of Fish and Wildlife (ODFW)

Oregon Conservation Strategy 

The Oregon Conservation Strategy addresses many conservation issues including climate change, 

land use changes, invasive species, disruption of disturbance regimes, barriers to animal 

movement, water quality and quantity, and challenges and opportunities for private landowners to 

initiate conservation actions. These issues have many goals and objectives that relate to land and 

forest management, which include: Climate Change – use the best available science, technology, 

and management tools to determine the vulnerability of species and habitats to climate at a 

landscape scale. Land Use Changes – manage land use changes to conserve farm, forest, and 

range lands, open spaces, natural or scenic recreation areas, and fish and wildlife habitats. Water 

Quality and Quantity – Maintain or restore water quality in surface and groundwater to support 

a healthy ecosystem, support aquatic life, and provide fish and wildlife habitat.

Wildlife Species Management Plans

The State Supports and encourages the Forest Service to integrate ODFW wildlife species 

management plans in the revised Forest Plans. ODFW wildlife species management plans 

identify important ODFW wildlife management policies and strategies, and could be used by the 

Forest Service to guide management actions related to specific species, such as Rocky Mountain 

elk, mule deer, bighorn sheep, wild turkey, and other species.
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Wildlife Area Management Plans

The goals set out in these plans include: protecting, enhancing and managing wetland habitats to 

benefit fish and wildlife species. To protect, enhance and manage upland habitats to benefit a 

wide variety of wildlife species, and to provide a variety of wildlife oriented recreational and 

educational opportunities to the public.

Department of Parks and Recreation

Oregon Statewide Outdoor Recreation Plan (SCORP)

The recreation plan identifies the U.S. Forest Service as one of several partners in recreation and 

natural resource program management and further acknowledges the “Forest Service is the largest 

single outdoor recreation provider in Oregon.” Chapter Eight of the recreation plan outlines five 

statewide outdoor recreation issues and provides strategic actions needed to address each issue. 

The issues identified include: Statewide Issue 1: Provide adequate funds for routine and 

preventative maintenance and repair of facilities. Statewide Issue 2: Fund major rehabilitation of 

existing outdoor recreation facilities at the end of their useful life. Statewide Issue 3: Add more 

recreational trails and better trail connectivity between parks and communities. Statewide Issue 

4: Recognize and strengthen park and recreation’s role in increasing physical activity in Oregon’s 

population. Statewide Issue 5: Recommend a standard set of sustainable park practices for 

outdoor recreation providers.

The Oregon recreation plan identifies challenges that confront public land managers, specifically 

the U.S. Forest Service, and notes a need for additional long distance trail opportunities, changing 

population demographics and the associated need for visitor services that respond to these 

changes, and sustainable planning and design for recreation facilities that provide quality 

recreation experiences. A comprehensive statewide recreation survey was conducted to inform 

Oregon’s recreation plan and included workshop participation from multiple recreation providers 

including the U.S. Forest Service.

Historic Preservation Office (SHPO), Oregon Historic Preservation Plan 2018-

2023

The preservation plan outlines two primary purposes: to guide internal SHPO activities including 

work plans and staffing; and to serve as the framework to coordinate statewide heritage 

preservation goals with individuals and organizations outside of the SHPO. The framework 

delivers Issue statements accompanied by Goal statements, and provides objectives for each 

individual issue. The ten Issue areas outlined in the Historic Preservation Plan are: Issue 1: 

Government Partnerships. Issue 2: Heritage Partner Networking and Advocacy. Issue 3: Public 

Outreach and Education. Issue 4: Professional Preservation Education. Issue 5: Digital 

Information Sharing and Accessibility. Issue 6: Identification and Designation of Cultural 

Resources. Issue 7: Preservation, Rehabilitation, and Protection of Cultural Resources. Issue 8: 

Grants and Funding. Issue 9: Economic Development. Issue 10: Statues, Ordinances, Codes, and 

Processes.

The historic preservation plan identifies the roles of the broader heritage community including 

federal and state agencies and acknowledges their roles to identify, evaluate, designate, and treat 

significant historic properties and archaeological sites. The preservation plan identifies a fifth 

component, “educate,” that is important for connecting history to our everyday lives and for a 

maintaining public support. 
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Garfield County, Washington

Garfield County Comprehensive Plan

The Garfield County Comprehensive Plan includes the following goals: 1, The natural resource 

industries goal is to maintain and enhance natural resource-based industries, including productive 

timber, agricultural, and fisheries industries. 2, The open space and recreation goal is to 

encourage the retention of open space and development of recreational opportunities, conserve 

fish and wildlife habitat, increase access to natural resource lands and water, and develop parks. 

3, The environment goal is to protect the environment and enhance the state’s high quality of life, 

including air and water quality, and the availability of water. 4, The citizen participation and 

coordination goal aims to encourage the involvement of citizens in the planning process and 

ensure coordination between communities and jurisdictions to reconcile conflicts.

Malheur County, Oregon

Malheur County Comprehensive Plan

The Malheur County Comprehensive Plan includes the following goals: 1, To develop a citizen 

involvement program that ensures the opportunity for citizens to be involved in all phases of the 

planning process. 2, To establish a comprehensive planning process and policy framework as a 

basis for all decisions and actions related to land use and to assure an adequate factual base for 

those decisions and actions. 3, To preserve and maintain forest lands for allowable agricultural 

and forest uses. 4, To conserve open space and protect natural and scenic resources through 

cooperating with other public agencies that manage open land in Malheur County, as well as 

cooperating with agencies responsible for the management of designated natural and scenic areas 

and encouraging the expanded protection of these resources on publicly owned land.

Union County, Oregon

Land Use Plan, Union County, Oregon

The Land Use Plan of Union County, Oregon includes the following goals: 1, That land and water 

resources be protected. 2, That all lawful and authorized uses existing at the time of adoption of 

the Plan be allowed to continue, and expand according to Zoning Ordinance provisions. 3, That 

existing uses be considered one of the primary considerations in establishing plan classification 

boundaries and that other physical, social, economic and legal factors also be taken into account. 

4, That any authorized use of land be encouraged to locate where it may have the opportunity to 

prosper without harm to its neighbors or to the economy of the County as a whole.

Asotin County, Washington

Asotin County Comprehensive Plan

The Asotin County Comprehensive Plan includes the following goals: 1, Agriculture - to 

encourage the retention of the existing agricultural land base of Asotin County. Discourage 

conversion of the agricultural land base to other land uses and then only in accordance with the 

guidelines of the Comprehensive Plan. It shall be required of all levels of government and their 

agencies to consider the adverse impacts of their programs and projects on agriculture. 2, Energy 

Conservation - Plan the use of land and encourage the use of urban design so as to minimize the 

demand for energy consumption and maximize the effectiveness of energy consumed. 3,

Drainage, Flooding, and Stormwater Run-Off - Actions regarding new proposed land uses 

should include provisions for the protection of the quality and quantity of ground water used for 

public water supplies. Actions regarding new proposed land uses should be reviewed for effects 
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on drainage, flooding, and storm-water run-off in the plan area and in the neighboring county 

area, including guidance for corrective actions of any discharges that pollute.

Columbia County, Washington

Columbia County Comprehensive Plan

The Columbia County Comprehensive Plan includes the following goals: 1, Natural Resource 

Industries - Maintain and enhance natural resource-based industries, including productive 

timber, agricultural, and fisheries industries. 2, Open Space and Recreation - Encourage the 

retention of open space and development of recreational opportunities, conserve fish and wildlife 

habitat, increase access to natural resource lands and water, and develop parks. 3, Environment -

Protect the environment and enhance the state’s high quality of life, including air and water 

quality, and the availability of water. 4, Historic Preservation - Identify and encourage the 

preservation of lands, sites, and structures that have historical or archaeological significance.

Morrow County, Oregon

Morrow County Comprehensive Plan

The Morrow County Comprehensive Plan includes the following goals: 1, Land Use Planning -

To establish an ongoing land use planning process and policy framework as the basis for all 

decisions and actions related to the use of land in the County and to assure an adequate factual 

base for such decisions and actions. 2, Forest Lands - To conserve the forest land base in the 

County to provide for the continued availability of these lands for forest use. To encourage the 

application of management practices that maximize the continued productivity of timber lands, 

such as addressed by the Oregon Forest Practices Act. To encourage and support management 

practices which support existing use levels, particularly as related to the forest products industry, 

the dependent livestock sector, and the dispersed recreational user. 3, Air, Water, And Land 

Quality - To maintain and improve the quality of the County's air, water and land resources. 

Wheeler County, Oregon

Wheeler County Comprehensive Plan

The Wheeler County Comprehensive Plan includes the following goals: 1, Citizen Involvement 

– To develop a citizen involvement program that insures the opportunity for citizens to be 

involved in all phases of the planning process. 2, Land Use Planning – To establish a land use 

planning process and policy framework as a basis for all decisions and actions related to use of 

land and to assure an adequate factual base for such decisions and actions. It will do this through 

identifying lands suitable for farming, grazing and forest production. Open space is created by the 

accepted farming practices in the County. It will also look to determine the land requirements for 

projected economic development and population growth. 3, Forest lands – To conserve 

forestlands for forest uses. 4, Air, Water, and Land Resources quality – To maintain and 

improve the quality of air, water and land resources of Wheeler County.

Crook County, Oregon

Crook County Comprehensive Plan

The Crook County Comprehensive Plan includes the following goals: 1, Citizen InvolvementTo develop a citizen involvement program that ensures the opportunity for citizens to be involved 

in all phases of the planning process. 2, Land Use Planning - To establish a comprehensive 

planning process and policy framework as a basis for all decisions and actions related to land use 
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and to assure an adequate factual base for those decisions and actions. 3, Agricultural Lands -

To preserve and maintain the agricultural land in the county for agricultural purposes. 4, Forest 

Lands - To preserve and maintain forest lands for allowable agricultural and forest uses. 5, Open 

Space, Scenic and Historic Areas and Natural Resources - To conserve open space and protect 

natural and scenic resources. 6, Air, Water, And Land Quality - To maintain and improve the 

quality of Malheur County's air, water, and land resources. 7, Natural Disasters And Hazards -

To protect life and property from natural disasters and hazards. 

Walla Walla County, Washington

Walla Walla County Comprehensive Plan

The Walla Walla County Comprehensive Plan includes the following goals: 1, Natural Resource 

Industries - Maintain and enhance natural resource-based industries, including productive 

timber, agricultural, and fisheries industries. 2, Open Space And Recreation - Encourage the 

retention of open space and development of recreational opportunities, conserve fish and wildlife 

habitat, increase access to natural resource lands and water, and develop parks. 3, Environment -

Protect the environment and enhance the state’s high quality of life, including air and water 

quality, and the availability of water. 4, Citizen Participation And Coordination - Encourage 

the involvement of citizens in the planning process and ensure coordination between communities 

and jurisdictions to reconcile conflicts. 5, Historic Preservation - Identify and encourage the 

preservation of lands, sites, and structures that have historical or archaeological significance. 6, 

Critical Areas - Recognize the importance of fish and wildlife habitat conservation areas while at 

the same time working towards a balance between preservation of those lands and the 

continuation of agriculture, forestry, mining and managed growth.

Grant County, Oregon

Grant County Comprehensive Plan

The Grant County Comprehensive Plan includes the following goals: 1, Forest Lands Element -

The Grant County Plan emphasizes the importance of wood products industry to the economy of 

the County. The Grant County Plan provides a list of 14 policies related to forest lands. In 

summary, these policies provide that forest resources should be considered when determining 

land use, that forest health and fire risk are important when residences are located near forested 

lands, and that wood products and agricultural needs are considered when making land use 

decisions on forest lands. 2, Natural Resources Element - The Grant County Plan recognizes the 

importance of natural resources; including, land, vegetation, land quality, minerals, water, air, 

fish, and wildlife. It emphasizes the consideration of economic, energy, environmental, and social 

consequences when there are use conflicts. The Grant County Plan’s overall land use policies are 

to: a, Support the County’s economic base. b, Maximize preservation of agricultural and forest 

uses. c, Minimize use conflicts and allow for mining on agricultural and forest lands. d,

Recognize current use patterns in development decisions. e, Encourage coordinated land 

management and conservation. f, Consider soil and use factors in proposals to alter current land 

uses. g, Seek a detailed County-wide soils analysis. h, Actively seek aid for stream bank 

improvement and erosion control. i, Promote County geology as a tourist-recreation base. j,

Preserve the limited soil good for intense agricultural use. k, Prohibit conversion of land uses 

which decrease the economic base. 
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Umatilla County, Oregon

Umatilla County Comprehensive Plan

The Umatilla County Comprehensive Plan includes the following goals: 1, Citizen Involvement 

– to develop a citizen involvement program that insures the opportunity for all citizens to be 

involved in all phases of the planning process. 2, Land Use Planning – To establish a land use 

planning process and policy framework as a basis for all decisions and action related to use of 

land and to assure an adequate factual base for such decisions and actions. 3, Agricultural 

Lands – To preserve and maintain agricultural lands through establishing four agricultural 

designations with several types of management regulations to protect and maintain the existing 

agricultural economy character of the county. 4, Forest Lands – To conserve forest lands for 

forest users through encouraging a multiple use concept for grazing/forestland areas that will 

conserve forest uses, including agricultural activities (e.g. cultivation) found intermixed within 

forested lands through appropriate policies in the Comprehensive Plan and corresponding 

protection measures in the Development Ordinance.

Umatilla County, Oregon

Umatilla County Natural Hazard Mitigation Plan

The Umatilla County Natural Hazard Mitigation Plan includes the following goals: Protect life 

and property, public outreach, planned prevention, agency/citizen coordination, natural resource 

protection, and emergency service planning.

Baker County, Oregon

Baker County Natural Resources Plan

The purpose of the Baker County Natural Resources Plan is “...to set forth the policies of Baker 

County in regards to the use, and access to, natural resources located on public land.” The Baker 

Plan also includes a list of “...principles to guide decision making governing natural resources 

within the County.” These principles are: 1, Expansion, revitalization and continuation of 

multiple uses on all public lands in Baker County. 2, Multiple use shall be inclusive rather than 

exclusive, thereby avoiding pitting one use against the other. 3, All plans shall mitigate based on 

multiple use rather than by a resource by resource issue. 4, Maintain flexibility in all plans to 

allow for extraction of natural resources from public lands and to continue to use existing 

resources in accordance with all laws. 5, Protect and preserve the following rights of all County’s 

citizens, including: a, Private property interests, such as water and grazing rights and access to 

lands, which have ties to public lands. b, Traditional economic structures in the county that form 

the base for economic stability. c, Historic custom, culture and values of the local people, and d,

Enjoyment of the natural resources of the County.

Wallowa County, Oregon

Wallowa County Natural Resource Plan

The Wallowa County Natural Resource Plan consists of the following documents: Wallowa 

County Hells Canyon National Rec. Area Comprehensive Mgmt. Plan (Alt. W), Wallowa County 

Community Wildfire Protection Plan, Upper Joseph Creek Watershed Assessment, Lower Joseph 

Creek Watershed Assessment and Rangeland Appendices, Wallowa County Board of 

Commissioners Travel Management Plan, Wallowa County - Nez Perce Tribe Salmon Habitat 

Recovery Plan, and Wallowa County Comprehensive Management Plan / Forest Plan. The latter 
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compiles direction from Wallowa County that is intended to apply to the Wallowa-Whitman 

National Forest. Key sections address Recreation, Ecological Condition, Forage Management, 

Forest Management, Heritage Resources and Traditional Uses, Riparian Management, and 

Wildlife Management. Each section includes management areas, standards, guidelines, and 

objectives.

Wallowa County, Oregon

Wallowa County Comprehensive Management Plan

The Wallowa County Comprehensive Management plan includes the following goals and 

objectives: 1, Recreation – To manage outdoor recreation to ensure that recreational and 

ecological values and public enjoyment of the area are maintained and enhanced and compatible 

with the other uses of the forest. 2, Vegetation – Sustainability of ecological functions and 

processes is deemed important to maintaining ecosystem health and shall be attained by 

promoting vegetation for seral stages (grassland vegetation) and structural stages (forested 

vegetation). 3, Forestland – To Manage forested vegetation to maintain and/or enhance forested 

watershed conditions through following the watershed approaches in the Wallowa County/Nez 

Perce Tribe Salmon Habitat Recover Plan for forest management. To use precommercial thinning 

to improve the health and vigor of sapling-sized material and promote stand differentiation. 4, 

Riparian – Maintain or enhance riparian conditions in Wallowa County through: a, improving 

riparian vegetation to increase streambank stability, water quality, dissipate energy during high 

flows and appropriately filter sediment/nutrients from runoff. b, improve vegetation to provide 

fish and wildlife habitat for a diversity of species. 

Wallowa County, Oregon

Wallowa County Community Wildfire Plan

The Wallowa County Community Wildfire Plan includes the following goals: 1, to promote 

wildfire awareness and target fire prevention and safety information across at-risk communities. 

2, to promote cooperative emergency fires response, identify available resources and needs, and 

review interagency communication and suppression strategies. 3, to identify, assess, and reduce 

hazardous fuels, coordinate risk reduction strategies, and prioritize fuel reduction areas and 

projects. 4, to complete annual monitoring and evaluation to assess progress and effectiveness 

and recommend changes as appropriate.

Wallowa County, Oregon

Wallowa County’s Economic Base

The Wallowa County Economic Base is an economic profile that concentrates on natural 

resources. In describing the economic base, they focus on the basic industries or the basic 

component of each industry and determine what percentage of the local economy is dependent on 

that industry. They found that timber production and processing is responsible for 6 percent of 

jobs in Wallowa County, whereas government agency jobs account for 14 percent of the jobs in 

the county.

Wallowa County, Oregon

Custom and Culture of Wallowa County Oregon

The Custom and Culture document for Wallowa County focused on the “custom, culture, and 

community stability that have been, still is, and will be Wallowa County.” With regards to natural 
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resources and land management, the document focuses on agriculture, outdoor recreation, 

grazing, and forestry.

Nez Perce Tribe, Idaho

Nez Perce Tribal Code

The Nez Perce Tribal Code includes provisions for Tribal Council and Government, 

Intergovernmental Rules and Regulations, Natural Resources and Environment, Water and Sewer 

Utility Authority, and Probate Ordinance. The Tribal Code includes sections related to natural 

resources management, such as Fish and Wildlife Provisions, and management of Salmon and 

Steelhead Guiding and Outfitting.

Nez Perce Tribe’s Integrated Resource Management Planning documents (2017)

The Nez Perce Tribe’s Integrated Resource Management Plan is intended to address the following 

questions and issues: 1, Economic development & returns: To what extent should the Tribe’s 

economic development efforts and economic revenue be maximized when impacts to its natural 

and cultural resources are anticipated? 2, Opportunities for resource restoration: When and to 

what extent should the Tribe’s lost or degraded natural and cultural resources be restored? 3, 

Opportunities for subsistence & traditional cultural practices: When and to what extent 

should the Tribe manage its natural and cultural resources to support traditional cultural 

practices? 4, Resource impact assessments: When and to what extent should the Tribe evaluate 

the impacts of its activities on its natural and cultural resources? 5, Resource protection: When 

and to what extent should the Tribe’s natural and cultural resources be administratively protected 

from harm? 6, Resource sustainability: How sustainably does the Tribe wish to manage its 

natural and cultural resources? 7, Resource impact assessments: When and to what extent 

should the Tribe evaluate the impacts of its activities on its natural and cultural resources? 8, 

Resource-based Tribal Employment: How would the embrace of various resource management 

strategies impact Tribal employment? 9, Rural & wild land use: How should the Tribe’s rural 

and wild lands be used?

Nez Perce Tribe Department of Fisheries Resources Management Plan

The Nez Perce Tribe Department of Fisheries Resources Management Plan includes the following 

management goals: 1, Biological, To achieve and maintain diverse and productive ecosystems 

with species composition and productivity consistent with historical conditions. To achieve and 

maintain fish abundance in tributary-specific areas at levels sufficient to support population 

persistence, harvest, and ecological processes. 2, Physical, to achieve and maintain in-stream 

physical habitat structure and function to support populations self-sustained by natural 

reproduction and consistent with historic conditions. To ensure passage/access for all life stages 

of aquatic species in all streams and rivers. 3, Harvest, to achieve harvest of 50% share of 

harvestable fish. Achieve tribal harvest in all population areas using traditional gear types and 

fishing methods and practices. Harvest opportunities currently available will be protected and 

enhanced. Mitigation goals must be met.

Wallowa County – Nez Perce Tribe Salmon Habitat Recovery Plan with MultiSpecies Habitat Strategy

The Wallowa County – Nez Perce Tribe Salmon Habitat Recovery Plan sets forth a plan to restore 

and maintain habitat for chinook salmon (Oncorhynchus tshawytscha) and, potentially, other 

salmonid fish in Wallowa County, Oregon. The goals for salmon recovery are to provide 

spawning, rearing, and migration habitat within the County to assist in the recovery of Snake 
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River salmonids. These goals will be reached through looking at water quantity, water quality, 

fuel density, stream structure, and habitat requirements in riparian areas.

Nez Perce Precious Lands Draft Wildlife Area Management Plan

The goals of the Nez Perce Precious Lands Draft Wildlife Area Management Plan are to: 1, 

Maintain or improve native plant communities and other desirable species to benefit fish and 

wildlife, and provide traditional gathering and cultural opportunities for tribal members. 2, To 

maintain or enhance fish and wildlife populations. 3, Provide public access for activities 

compatible with maintaining high quality wildlife populations and habitat. 4, Foster productive, 

interactive relationships with neighboring landowners, including private individuals and state and 

federal agencies. 5, Conduct Monitoring and Evaluation activities to ensure that management 

actions are providing the desired response and/or benefit.

Burns Paiute Tribe, Oregon

Burns Paiute Tribal Code

The purpose of the Burns Paiute Tribal Code is to provide a system of criminal justice, law 

enforcement, and resolution of civil matters for the people of the Reservation and members of the 

Burns Paiute Indian Tribe. The code covers a number of articles that relate to land and forest 

management including: Natural and Cultural Resources, and Rangeland Management.

Warm Springs Tribe, Oregon

Warm Springs Tribal Code

The Warm Springs Tribal Code includes provisions for Tribal Council and Government, 

Management, Tribal Courts, Public Safety and Justice, Physical Facilities and Natural Resources, 

Human Services, Enterprises, and Commercial Law. The Tribal Code includes sections related to 

natural resources management, such as Hunting and Trapping Protection and the Management of 

Archaeological, Historical, and Cultural Resources. The Warm Springs Wild and Scenic Rivers 

Act includes the following objectives: Coordination with Federal and State River Planning 

Efforts – effort will be made to coordinate tribal wild and scenic river plans with state and 

federal planning and management efforts. All efforts will be made to ensure that river plans are 

coordinated and consistent with each other. Plans will be adopted by Tribal Council resolution. 

Range Management Within River Protection Areas – Grazing of livestock within river 

protection areas must be done in a manner consistent with protection and enhancement of the 

natural values set forth in WSTC 401.100.

Warm Springs Tribe Comprehensive Plan

The Warm Springs Tribe Comprehensive Plan includes the following goals: 1, to preserve, protect 

and enhance our cultural, environmental and natural resources. 2, That they are a healthy, safe, 

productive and knowledgeable people. 3, That their growing economy meets the income, 

employment and business needs of the community. 4, That their homes and community are 

sources of pride and that they have various choices of where to live. 
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Confederated Tribes of the Umatilla Indian Reservation (CTUIR), 

Oregon

CTUIR Tribal Code

The Confederated Tribes of Umatilla Indian Reservation (CTUIR) Tribal Code includes codes 

related to Environmental Health and Safety, Fish and Wildlife, Historic Preservation, Land 

Development, Right to Work, and Tribal Employment Rights. The Tribal Code includes sections 

related to Natural Resources Management, such as Range, Agriculture and Forestry, Land 

Management, and Fisheries and Wildlife.

CTUIR Forest Management Plan

The Confederated Tribes of the Umatilla Indian Reservation Forest Management Plan includes 

the following goals and objectives: Goal 1, to provide sustainable and predictable outputs and 

services including, but not limited to, high quality water, fish and wildlife habitat, native plant 

communities, and timber. Goal 2, to sustain traditional, subsistence, and other cultural needs of 

the Confederated Tribes. Goal 3, to provide consistent direction for management of forest 

resources. Objective 1, to identify desired conditions of vegetation structure, composition, and 

distribution; hydrologic process and functions; and aquatic habitat structure and diversity. 

Objective 2, to provide for the uses and values of the Confederated Tribes regarding natural 

resources consistent with maintaining healthy, diverse ecosystems. Objective 3, to emphasize 

adaptive management. 

CTUIR Comprehensive Management Plan

The Confederated Tribes of the Umatilla Indian Reservation Comprehensive Management Plan 

includes the following goals and objectives: 1, Land Base Restoration – Restore Umatilla Indian

Reservation Lands to the extent feasible to pre-treaty conditions to optimize current and 

traditional tribal land use values and ownership. 2, Natural Resources – to protect, restore, and 

enhance the first foods – water, salmon, deer, cous, and huckleberry – for the perpetual cultural, 

economic, and sovereign benefit of the CTUIR. They will accomplish this by utilizing traditional 

ecological and cultural knowledge and science to inform: a, population and habitat management 

goals and actions; and b, natural resource policies and regulatory mechanisms. 3, Cultural 

Heritage – to protect, restore, interpret and foster the CTUIR’s cultural and historical knowledge, 

objects, information, places and resources for the benefit of current and future generations. 4, 

Treaty Rights Protection – to provide first foods resources and the ecological conditions 

necessary for the long term, and sustained exercise of rights reserved in the treaty of 1855 for 

fishing, hunting, gathering and livestock pasturing and associated water rights for instream flow 

and consumptive use, and to protect and defend these treaty-reserved rights.

Consistency Conclusion

Given the programmatic nature of the revised Forest Plans, the Forest Service found no 

inconsistencies, interrelated impacts, or conflicts with these other government documents – with 

the exception of the Baker County Natural Resources Plan,2 as adopted in July 2016. The Baker 

County Natural Resources Plan (hereafter referred to as the “Baker Plan”) articulates principles 

and policies for public lands within Baker County, including national forest lands. Although the 

revised Forest Plans share many common principles with the Baker County plan, the Forest 

 2

http://www.bakercounty.org/commissioners/pdfs/Adopted_Natural_Resource_Plan_20160620C.p

df
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Service review also identified several potential interrelated impacts. The paragraphs below 

provide a detailed review of the Baker Plan with respect to the revised Forest Plans.

The Forest Service acknowledges that some interrelated impacts may occur across national forest 

boundaries regardless of the revised Forest Plans. Some of these potential impacts may occur 

naturally, such as those due to wildfires, insects, diseases, and wildlife. Many cross-boundary 

impacts, although addressed by the revised Forest Plans, cannot be resolved by the revised Forest 

Plans alone. For example, although the revised Forest Plans analyze an increase in forest thinning 

to reduce the risks of uncharacteristic wildfires (that is, to reduce wildfire size and severity) it is 

widely understood that wildfires are a natural part of the landscape and will cross jurisdictional 

boundaries in the future. Even so, the Forest Service will continue to work with its neighbors to 

reduce cross-boundary impacts.

The revised Forest Plans provide a programmatic framework for the management of the Malheur, 

Umatilla, and Wallowa-Whitman National Forests. By itself, this programmatic framework will 

not directly impact current national forest uses or conditions without additional project-level 

analysis, decisionmaking, and/or implementation. By design, the revised Forest Plans do not 

directly impact Baker County’s ability to pursue its plans and policies in areas under County 

jurisdiction. To confirm this, the Forest Service reviewed the Baker County Comprehensive Plan 

and found no interrelated impacts or conflicts. As stated in the Baker County Comprehensive 

Plan (p. 34, Goal II, Part H, Other Lands), “Lands managed by the United States Forest Service 

and the Bureau of Land Management are beyond the scope of the County's planning jurisdiction.” 

In contrast with the Baker County Comprehensive Plan, its Natural Resources Plan contains a 

number of policies that are intended to apply to public lands that are beyond the scope of the 

County’s self-defined planning jurisdiction. 

Consideration of the Baker County Natural Resources Plan Objectives

(Baker Plan): 

1. Expansion, revitalization and continuation of multiple uses on all public lands in Baker 

County. 

2. Multiple use shall be inclusive rather than exclusive, thereby avoiding pitting one use 

against the other. 

3. All plans shall mitigate based on multiple use rather than by a resource by resource issue. 

4. Maintain flexibility in all plans to allow for extraction of natural resources from public 

lands and to continue to use existing resources in accordance with all laws. 

5. Protect and preserve the following rights of all County citizens, including:

a. Private property interests, such as water and grazing rights and access to lands, which 

have ties to public lands;

b. Traditional economic structures in the county that form the base for economic 

stability; 

c. Historic custom, culture and values of the local people; and 

d. Enjoyment of the natural resources of the County.

Many of the principles and policies of the Baker Plan are consistent with the social, economic, 

and ecological goals and plan components of the revised Forest Plans. However, there are also 

important differences. Below is a summary of Baker Plan policy statements related to the revised 
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Forest Plans. After each policy statement is a Forest Service response, including an assessment of 

interrelated impacts, a determination of how the revised Forest Plans should deal with the impacts 

identified, and, where conflicts with Forest Service planning are identified, consideration of 

alternatives for their resolution.

Economy: The Baker Plan economic policy is to ensure that economic considerations are taken 

into account when making land management decisions and to minimize any adverse economic 

impacts.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. The revised Forest Plans consider economic values and seeks to 

balance them with social and environmental values.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Access: The Baker Plan’s policy on access is to “...provide access for multiple land uses while 

respecting private property rights as well as utilizing the resources on public lands.” The Baker 

Plan also includes a policy that there will be “no net loss to access” and “no net loss of our open 

roads system.”

Forest Service response: 

• Assessment of interrelated impacts: The revised Forest Plans support access for multiple 

uses. However, a requirement of “no net loss” of open roads is not included in the 

revised Forest Plans. Such a commitment would not be possible at the programmatic 

level of the revised Forest Plans, given the variety of site-specific resource issues (e.g., 

water quality, fish habitat, wildlife habitat) that need to be evaluated before making a sitespecific decision. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

The revised Forest Plans, by themselves, will not change the national forest transportation 

system without further analysis, decision-making, and implementation at the project 

level. The Forest Service will provide additional opportunities for County input at the 

project level.

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Agriculture: The Baker Plan includes a policy to maintain historic stocking rates for federal 

grazing permits. It also includes a policy that historical stocking rates should only be reduced 

under certain conditions: (a) failure to meet range health standards is established on the basis of 

current, on-the-ground monitoring data; (b) failure to meet range health standards is shown to be 

caused by current, as opposed to historic, livestock management practices; and (c) all adaptive 

management approaches have been exhausted.

Forest Service response: 

• Assessment of interrelated impacts: The revised Forest Plans support continued livestock 

grazing. In general, the Forest Service agrees with the County regarding the value of 

current, on-the-ground monitoring data, and the Forest Service considers the 
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contributions of current livestock management practices and the mitigating effects of 

adaptive management approaches. However, the revised Forest Plans do not include a 

requirement to maintain historic stocking levels for federal grazing permits subject to the 

County’s three conditions. The revised Forest Plans do not determine stocking levels; this 

is a site-specific consideration that would not be appropriate at the level of the revised 

Forest Plans. The revised Forest Plans determine areas suitable for livestock grazing, and 

the revised Forest Plans address a variety of resource concerns related to grazing. For 

example, a guideline to address the relationship between riparian vegetation condition 

and grazing in riparian areas identifies annual use indicators and values, such as stubble 

height and woody browse utilization. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Suitability determinations, standards, guidelines, etc. in the revised Forest Plans will 

influence future, site-specific decisions regarding grazing. To address potential impacts, 

the Forest Service considered the input of permittees, counties, and regulatory agencies 

during the planning process. 

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: The Forest Service developed and analyzed a range of alternatives 

for livestock grazing, and Baker County provided input regarding these alternatives. 

Further discussion and clarification at the site-specific level is recommended to resolve 

potential conflicts between plans and policies.

Energy: The Baker Plan’s energy policy is that there will be no new development of energy 

resources unless they directly benefit residents of the County. In addition, there will be no 

development of alternative energy on forested lands.

Forest Service response: 

• Assessment of interrelated impacts: The revised Forest Plans make general suitability 

determinations for energy development but does not restrict the new development of 

energy resources to projects that directly benefit residents of the County. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

There are differences between the Baker Plan policy and federal policy regarding energy 

development on national forests. For example, the Energy Policy Act of 2005 encourages 

energy development in suitable areas and, accordingly, the revised Forest Plans analyze 

wind energy potential across the landscape and determines areas that are generally

suitable for wind energy development. In the future, a proposed wind energy project 

would need to be further analyzed at the site-specific level and follow Forest Service 

procedures for a Special Use permit. To offer another example, new power lines on the 

national forests would also require site-specific analysis and Special Use permits.

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Future energy development proposals on the national forests will 

require additional site-specific analysis and decision-making, and the County will have 

opportunities to comment.

Forest Resources: The Baker Plan’s policy directs that timber harvest should be used to promote 

forest health, prevent timber waste, bolster the economy, and foster a permanent road system. It 

is the County’s policy that “all tree mortality caused by forest fire and pests shall be harvested 

before additional loss of economic value occurs.”
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Forest Service response:

• Assessment of interrelated impacts: The revised Forest Plans are intended to support 

forest health and provide economic benefits. To that end, the revised Forest Plans’ 

proposed Timber Sale Program Quantities would more than double current levels of 

timber harvest. However, fostering a permanent road system is not a desired condition 

for timber harvest in the revised Forest Plans. Further, the revised Forest Plans cannot 

commit that “all tree mortality caused by forest fire and pests shall be harvested before 

additional loss of economic value occurs.” In contrast, the revised Forest Plans include 

desired conditions for snags and post-fire habitat that are based on the natural range of 

variation. Future salvage logging decisions will require site-specific analysis. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

During the planning process, the Forest Service developed and analyzed a range of 

alternatives for timber harvest, including suitable acres and outputs. Baker County 

provided input regarding these alternatives.

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Further discussion and clarification will be needed to minimize 

potential conflicts between plans and policies. Future timber harvest and salvage logging 

projects on the national forests will require additional site-specific analysis and decisionmaking, and the County will have opportunities to provide input.

Invasive Species: The Baker Plan’s policy is to reduce and treat the spread of invasive plant and 

animal species.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. The Forest Service also works to reduce and treat the spread of 

invasive plant and animal species, and the revised Forest Plans support this continued 

effort.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Mining: The Baker Plan’s policy is to foster and encourage mineral development within the 

county. 

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. However, there are broader differences between County policy and 

existing federal policy regarding mineral administration, including the schedule for 

approving mining Plans of Operation, Best Management Practices, mitigation measures, 

and reclamation bonds. The Forest Service manages mining and minerals consistent with 

the General Mining Act of 1872 and associated regulations (e.g., 36 CFR 228). 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

The revised Forest Plans cannot address the potential impacts. 
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• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Further discussion and clarification will be needed to minimize 

potential impacts and conflicts between our plans and policies.

Recreation and Tourism: The Baker Plan supports maintaining or increasing recreational 

opportunities and opposes land use fees or increasing land use fees to participate in recreation 

within the county. 

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. The revised Forest Plans support recreation and tourism, and the 

Forest Service will continue to work with the County to enhance sustainable recreation 

and tourism opportunities. Fees are not a Forest Plan decision.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Special Designations: The Baker Plan includes a policy that no special designations should be 

made within the county unless the county supports the designation (e.g. Recommended 

Wilderness, Wild and Scenic Rivers).

Forest Service response: 

• Assessment of interrelated impacts: Baker County has indicated that it does not support 

special designations in the revised Forest Plans. However, the revised Forest Plans still 

include alternatives with proposed new Recommended Wilderness and Wild and Scenic 

River designations on national forest lands within Baker County. These areas were 

analyzed in accordance with the Wilderness Act, Wild and Scenic Rivers Act, and 

associated federal regulations. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

During the planning process, the Forest Service developed and analyzed a range of 

alternatives for Recommended Wilderness and other special designations. Baker County 

and many others provided input on these alternatives, and the Forest Service made 

adjustments to the revised Forest Plans. For example, the Recommended Wilderness 

areas in the revised Forest Plans have been allocated predominantly within pre-existing 

inventoried roadless areas, and boundaries have been drawn to minimize impacts on 

current uses. 

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: The revised Forest Plans include a range of alternatives for special 

area designations that will be considered in the final decision.

Threatened or Endangered Species: The Baker Plan’s policy is that threatened or endangered 

species should be managed in strict accordance with the provisions of the Endangered Species 

Act.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. The revised Forest Plans must comply with the Endangered Species 
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Act. Additionally, the law requires a special review, called “formal consultation,” by the 

U.S. Fish and Wildlife Service and National Marine Fisheries Service to ensure 

compliance with the Act.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Water and Water Rights: The Baker Plan’s policy is that any federal decision affecting water or 

water rights is coordinated with Baker County.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. The Forest Service must comply with State law on water rights.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Watersheds: The Baker Plan’s policy is to sustain economic development and to maintain and 

improve stream, floodplain, wetland, and groundwater functions.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Wildfire: The Baker Plan’s policy is to promptly and effectively respond to wildfires and ensure 

coordination with Baker County on wildfire response.

Forest Service response: 

• Assessment of interrelated impacts: There are no interrelated impacts at the level of the 

revised Forest Plans. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Not applicable

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Not applicable

Wildlife: The Baker Plan’s policy is to mitigate damage caused by wildlife to private land and to 

prohibit establishing wildlife corridors. 

Forest Service response: 
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• Assessment of interrelated impacts: Various Forest Plan components work together to 

encourage wildlife (e.g., elk) to use the national forests and reduce wildlife damage to 

private lands. (Please note: The Forest Service is responsible for providing quality 

habitat for wildlife on national forests, whereas the State Departments of Fish and 

Wildlife are responsible for wildlife populations.) Most Forest Plan alternatives do not 

include wildlife corridors, but Alternatives C and E do include wildlife corridors.

• Determination of how the revised Forest Plans should deal with the impacts identified: 

Baker County asked for no wildlife corridors, while other commenters asked for wildlife 

corridors. In response, the revised Forest Plans include alternatives with and without 

wildlife corridors. 

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Wildlife corridors will be considered in the final decision. If they 

are ultimately included in the final revised Forest Plans, further discussion will be needed 

to minimize potential impacts or conflicts between plans and policies.

Data Quality: The Baker Plan section on Data Quality requires that “all data—environmental, 

economic, and social—used to develop federal land and natural resource use decisions be 

impartial, collected using tested and peer reviewed methods, and current.” The county opposes 

using “computer modeling and other remotely-collected data,” although the county allows for 

these data to supplement monitoring or other on-the-ground data, with the caveat that we state the 

methods, estimate mapping error, and apply methods at the appropriate scale.

Forest Service response: 

• Assessment of interrelated impacts: The Forest Service agrees with the County on the 

principal of data quality and the importance of stating methods, estimating mapping error, 

and applying methods at the appropriate scale. The revised Forest Plans use a variety of 

information sources, including field-collected monitoring and trend data, remotely 

collected data, as well as information derived from computer modeling programs that use 

both remotely and field-collected data. 

• Determination of how the revised Forest Plans should deal with the impacts identified: 

The Forest Service acknowledges the County’s opposition to “computer modeling and 

other remotely-collected data.” However, using only on-the-ground data would not be 

practical at the level of the revised Forest Plans. Given the need to aggregate information 

across an approximately five million acre planning area, computer modeling and 

remotely collected data are appropriate.

• Where conflicts with Forest Service planning are identified, consideration of alternatives 

for their resolution: Further discussion may be needed to minimize potential impacts or 

conflicts between plans and policies.

Comment Letters from Native American Tribes

and Federal, State, and Local Agencies and Governments

The following letters were received during the comment period on the draft environmental impact 

statement from Native American Tribes and Federal, State, and local agencies and governments. 

They are reproduced here in their entirety as required by Forest Service Handbook 1909.15.
Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

Confederated Tribes of the Umatilla 

Indian Reservation

Department of Natural Resources

Administration

46411 Timíne Way

Pendleton, OR 97801

www.ctuir.org ericquaempts@ctuir.org

Phone 541-276-3165 Fax: 541-276-3095

August 29, 2014

Kevin Martin, Forest Supervisor Umatilla National Forest

72510 Coyote Rd.

Pendleton, OR 97801 Dear Kevin:

The Confederated Tribes of the Umatilla Indian Reservation (CTUIR) Department of Natural 

Resources (DNR) appreciates the opportunity to comment on the Draft Environmental Impact 

Statement for the Proposed Revised Land Management Plans for the Malheur, Umatilla, and 

Wallowa Whitman National Forests (DEIS). The DNR appreciates how much the plan has 

improved over the years, however the delays and staff turn-over at the Forest Service has led to 

some staff fatigue of reviewing this plan. Based on the DEIS, the CTUIR DNR believes that 

Alternative C is the appropriate alternative to address treaty reserved rights and resources. 

DNR is concerned that work on cultural resources among the forests remains inconsistent.

General Comments:

Language in the DEIS regarding our comments on Treaty rights was improved and the 

CTUIR appreciates the changes:

The Forest Service has the requirement to manage lands with full consideration of the 

Federal trust responsibilities to tribal rights and to the interests and treaty reserved 

rights and resources of federally recognized American Indian tribes.

However, the language was moved from Chapter 1, page 11 in the May 2012 draft to Volume 3, 

Chapter 4, Page 2, over 700 pages into the document. DNR believes that the document should 

mention Treaty rights in Volume 1, Chapter 1, Page 16-17, in the Legal and Regulatory

Framework section. This section mentions “American Indian reserved rights” but does not 

specifically mention the Treaties that reserve those rights. This might seem trivial to an 

uninformed observer, but under the Constitution of the United States, the Treaty of 1855, 12 

Stat. 945, has the same standing as the Clean Water Act, the Endangered Species Act and the 

National Environmental Policy Act. Article VI of the US Constitution states:

This Constitution, and the laws of the United States which shall be made in pursuance 

thereof; and all treaties made, or which shall be made, under the authority of the United 

States, shall be the supreme law of the land; and the judges in every state shall be bound 

thereby, anything in the Constitution or laws of any State to the contrary 

notwithstanding.
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 3 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

Further, in Volume 3, Appendix D, Laws and Regulations Relevant to Forest Planning, on page 

385 there is a section regarding the Treaty of 1855. The section quotes the CTUIR Treaty of 

1855 but for some reason includes the Nez Perce in the reference. The Treaty of 1855 between 

the tribes that are now the CTUIR is codified at 12 Stat. 945, and on hunting states “the 

privilege of hunting, gathering roots and berries and pasturing their stock on unclaimed lands in 

common with citizens, is also secured to them.” The Treaty with the Nez Perce, 12 Stat. 957, 

states that the tribe reserved “...the privilege of hunting, gathering roots and berries, and 

pasturing their horses and cattle upon open and unclaimed lands.” The language is not very 

different, but it is important to recognize that each treaty is unique and should be treated as 

such. DNR recommends quoting the language from the two treaties separately with the 

appropriate citation to the Statues at Large.

In response to our earlier comments, the DEIS included a sentence that states:

As a Federal agency, the Forest Service’s legal responsibilities are identified in 

treaties and clarified in statutes, executive orders, and case law enacted and 

interpreted for the protection and benefit of federally recognized tribes.

This sentence occurs on page 382 of Volume 2, Chapter 3. Unfortunately, the sentence it was 

to replace is still on page 381, the first sentence in the Tribal and Treaty Resources section. 

Please include the above quoted language in the final EIS. Also, the uncorrected sentence is in 

the Forest Plan itself in Part 1, page 64.

The CTUIR DNR appreciates the inclusion of the section on Culturally Significant Foods in 

Volume 2, Chapter 3, Page 392. However, the section does not include water. Water is one 

of the First Foods and must be included in the section. Also, DNR would appreciate it if you 

included the First Foods in order. The second sentence under the section would read:

These culturally significant foods include water, fish, big game, roots and berries that 

are used for both ceremonies and subsistence needs.

When you identify culturally significant foods, please reference them all and place them in 

this order. It is the order they are ceremonially served in the Longhouse.

Cultural Resources:

This EIS does not contain an adequate analysis of cultural resources. First, the document only 

uses the National Historic Preservation Act for consideration of the resources. The National 

Environmental Policy Act allows for a much broader consideration of cultural resources, 

including those that are not place based. A herd of elk or a species of plant may be important 

cultural resources under NEPA but, lacking a specific footprint, would not be considered under 

the NHPA. Page 427 of Volume II states, “All alternatives would provide management 

direction for cultural resources in a manner consistent with the laws, executive orders, and 

regulations listed previously.” Section 110 of the NHPA requires understanding of all of their 

resources.
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 4 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

The DEIS does not contain the MA 2E lands of the Wallowa-Whitman National Forest which 

precludes a comprehensive understanding of the cultural resources in that Forest. The current 

management practices of the Forests in project specific NEPA is to ask tribes to identify 

properties of religious and cultural significance, a task the CTUIR is unfunded to provide on 

every single NEPA project on Forest Service lands. The Forest Service must develop a 

comprehensive plan to address both archaeological sites as well as traditional cultural properties 

on more than a NEPA specific case-by-case basis. This DEIS is an opportunity to identify areas 

that will be managed specifically to protect cultural resources. The Malheur National Forest has 

acknowledged a mining area to protect, the Umatilla National Forest also protects mining areas 

and a huckleberry gathering area, whereas the Wallowa-Whitman National Forest has not 

designated any MA 2E in this DEIS. With the limited consideration given to cultural resources, 

the plan acknowledges that Alternative C will have the lowest potential for damaging cultural 

resources and that wilderness designations have the best effects on cultural resources.

Table 392 of the DEIS, Volume 2, Chapter 3, Page 427 illustrates problems the forests have with 

managing cultural resources. The Wallowa-Whitman has found more sites not eligible than 

eligible. There is no evidence that criteria other than (d) were used in evaluating archaeological 

sites. The lack of priority assets suggests that heritage resources are really not important to the 

Wallowa-Whitman and the Umatilla National Forests. When the CTUIR asked what criteria 

were used to determine if sites were eligible, CTUIR was informed that “all criteria were 

considered and appropriate consultation was conducted at the time of the determinations” even 

though some of the decisions were made “many years ago.” With the limited communication 

with Wallowa Whitman on cultural resources, the CTUIR is not confident that these eligibility 

determinations were made with the appropriate criteria or that consultation occurred.

The CTUIR is disappointed in how the Forest Service has responded to our comments on 

previous iterations of these plans. Cultural resources comments in particular remain 

unaddressed; no discussion was presented on whether and how the comments have been 

resolved.

Of particular note, the Forest Service failed to take the opportunity presented by the Forest Plan 

to consider and identify areas where energy development is and is not appropriate. Such 

development dramatically impacts cultural and natural resources. In the past we have expressed 

concerns about proposed developments and were told that the Forest Plan is the best place to
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 5 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

address such concerns. Further, the MA 2E category for Historical Areas is treated differently 

through the alternatives in the suitability matrix. For instance, in Table A-45, Energy 

Development is generally suitable under Alternative C, but generally unsuitable under 

Alternatives B, D, E and F. Also, in Table 25 of the Proposed Revised Land Management Plan, 

Energy Development is identified as generally unsuitable in MA 2E. Energy development is 

generally unsuitable in MA 2E.

We have significant concerns regarding the reliance on guidelines rather than standards. The 

CTUIR requires standards so that we can predict what decisions will be made and the impacts of 

those decisions. We have found that guidelines are too nebulous and can be adjusted on a project 

by project basis; this will likely result in impacts to First Foods and other cultural and natural 

resources.

In Volume 3, Appendix D, under Tribal and Treaty Resources the American Indian Religious 

Freedom Act (AIRFA) is identified. Please include in this section reference to the Religious 

Freedom Restoration Act (RFRA), 42 USC §§ 2000bb et seq. RFRA was passed to address, 

among other things, the legal shortcomings identified in AIRFA.

Elk:

While the DEIS addresses elk security and road densities, it does so with a focus on hunting 

season security requirements. Elk security is a year round issue with elk summer distribution 

being effected by spring antler and mushroom hunters and summer recreationists. Elk are being 

pushed out of traditional summer ranges on Forest lands to lower elevation private range lands in 

traditional winter range. This displacement has significant social, political and economic 

impacts. Elk displaced onto private lands are unavailable to tribal hunters exercising treaty 

retained rights to hunt on “open and unclaimed lands”. More emphasis should be in the DEIS 

and the Forest Plan to preserve elk security habitat.

Bighorn sheep:

The CTUIR strongly supports the measures in the DEIS to address issues of contact and disease 

transmission between domestic and wild bighorn sheep. In particular we support the use of a 

science based risk of contact assessment similar to the Payette protocol. We also appreciate the 

clear standards and guidelines relative to protection of bighorn sheep. Alternative C appears to 

provide the greatest level of protection for this important species and we encourage the inclusion 

of a foray distance of 35 km in the determination of lands suitable for domestic sheep grazing 

and trailing in the selected alternative. The following comments reflect the work of the CTUIR in 

collaboration with state and tribal wildlife managers and other advocates for big horn sheep in 

the region. The language in bold is included in the DEIS or Forest Plan.

Any selected alternative should identify and map all habitat that is unsuitable for domestic sheep 

grazing. All currently unoccupied bighorn sheep habitats should be classified as unsuitable for 

domestic sheep and goat grazing and trailing in the selected alternative. In order to maintain
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 6 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

viability populations of bighorn sheep, the standards and guidelines for Range Management 

and Domestic Livestock Grazing must be expanded and clarified. Specifically as follows:

RNG-9 Standard

Domestic sheep or goat grazing shall not be authorized or allowed on lands where 

effective separation from bighorn sheep cannot be reasonably maintained.

This standard does not define what “effective separation” between domestic and bighorn 

sheep means. It should clarify that in determining “effective separation” a quantitative risk 

assessment such as the one referenced in the August 19, 2011 USFS Washington Office 

Directive from the Deputy Chief, National Forest System, must be used. A qualitative 

assessment is not good enough.

RNG-10 Standard

The use of domestic goats or sheep for manipulation of vegetation (i.e., noxious weed 

control, fuels reduction) shall not be authorized or allowed within or adjacent to 

source habitat for bighorn sheep.

“Source habitat” should be defined in the forest plan glossary.

RNG-11 Standard

The use of recreational pack goats shall not be authorized or allowed within or adjacent 

to source habitat for bighorn sheep.

“Adjacent” need to be defined. What size buffer will be placed on source habitat? The 

literature supports 23 km?

How will the public be notified of this restriction? Will be signs be placed at trailheads?

The forest plans should implement a free use permit/registration system requiring activities 

that minimize risk and control of pack goats at all times (such as highlining or tethering at 

night).

This would be a cost effective way to make pack goat users implement good practices and 

make them aware of the risks to bighorn sheep. If such a system is not but in place pack goats 

should be banned.

This standard should be expanded or a new standard drafted requiring any contact 

between recreational pack goats and bighorn sheep be reported.

RNG-12 Standard
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 7 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

An effective monitoring program shall be in place to detect presence of bighorn sheep in 

identified high-risk areas when authorized domestic sheep or goats are present on 

adjacent or nearby allotments.

What “effective monitoring” is must be defined in the standard or glossary. Fly-overs are the 

most effective way to monitor. The standard must require that monitoring occur prior to the 

turn out date. Waiting until the last minute/day before turn out is not enough. The monitoring 

timeframe should be based on weather and terrain. The Forest Service should coordinate with 

state agencies on monitoring, sharing data.

How will high-risk areas be identified? This should be modeled and mapped as part of the 

forest plan revision process and incorporated into the final forest plans.

How will domestic strays be monitored for? If monitoring does not pick up strays then it is 

not effective.

RNG-13 Guideline

Trailing of domestic sheep or goats should not be authorized or allowed within 7 miles 

of bighorn sheep home ranges

This should be a standard. “Should” changed to “shall”. This is an opportunity for 

domestic straying.

Standard should require compliance monitoring by the permittee and the Forest Service 

during trailing activities, this would minimize strays.

Where did the 7 mile distance come from? The separation distance should be biologically 

justified and ensure that bighorn sheep have minimal risk of contact with domestic sheep. The 

literature supports a greater distance.

If this distance cannot be obtained, then trucking should be used rather than trailing.

RNG-14 Standard

When effective monitoring has not been conducted for bighorn sheep presence, 

domestic sheep or goat grazing shall not be authorized.

This standard should be a part of RNG-12; see comments for RNG-12

RNG-15 Standard

Permitted domestic sheep and goats shall be counted onto and off of the allotment by 

the permittee. A reasonable effort to account for the disposition of any missing sheep 

must be made by the permittee.

Permitted domestic sheep and goats should be counted on and off using pit tags and an 

automatic counter. This would also permit the identification of responsible permittee should a 

stray be found.
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 8 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

This standard must be expanded to define what a reasonable disposition of missing sheep 

means. The most effective method would be a fly over.

The permittee should be required to develop a written agreement with relevant federal and 

state wildlife and agricultural agencies (such as the U.S. Fish and Wildlife Service and 

Oregon Department of Agriculture) that addresses the retrieval and disposition of stray 

domestic sheep on public lands. E.g. U.S. Fish and Wildlife Service will do a fly over.

The standard must state what will happen to the missing sheep if found. The permittee should 

be required to coordinate with the Oregon Department of Agriculture to deal with the missing 

sheep - they are the state agency with authority over domestics.

RNG-16 Standard

When permitted sheep are found to be missing, the Forest Service shall be notified 

within 24 hours.

The Forest Service is not able to deal with missing sheep. The permittee should also be 

required to notify the relevant agencies and implement the agreement discussed above.

RNG-17 Standard

Authorized domestic sheep or goats shall be individually marked in a manner that allows 

immediate identification of ownership at a distance during the grazing season at all times 

while on NFS lands.

Including this standard in the adopted forest plans is essential to managing viable populations 

of bighorn sheep across NFS lands in the Blue Mountains. If a sheep is found off allotment it 

is essential that the responsible permittee can be identified.

RNG-18 Standard

Implement emergency actions when bighorn sheep presence is detected within 7 miles 

of active domestic sheep or goat grazing or trailing. Actions to be taken shall ensure 

separation between bighorn sheep and domestic sheep or goats.

The 7 miles distance must be biologically justified in the forest plan analysis; see comments 

to RNG-13.
CTUIR DNR Letter to Kevin Martin Subject: 

Three Forest Plan Revision

August 29, 2014

Page 9 of 8

Treaty June 9, 1855 ~ Cayuse, Umatilla and Walla Walla Tribes

An emergency action plan must be part of any EA developed for domestic sheep/goat 

allotment adjacent to source habitat/core home ranges. This emergency action plan must be 

incorporated into Annual Operating Instructions (AOI) for grazing allotments and trailing 

permits

RNG-19 Guideline

To maintain separation, when bighorn sheep are found within 7 miles of an active 

domestic sheep and goat allotment, implementation of emergency actions for domestic 

sheep and goat grazing could include:

Reroute (move) domestic sheep or goats to a new routing path that will take them 

away from the likely bighorn movement; this may involve rerouting within the 

permitted allotment, movement to a different allotment, or, if the situation cannot 

otherwise be resolved, moving the permitted sheep off of the national forest until the 

situation can be resolved.

Inform the appropriate state agency of the bighorn sheep location

Actions that reroute or move domestics should be considered prior to a state agency taking 

action. It is Idaho policy and common practice in Oregon to shoot a foraying bighorn sheep 

ram. Bighorn sheep should not be killed if alternative actions can be taken to ensure that 

separation is maintained.

New standards should be drafted to address the issue of diseased domestic sheep. The forest 

plans should contain a standard should require that sick or diseased animals on range be 

reported to land management or wildlife agency personnel as soon as possible after 

recognition; after that initial notification, inter-agency coordination should promptly occur. 

New standards should also be drafted to address stocking of allotments not currently under 

permit to domestic sheep and goats should only be permitted after an adequate quantitative risk 

assessment has been completed.

Conclusion

Overall, the document has greatly improved. Due to time constraints we were not able to 

review every element of the Forest Plan and DNR looks forward to meeting with the Forest 

Service to discuss our issues, concerns, and recommendations for improving consistency 

among the Forests in identifying and protecting cultural resources. Thank you.

Sincerely,

Eric Quaempts, 

Director Department of Natural Resources
Nez Perce Tribal Executive Committee

August 15, 2014 

Blue Mountains Forest Plan Revision Team 

P.O. Box 907 

Baker City, Oregon 97814 

By Electronic Mail 

(http://www.fs.usda/gov/goto/BlueMountainForestP'lanRevisionComments)

Re: Nez Perce Tribe's comments on the Blue Mountains National Forests Proposed Revised 

Forest Plan and Draft Environmental Impact Statement.

Dear Sir or Madam: 

On behalf of the Nez Perce Tribe (Tribe), thank you for the opportunity to comment on the Blue 

Mountains National Forests Proposed Revised Forest Plan (Forest Plan) and Draft Environmental 

Impact Statement (DEIS). This letter and the attached comments represent the comments of the 

Tribe. 

As described in the Blue Mountains DEIS, the proposed action is a revision of the land 

management plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests (collectively 

referred to as the Blue Mountains). The proposed Forest Plan includes revised goals, objectives, 

standards; guidelines, suitable uses and activities, management area designations including special 

areas, and monitoring items. The proposed Forest Plan aims to modernize the existing forest plan 

so that it will more adequately address present-day forest management issues. 

Specifically, the proposed Forest Plan aims to better protect the aquatic and terrestrial environment, 

manage fuels and fire risk, address climate change, and recognize the interdependency of social and 

economic components with national forest management. To accomplish these goals, the Forest Plan 

addresses issues pertaining to ·access, economic and social well-being, livestock grazing and 

grazing land vegetation, old forest, recommended additions to the national wilderness preservation 

system, and ecological resilience. Pursuant to these specific issues, the Forest Service developed 

six alternatives (A-F) from which a preferred alternative was chosen. While the Forest Service has 

chosen alternative E as its preferred alternative, the Tribe prefers that alternative C is chosen for the 

final Forest Plan.
Blue Mountain Forest Plan Revision Team 

August 15, 2015 

Page 2 

As the Forest Service is aware, the Tribe has occupied and used much of the present-day Wallowa 

Whitman and Umatilla National Forests for subsistence, cultural, religious, and economic purposes 

since time immemorial. Much of these forests are located within territory subject to the Tribe's 

1855 Treaty with the United States, as well as lands the United States, through the Indian Claims 

Commission, has determined to be the exclusive use and occupancy area of the Tribe. The Tribe 

has a substantial interest in ensuring that the Forest Service, as an agency of the United States, 

discharges its responsibilities for management of the National Forests in a manner that fully honors 

and safeguards the rights the Tribe reserved, and the United States secured, by treaty over 150 

years ago before there was a National Forest or States of Oregon and Washington. 

The Tribe is also a co-manager of its treaty-reserved resources. Given the Tribe's enormous stake in 

ensuring that its members may continue to access and exercise treaty rights on the National Forest 

and other areas within the Tribe's aboriginal territory for future generations, the Tribe devotes 

substantial time, resources, and effort into restoring fish and their habitat on the National Forest. 

The Tribe's restoration efforts in Northeast Oregon have rebuilt extirpated fish runs and improved 

miles of fish habitat through passage improvement, riparian restoration and sediment abatement. 

These improvements not only benefit the Tribe, but also the general public that reside near or travel 

to the National Forest. 

Following a careful review of the Forest Plan and DEIS, the Tribe concludes that Alternative C, 

with additional recommendations provided in the attached comments, is the Tribe's preferred 

alternative because it is most protective of, and consistent with, the Tribe's treaty-reserved rights, 

interests and priorities. It follows that the Tribe does not support alternative E, the Forest Service's 

preferred alternative, because, for the reasons discussed in the attached comments, that alternative 

inadequately protects and advances the Tribe's rights and interests. 

The Tribe, by this letter, requests, in accordance with applicable federal laws and executive order, 

formal consultation with the Forest Service so that the Forest Service may discuss how the Tribe's 

comments will be addressed sufficiently in advance of any decision the agency makes on the Forest 

Plan. 

Thank you again for the opportunity to comment on this matter. Please contact Michael Lopez, 

Staff Attorney, Nez Perce Tribe Office of Legal Counsel, at (208) 843-7355 with any questions. 

The Forest Service is also welcome to contact Rachel Edwards, Executive Assistant, Nez Perce 

Tribal Executive Committee, at (208) 843-2253 to schedule a consultation. 

Sincerely,

Silas C. Whitman 

Chairman
2

NEZ PERCE TRIBE'S COMMENTS ON THE BLUE MOUNTAINS NATIONAL

FORESTS PROPOSED REVISED LAND MANAGEMENT PLAN

AND DRAFT ENVIRONMENTAL IMPACT STATEMENT

I. GENERAL COMMENTS

a. The Nez Perce Tribe's Interest in the Blue Mountains National Forests Proposed 

Revised Land Management Plan

Since time immemorial, the Nez Perce Tribe (Tribe) has occupied and used over 13 million 

acres of land now comprising north-central Idaho, southeast Washington, northeast Oregon, and 

parts of Montana. Tribal members engaged in fishing, hunting, gathering and pasturing across 

their vast aboriginal territory, and these activities still play a major role in the subsistence, 

culture, religion, and economy of the Tribe. 

In 1855, the United States entered into a treaty with the Tribe. Treaty of June 11, 1855 with the 

Nez Perces, 12 Stat. 957 (1859). In this treaty the Tribe explicitly reserved, and the United 

States secured, among other provisions, a permanent homeland as well as, in Article III, " the 

right to fish at all usual and accustomed places in common with citizens of the Territory; and of 

erecting temporary buildings for curing, together with the privilege of hunting, gathering roots 

and berries, and pasturing their horses and cattle upon open and unclaimed lands.” Id. Article 

II of the Treaty described the Tribe’s exclusive use Reservation: it encompassed all of present 

day Wallowa County, and includes much of the lands and waters comprising the WallowaWhitman and Umatilla National Forests. Article I of the Treaty described the even larger Nez 

Perce aboriginal territory that was in part ceded, which naturally included, much of the lands 

and waters of the Umatilla and Wallowa-Whitman National Forests.

3 By contrast, for example, 

the lands ceded to the west in the Confederated Tribes of the Umatilla Indian Reservation 

(CTUIR) 1855 Treaty are by definition bounded on the east by the ceded area of the Nez Perce 

1855 Treaty, emphasizing the distinct aboriginal territories of respective tribes. 

This is important. There are no “joint use” tribal rights within the aboriginal lands that the Nez 

Perce Tribe alone ceded to the United States under Article I of the Nez Perce Treaty of 1855. 

Nor are there any "joint use" areas with any other tribe within the lands reserved by the Nez 

Perce Tribe as its "exclusive use" Reservation in Article II of the Nez Perce Treaty of 1855. 

And the Tribe's treaty-based boundaries for both homeland and aboriginal territory encompass 

much of the Umatilla and Wallowa-Whitman National Forests. 

The 1855 Walla Walla Treaty Council minutes memorialize this. No other treaty tribes were 

included within the exclusive Nez Perce Reservation because it was “Nez Perce country”: the 

lands being ceded, and reserved, by the Nez Perce were “their land” and, for example, the three 

CTUIR tribes instead requested a reservation “in their own country.” 18 Ind. Cl. Comm. 1, 

110-11 (1967); see Bureau of Indian Affairs, Certified Copy of the Original Minutes of the 

Official Proceedings at the Council in Walla Walla Valley, which culminated in the Stevens 

Treaty of 1855, pp. 34-39. The 1967 decision of the Indian Claims Commission (ICC) in its 

determination of the geographic area of Nez Perce aboriginal title and exclusive use is 

additionally instructive. The ICC was created by Congress in 1946 to hear claims by Indian 

tribes for, among other things, inequitable compensation for the taking of aboriginal lands by 

 3 The 1863 Nez Perce Treaty by express terms did not abrogate but was instead 

"supplementary and amendatory" of the 1855 Treaty: it reduced the size of the land reservation, but otherwise preserved "all 

the provisions" not "specifically changed," including the 1855 Article III fishing rights. 14 Stat. 647, Preface and Article VIII.
the United States. Compensation for aboriginal title required proof of “actual and exclusive 

use and occupancy ‘for a long time’ prior to the cession, transfer, or loss of the property.” 18 

Ind. Cl. Comm. 1, 128 (citations omitted). 

In its Nez Perce decision, the ICC made comprehensive findings, based on detailed competing 

anthropological evidence from the Nez Perce Tribe and the United States, of the area of 

exclusive use and aboriginal ownership of the Nez Perce Tribe. The Nez Perce exclusive 

use/aboriginal title area found by the ICC includes, and far surpasses, all of present day 

Wallowa County, and all of the lands and waters of this project area. Id. at 117-18. It is notable 

that even the United States’ adversarial expert in the case reported that, for example, Cayuse 

and other friendly Indians fished in the Wallowa Valley in summer only “by the permission of 

the Nez Perce,” in what was “Nez Perce country.” Id. at 110; see also U.S. v. Oregon, 29 F.3d 

481, 487 (9th Cir. 1994) (relying on ICC’s 1967 Nez Perce Tribe decision for historical 

determination of Nez Perce Tribe’s 1855 Treaty fishing rights). “Exclusive use” could 

encompass friendly permission, but it meant the power to exclude. No other tribes were 

permitted to use the territory the ICC found to have been exclusively Nez Perce. 

The ICC concluded its finding of Nez Perce exclusive use in what is now Northeast Oregon by 

stating, “The Nez Perce were clearly the dominant tribe. Their population was much larger 

than any of these three tribes to the west. But they were friendly and there was much 

intermarriage. The Nez Perce had a definite sense of territorial ownership of the lands used and 

occupied by them.” Id. at 111. The ICC’s finding of exclusive use in Northeast Oregon was 

one of the several findings that supported its final conclusion: “[T]he Nez Perce Tribe of 

Indians had exclusively used and occupied continuously for a long time the following described 

area in the present states of Oregon, Washington and Idaho” – which then describes an area 

encompassing all of north-central Idaho, northeast Oregon and southeast Washington, naturally 

including all of present day Wallowa County and all of the lands and waters of this project area. 

Id. at 117-18.

These project lands and waters provide irreplaceable habitat for tribal resources, including 

Snake River Basin Spring/Summer Chinook salmon, Snake River Basin steelhead. These and 

other aquatic resources are subject to the exercise of the Tribe’s treaty-reserved rights. See e.g., 

Sohappy v. Smith, 302 F. Supp. 899 (D. Or. 1969), aff’d, United States v. Oregon, 529 F.2d 570 

(9th Cir. 1976); Washington v. Washington State Commercial Passenger Fishing Vessel Ass’n, 

443 U.S. 658 (1979) (Fishing Vessel).

The treaty-reserved right to take fish and other resources reserved by the Tribe presumed the 

continued existence of those resources. See Fishing Vessel at 678–79. Thus, the Treaty secures 

to the Tribe the continued existence of those biological conditions necessary for the resources 

that are the subject matter of the treaties. See Kittitas Reclamation District v. Sunnyside Valley 

Irrigation District, 763 F.2d 1394 (9th Cir. 1985), cert. denied, Sunnyside Valley Irrigation 

District v. United States, 474 U.S. 1032 (1985). Harm to these resources and their habitat will 

harm the Tribe and its members.

Treaty tribes, such as the Nez Perce, have been recognized as managers of their treaty-reserved 

resources. U.S. v. Washington, 384 F. Supp. 312, 339-40, 403 (W.D. Wash. 1974). As a 

manager, the Tribe has devoted substantial time, effort, and resources to the recovery and comanagement of treaty-reserved resources within its treaty territory.
The lands and waters of the Wallowa-Whitman and Umatilla National Forests are part of the 

Tribe’s vast aboriginal and treaty lands, over which the Tribe has treaty-reserved rights. The 

proposed Blue Mountains Forest Plan (Forest Plan) and Draft Environmental Impact Statement 

(DEIS) encompasses a significant part of the Tribe’s aboriginal territory, including but not 

limited to much of the Wallowa-Whitman and Umatilla National Forests. These National 

Forest System (NFS) lands and waters provide irreplaceable habitat for tribal treaty resources 

including Spring/Summer Chinook salmon, Endangered Species Act (ESA) threatened 

steelhead and bull trout, elk, deer, and bighorn sheep.

In reviewing the Forest Plan, the Tribe was disappointed to see that the Tribe’s 1855 Treaty (12 

Stat. 957) was not explicitly identified or adequately described in the Legal Framework section. 

Although this section states that “[t]he revised forest plans will continue to honor American 

Indian reserved rights through consultation and coordination,” the Forest Service fails to 

identify these “reserved rights” as rights reserved in the Tribe’s 1855 Treaty with the United 

States which are “the supreme law of the land” under Article VI (the Supremacy Clause) of the 

United States Constitution.

In addition, the Tribe was unable to identify any explicit reference or description of the Tribe’s 

1855 Treaty in the proposed Forest Plan or DEIS. The Tribe observes that the sections in 

Appendix D labeled “Tribal and Treaty Resources” and “Heritage Program,” while identifying 

some congressional legislation addressing American Indian interests, provides no reference at 

all to the 1855 Treaty.

Although the Tribe appreciates the Forest Service including a "Tribal Rights and Interest" 

section in the Forest Plan and "Tribal and Treaty Resources" Section in the DEIS, these sections 

provide vague and inadequate references to the Tribe's history and treaty rights. The sections 

also inappropriately lump tribes' treaties together without providing any individual attention or 

precision to the language of those treaties or their application to the National Forest. The Tribe 

requests that the Forest Service reflect the Tribe's 1855 Treaty accurately by describing the 

Article III language, noted above. The Tribe also requests that the Forest Service acknowledge 

in the document the 1855 Treaty's primacy under the Supremacy Clause of the United States 

Constitution. Finally, the Tribe asks that the Forest Service recognize and describe the Tribe's 

unique and legally-protected relationship with the Wallowa-Whitman and Umatilla National 

Forests as described above. 

Moreover, in the Desired Conditions subheading in the “Roads and Trails Access” section in 

the Forest Plan, the Tribe observes that the document inadequately addresses Tribal access for 

treaty-reserved purposes. The document states: “[t]he need for tribal access to traditional sites 

is acknowledged and supported.” The Tribe appreciates the agency’s acknowledgement and 

support for tribal access to traditional sites. The tribes’ rights to believe, express, and exercise 

their traditional religions (including having access to sites, use and possession of sacred 

objects, and the freedom to worship through ceremonial and traditional rights) are also 

protected by law. The Forest Plan should also include an express acknowledgement of, and 

support for, access for exercise of treaty-reserved rights. The Tribe requests that the Forest 

Service include language stating that tribal members exercising treaty rights will be 

accommodated.

The Forest Service has acknowledged the Tribe and the Forest Service’s relationship in 

memoranda of understandings/agreements including the Memorandum of Agreement between 

the Forest Service and the Tribe “Establishing a Cooperative Relationship to Facilitate Exercise 
of the Treaty Reserved Pasturing Rights set forth in the 1855 Treaty with the Nez Perce Tribe” 

and the Memorandum of Understanding between the Forest Service and the Tribe waiving 

camping fees and stay limits.

Finally, under the Social and Economic Well-Being Section in the Forest Plan, the Tribe 

observes that the Forest Service appears not to take into account the Tribe’s participation in and 

contribution to the economy of the Blue Mountains National Forests. The Tribe sees, for 

example, that treaty-reserved resources (fish, game, roots and berries, etc.) are not included 

among the Goods and Services or Forest Products subheadings in the Forest Plan. Instead, the 

Forest Service characterizes goods and services to include wood for sawmills, forage for 

livestock, water for irrigation, recreation, and minerals. Moreover, the Social and Economic 

Well-Being part of the Methodology Section in Appendix B of the DEIS reveals that county 

economies, but not the Tribe’s economy, were the sole metrics considered for the analysis.

As the Forest Service is well aware, the Tribe has a substantial and growing presence in the 

Blue Mountains National Forests economy. The Tribe’s Department of Fisheries Resource 

Management has an office located in Joseph, Oregon with several tribal and non-tribal 

employees who reside year-round and seasonally in the area. There are 18 full time employees, 

most of whom are professional level staff (requiring a college degree), and about seven 

seasonal technicians working out of the field office. In addition we have four harvest monitors 

and two Conservation Enforcement officers staying in Joseph area locations during the spring 

chinook fishing season (these individuals can also be expected to buy goods in the area and the 

enforcement officers would use lodging as well). The Tribe brings in a number of contracts to 

do work out of the Joseph Office, totaling about $1.8 million annually. The work includes 

hatchery production on the Lostine and Imnaha rivers, steelhead and chinook monitoring in the 

Lostine and Imnaha and tributaries and watershed restoration work throughout Wallowa 

County. The Tribe requests that the Forest Plan and DEIS consider the Tribe’s contributions of 

millions of dollars to the local Blue Mountains economy through jobs, taxes, goods and 

services.

b. The National Forest Management Act: The Importance of Standards

The National Forest Management Act (NFMA) guides Forest Service management of the 

national forests. It sets out both procedural and substantive requirements that the Forest Service 

must comply with while fulfilling its directive under the Organic Act. Procedurally, NFMA 

requires the Forest Service to develop forest management plans for every unit of the NFS. 

National Forest Management Act 16 U.S.C. § 1604(a). These forest management plans set out 

the specifics for how each forest will comply with NFMA. Substantively, NFMA requires the 

Forest Service to achieve a number of conservation objectives. 16 U.S.C. §1604(g)(3). NFMA 

provides the foundation and boundaries for national forest management, while forest plans 

provide a specific path to accomplish the requirements of NFMA.

The substantive requirements of NFMA require the Forest Plan to contain clear standards and 

guidelines that "insure" the protection of the environment. 16 U.S.C. §1604 (c). Courts have 

long held that standards are clear and enforceable requirements. Miller v. U.S., 163 F.3d 591, 

594 (9th Cir. 1998). Courts have consistently viewed guidelines as non-enforceable, 

discretionary regulations. Id. But the use of suggestive language like "should" and "may", as 

opposed to "shall" or "must" is enough for courts to find that a standard or guideline is not a 

mandatory requirement. Ecology Center v. Castaneda, 574 F.3d 652,661 (9th Cir. 1998). If 

guidelines supplant standards or if standards contain discretionary or vague language, then the 
Forest Service, under the rubric of management flexibility and adaptability, often sacrifices 

enforceability and accountability to the tribal and general public for the agency's 

decision-making affecting National Forest lands. 

From the Tribe’s perspective standards are an extremely important element of the Forest Plan 

because they are legally required by NFMA, provide legal accountability for actions on the 

Forest, and increase forest management consistency and predictability. NFMA legally requires 

standards to be included in forest plans in order to insure environmental and natural resource 

protection. 16 U.S.C. §1604. Standards also provide accountability on part of the Forest 

Service to stick with the direction and policies of the Forest Plan. Finally, this accountability 

creates consistent and predictable management decisions, which are extremely important to 

resource users and co-managers. While the Tribe understands standards may in some instances 

limit agency flexibility, the Tribe believes agency accountability, consistency, and predictability 

overwhelmingly weigh in favor of creating meaningful, enforceable standards.

Given the Forest Service's stated commitment to honoring tribal treaty rights and interests, the 

Tribe formally requests that the Forest Service include a standard in the Forest Plan that fully 

reflects this commitment. The current Clearwater National Forest Plan contains the following 

standard: "Ensure that Forest actions are not detrimental to the protection and preservation of 

Indian Tribes' religious and cultural sites and practices and treaty rights." The Tribe requests 

that this same language be included as a standard in the Forest Plan. In addition, since, as the 

Forest Plan states, treaty rights are often honored through agreements and consultation and 

coordination with affected Indian tribes, the Forest Plan should also include the following 

language which is also in the current Clearwater National Forest Plan: "Insure proposed 

practices and management activities are coordinated with Indian tribes to insure requirements 

of all laws and regulations are met and terms of Indian Treaties are upheld." 

The Tribe believes that incorporating the above language as standards in the Forest Plan will 

not only greatly assist the Forest Service with honoring its commitment to protecting tribal 

treaty rights, but also establish a reasonable and consistent framework for Forest Service line 

officers to coordinate and facilitate the protection of treaty rights into agency decision-making. 

c. NEPA

The National Environmental Policy Act (NEPA) is America's basic "charter for protection of 

the environment." 40 C.F.R. § 1500.l(a). NEPA serves two purposes: (1) "it ensures that the 

agency, in reaching its decision, will have available, and will carefully consider, detailed 

information concerning significant environmental impacts," and (2) it "guarantees that the

relevant information will be made available" to the public so it may play a role in the

decision-making process. Robertson v. Methow Valley Citizens Council, 490 U.S. 332,349 

(1989). 

Under NEPA, federal agencies must take a "hard look" at the environmental consequences of 

their actions before action is taken. Blue Mountains Biodiversity Project v. Blackwood, 161 F.3d 

1208, 1211 (9th Cir. 1998). Taking a hard look requires the agency to provide "a reasonably 

thorough discussion of the significant aspects of the probable environmental consequences." 

California v. Block, 690 F.2d 753, 761 (9th Cir. 1982). The hard look doctrine bars "[g]eneral 

statements about 'possible effects' and 'some risk' ... absent a justification regarding why more 

definitive information could not be provided." Neighbors of Cuddy Mountain v. US. Forest 

Serv., 137 F.3d 1372, 1380 (9th Cir. 1998). This "ensures that important effects will not be 
overlooked or underestimated only to be discovered after resources have been committed or the 

die otherwise cast." Robertson, 490 U.S. at 349. 

In reviewing the DEIS, the Tribe has concluded that the Forest Service fails to adequately 

evaluate the Forest Plan's impacts on treaty rights and interests. The Tribe requests that the 

Forest Service explain in further detail, including providing empirical support in the DEIS, its 

determination that "[a]ll alternatives ... would provide protection for habitat and watershed 

conditions that would contribute to species viability at sustainable and harvestable levels." As 

the Tribe's comments indicate below, the Tribe has several concerns with proposed 

management as described in the Preferred Alternative that we believe will negatively affect 

tribal treaty resources in the short and long term. 

II. SPECIFIC COMMENTS

a. Fisheries, Aquatic Habitat, and Riparian Areas.

1. Proposed Change From Riparian Habitat Conservation Areas To Riparian Management

Areas

The Tribe is concerned with the proposed change of Riparian Habitat Conservation Areas 

(RHCAs) to Riparian Management Areas (RMAs). This will likely lead to much more active 

management within these sensitive areas than is scientifically supported and could cause 

damage to treaty resources. It seems that there is much less ecological justification than the 

Forest has alluded to in their analysis. One only needs to look to a nearby Forest, also 

conducting analysis to find much different conclusions. For example, the June 2014 Nez Perce 

- Clearwater Forest Plan Assessment (Pg. 1-123, 1-124) comes to this conclusion: "Scientists 

interested in interactions between fire and the aquatic environment recognize that vegetation 

treatments may need to take place in some altered ecosystems of the Pacific Northwest, 

especially considering current and future effects of climate change (Bisson et al. 2003; Noss et 

al. 2006; Reeves et al. 1995; Rieman and Clayton 1997; Rieman et al. 2000; Everest and 

Reeves 2007; Luce et al. 2012). Public land managers often display a need for treatment in 

riparian areas by identifying fuel accumulations and the potential for severe wildfire. To date, 

justification for treatments in riparian reserves is based on anecdotal information or 

information gained from studies on forest harvest and forest fire (Stone et al. 2010). 

Consequently, considerable social and scientific debate occurs regarding the need to treat 

riparian forests because of Juel accumulation (Rhodes and Baker 2008; Stone et al. 201 OJ. 

Ecological justification for treatments in riparian reserves has yet to be supported by empirical 

evidence, because few studies in the literature are specifically designed to address this question 

(Arkle and Pilliod 2010; Stone et al. 201 OJ. 

Given that the positive and negative impacts of riparian fuel treatments remain largely 

undocumented in the literature, additional experimental studies of fuel treatment effects on 

aquatic and riparian ecosystems are needed before generalizations can be made across 

different forest types and local conditions (Dwire et al. 201 O; Stone et al. 201 OJ. Therefore,

proposals to treat fuels within riparian reserves should proceed with caution (emphasis 

added). When developing fuel treatments that consider the aquatic environment, the potential 

for success may be greater when particularly damaging roads are decommissioned (Rieman 

and Clayton 1997). Where habitat is less degraded, researchers suggest mimicking natural 

disturbances, avoiding simplistic treatments, and maintaining a strong focus on 
experimentation and monitoring (Reeves et al. 1995; Rieman and Clayton 1997; Gresswell 

1999; Bisson et al. 2003; Luce and Rieman 2010; Arkle and Pilliod 2010)."

Given the above information, and that much of it comes from Forest Service research, it seems 

that the Forest's desire to create RMAs is premature based on the available science. The Tribe 

suggests leaving RHCAs in place and conducting further study to determine if a different status 

is warranted in the future. The Forest should take a much harder look at the proposed change of 

RHCAs to RMAs before proceeding. 

2. RHCAs, Standards, And Guidelines

In Volume 1, pg. 271 of the DEIS the Forests state that "the most persistent and widespread 

water quality concern for all three national forests is high stream temperatures during low 

flows in summer. High summer air temperatures, changes in stream surface shading caused by 

Forest Service management activities (emphasis added), and low flows are important factors 

contributing to warmer water." On page 272 of the DEIS the Forests admit that "Water quality 

has improved in recent years as a result of changes in management motivated by direction in 

PACFISH and INFISH, implementation of water quality best management practices (BMPs), 

direction in the Regional Aquatic Restoration Strategy, fish recovery plans, and through 

partner investments. Examples include increased emphasis on protecting streamside areas to 

reduce impacts to shade producing vegetation, repairing and removing unstable roads, and 

diverting acid mine discharge into off-stream settling ponds. “Yet, in the development of the 

forest plan revision the Forests have stepped away from following the direction of PACFISH 

and INFISH and rather than protecting riparian habitats through RHCAs are attempting to 

secure measures through designation of RMAs that would allow more active management 

within these proven sensitive areas. The draft Forest Plan needs to be adjusted to designate 

riparian areas as RHCAs and the following guidelines need to be changed to standards. 

Additional standards should be added to the Forest Plan Revision to achieve the direction and 

intent of PACFISH and INFISH. 

3. Timber Management in RHCAs

PACFISH is very clear in prohibiting timber harvest (TM-1), including non-Indian fuelwood 

cutting in RHCAs except under very limited circumstances caused by catastrophic events and 

after ecosystem analysis at the watershed scale has been completed. Silvicultural practices for 

RHCAs may be used to acquire desired vegetation characteristics where needed to attain 

Riparian Management Objectives. In the proposed Forest Plan, the direction and intent of

PACFISH has been marginalized, opening Riparian Habitat Conservation Zones to all manner 

of manipulation which may harm treaty rights and resources. The following "guidelines" in the 

Draft Blue Mountain Forest Plan should be changed to "standards" and read as follows: 
MA 4B RMA-FOR-1 S-112. STANDARD Timber harvest and thinning will occur in RMAs 

only as necessary to maintain, restore or enhance conditions that are needed to support aquatic 

and riparian dependent resources. 

MA 4B RMA-FOR-3 S-113. STANDARD New landings, designated skid trails, staging or 

decking shall not occur in RMAs, unless there are no reasonable alternatives, in which case 

they shall:

 be of minimum size

 be located outside the active floodplain

 minimize effects to large wood, bank integrity, temperature, and sediment levels

4. Timber Management (General)

The following "guidelines" in the Draft Blue Mountain Forest Plan should be changed to 

"standards" and read as follows: 

FOR-6 S-38 STANDARD Silvicultural treatments shall include provisions to avoid 

detrimental changes in water temperatures, blockages of water courses, and deposits of 

sediment. 

FOR-7 S-39 STANDARD Timber harvest projects shall include provisions for the 

maintenance or restoration of soil and water resources, including protection for streams, stream 

banks, shorelines, lakes, wetlands, and other bodies of water. 

FOR-9 S-41 STANDARD Timber harvest shall not cause irreversible damage to soil, slope, or 

other watershed conditions. 

5. Roads in RHCAs

PACFISH is very clear in requiring coordination to achieve consistency in road design, 

operation and maintenance between landowners and other stakeholders. It requires ecosystem 

analysis prior to construction of new roads or landings in RHCAs. It also requires both road 

and transportation plans and determination of the influence of each road on Riparian 

Management Objectives (RMO). In the Draft Blue Mountains Forest Plan, the direction and 

intent of PACFISH has been marginalized, opening Riparian Habitat Conservation Zones to 

roading activities which may harm treaty rights and resources. The following "guidelines" in 

the Draft Blue Mountain Forest Plan should be changed to "standards" and read as follows: 

MA 4B RMA-RD-4 S-120. STANDARD Wetlands and unstable areas shall be avoided when 

reconstructing existing roads or constructing new roads and landings. Minimize impacts where 

avoidance is not practical. 

MA 4B RMA-RD-8 S-121. STANDARD Construction or reconstruction of stream crossings 

shall allow passage for other riparian dependent species where connectivity has been identified 

as an issue.
MA 4B RMA-RD-10 S-123. STANDARD Guideline Hydrologic connectivity and sediment 

delivery from roads will be minimized. This includes roads inside and outside of riparian 

management areas. 

MA 4B RMA-RD-11 S-124. STANDARD Guideline Road drainage shall be routed away from 

potentially unstable channels, fills, and hillslopes. This applies both inside and outside of 

riparian management areas. 

To continue to meet the requirements of PACFISH, the following standards need to be added to 

the Draft Blue Mountain Forest Plan: 

Standard RF-1. Cooperate with federal, tribal, state, and county agencies and cost-share 

partners to achieve consistency in road design, operation, and maintenance necessary to attain 

RMOs. 

Standard RF-2. For each existing or planned road, meet the RMOs and avoid adverse effects 

on aquatic resources as described below:

a. Ecosystem Analysis at the Watershed Scale shall be completed prior to construction of 

new roads or landings in RHCAs.

b. Road and landing locations in RHCAs shall be minimized.

c. Initiate development and implementation of a Road Management Plan or a 

Transportation Management Plan. At a minimum, the plan shall address the following 

items:

• Road design criteria, elements, and standards that govern construction and 

reconstruction.

• Road management objectives for each road.

• Criteria that govern road operation, maintenance, and management.

• Requirements for pre-, during-, and post-storm inspections and maintenance.

• Regulation of traffic during wet periods to minimize erosion and sediment delivery 

and accomplish other objectives.

• Implementation and effectiveness of monitoring plans for road stability, drainage, 

and erosion control.

• Mitigation plans for road failures.

d. A void sediment delivery to streams from the road surface. Outsloping of the roadway 

surface is preferred, except in cases where outsloping would increase sediment 

delivery to streams or where outsloping is infeasible or unsafe. Route road drainage 

away from potentially unstable stream channels, fills, and hillslopes.

e. A void disruption of natural hydrologic flow paths.

f. A void side casting of soils or snow. Side casting of road material is prohibited on road 

segments within or abutting RHCAs.

Standard RF-3. Determine the influence of each road on RMOs. Meet RMOs and avoid 

adverse effects on aquatic resources by:

a. Reconstructing road and drainage features that do not meet design criteria or operation

and maintenance standards that have been shown to be less effective than designed for 
controlling sediment delivery, that retard attainment of RMOs, or that do not protect 

watersheds from increased sedimentation.

b. Prioritizing reconstruction based on the current and potential damage to aquatic 

resources and their watersheds, the ecological value of the riparian resources affected, 

and the feasibility of options such as helicopter logging and road relocation out of 

RHCAs.

c. Closing and stabilizing or obliterating and stabilizing roads not needed for future 

management activities. Prioritize these actions based on the current and potential 

damage to aquatic resources in watersheds and the ecological value of the riparian 

resources affected.

Standard RF-5. Provide and maintain fish passage at all crossings of existing and potential 

fish-bearing streams. 

6. Livestock Grazing in RHCAs

PACFISH is very clear in modifying or restricting domestic grazing in RHCAs unless they do 

not retard or prevent attainment of RMOs. In the Forest Plan, the direction and intent of 

PACFISH has been downgraded, opening Riparian Habitat Conservation Zones to potentially 

damaging grazing activities which may harm treaty rights and resources. The following 

"guidelines" in the Draft Blue Mountain Forest Plan should be changed to "standards" and read 

as follows: 

MA 4B RMA-RNG-3 S-116 STANDARD During allotment management planning, remove

existing livestock handling or management facilities from riparian management areas that

retard or prevent attainment of RMOs or are likely to adversely affect aquatic resources. 

MA 4B RMA-RNG-4 S-117. STANDARD Livestock trailing, bedding, watering, loading, and 

other handling in riparian management areas shall be minimized. 

The following "standard" in the Draft Blue Mountain Forest Plan should be changed to read as 

follows: 

MA 4B RMA-RNG-1 S-48 STANDARD New livestock handling and/or management 

facilities shall be located outside riparian management areas, except for those that inherently 

must be located in a riparian management area and those needed for resource protection. 

To continue to meet the requirements of PACFISH, the following standards need to be added to 

the Draft Blue Mountain Forest Plan: 

Standard GM-4. Adjust wild horse and burro management to avoid impacts that prevent 

attainment of RM Os or adversely affect aquatic resources. 

7. Minerals Management in RHCAs

PACFISH is very clear in avoiding adverse impact by mineral operations in RHCAs or critical 

habitat and requiring a reclamation plan, approved Plan of Operations ( or other such governing 

document), and reclamation bond for those operations that would be located in an RHCA and 

could affect attainment of RMOs or could adversely affect listed anadromous fish. In the Forest 

Plan, the direction and intent of PACFISH has been downgraded, opening Riparian Habitat 

Conservation Zones and critical habitat to potentially damaging operations which may harm
treaty rights and resources. The following "guidelines" in the Draft Blue Mountain Forest Plan 

should be changed to "standards" and read as follows: 

MA 4B RMA-MIN-4 S-130 STANDARD The operating plans for existing activities shall be 

adjusted to minimize adverse effects to aquatic and riparian dependent resources in the 

RHCAs. 

To continue to meet the requirements of PACFISH, the following standards need to be added to 

the Draft Blue Mountain Forest Plan: 

Standard MM-1. Avoid adverse impacts to listed species and designated critical habitat from 

mineral operations. If the Notice of Intent indicates that a mineral operation would be located in 

an RHCA and could affect attainment of RMOs or could adversely affect listed anadromous 

fish, then require a reclamation plan, approved Plan of Operations (or other such governing 

document), and reclamation bond. For effects that cannot be avoided, such plans and bonds 

must address the following items to attain RMOs and avoid adverse effects on listed 

anadromous fish: the costs of removing facilities, equipment, and materials; recontouring 

disturbed areas to approximate pre-mining topography; isolating and neutralizing or removing 

toxic or potentially toxic materials; salvage and replacement of topsoil; and seedbed 

preparation and revegetation. Ensure Reclamation Plan contain measurable attainment and 

bond release criteria for each reclamation activity. 

Standard MM-2. Locate structures, support facilities, and roads outside RHCAs. Where no 

alternative to siting facilities in RHCAs exist, locate and construct the facilities in ways that 

avoid impacts to RHCAs and streams and that avoid adverse effects on aquatic resources. 

Where no alternative to road construction exists, keep roads to the minimum necessary for the 

approved mineral activity. Close, obliterate, and revegetate roads no longer required for mineral 

or land management activities. 

Standard MM-3. Prohibit solid and sanitary waste facilities in RHCAs. If no alternative to 

locating mine waste (waste rock, spent ore, tailings) facilities in RHCAs exists, and if releases 

can be prevented and stability can be ensured, the:

a. Analyze the waste material using the best conventional sampling methods and analytic 

techniques to determine its chemical and physical stability characteristics.

b. Locate and design the waste facilities using the best conventional techniques to ensure 

mass stability and prevent the release of acid or toxic materials. If the best conventional 

technology is not sufficient to prevent such releases and ensure stability over the long 

term, prohibit such facilities in RHCAs.

c. Monitor waste and waste facilities to confirm predictions of chemical and physical 

stability, and make adjustments to operations as needed to avoid adverse effects to 

aquatic resources and to attain RMOs.

d. Reclaim and monitor waste facilities to assure chemical and physical stability and 

revegetation, to avoid adverse effects to aquatic resources, and to attain the RMOs.

e. Require reclamation bonds adequate to ensure long-term chemical and physical stability 

and successful revegetation of mine waste facilities.

Standard MM-4. For leasable minerals, prohibit surface occupancy within RHCAs for oil, gas, 

and geothermal exploration and development activities where contracts and leases do not 

already exist, unless there are no other options for location and RMOs can be attained and 
adverse effects to aquatic resources can be avoided. Adjust the operating plans of existing 

contracts to (1) eliminate impacts that prevent attainment of RMOs and (2) avoid adverse 

effects to native aquatic species. 

Standard MM-5. Permit sand and gravel mining and extraction within RHCAs only if no 

alternatives exist, if the action(s) will not retard or prevent attainment of RMOs, and if adverse 

effects to native aquatic species can be avoided. 

Standard MM-6. Develop inspection, monitoring, and reporting requirements for mineral 

activities. Evaluate and apply the results of inspection and monitoring to modify mineral plans, 

leases, or permits as needed to avoid adverse effects on native aquatic species and to eliminate 

impacts that prevent attainment of RMOs. 

8. Fire Management in RHCAs

PACFISH is very clear in design of fuel treatment and fire suppression strategies, practices, and 

actions so as to not prevent attainment of RMOs and to minimize disturbances of riparian 

ground cover and vegetation. In the Forest Plan, the direction and intent of PACFISH has been 

downgraded, opening Riparian Habitat Conservation Zones and critical habitat to potentially 

damaging operations which may harm treaty rights and resources. The following "guidelines" 

in the Draft Blue Mountain Forest Plan should be changed to "standards" and read as follows: 

MA 4B RMA-FIRE-1 S-104 STANDARD Disturbed areas, such as firelines, drop-points, 

camps, roads, and trails, shall be restored by actions such as scattering slash piles, replacing 

logs and boulders, scarifying soils, recontouring terrain, and reseeding with native species. 

MA 4B RMA-FIRE-2 S-105 STANDARD Chemicals and retardant shall not be used for 

suppression and mop-up within riparian areas. An exception may be warranted in situations 

where overriding immediate safety imperatives exist, or, following a review and 

recommendation by a resource advisor and a fishery biologist, when the action agency 

determines an escaped fire would cause more long-term damage to fish habitats than 

chemical delivery.

MA 4B RMA-FIRE-5 S-108 STANDARD Temporary firefighting facilities (e.g., incident 

bases, camps, helibases, staging areas, helispots, and other centers) for incident activities shall 

be located outside RMAs. When no practical alternative exists, all appropriate measures to 

maintain, restore, or enhance aquatic and riparian dependent resources shall be used. (See 

guideline MA4B-RMA-FIRE-1). 

MA 4B RMA-FIRE-6 S-109 STANDARD Aerial application of chemical retardant, foam, or 

other firefighting chemicals and petroleum shall be avoided within 300 feet of waterways. An 

exception may be warranted in situations where overriding immediate safety imperatives 

exist, or, following a review and recommendation by a resource advisor and a fishery 

biologist, when the action agency determines an escaped fire would cause more long-term 

damage to fish habitats than chemical delivery to surface waters.
MA 4B RMA-FIRE-7 S-110 STANDARD Water drafting sites shall be located and managed 

to minimize adverse effects on stream channel stability, sedimentation, and in-stream flows 

needed to maintain riparian resources, channel conditions, and fish habitat. 

MA 4B RMA-FIRE-9 S-111 STANDARD General1y, Firelines shall be located and 

configured to minimize sediment delivery, creation of new stream channels, and unauthorized 

roads and trails. An exception may be warranted in situations where overriding immediate 

safety imperatives exist, or, following a review and recommendation by a resource advisor 

and a fishery biologist, when the action agency determines an escaped fire would cause 

more long-term damage to fish habitats. 

FIRE-3 S-28 STANDARD Mechanical fireline shall not be constructed in areas with greater 

than 35 percent slope or on highly erodible soils unless potential adverse effects can be 

mitigated. An exception may be warranted in situations where overriding immediate 

safety imperatives exist, or, following a review and recommendation by a resource advisor 

and a fishery biologist, when the action agency determines an escaped fire would cause 

more long-term damage to fish habitats. 

To continue to meet the requirements of PACFISH, the following standards need to be added to 

the Draft Blue Mountain Forest Plan: 

STANDARD FM-4 Prescribed burn projects and prescriptions should be designed to 

contribute to the attainment of the RMOs. 

9. Recreation Management in RHCAs

PACFISH is very clear in how the design and maintenance of recreation facilities must not 

prevent attainment of RMOs and minimize disturbances of riparian ground cover and 

vegetation. In the Forest Plan, the direction and intent of PACFISH has been downgraded, 

opening Riparian Habitat Conservation Zones and critical habitat to potentially damaging 

activities which may harm treaty rights and resources. The following "guidelines" in the Forest 

Plan should be changed to "standards" and read as follows:

MA 4B RMA-REC-1 S-126 STANDARD Generally, Placing new facilities or infrastructure 

within expected long-term channel migration zones shall be avoided. Where activities, such as 

the placement or construction of road-stream crossings, boat ramps, docks, and interpretive 

trails, inherently must occur in RMAs, locate them to minimize impacts on riparian dependent 

resource conditions (e.g., within geologically stable areas, avoiding major spawning sites). 

MA 4B RMA-REC-2 S-127 STANDARD Remove or relocate existing recreation facilities 

that are causing unacceptable impacts in RMAs should be considered. 

To continue to meet the requirements of PACFISH, the following standards need to be added to 

the proposed Forest Plan: 

Standard RM-1. Design, construct, and operate recreation facilities (including trails) and 

dispersed sites in a manner that does not retard or prevent attainment of RMOs and avoids 

effects on aquatic resources. Complete Ecosystem Analysis at the Watershed Scale prior to 

construction of new recreation facilities in RHCAs. For existing recreation facilities inside 

RHCAs, assure that facilities or use of facilities will not prevent attainment of RMOs or 

adversely affect native aquatic species. Relocate or close recreation facilities where RMOs 

cannot be met or adverse effects on aquatic resources cannot be avoided. 
Standard RM-2. Adjust dispersed and developed recreation practices that retard or prevent 

attainment of RMOs or adversely affect aquatic resources. Where adjustment measures such as 

education, use limitations, traffic control devices, increased maintenance, relocation of 

facilities, and specific sites closures are not effective in meeting RMOs and avoiding adverse 

effects on aquatic resources, eliminate the practice or occupancy. 

10. Watershed and Habitat Restoration in RHCAs

PACFISH is very clear in cooperation with other stakeholders to develop Coordinated Resource 

Management Plans, designing projects that promote long term ecological integrity of 

ecosystems and not using restoration as a substitute for preventing habitat degradation. In the 

Forest Plan, the direction and intent of PACFISH has been downgraded, opening Riparian 

Habitat Conservation Zones and critical habitat to potentially damaging operations which may 

harm treaty rights and resources. To continue to meet the requirements of PACFISH, the 

following standards need to be added to the proposed Forest Plan: 

Standard WR-1. Design and implement watershed restoration projects in a manner that 

promotes the long-term ecological integrity of ecosystems, conserves the genetic integrity of 

native species, and contributes to attainment of RMOs. 

Standard WR-2. Cooperate with federal, state, local, and tribal agencies, and private 

landowners to develop watershed-based Coordinated Resource Management Plans (CRMPs) or 

other cooperative agreements to meet RMOs. 

Standard WR-3. Do not use planned restoration as a substitute for preventing habitat 

degradation (i.e. use planned restoration only to mitigate existing problems, not to mitigate the 

effects of proposed activities). 

Standard FW-1. Design and implement fish and wildlife habitat restoration and enhancement 

actions in a manner that contributes to attainment of the RMOs. 

Standard FW-2. Design, construct, and operate fish and wildlife interpretive and other 

user-enhancement facilities in a manner that does not retard or prevent attainment of RMOs or 

adversely affect aquatic resources. For existing fish and wildlife interpretive and other 

user-enhanced facilities inside RHCAs, assure that RMOs are met and adverse effects on 

aquatic resources are avoided. Where RMOs cannot be met or adverse effects on aquatic 

resources avoided, relocate or close such facilities. 

Standard FW-3. Cooperate with federal, tribal, and state wildlife management agencies to 

identify and eliminate wild ungulate impacts that prevent attainment of the RMOs or adversely 

affect listed anadromous and inland native fish.

Standard FW-4. Cooperate with Federal, tribal, and State wildlife management agencies to 

identify and eliminate wild adverse effects on native anadromous and inland fish associated 

with habitat manipulation, fish stocking, fish harvest, and poaching. 

Standard RA-1. Identify and cooperate with federal, tribal, state, and local governments to 

secure instream flows needed to maintain riparian resources, channel conditions, and aquatic 

habitat. 

Standard RA-2. Trees may be felled in RHCAs when they pose a safety risk. Keep felled trees 

on site when needed to meet woody debris objectives. 
11. Riparian Habitat - Measurable Objectives

As indicated on page 168 of Volume 3 of the DEIS (and shown below), PACFISH imposed 

riparian management objectives that are measurable. The preferred alternative lists objectives 

for riparian habitat and water quality habitat improvement in the form of site, acres, or miles 

"restored or improved" by unknown means. The proposed plan does not provide any parameters 

that can be directly measured to determine the effectiveness of any actions on the Forests. 

Subsequently, the Forests propose a monitoring plan that poses monitoring questions that 

cannot be answered since there are no measurable objectives. The Forest Plan needs to be 

adjusted to include PACFISH RMOs or, if available and scientifically supported, updated 

tangible and measurable objectives.

PACFISH and INFISH interim riparian management 

objectives 

Habitat Feature 

Riparian Management 

Objectives 

Water Temperature No measurable increase in 

maximum water temperature 

(7-day moving average of daily 

maximum temperature 

measured as the average of the 

maximum daily temperature of 

the warmest consecutive 7-day 

period). Maximum water 

temperatures below 59F within 

adult holding habitat and below 

48F within spawning and 

rearing habitats. 

Large woody debris (forested systems) East of Cascade Crest in 

Oregon, Washington, Idaho: 

> 20 pieces per mile; > 12 inch 

diameter; > 35 foot length 

Bank Stability (nonforested systems) > 80% stable 

Lower Bank Angle (nonforested systems) > 75% of banks with < 90 

degree angle 

Width/Depth Ratio (all systems) < 10, mean wetted depth 

divided by mean depth 

Pool Frequency Wetted width 

(feet) 

10 20 25 50 75 100 125 150 200

Pools per 

mile

96 56 47 26 23 18 14 12 9

12. Roads

The preferred alternative includes desired conditions for road density in watersheds with 

anadromous fish and bull trout. However, to achieve road density reduction goals, the Forests 

propose a method that only reduces road density on paper and does nothing to address the 

effects road density actually has on the landscape. The DEIS Volume 1, pg. 73 states "It is 

assumed that open motor vehicle route density desired conditions would be met by reclassifying 

maintenance level 2 roads to maintenance level 1 (custodial care) roads through individual 
project planning and decision making. While no road maintenance is expected for maintenance 

level 1 roads. Standard practice indicates that areas with site specific resource concerns would 

be treated as necessary."Roads not proposed for designation as a motor vehicle route in the 

project may have a long-term adverse effects on water quality and treaty resources if they are 

not properly maintained. Reclassifying roads, removing them from maps, and curtailing any 

maintenance does not result in fewer roads physically on the landscape which can lead to 

detrimental effects to the landscape. Existing routes are a primary source of long-term 

management-related sediment. Road closures and lower maintenance levels would be 

beneficial to water quality only if the roads are properly decommissioned and well maintained 

after closure. The Forest Plan needs to be adjusted to either eliminate this false means of 

reducing road densities or create a standard requiring all roads being classified to a lower 

maintenance level to receive proper decommissioning prior to reclassification. 

13. Priorities

In the existing Forest Plan direction on priorities are clarified for those instances of inevitable 

conflict during resource management. For example, in the existing 1990 Wallowa-Whitman 

Forest Plan it states in Chapter 4 under the "Conflicts With Other Uses" section:

"Give management and enhancement of water quality, protection of watercourses 

and streamside management units, and fish habitat priority over uses described 

in all other management standards or guidelines.”

The Revised Forest Plan as proposed lacks any direction on setting priorities when there is a 

conflict during management activities. Desired conditions, objectives, and guidelines do NOT 

set priority or provide for adequate protection of critical aquatic resources. Standards must be 

set to provide priority and undeniable protection to water quality, protection of riparian areas, 

and fish habitat. 

14. Tiering To Non-NEPA Documents & Lack Of Consultation

Page 100 of the proposed Forest Plan states, "Implementation of the watershed restoration 

element is tiered to the regional Aquatic Restoration Strategy ... ". The Pacific Northwest 

Region Aquatic and Riparian Conservation Strategy (ARCS), August 13, 2008 does not appear 

to have gone through the NEPA analysis and decision process to look at a range of alternatives, 

consider cumulative impacts, include public involvement, or perform Tribal Consultation. 

Although the ARCS claims that it is not Forest Plan Direction; it is a regional strategy (ARCS 

pg. 5), the Region expects that plan components within the ARCS will be included in Forest 

Plan Revisions "as worded" (ARCS pg. 5). Such a use of anon-NEPA document is inconsistent 

with NEPA and NFMA. 

The DEIS (Volume 1, Chapter 3, pg. 277) states that "the ARCS as incorporated into the revised 

forest plan preserves elements (emphasis added) of PACFISH/JNFISH."However, the ARCS 

has failed to go through ESA consultation. The Forests are short circuiting established 

Biological Opinions (P ACFISH/INFISH) to implement standards and guidelines that lack 

proper consultation. This could potentially jeopardize ESA listed species. 

If the ARCS is to be used in the revised Forest Plan, it needs to be go through the proper NEPA 

and Consultation processes PRIOR to the forests tiering their revised Forest Plan to it. 
15. Livestock Grazing & Grazing Land Vegetation

In its 1855 Treaty with the United States, the Tribe reserved, and the United States secured to 

the Tribe, the right to pasture their horses and cattle on open and unclaimed lands, which 

includes National Forest lands. (The US Forest Service, Wallowa-Whitman National Forest and 

the Tribe have a Memorandum of Understanding Establishing a Cooperative Relationship to 

Facilitate Exercise of the Treaty-Reserved Rights set forth in the 1855 Treaty with the Nez 

Perce Tribe.) These National Forest lands also contain a diversity of resources important to the 

Tribe. Unfortunately, much of this rangeland is significantly degraded. Current vegetation 

survey 

(CVS) data indicate that 57% of rangeland on the Umatilla National Forest, and 58% of the 

rangeland on the Wallowa-Whitman National Forest, are in poor condition (Vol. I Table 85). 

Over a century of mismanagement has led to the poor condition of many grazed areas of the 

Forests. Though conditions improved somewhat by the end of the 20th century, the 

management strategy embraced in this DEIS reflects, in large part, the strategy of the 1990 

Forest Plan, under which "the trend ... appears static" (Vol. I p. 139). In fact, average rangeland 

condition under the 1990 Forest Plan declined from 56/100 in the 1990s to 47/100 by 2004 

(Vol. I p. 138). Under the preferred alternative, this trend may be expected to continue. 

Livestock are still allowed to occasionally graze areas deemed unsuited for livestock grazing. 

Utilization rates are still sampled only as administrative resources permit. The permittees 

themselves are still generally relied upon to self-report problems as they develop. Policies still 

provide extensive discretion to managers to remedy resource impacts, or not, as they see fit. 

CVS data clearly demonstrate that existing policies have resulted in a decline, not 

improvement, in rangeland condition. Yet the preferred alternative of the DEIS downgrades 

maximum utilization levels (the sole rangeland standard identified in the 1990 Forest Plan) to 

mere guidelines and provides no new standards on a range of documented resource concerns 

associated with livestock grazing. 

The Tribe is skeptical that the guidelines identified for the preferred alternative will facilitate 

progress toward desired future conditions as claimed. For example, the alternatives presented in 

the DEIS identify varying levels of forage utilization in upland and riparian areas (Vol. I pp. 

131- 134). Whichever alternative is implemented, a set of utilization criteria will be used to 

trigger management changes when maximum utilization levels are reached (Vol. I p. 146).

Unfortunately, this strategy relies entirely on active, continuous monitoring of utilization levels 

across all active grazing allotments and rapid responses to violations of these thresholds. The 

Tribe believes that due to continuing budget limitations, the Forest Service is unlikely to be 

afforded sufficient resources to conduct the extensive and intensive monitoring necessary to 

ensure compliance with these guidelines. Overutilization of some of the most sensitive upland 

and riparian areas will therefore almost certainly occur, not as a consequence of the chosen 

alternative but as a consequence of the manner in which grazing is administered on the Forests. 

The Tribe recommends that administrative limitations such as this be accounted for either 

through uniform reductions in allowable utilization across all alternatives or through selection 

of an alternative with relatively low maximum utilization standards, such as Alternative C. 

Recommended changes to the guidelines of the preferred alternative follow the next section. 

16. Livestock Grazing Suitability
Capability and suitability determinations are used to differentiate livestock stocking rates and 

use across the various alternatives being considered. However, nowhere in the DEIS are these 

determinations made available in a spatially explicit format (e.g. Forest-wide maps), precluding 

the full evaluation of the alternatives with regard to livestock grazing. Furthermore, the actual 

distribution of active allotments on the Forests appears in only one DEIS figure (Vol. II p. 240, 

Figure 33), while no map is provided showing the location of vacant allotments. The Tribe 

requests that a high-resolution map and/or GIS data be made available in the Final 

Environmental Impact Statement (FEIS) which depicts the extent and distribution of all 

allotments (active and vacant) and acres deemed suitable for livestock grazing, per alternative, 

across the Forests. 

The Tribe is alarmed to learn that only 42% and 44% of the land within active allotments on the 

Umatilla National Forest and Wallowa-Whitman National Forest, respectively, is actually 

classified as suitable for livestock grazing. Though only the suitable acres within each 

allotment will be used to calculate Animal Unit Months (AUMs), it is very likely that 'limited 

grazing' 

(RNG-4 G-46) will occur on at least portions of the 56-58% of the land within allotments 

which the Forest has determined is not suitable for livestock grazing, including areas set aside 

for recreation, threatened and endangered species, and ecosystem health. The flexibility 

afforded by RNG-4 G-46 is inappropriate given the diversity of important Tribal values and 

resources associated with areas deemed not suitable for livestock grazing. 

The Tribe recognizes that the management of individual allotments is based upon project-level 

analyses. Nonetheless, the Forest Plan will provide important direction regarding the acres 

suitable for livestock grazing, stocking rates, protection buffers, utilization standards, and other 

factors which have long impacted the ecological health of the Forests and region. Only 

Alternative C provides standards (rather than guidelines) for forage utilization, limits suitable 

acres to areas most appropriate to livestock use, ensures rapid progress toward rangeland 

desired future conditions, and contains important controls on domestic sheep grazing and 

trailing near bighorn sheep home ranges (see the Tribe's separate comments regarding terrestrial 

wildlife species). On that combined basis, the Tribe supports Alternative C with regard to 

livestock grazing. As an alternative, recommended changes to the standards and guidelines of 

the preferred alternative follow this narrative.

The following Standards and Guidelines should be modified as follows and established for the 

preferred alternative: 

RNG-1 G-43 Modified. STANDARD Grazing after wildland fire shall be deferred until 

vegetation recovers to a condition where grazing will not cause the percent composition of 

native species to be reduced (cause a downward trend in key species). This generally will be a 

minimum of 5 years, but could be up to 10 years depending on the extent and severity of the 

fire and other factors. 

RNG-2 G-44. STANDARD New fences shall be designed to accommodate wildlife 

movement. 

RNG-3 G-45. STANDARD All new water developments shall provide for small mammal and 

bird escapement. 
RNG-4 G-46. STANDARD In areas classified as less than fully capable or suitable, only 

limited grazing shall be authorized or allowed only after the limitations of the site are 

considered in designing the site-specific allotment management plan. 

RNG-5. STANDARD [Maximum percent utilization of 30% for all departure classes and 

management systems] 

RNG-6 G-47. STANDARD Upland shrub utilization shall not exceed 25 percent as 

determined by any science-based method. 

RNG-7. STANDARD Grazing utilization within occupied greater sage-grouse habitats shall

not exceed 40 percent at any time during the grazing season and shall be determined 

specifically for each greater sage-grouse habitat, i.e., grazing utilization measured as an average 

of the entire pasture or grazing unit shall not be used to determine compliance with this 

guideline. 

RNG-8. STANDARD During greater sage-grouse breeding season, livestock turnout and 

trailing shall avoid concentration on known greater sage-grouse leks (protected activity 

centers). 

b. Wildlife and Other Natural Resources

1. General Comments

In general, the Tribe believes that the proposed alternatives fail to encompass a broad array of 

management strategies with regard to wildlife resources. For example, more restrictive 

alternatives such as Alternative C would do relatively little to correct coarse-scale departures in 

historic forest habitat conditions, yet more permissive alternatives such as Alternatives D and E 

contain very few standards necessary to ensure essential habitat elements and favorable site 

conditions are maintained during and after active management operations at the project level. 

Recommended changes to the standards and guidelines of the preferred alternative follow this 

narrative. 

Separately, the Tribe recommends that the distribution of Management Areas from Alternative 

C be selected for adoption. Land allocations from Alternative C contain a number of elements 

important for the maintenance of Tribal wildlife resources, particularly the designation of

Wildlife Corridors (MA 3C) and the minimization of lands allocated to MA 4A. The Tribe's 

concerns regarding the extent of MA 4A under the various alternatives are described below as 

well. 

2. Terrestrial Species Viability

The Tribe applauds the deliberative, analytical approach the Forest Service has taken to assess 

the viability of focal species on the Forests. In principle, we further support the strategy of 

managing for the historical range of ecological variability (HRV) to support the viability of the 

widest diversity of native wildlife species historically present on the landscape. Vegetation 

dynamic development tool models and Bayesian belief networks provide powerful means of 

assessing historic, current, and future habitat condition and species viability, and their use here 

has strengthened the overall analysis considerably. 

However, the results from these tools indicate that the proposed alternatives all insufficiently 

promote upward trends in viability for the majority of focal species on the Forests. The DEIS 
emphasizes changes in source habitat for a number of focal species, yet those changes represent 

only one component of the overall viability assessment for each species. Multiple figures 

illustrate increasing extents of source habitat for many species, yet an overall decrease in 

viability concern is predicted for only six of23 focal species on the Wallowa-Whitman National 

Forest and seven of 23 focal species on the Umatilla National Forest, and even then only under 

a subset of alternatives. For most focal species analyzed and alternatives considered, overall 

viability is expected to remain static, even for those species with high viability concern. In 

many cases, increases in source habitat are predicted to be negatively offset by other 

management elements, including inadequate snag retention, continued livestock grazing, and 

high road densities. 

The Tribe applauds the Forest Service in their use of tools developed on the Payette National 

Forest to quantify annual risk of contact between bighorn sheep and domestic sheep allotments. 

As noted previously, the actual distribution of active allotments on the Forests appears in only 

one DEIS figure (Vol. II p. 240, Figure 33), while no map is provided showing the location of 

vacant allotments. The Tribe requests that a high-resolution map and/or GIS data be made 

available in the FEIS which depicts the extent and distribution of all allotments (active and 

vacant) and acres deemed suitable for livestock grazing, per alternative, across the Forests. 

Based on supplemental data provided to the Tribe by Forest Service staff, Alternative C 

classifies as unsuited for domestic sheep grazing areas important for maintaining the long-term 

viability of bighorn sheep populations, as reflected in Table 318 (Vol. II p. 241). Therefore, the 

Tribe strongly recommends that the suitability determination of Alternative C be adopted for all 

alternatives under consideration. The Tribe further recommends that all areas modeled as 

potential but currently unoccupied bighorn sheep habitat on the Forests be classified as 

unsuited for domestic sheep grazing to ensure that bighorn sheep populations, a vital resource 

to the Tribe, are afforded the opportunity to recover toward historic levels. 

Assessing annual risk of contact is only one element to a full assessment of bighorn sheep 

viability on these Forests. The DEIS neither includes nor references analyses regarding risk of 

extirpation (the ultimate measure of viability), as was utilized on the Payette National Forest, 

nor does it conduct the viability outcome modeling approach embraced for all other focal

species within the Blue Mountains. The Tribe recommends that the background analyses and 

results used to support the narrative of the DEIS be included in the FEIS. 

The Tribe is pleased to see a number of important standards and guidelines specific to bighorn 

sheep viability shared across all alternatives. However, the Tribe's analysis of domestic sheep 

grazing practices on another National Forest has identified a number of concerns which may be 

relevant to the proposed Forest Plan revisions as well:

A. Inadequate monitoring and ineffective responses to violations of LRMP standards can 

perpetuate resource degradation and corrode confidence in Forest Service management.

B. Because domestic sheep are typically not individually identifiable or counted precisely 

by Forest Service staff during on/off counts, following scatter events, or periodically 

during the grazing season, stray domestic sheep are likely to be present on the Forests 

during and after the grazing season, dramatically increasing disease risk to bighorn 

sheep populations in the vicinity.

C. The implementation of emergency actions in response to bighorn-domestic contact is 

essential, yet such actions elsewhere are infrequently triggered, insufficiently executed, 
and poorly documented in most cases. This is particularly so when the duty to trigger 

such actions falls primarily upon the permittees themselves who have substantial 

incentive to remain silent. An emergency response plan should be considered an 

essential element of Forest Plan direction associated with bighorn sheep, and its 

implementation and enforcement should be incorporated explicitly as a standard within 

the Forest Plan. Recommended changes to the standards and guidelines of the preferred 

alternative follow this narrative.

3. Canada Lynx

The DEIS identifies early stage seral boreal forest and late-successional forest as important 

habitats for foraging and reproducing lynx, with focal species representation by the boreal owl 

and water vole. The DEIS concludes that at the broad scale, viability concerns for boreal owl 

and water vole are decreasing or low and stable, respectively, and that therefore habitat for lynx 

is being maintained or is moving toward HRV. On the contrary, the viability concern for boreal 

owl on the Wallowa-Whitman National Forest and Umatilla National Forest is predicted to be 

stable or increasing across the proposed alternatives (Tables 300 and 301), and the decadal 

change in boreal owl source habitat on the Umatilla National Forest is projected to decrease 

under all alternatives (Figure 20). The DEIS lacks necessary information regarding viability 

outcomes by alternative for these two focal species or for Canada lynx themselves. 

4. Gray Wolf

The Tribe has long supported the reintroduction and health of gray wolf populations in the 

northern Rockies and Pacific Northwest and recognizes the challenges regarding wolf 

management in these regions. The Tribe is pleased to note that the Forest Service recognizes 

the important role of motorized route densities in exposing wolves to human disturbance and 

harvest. On this basis, the Tribe supports alternatives which minimize the density for open 

motorized routes yet is troubled by the lack of diversity in desired route densities in the 

proposed alternative. The Tribe further supports those alternatives, such as Alternatives C, 

which minimizes the amount of land classified as MA 4A (General Forest) to improve the 

viability of wolf populations on the Forests. Separately, the Tribe recommends that the 

distribution of Management Areas from Alternative C be selected for adoption. 

An important element influencing the viability of wolves on the Forests which the DEIS does 

not address is livestock grazing. Wolf pack reductions are commonly justified on the basis of 

responding to and preventing livestock depredations throughout the region, yet 58-80% of the 

Forests are currently classified as lands available for grazing by domestic cattle and sheep 

(Table 84). A direct tradeoff is likely to exist, therefore, between wolf viability and the area

made available for permitted livestock grazing on the Forests. On this basis, the Tribe supports 

Alternative C which minimizes the area of the Forests available for livestock grazing to 

improve the viability of wolf populations on the Forests. Separately, the Tribe recommends that 

the distribution of Management Areas from Alternative C be selected for adoption. 

5. Wolverine

The Forest Service correctly notes that winter motor vehicle use is an important factor 

influencing the viability of wolverine on the Wallowa-Whitman National Forest. On that basis, 

the Tribe supports Alternative C which minimizes the area of the Wallowa-Whitman National 

Forest available for winter motor vehicle use to improve the viability of wolverine populations 
on the Forest. Separately, the Tribe recommends that the distribution of Management Areas 

from Alternative C be selected for adoption. 

6. Sensitive Species

Table 321 identifies 47 Region 6 Sensitive Species known or predicted to occur on the Forests. 

Of those which occur on the Wallowa-Whitman National Forest, 47% (22 of 47) are expected 

to be impacted at the individual or habitat level, but not pushed into a downward trend in 

viability or toward federal listing. For many species, the DEIS relies not on individual 

assessments but rather on proxy assessments of focal species representing a group of species 

with similar habitat requirements (Vol. II p. 262). The Tribe recognizes that ecosystem 

management is intended to move beyond attempts to weigh the (at times competing) needs of 

multiple species considered individually. Nonetheless, Sensitive Species have been so 

designated partly due to the failure of other approaches to reflect their needs and statuses. 

Sensitive Species identified as 'fine scale' species comprise 38% (18 of 47) of the Sensitive 

Species identified in Table 321 and therefore receive little additional analysis at the Forest Plan 

level (Vol. II p. 262). Limited habitat, limited distribution, riparian habitat, and special habitat 

are discussed thematically, generally in the context of site-specific considerations. Species 

which occupy narrow habitats such as these are among the most sensitive to management 

impacts, serving only to emphasize the importance of establishing clear guidance at the Forest 

Plan level designed to ensure the viability of these species wherever they occur. On that basis, 

the Tribe supports Alternative C which minimizes the area of the Forests available for livestock 

grazing in both high-elevation and riparian areas. As an alternative, recommended changes to 

the standards and guidelines of the preferred alternative follow this narrative. 

7. Management Indicator Species (General Comments)

The methodology used to evaluate impacts to Management Indicator Species within the DEIS 

limits the ability of the reader to "estimate the effects of each alternative on fish and wildlife 

populations" (36 CFR 219.19(a)(l)). The selection of separate, largely discrete sets of 

Management Indicator Species for the action and no-action alternatives has resulted in a DEIS 

in which the planning alternatives are inconsistently "stated and evaluated in terms of both 

amount and quality of habitat and of animal population trends of the management indicator 

species" (36 CFR 219.19(a)(2)). Extensive assessments of the American marten, northern threetoed woodpecker, primary excavators, and northern goshawk provide important context for 

evaluating the no-action alternative yet provide little basis for evaluating the relative impacts of 

the action alternatives under consideration. Similarly, the failure to assess the impact of the noaction alternative on both white-headed woodpecker and mule deer prevents a meaningful 

comparison of the alternatives for those species as well. The Tribe recommends that the lists of 

Management Indicator Species for each Forest be standardized across all alternatives. 

The DEIS evaluates impacts to the subset of Management Indicator Species common to all 

alternatives using separate methodologies and techniques for the no-action and the action 

alternatives. This approach limits the ability of the reader to compare the relative impacts of all 

the alternatives under consideration. The Tribe recommends that analyses for each species rely 

on the same metrics across all alternatives, rather than relying upon 1990 metrics for the 

no-action alternative. 
In addition, two factors limit the ability of the reader to understand the predicted outcomes of 

the various alternatives: a) the use of actual acreages to evaluate impacts, rather than the 

percentage of the median HRV as used for Focal Species, and b) the lack of integrative 

syntheses of the factor-specific analyses currently presented. Predictions that integrate the 

results of the predictions for all the various factors important to the species of interest should be 

presented as summaries to the factor-by-factor treatment currently presented. 

Analyses indicate that none of the action alternatives on the Wallowa-Whitman National Forest 

is projected to maintain habitat for pileated woodpeckers within the historic range of variability 

(Vol. II Fig. 46). This suggests to the Tribe that efforts to restore ponderosa pine habitats within 

the Wallowa-Whitman National Forest may be overzealous, with reductions to other habitat 

types below their respective historic ranges of variability. In addition, the discussion regarding 

Rocky Mountain elk as a Management Indicator Species relies extensively on dated research 

and standards, which is surprising considering the plethora of scientific advancements made by 

Forest Service researchers studying the responses of elk to land management specifically within 

the Blue Mountains region. The Tribe recommends that recent research from staff at the 

Starkey Experimental Forest and Range be reviewed and incorporated within the FEIS, with 

edits to the document made as needed to ensure Forest Plan consistency with the best available 

science. 

8. Domestic Livestock Grazing in Relation to Management Indicator Species

Just as the DEIS discusses the impact of domestic livestock grazing to Management Indicator 

Species within this section as a supplementation to the Rangeland Resource section, the Tribe 

submits the following comments on such impacts separate from those associated with the 

Rangeland Resource section.

As the DEIS acknowledges, livestock grazing can have significant impacts to forage quality 

and availability to elk. Yet as the DEIS only briefly addresses, livestock grazing may have a 

variety of impacts beyond the direct utilization of available forage, including displacement, 

fine-scale avoidance, riparian degradation, etc. It is regrettable, therefore, that the narrative 

presented primarily focuses on the shared utilization of forage and the presumption that forage 

utilization guidelines alone will maintain habitat for elk across the landscape. In addition, the 

developed alternatives are virtually uniform with regard to the amount of elk forage areas made 

available for livestock grazing. Consistent with our comments regarding Rangeland Resources 

recorded elsewhere, the Tribe recommends that a wider array of alternative livestock 

management strategies and analyses be developed that more adequately consider all of the 

impacts of livestock grazing on forage availability for elk, including the factors identified 

above. 

9. Hunted Species

Rocky Mountain elk, bighorn sheep, and a number of other hunted species are very important 

to the Tribe. As the DEIS notes, not all hunted species are likely to respond in a positive 

manner to a return to the historical range of habitat variability. It is equally apparent, however, 

that a number of other plant and wildlife resources important to the Tribe have become 

depressed through habitat alteration beyond the historic range of variability. The Tribe 

appreciates the challenge noted by Woolever and quoted on Vol. II page 327. On balance, the 

Tribe supports the Forest Service's use of HRV as a guide for terrestrial ecosystem management 

within the Blue Mountains. 
Disturbance to big game species from open motor vehicle routes and foraging reductions 

through livestock grazing both represent negative stressors on wintering big game. On these 

bases, the Tribe supports Alternative C which minimizes both the amount of land classified as 

MA 4A 

(General Forest) and the land available for livestock grazing on the Forests. Separately, the 

Tribe recommends that the distribution of Management Areas from Alternative C be selected 

for adoption. 

10. Habitat Connectivity

Habitat connectivity is an important yet underserved component of healthy wildlife populations 

in the region. As noted in the DEIS, Alternative C contains a number of provisions designed to 

maintain and enhance such connectivity across the Blue Mountains. On that basis, the Tribe 

supports Alternative C. Separately, the Tribe recommends that the distribution of Management 

Areas from Alternative C be selected for adoption. 

11. Cumulative Effects

The discussion of cumulative effects presented in the DEIS identifies a number of important 

factors impacting wildlife populations at a regional scale. Unfortunately, the actual effects of 

the various alternatives on regional populations are not evaluated. The Tribe recommends that 

additional analyses be conducted to evaluate the cumulative effects of the proposed alternatives 

in the context of non-Forest management activities in the region. 

12. Climate Change

The discussion of wildlife and climate change presented in the DEIS identifies a number of 

predicted impacts of a changing climate on wildlife populations. Unfortunately, the actual 

effects of the various alternatives on regional populations are not evaluated in this context. The 

Tribe recommends that additional analyses be conducted to evaluate the effects of the proposed 

alternatives in the context of climate change.

13. Standards and Guidelines for Wildlife and Other Natural Resources Comments

The following Standards and Guidelines should be modified as follows and incorporated into 

the preferred alternative pursuant to the comments above: 

WLD-HAB-1 G-1. STANDARD Management activities that limit the ability of wildlife to 

disperse between patches of source habitat shall be avoided; area and patch size of late old 

structure shall be maintained and road density within and between old forest patches shall be 

maintained or reduced. 

WLD-HAB-2 G-2. STANDARD The extent of existing late old structure stands within the 

moist and cold old forest types that are 300 acres or larger shall not be reduced or fragmented. 

WLD-HAB-3 G-3. STANDARD Riparian corridors connecting moist and cold old forest types 

shall be improved. 

WLD-HAB-4. STANDARD Cold and moist late old structure habitats 300 acres or greater and 

separated by less than 2 miles shall be connected by forested corridors 300 feet wide or wider 

with a 60 percent or greater canopy cover. 
WLD-HAB-5. STANDARD Manage for old age trees so as much old forest structure as 

possible is sustained over time across the landscape. Sustain a mosaic of vegetation densities 

(overstory and understory), age classes m1d species composition across the landscape.

WLD-HAB-7 G-10. STANDARD Nest disturbing management activities shall not occur 

within a radius of 1,320 feet from known active goshawk nests between April 1 and August 1. 

WLD-HAB-8. STANDARD Establish northern goshawk dispersal post-fledgling family areas 

in appropriate habitat when current density does not attain a post-fledgling family area every 

two and one-half miles. 

WLD-HAB-9. STANDARD Northern goshawk home range establishment:

a. Post-fledgling family areas shall be approximately 600 acres in size. Post-fledgling 

family areas shall include the nest sites and consist of the habitat most likely to be used 

by the fledglings during their early development.

b. Establish a minimum of three nest areas and three replacement nest areas per 

post-fledging family area. The nest areas and replacement nest areas shall be 

approximately 30 acres in size. A minimum total of 150 acres of nest areas shall be 

identified within each post-fledgling family area.

c. Nest site selection shall be based first on using active nest sites followed by the most 

recently used historical nest areas. When possible, all historical nest areas shall be 

maintained.

d. Manage for nest replacement sites to attain sufficient quality and size to replace the 

three suitable nest sites.

WLD-HAB-10 G-11. STANDARD To the extent practical, Known cavity or nest trees shall be 

preserved when conducting prescribed burning (planned ignition) activities, mechanical fuel 

treatments, and silvicultural treatments. 

WLD-HAB-11. STANDARD Manage for breeding areas that will support a minimum of 3 

reproductive pairs of pileated woodpeckers per watershed. 

WLD-HAB-13 G-16. STANDARD Motor vehicle use within elk winter range shall not be 

authorized or allowed between December 1 and April 30. 

WLD-HAB-14. STANDARD In greater sage-grouse habitat, developing new roads, motor 

vehicle trails, and artificial water impoundments shall be avoided. During the breeding season, 

seasonal closure of open motor vehicle routes within 2 miles of known leks (protected activity 

centers) shall be considered. 

WLD-HAB-15. STANDARD Surface occupancy for mineral or fossil fuel exploration or 

extraction shall not be authorized or allowed within 3 miles of occupied greater sage-grouse 

leks (protected activity centers). 

WLD-HAB-16. STANDARD Power lines, communication towers, meteorological towers, and 

other tall structures shall not be constructed within 2 miles of greater sage-grouse leks 

(protected activity centers). 
WLD-HAB-17. STANDARD Construction of wind turbines shall not be authorized or allowed 

within 3 miles of known greater sage-grouse leks (protected activity centers). 

WLD-HAB-18 G-7. STANDARD Bat maternity and roost hibernation sites shall not be 

disturbed. 

WLD-HAB-19 G-4. STANDARD Greater than 50 percent of post-fire source habitat shall be 

retained and shall not be salvage logged, except in the wildland urban interface. 

WLD-HAB-21 G-6. STANDARD Where salvage logging occurs, all snags 21 inches d.b.h. 

and greater and 50 percent of the snags from 12 to 21 inches d.b.h. shall be retained except for 

the removal of danger/hazard trees. Snags shall be retained in patches. 

WLD-HAB-22. STANDARD Following wildfires greater than 10 acres in greater sage-grouse 

habitat at high risk of annual grass invasions, seeding with an appropriate mixture of native 

species shall be accomplished to reduce the probability of cheatgrass establishment. 

WLD-HAB-23. STANDARD Prior to potentially disturbing activities, potential bat sites shall 

be surveyed to determine presence or absence of bats with a high degree of confidence.

WLD-HAB-24. STANDARD At least one year of survey of the analysis area, including a half 

mile beyond the boundary prior to activities that modify habitat, shall be completed. Two years 

of survey shall be accomplished to verify questionable sightings, unconfirmed nest sites, etc. If 

nesting goshawks are found during the first year of inventory, a second year of inventory is not 

needed in that territory. 

WLD-HAB-25 G-12. STANDARD Where management activities occur within riparian 

habitat, the quantity, stature, and health of shrubs shall not be reduced or degraded. 

WLD-HAB-26 G-14. STANDARD Roads and trails shall not be constructed within high 

elevation riparian areas. 

WLD-HAB-27 G-15. STANDARD Residual herbaceous vegetation within riparian areas shall

be maintained at a level adequate to prevent stream bank degradation. 

WLD-HAB-28 G-13. STANDARD Vigor and areal extent of seed producing grasses and forbs 

shall not be reduced. 

RNG-9 S-2. STANDARD Domestic sheep or goat grazing shall not be authorized or allowed 

on lands where effective separation from bighorn sheep, as defined by a quantitative risk 

assessment, cannot be reasonably maintained. 

RNG-12. STANDARD An effective monitoring program shall be in place to detect presence of 

bighorn sheep and stray domestic sheep in identified high-risk areas, based on a quantitative 

risk assessment, when authorized domestic sheep or goats are present on adjacent or nearby 

allotments. 

RNG-13. STANDARD Trailing of domestic sheep or goats shall not be authorized or allowed 

within 7 [an empirically-derived, scientifically-defensible number of] miles of bighorn 

sheep home ranges. 

RNG-15. STANDARD Permitted domestic sheep and goats shall be counted onto and off of 

the allotment by the permittee Forest Service personnel using an automated, reliable 
system which produces a verifiable record of the count. A reasonable effort to Full 

accounting for of the disposition of any missing sheep must shall be made by the permittee. 

RNG-18. STANDARD Implement emergency actions when bighorn sheep presence is detected 

within 7 [an empirically-derived, scientifically-defensible number of] miles of active 

domestic sheep or goat grazing or trailing. Actions to be taken shall ensure separation between 

bighorn sheep and domestic sheep or goats and be consistent with the emergency response 

plan. 

RNG-19. STANDARD To maintain separation, when bighorn sheep are found within 7 [an 

empirically-derived, scientifically-defensible number of] miles of an active domestic sheep 

and goat allotment, implementation of the emergency response plan shall occur. Emergency 

actions for domestic sheep and goat grazing could include: Reroute (move) domestic sheep or 

goats to a new routing path that will take them away from the likely bighorn movement; this 

may involve rerouting within the permitted allotment, movement to a different allotment, or, if 

the situation cannot otherwise be resolved, moving the permitted sheep off of the national forest 

until the situation can be resolved. Inform the appropriate state agency of the bighorn sheep 

location.

NEW RANGE STANDARD Domestic sheep or goat grazing shall not be authorized or 

allowed in the absence of an emergency response plan designed to maintain and rapidly 

reestablish separation of at least (an empirically-derived, scientifically-defensible number 

ofl miles from bighorn sheep. 

NEW RANGE STANDARD Stocking of allotments not currently authorized for domestic 

sheep and goat use shall only be permitted after a complete quantitative risk assessment 

has been completed. 

14. Old Forest

The Tribe is concerned that the proposed alternatives fail to encompass a broad array of 

management strategies with regard to old forest conditions. For example, more restrictive 

alternatives such as Alternative C would do relatively little to correct coarse-scale departures in 

historic forest habitat conditions, yet more permissive alternatives such as Alternatives D and E 

contain very few standards necessary to ensure that large-diameter trees are maintained during 

and after active management operations at the project level. Recommended changes to the 

standards and guidelines of the preferred alternative follow this narrative. 

The following Standards and Guidelines should be modified as follows and established for the 

preferred alternative: 

FOR-6 G-38. STANDARD Silvicultural treatments shall include provisions to avoid 

detrimental changes in water temperatures, blockages of water courses, and deposits of 

sediment. 

FOR-7 G-39. STANDARD Timber harvest projects shall include provisions for the 

maintenance or restoration of soil and water resources, including protection for streams, stream 

banks, shorelines, lakes, wetlands, and other bodies of water. 

FOR-8 G-40. STANDARD Silvicultural treatments shall be developed through 

interdisciplinary review that considers multiple use of the general area and ensures that the 
harvest systems used are not selected primarily because they give the greatest dollar return or 

the greatest unit output of timber. 

FOR-9 G-41. STANDARD Timber harvest shall not cause irreversible damage to soil, slope, 

or other watershed conditions. 

FOR-10 G-42. STANDARD Timber harvest on lands not suitable for timber production shall

occur only to meet multiple-use purposes other than timber production. 

OF-1 G-59. STANDARD Management activities within and outside old forest stands shall 

retain live trees ≥21 inches d.b.h., except when: - Tree(s) need to be removed to favor 

hardwood species, such as aspen or cottonwood, or other special plant habitats. - Late 

seral species, such as grand fir, are competing with large diameter early seral species, such 

as ponderosa pine. - Tree(s) need to be removed to reduce danger/hazard trees along 

roads and in developed sites. - A limited amount of old forest trees need to be removed 

where strategically critical to reinforce and improve effectiveness of fuel reduction in 

wildland-urban interfaces.

OF-2. STANDARD New motor vehicle routes shall not be constructed in old forest stands.

15. Plant Species And Nonnative Invasive Species

The Tribe is very concerned that the DEIS fails to encompass alternatives which best promote 

the recovery of the threatened Spalding’s catchfly. All existing alternatives would continue to 

classify the occupied habitat of this species as suitable for livestock grazing. Indeed, the Forest 

Service expects that the preferred alternative “may effect, and would be likely to adversely 

affect” Spalding’s catchfly (DEIS Vol. II p. 352). The proposed standard regarding seasonal 

livestock use during the active growth period of Spalding’s catchfly (PL-TES-1) allows 

substantial discretion based on historical use, a weak basis of protection. Proposed guideline 

PL-TES-4 provides virtually no assurance that utilization will not exceed 30 percent, itself an 

alarmingly high rate of potential direct utilization of a threatened species. As noted previously, 

utilization triggers are only effective when active, continuous monitoring of actual rates of use 

is conducted. The Tribe believes that due to continuing budget limitations, the Forest Service is 

unlikely to be afforded sufficient resources to conduct the extensive and intensive monitoring 

necessary to ensure compliance with standards and guidelines specific to this species. The 

Tribe recommends that all areas containing known Spalding’s catchfly populations on the 

Wallowa-Whitman National Forest be classified as unsuitable for livestock grazing and 

reclassified as botanical areas, as the Forest Service has proposed (with the Tribe’s support) for 

the Umatilla National Forest.

A number of the sensitive plant species discussed in the DEIS are impacted predominantly by 

livestock grazing. The Tribe has provided comments elsewhere specific to livestock grazing 

and grazing land vegetation, which are informed by our interest in the Tribe’s Treaty resources 

and the recovery of rare and culturally-important plant species. Overall, the Tribe supports 

efforts to minimize the extent and intensity of livestock grazing on the Forests, particularly 

where the recovery of these plant resources is hindered by continued livestock use and where 

invasive nonnative species are present or likely to spread. On that basis, the Tribe supports 

Alternative C. Alternatively, recommended changes to the standards and guidelines of the 

preferred alternative follow this general narrative.
The following Standards and Guidelines should be modified as follows and established for the 

preferred alternative: 

PL-TES-1. STANDARD Livestock grazing shall not be authorized or allowed during the 

Silene spaldingii active growth period (generally between May 15 and August 30) in pastures 

that exhibit low departure from the desired condition, unless the grazing management history 

demonstrates that livestock avoid Silene spaldingii occupied habitat.

PL-TES-3. STANDARD Domestic livestock grazing shall not be authorized or allowed in 

the fens/bogs sensitive plant habitat groups.

PL-TES-4. STANDARD Maximum forage utilization of key species shall not exceed 30 15

percent in occupied habitat of threatened, endangered, and sensitive plant species, except where 

an approved conservation strategy, conservation agreement, or recovery plan approves an 

alternate use level.

PL-TES-5. STANDARD New water developments and salting shall not be authorized or 

allowed within one-quarter mile of occupied habitat of threatened, endangered, or sensitive 

plant species.

PL-TES-6. STANDARD Timber harvest and associated vegetation activities shall avoid the 

occupied habitat of threatened, endangered, and sensitive plant species (minimum 100 foot 

buffer), unless the silvicultural prescription will benefit the species or its habitat.

PL-TES-7. STANDARD Slash piles and other fuels shall be managed to avoid the occupied 

habitat of threatened, endangered, and sensitive plant species (minimum 100 foot buffer).

PL-TES-8. STANDARD Wildland fire (planned and unplanned) suppression lines shall not 

be constructed within occupied habitat of threatened, endangered, and sensitive plant species.

PL-TES-9. STANDARD New road construction shall be designed to avoid the occupied 

habitat of threatened, endangered, and sensitive plant species (minimum 25-foot buffer).

PL-TES-10. STANDARD All new trail construction shall be designed to avoid the occupied 

habitat of threatened, endangered, and sensitive plant species (minimum 25-foot buffer).

PL-TES-11. STANDARD Mining operations shall be authorized or allowed only if activities 

are planned to avoid threatened, and endangered, and sensitive plant species. Sensitive plant 

species should be avoided to the greatest extent possible.

PL-TES-12. STANDARD Land exchanges shall avoid the disposition of occupied habitat of 

threatened, endangered, and sensitive plant species.

c. Cultural Resources

1. General Comments

The Forest Service states that the goals are to return the forest ecosystem to its “historic levels,” 

or similar terminology. The goal seems to be a return to precontact forest conditions, but the 

starting point for this is inherently flawed. By starting around 1910, the Forest Service ignores 

the effects of the previous 50 years of euroamerican logging, homesteading, mining, livestock 

(especially domestic sheep) grazing, road building, invasive species, and burning. 
The Section 2.6 description of cultural resources is adequate, but could benefit from expanded 

description and definition of traditional cultural properties and sacred sites, especially as Forest 

Service is emphasizing these resources through consultation. Trails should also be included in 

the discussion of historic properties, as many existing trails, including the Nez Perce National 

Historic Trail and the Oregon Trail, are eligible for National Register of Historic Places 

(NRHP) listing, or already listed.

Sections 2.9 and 2.10 concerning Tribal Rights and Interests and Culturally Significant Foods is 

a welcome expression of the aspiration of the Forest Service to protect and perpetuate Tribal 

members continuing use of the landscape and the traditional resources they rely upon. The 

discussion of MA G2 Nationally Designated Trails omits the Nez Perce National Historical 

Trail (p 85). The revised Forest Plan must discuss the Nez Perce National Historical Trail. The 

Cultural Resources Guidelines (CUL-1 G-50, p 128) must require consultation and concurrence 

with the affected Indian Tribe(s). It is inappropriate to negotiate agreements solely with State 

Historical Preservation Office (SHPO) Tribal resources (p 128).

2. Forest Plan DEIS

The DEIS avoids substantive discussion of cultural or heritage resources, but states that 

“Avoidance of cultural resources, consideration of traditional values, and reasonable access 

through agreements, permits, and recognition of their sovereignty and legal rights are all part of 

the development and evaluation of the alternatives. As a result, American Indian populations 

would not be disproportionately impacted by any alternative. (vol 1, p126). 

Most of the possible undertakings allowable through this DEIS have the potential to severely 

impact cultural resources. As a programmatic document, the DEIS does not provide specific 

enough project activities or locations that can be analyzed by the Tribe for impacts to specific 

resources. The Forests are far from completing archaeological inventories of possible project 

lands and inventories for Nez Perce ethnographic resources have yet to begin. 

Given this lack of information, it is unclear how the Forest Service can accomplish the goals 

stated above. If projects are proposed in areas with significant cultural and heritage resources, it 

is unclear how the Forest Service will ensure that these resources are avoided, much less that 

the agency will consider traditional values and ensure reasonable access to Tribal members. 

Again, unless sites are identified early, planners cannot avoid them during alternative 

development and evaluation.

Past agency practice of simply working around sites often does not work because it highlights 

locations to the public that possess significant archaeological or biological resources. 

Although the DEIS assumes that all cultural and heritage properties will be avoided, and 

therefore no adverse effects will occur, the Forest Plan (p. 128) provides an exception to 

Cultural Resources protection, through a programmatic agreement or specific mitigation plan 

developed in consultation with the appropriate State Historic Preservation Officer. 

Although situations may arise when this is an acceptable alternative, the Forest Service must 

require consultation with and concurrence from the affected Indian Tribe(s). It is inappropriate 

for the agency to negotiate agreements solely with SHPO Tribal resources. Cultural Resources 

should be listed as an “outstandingly remarkable values for designated wild and scenic rivers” 

in each of the three Forests (vol. 3, p 398).

The Shoshone-Bannock Tribes

August 5, 2014

Kent Connaughton

USDA Forest Service, Pacific Northwest Region 

1220 SW 3rd Avenue

Portland, OR 97208

The Shoshone-Bannock Tribes (Tribes) is aware that the U.S. Forest Service (FS) is requesting 

input to identify issues and management opportunities for preparing the Blue Mountains National 

Forests Proposed Revised Land Management Plan (Plan). We would like to submit the following 

initial comments in regard to this planning effort and inform the FS that our ancestral lands 

encompass the planning area. The FS should also be aware that Tribes has an exemption under 

the Endangered Species Act to harvest listed Snake River spring/summer Chinook salmon 

located in the Grande Ronde and Imnaha basins. As the Tribes have ancestral ties to the 

landscape within your planning area and reserved treaty rights under the Fort B1idger Treaty of 

1868 (15 Stat. 673) we submit the following comments for your consideration.

Government-to-Government Consultation

As part of coordinating land management actions on the Forest, the Tribes would like the FS to 

meet with our technical staff as soon as possible to better understand the planning issues and 

convey our priority rights and interests to the FS. We would also like the plan to have goals and

objectives for: 1) government-to-government consultation with the Tribes, 2) standards to 

ensure management actions are consistent with Treaty and Inherent Rights retained by the 

Tribes, and 3) management actions that maintain or increase open space and actions that promote 

high quality habitat for native fish, wildlife, and plant communities. We would also like the FS to 

develop goals and objectives that provide for quality bighorn sheep, sage grouse and anadromous 

fish habitat allowing for the expansion and the recovery of threatened, endangered and other 

special status species within the planning area.

Executive Summary, Legal Framework, Vision, Tribal and Treaty Resources

Under Article 4 of the Treaty with the Eastern Band Shoshoni and Bannock of 1868 (15 Stat. 

673), the Tribes "have the right to hunt on the unoccupied lands of the United States so long as
game may be found thereon, and so long as peace subsists among the whites and Indians on the 

borders of the hunting districts". Therefore, it is highly important to the Tribes that this Treaty 

and off-reservation rights to take subsistence be acknowledge in the Executive Summary, 

Introduction, Legal Framework, and Vision. More specifically, we would like the Plan state that 

management of Forest Service lands recognizes and are consistent with the Treaty Rights and 

interests retained by the Shoshone-Bannock Tribes and that their homeland territories extend into 

the planning area. The vision should also acknowledge that the FS seeks to maintain and improve 

consultation with the Tribes on lands held in trusts.

Development on Unoccupied Lands

The FS should develop a desired future condition that perpetually designates and promotes open 

spaces; and, the maintenance and enhancement of native fish, wildlife, and plant populations. 

Objectives to this desired future condition should include removal of fencing, surface disturbing 

activities, development of buildings and structures (e.g., water development projects, power 

lines, etc.), and agriculture activities within five years of Plan approval. The Tribes support vast 

open space and landscapes that support abundant populations of native fish, wildlife, and plant 

species which would provide abundant opportunities for the Tribes to exercise off-reservation 

treaty 1ights. At the very least, we would like the FS to identify areas where this could occur 

and/or ways that this desired future condition can be accommodated under the multiple use 

mandate. One method available at the Federal Level for promoting open space and long-term 

enhancement of fish & wildlife habitat is the designation of Wilderness and increasing habitat 

connectivity by reducing development and road density. Habitat connectivity should be 

evaluated using landscape ecological approach based upon habitat patch metrics such as 

connectivity, diversity, perimeter to edge ratio, patch size, patch evenness, etc. We would like to 

see this type of analysis and consideration in the environmental impact statement and plan.

Federal Land Transfers·

We want to inform you of our policy on land tenure adjustments. The Tribes opposes any federal 

land disposition, sale, or transfer to private entities or state and local governments based upon 

two fundamental reasons. First, the United States government entered into a solemn treaty with 

the Shoshone and Bannock tribal peoples in which the Tribes reserved certain off- reservation 

hunting, fishing, and gathering rights which we continue to exercise on unoccupied lands of the 

United States. Secondly, the United States, including its federal agencies, have a trust 

responsibility as established in the Fort Bridger Treaty and other federal laws, policies and 

executive orders to protect and preserve the rights of Indian tribes, and to consult with the Tribes 

prior to such land sales or transfers. To better understand our position we have attached our 

position statement regarding the transfer of federal lands.
Campground Policy & Access

Traditionally, the Shoshone and Bannock peoples were nomadic and migrated throughout the 

region to sustain their livelihoods. There was no understanding of "permanent settlement" until 

the United States forced our people to the Fort Hall Reservation. Tribal elders have indicated that 

when Tribal members went to pursue subsistence there was no boundaries and would freely take 

subsistence as the need arose. However, federal land managers have since developed 

campground reservation systems, lotteries and fees limiting Tribal members' access to traditional 

subsistence opportunities and reduce access when exercising off-reservation rights to hunt, fish, 

and gather on unoccupied lands. As the Tribes exercises inherent and reserved treaty rights 

witl1in their own authorities and responsibilities, federal land developed campground fees, 

access points, reservation systems, and any other fee-based campground services shall not apply 

to the enrolled members of the Shoshone-Bannock Tribes or agents acting on their behalf to 

complete work for the Tribal government. This is in accordance with Article IV of the Fort 

Bridger Treaty, which does not state, nor was it the intent of our leaders at the time of signing, to 

impose or restrict Tribal members from exercising off-reservations rights; and, provided for 

through a 'Prohibition of Fees' under the Recreational Enhancement Act, which gives the FS 

authority to collect such fees. Again, we have attached our positions statement on camping on 

federal lands.

The Tribes should also be afforded special access accommodations when exercising offreservation treaty rights to hunt, fish, and gather. Access restrictions now imposed by the Federal 

government to unoccupied lands were not in the contemplation of the drafters of the Fort Bridger 

Treaty. Therefore, when necessary access should be accommodated to tribal members exercising 

off-reservation treaty rights.

Climate Change Policy

We are also greatly concerned with the impacts of climate change and how federal land 

management actions may be contributing to climate change. Not only does the development of 

solid minerals, fluid minerals, and energy fragmentation and reduce habitat for wildlife, fish, and 

native plants, this type of development can contribute to climate change. For example, native 

plant communities are known to sequester carbon and ameliorate climate. Surface disturbance 

and occupancy reduces the ability of native plant communities to provide climate regulating 

ecosystem services. Emissions that result for fluid minerals contributes directly to climate 

change through increased radiant forcing. Although, these types of actions may seem limited to 

the region the effects of climate change impact the globe. Therefore, we do not support actions 

posed by the BLM that contribute to positive radiant forcing. We do support actions that help 

mitigate the effects of climate change. For example, establishing management actions and 

objectives to promote climate regulating ecosystem services and maintenance and enhancement 

of large landscapes dominated by native vegetation. To better help you understand our position 

on climate change we have attached our Climate Change Policy.
Livestock Grazing

The Tribes have become gravelly concern about disease spread from livestock and subsequent 

declines of bighorn sheep, not to mention the degradation of native plant communities and 

spread of invasive plants from excessive livestock grazing. It should also be noted that the 

potential for disease transmission to bighorn sheep is not limited to domesticated sheep, but 

cattle as well (Wolfe et. al 2010). As such, the Tribes feels that all alternatives should consider 

retiring domestic sheep grazing from all grazing allotments within and near (30 mile buffer) 

suitable habitat (e.g., mountainous areas, cliffs, steep riverbanks, and gullied badlands with 

appropriate food and water). This would allow bighorn sheep to spread into historic habitat 

regions and reduce risks of transmission. The bighorn sheep is an iconic and sacred animal 

species of the Tribes, and there needs to be extreme caution and discretion when considering to 

allow domestic livestock grazing across its range.

The Tribes cannot support any allotment plan that has the potential for passive, continuous 

grazing activities in riparian areas because of the likelihood that there will be an adverse impact 

on the watershed. Passive, continuous grazing means grazing throughout the growth period with 

little or no effort to control the duration or distribution of livestock use in particular areas. There 

is often a habitual overuse of the riparian areas, even though there may be abundant forage 

nearby. The FS should retain the right to require curtailment of grazing activities to protect the 

riparian area. It is essential that there be responsible stockmanship by the permit holder, and 

management should require trained range riders to prevent the deterioration of the allotment's 

riparian areas. Therefore, the Plan should establish goals and objectives to establish active 

grazing management that entails continual monitoring and animal movement's to avoid or reduce 

impacts to sensitive areas (e.g., riparian areas, rare plant habitat, etc.).

Native Fish, Wildlife, and Plants

The Tribes have a mission to protect, restore, and enhance native wildlife, fish, and plant 

resources to support our reserved rights to hunt, fish, and gather. Management should be 

considerate of avoiding unnecessary disturbances to wildlife, fish, and native plant communities, 

or adverse loss or degradation of habitat. With that there should be a discussion of the overall

goals for native fish, wildlife and plants, as it relates to providing opportunities to the Tribes to 

harvests native fish, wildlife, and plants. We suggest the following Desired Condition to be 

incorporated into the planning document.

Desired Condition: Protect, restore, and enhance fish, wildlife, and native plant 

resources in accordance with the Tribes' unique interests and vested rights. Provide 

ample opportunities for exercising inherent, indigenous, and treaty protected rights of 

Tribal members to fair process and the priority right to harvest pursuant to the Fort 

Bridger Treaty of July 3, 1868 (15 Stat. 673).

There should also be a justification for how the Plan will meet or least not prove adverse to this 

desired condition.
Ecosystem Services

The Plan needs to provide a methodology for quantifying and valuing native fish, wildlife, plant, 

and ecosystem service losses and gains that result from management. This methodology is 

needed to show how services are loss as a result of development and disturbance, as well as how 

services are gained through proper reclamation, restoration, and management. The metrics 

developed should also be used as a mechanism to ensure reclamation, restoration, mitigation, and 

management is adequate. At a minimum there should be metrics developed for biodiversity, 

carbon sequestration, wild foods, fish & wildlife habitat, medicinal resources, pollinator services, 

drinking water, aesthetic losses, opportunities for hunting, fishing, and gathering, and spiritual 

experience. These ecosystem services are highly important to the Tribal people, especially as it 

relates to fish & game, drinking water, medicines, and maintaining cultural connection with the 

air, land, and water. We suggest the FS look into the latest literature on assessing ecosystem 

services and develop a way to consider losses and gains, as well as how to incorporate the 

concept into restoration, reclamation, mitigation, and management goals and objectives. This is 

one mechanism for conveying changes in resource conditions overtime during government to 

government consultation meetings.

Invasive Species

Non-native invasive species are having a profound impact upon the ecosystem and management 

throughout the West and FS management should not contribute to the spread and proliferation of 

invasive species, including non-native weeds. Therefore the EIS and Plan, should have a 

thorough discussion and plan for implementing an effective integrated pest management plan.

At a minimum, this plan should consider the following:

• Ways to prevent new infestations 

♦ Education outreach

♦ Signage

• Actions and commitments for early detection of new invaders 

♦ Trained observers

♦ Sampling techniques

♦ Monitoring

• Biology of invasive species

♦ Growth form and physiology

♦ Dispersal vectors

♦ Location and extent of invasion

• Feasibility of eradication vs. control

♦ Elimination of propagules from seed bank

♦ Eradication efficiency

♦ Weed decreases/increases over time and control potential

• Eradication and/or Control Strategy

♦ Control methods (e.g., herbicide, mechanical, cultural, biological, etc.)

♦ Restoration

♦ Timelines

♦ Monitoring

♦ Costs
• Treatment effective and evaluation plan

♦ Record keeping actions

♦ Adaptive management

Thorough consideration of each individual species biology will help develop a successful 

integrated pest management plan for the entire planning area. It would also be good to provide a 

discussion about the need for control/eradication and problems invasive species pose to the 

ecosystem and other uses of the Forest.

If Forest improvement funds are insufficient to promote the implementation of an effective pest 

management program, the Tribes suggest development and exploitive use is reduced, reflecting 

the need for commensurate funding due to degradation from such actions. Individuals, 

associations, and corporations involved in extractive use of the Forest must bear the burden of 

recovery, reclamation, and restoration costs make reduce the spread of non-native invasive 

species that result from their actions.

Special Areas & Cultural Resources

The Tribes would like the FS to consider designating routes utilized by the Indians during 

Bannock-Paiute War of 1878 as a National Historic Trail System under the National Trails 

System Act. At a minimum, we would also like to see some type of special designation to protect 

portions of this trail, especially burial sites and battlegrounds. We would like to have the FS meet 

with our Language and Culture Preservation Department about how to best handle trail 

protection and the management of cultural resources.

The Desired Condition for Cultural Resources gives no weight to the Tribes interests in the 

management of cultural resources and is rather ambiguous in regard to the statement that 

Traditional Cultural Properties are available for "appropriate use". We suggest the following 

language be utilized for Desired Condition.

Desired Condition: Significant historic sites are protected and managed to standard as part 

of the Heritage Program. Prehistoric, Traditional cultural properties, and historic sites of 

interests to Tribes are protected and managed to standards set by the Heritage Program in 

consultation, cooperation, and coordination with the Tribes. Knowledge of cultural 

resources is enhanced by scientific study, consultation with American Indian Tribes, and 

public understanding of cultural history is enhanced through interpretation and education.
The Shoshone-Bannock Tribes look forward to working with the Forest Service on this Plan and 

DEIS. Please respond to these comments in a written format, noting where the comments were 

incorporated or rationale for why they were disregarded. For comments or questions regarding 

this submission, please contact Cleve Davis at (208) 239-4552 or by email 

cbdavis@sbtribes.com.

Sincerely,

Nathan Small

Chairman, Fort Hall Business Council 

Shoshone-Bannock Tribes

LITERATURE CITED

Wolfe, L.L., B. Diamond, T.R. Spraker, M.A., Sirochman, D.P. Walsh, C.M. Machin, D.J. Bade,

M.W. Miller. 2010. A bighorn sheep die-off in southern Colorado involving a 

Pasteurellaceae strain that may have originated from syntopic cattle. Journal of Wildlife 

Diseases, 46(4):1262-8.

[Note: The following attachments to this letter are available upon request from the planning 

record]

Attachment 1: Federal Land Transfers Policy

The Shoshone-Bannock Tribes' Position Regarding the Transfer of Federal Lands, July 2005

Attachment 2: Campground Policy

Shoshone-Bannock Tribes Position Statement Regarding Developed Campgrounds on Federal 

Lands GAME-06-0506

Attachment 3: Climate Change Policy

Resolution No. ENVR-2014-0299

Attachment 4: Snake River Policy Statement

The Policy of the Shoshone-Bannock Tribes Management of Snake River Basin Resources, 

1994, Resolution No. GAME-94-1049

1

State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

State of Oregon

Comments on

Blue Mountains National Forests

Draft Environmental Impact Statement and Proposed Revised Land 

Management Plan

August 2014

The State of Oregon (hereafter referred to as the State) provides the following comments on the 

Blue Mountains National Forests Draft Environmental Impact Statement (DEIS) and Proposed 

Revised Land Management Plan (PRLMP), affecting management of approximately 5.5 million 

acres in northeastern Oregon and southeastern Washington, including the Malheur, Umatilla, 

and Wallowa-Whitman National Forests. The State acknowledges and appreciates the amount 

of work to date in the development of the Blue Mountains National Forests DEIS and PRLMP by 

the he Forest Service (FS), its interdisciplinary team and others involved in this ambitious 

undertaking. 

The State’s comments have been developed with significant contributions from the Oregon 

Department of Fish and Wildlife (ODFW) and the Oregon Department of Forestry (ODF). ODFW 

and ODF appreciate the opportunity afforded the State to participate with the FS under the 

agreement that gives the State cooperating agency status. The mission of ODFW is to protect 

and enhance Oregon’s fish and wildlife and their habitats for use and enjoyment by present and 

future generations, and the agency has statutory obligations to manage fish and wildlife 

resources of Oregon. The mission of ODF is to serve the people of Oregon by protecting, 

managing, and promoting stewardship of Oregon's forests to enhance environmental, 

economic, and community sustainability. 

Overall, while the State has concerns over the DEIS and PRLMP documents as reflected in the 

comments and suggestions below, Oregon remains supportive of completing the revision of 

forest plans for the Blue Mountains National Forests. The State’s comments tier to the Oregon 

Board of Forestry’s Federal Forest Principles4 as adopted in July 2014, and also reiterates several 

issues the State identified during public scoping in 2010. The State has a long history of working 

with the Blue Mountains FS staff and looks forward to continued work with the FS and other 

partners to help shape a plan for the Blue Mountains National Forests. In addition, the State will 

continue to work closely with the FS at the field level within the planning area, to support local 

forest collaboratives, implement the Northern Blue Mountain Cohesive Wildfire Strategy5

, and 

provide technical assistance and resources to adjoining private forestland owners. 

The following is a summary of the primary issues and concerns the State found in its’ review of 

the Blue Mountains National Forests DEIS and PRLMP (in no particular order):

 4 http://www.oregon.gov/odf/Pages/board/BOF_Subc_Fed_Forests.aspx 5 http://bluemtnwildfirestrategy.org/
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

2

OVER-ARCHING ISSUES 

1. Collaboration and Partnerships. The State asserts that National Forests should be 

managed with a clearly defined vision and strategic goals developed and implemented 

through a collaborative partnership that includes public involvement. The State believes 

that increasing the scale and pace of forest health restoration on FS managed forests in 

eastern Oregon will contribute to the health and resiliency of Oregon’s dry-side forest 

ecosystems, communities and economy. The State supports partnerships between 

federal, state, county, city, tribes, conservation and environmental non-governmental 

organizations, private forest products and energy business organizations (e.g., Wallowa 

County Natural Resources Advisory Committee, Blue Mountains Elk Initiative, Blue 

Mountains Forest Partners, Wallowa-Whitman National Forest Collaborative, Umatilla 

Forest Collaborative Group). Within the Planning Area, local forest collaboratives have a 

wealth of local, project-based knowledge, and have been an effective venue to build 

stakeholder agreement. They have also been effective in providing 

review/recommendations for forest management activities and have reduced litigation 

of FS land management actions. The State has invested in collaboration as a governance 

model and envisions it growing in utility and effectiveness within the timeframe of the 

PRLMP. Further, various laws require collaboration on the part of the FS, and the agency 

has engaged this approach to date. However, the DEIS is inadequate in its reflection of 

the role it sees for collaboration and partnership’s in achieving objectives over the life of 

the Plan. 

The State asserts that management actions occurring on the Blue Mountains National 

Forests directly and indirectly affect what happens on adjacent private lands.

Recognizing that the effects upon forest health, fish, and wildlife are connected to larger 

landscapes that include other public and private lands—and that actions on one land 

ownership can affect the other—the State believes the DEIS/ PRLMP should do more to 

consider how neighboring non-federal landowners and resources (e.g., habitat, fish, 

wildlife) may be affected when analyzing management alternatives/actions related to 

forest and watershed health, wild fire, roads, recreation, distribution and abundance of 

fish and wildlife, and invasive species. (Along those lines, the State also provides 

additional comments specific to key points and neighboring private lands as noted in 

other principal issues to follow).

 The State recommends the PRLMP specifically mention and address how the FS will 

ensure and improve engagement of local collaboratives to achieve the vision of the 

PRLMP. Specifically, the State believes the FS should identify how the role of 

collaboratives in advancing projects or other efforts needed to attain “Desired 

Conditions” as well as how collaboratives could be better engaged to improve 

efficiency and effectiveness outcomes in project planning, implementation, and 

monitoring. 

 The State recommends the PRLMP better address how it will ensure, improve, and 

promote coordination between agencies and partners to address forest, fish, and 

wildlife issues that extend across land ownership boundaries and jurisdictions (i.e., 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

3

All-Lands Approach). Specifically, the State recommends PRLMP promote a “no 

adverse relationship” approach to neighboring non-federal lands.

2. Planning Rule Conformance. Given the decade-plus history on this effort, the State 

understands the FS is using the 1982 Planning Rule as the basis for plan development 

while also using complementary components from the 2012 Rule. In reviewing the 

DEIS/PRLMP, the State was not able to distinguish whether the 1982 or 2012 Planning 

Rule components were used for parts of the plan as discussed in the narrative of the 

PRLMP. Clearer identification and declaration of planning rule components is necessary 

for adequate review to determine if the FS is conforming to the National Forest 

Management Act. 

 The State recommends that DEIS/PRLMP, wherever appropriate, declare which 

specific provisions (including references) of the 1982 and 2012 Planning Rules are 

being utilized. The State suggests that this would be best provided both in the 

narrative of PRLMP and in a summary table for quick review. 

3. Travel Management. Use of motorized off-highway vehicles (OHV) is a significant issue 

in the Blue Mountains National Forests. The State recognizes that OHV use has 

increased since the last Forest Plan, is continuing to increase, and so is the demand for 

off-road travel areas as well as pressures upon natural resource values. OHV use—

especially when unplanned or outside designated routes—can result in resource 

damage and displacement of wildlife. Further, the Forest Service’s capacity to monitor 

and enforce OHV use / travel management restrictions is inadequate in the face of 

growing pressures. growth in use and Given this and the road density summaries in the 

DEIS/PRLMP, the State believes that specific direction related to OHV management, 

road density, and enforcement of open vs. closed road/trail designations is extremely 

important to maintaining functional fish and wildlife habitats in the Blue Mountains 

National Forests. The State understands that the Forest Service is proposing to proceed 

with travel management decisions being placed at the project level. While potentially 

effective in a given project area, this approach may miss the broader need to plan at a 

landscape-wide level as well as the problems that can arise when this broader approach 

is not taken. The State believes more specificity is needed in the PRLMP to address 

forest-wide issues and concerns related to travel management. The State also asserts 

that monitoring of the impacts of this approach are imperative to assess whether the 

PRLMP is achieving broader aquatic and wildlife objectives. 

 The State recommends the PRLMP document a better crosswalk between the 

PRLMP and FS Travel Management Rule, and that the PRLMP should communicate 

its implementation across the landscape more clearly. Specifically, the State 

recommends the PRLMP identify and propose how project-level implementation of 

travel management will be linked to Plan- and landscape-level goals/objectives 

and “Desired Conditions”. 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

4

 The State recommends that monitoring efforts be robust to determine if broader 

aquatic and wildlife protection objectives are being achieved with project-level 

implementation of travel management.

 The State recommends that each Blue Mountains National Forest develop Forestspecific plans to fulfill the Travel Management Rule direction and tier to the PRLMP 

objectives.

4. “Desired Conditions” and “Standards and Guidelines”. The State values management 

flexibility and discretion in today’s context for managing National Forests and is 

encouraged by the flexibility the PRLMP provides to the local Forest and District staff 

professionals. To this end, the State supports the “adaptive and active management” 

philosophy articulated in the PRLMP. The State also recognizes the need for improved 

site-specific data available to Federal land managers and therefore supports reliance 

upon “Desired Conditions” as primary management drivers to allow local Forest staff to 

work in collaboration with partners to develop project-level decisions. However, the 

State also believes that “Standards and Guidelines” are important PRLMP components 

to provide measurable objectives and ensure project-level management actions trend 

toward “Desired Conditions” over the PRLMP’s time horizon. Setting forth “Desired 

Conditions” is not enough to ensure accountability to the public in achieving those 

conditions and related management objectives, and the State believes reasons exist for 

concern with the DEIS / PRLMP approach at this point in time.

The State believes it is important to know what the existing condition of the Blue 

Mountains National Forests is relative to the desired future condition. The State asserts 

this is not clear in the DEIS/PRLMP. In addition, the standards and guidelines used in 

past forest plans were instituted for a reason, and the State would like to know whether 

the underlying reasons have now been addressed or how this will be assured moving 

forward. In other words, since the goals and/or commitments were made in the last 

Forest Plan, have the “Standards and Guidelines” that would now be replaced (or the 

objectives to which they relate) been met? Is the trend in a positive direction? Or is 

there insufficient data to say, and if so, what assurance does the public have that the FS 

will meet desired conditions moving forward? The State requests and assessment of 

monitoring data related to the 1990 Blue Mountains Forests Land and Resource 

Management Plans “Standards and Guidelines” to provide this important baseline.

Even under the proposed “Desired Conditions” framework, the State believes 

“Standards and Guidelines” can be useful to target explicit management direction and 

measurable outcomes when warranted for specific resources. Further, the State notes 

that although the PRLMP relates to individual Blue Mountains National Forests, the 

“Standards and Guidelines” related to active management are the same across the 

Malheur, Umatilla and Wallowa-Whitman National Forests. The State appreciates the 

guidance provided by this level of “Standards and Guidelines”, noting that few have 

specific and hard targets. The State does find some inconsistency in the ability of the 

manager to utilize site-specificity in meeting particular “Standards and Guidelines”. In 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

5

some cases, the lack of this ability is limiting and in other cases it may not yield enough 

direction to design a management project with a high-level of certainty.

The State appreciates the reconsideration of management direction provided by the 

“east side screens”, which were intended as interim but based on underlying natural 

resource concerns. In particular, the State recognizes the continued need to maintain 

and recruit older forests and larger trees across the eastern Oregon landscape, while 

also recognizing there are more appropriate means of achieving this outcome at the 

project scale than a “one size fits all” approach of a diameter threshold. The State 

acknowledges the work of local collaboratives and the science community in providing 

the first opportunities to evaluate an age threshold as a means to ensure adequate 

distribution of older forests. The State agrees with the direction in the PRLMP to 

manage for older forests based on stand and individual tree age and encourages the FS 

to work with forest collaboratives in determining site-specific project design.

 The State recommends drafting “Desired Conditions” with measurable / 

quantitative targets that correspond to the vision of the Plan; and tier “Standards 

and Guidelines” in a manner that provides project-level direction and allows for 

assessment of achievement over the time horizon of the PRLMP. “Desired 

Conditions” should be detailed enough to gauge overall Plan effectiveness at 

achieving the vision of the PRLMP.

 The State recommends providing additional clarity to increase management 

flexibility within some “Standards and Guidelines”. Specifically:

• Develop a specific Standard & Guideline for management of Individual Old 

Trees within MA 4A General Forest. Remove the site specificity clause of OF-1 

G-59 within MA 4A and rely on the 150 year old threshold. Maintain the site 

specificity component for all other land allocations. 

5. Monitoring and Evaluation Plan. The State believes a robust and detailed monitoring 

strategy, supported by appropriate research, must be implemented and directly 

connected to an adaptive management feedback loop as a key part of the PRLMP. In 

particular, the State notes that monitoring of the Standards and Guidelines of the 1990 

Plan was not adequate to determine Plan effectiveness for particular fish and wildlife 

objectives. Given the reliance on “Desired Conditions” and increased management 

flexibility at the expense of robust “Standards and Guidelines” in the PRLMP, the State 

asserts that monitoring and evaluation is imperative to assess implementation over the 

life of the PRLMP.

The State believes the PRLMP provides only a very general framework for monitoring 

and evaluation, and lacks sufficient detail to ensure the PRLMP is implemented as 

intended or whether it is achieving its intended objectives. The State cannot determine 

if the FS will invest in status and trend monitoring, whether it will coordinate its 

monitoring with other agencies/partners, or whether there is a commitment to start 

baseline monitoring needed to detect the effects of management actions and external 

drivers like climate change. Further, the State believes an opportunity exists to enhance 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

6

monitoring efforts through engagement with local forest collaborative groups, statelevel partners, and other interests, which should be further identified through the 

PRLMP.

 The State recommends PRLMP provide much more detail and clarification of the 

monitoring and evaluation strategy within PRLMP, including connections to local 

collaborative, state or other partner engagement. The FS should consider, through 

an interagency coordination effort, developing a multi-organizational 

monitoring/evaluation strategy. Objectives for monitoring should be prioritized 

and set by interagency needs using a multi-scale approach of analysis, including 

regional assessments, basin assessments, watershed analysis, and project analysis.

 The State recommends the FS document a commitment to adequately fund and 

implement the monitoring component of the PRLMP.

6. Economic Goals and Outputs. The State applauds the FS for articulating that the vision 

of the PRLMP “recognizes that social and economic components cannot be separated 

from ecological systems.” This triple-bottom-line approach is consistent with the Board 

of Forestry’s vision and aligns well with ODF’s Federal Forest Principles. The PRLMP, 

however, seems inconsistent in its approach. The State notes that this social-economicecological interconnection is not articulated within the desired conditions language 

under Goal 1: Promote Ecological Integrity, yet the ecological components are included 

in the desired conditions of Goal 3: Promote Economic Well-being. 

The State asserts that the PRLMP undersells the contribution of management of Blue 

Mountains National Forests to local communities and economies. The State believes 

that the PRLMP must identify and produce a predictable and sustainable level of wood 

products as well as non-timber resources and values that contribute to social well-being 

and economic stability of rural communities. The FS should identify where opportunities 

for timber production and ecological restoration are mutually supportable, as well as 

what level and average diameter class of trees are likely to be sustained over time as 

part of achieving “Desired Conditions” across the Blue Mountains Forests. This would 

allow for improved business planning and stability, targeted business investment, and 

potential diversification of economic opportunities. Overall, the State believes the 

PRLMP does not adequately address Issue 2 (Economic and Social Well-being), 

developed to respond to public comment on the proposed action. Two examples are:

• Recognition and assessment of FS management to provide adequate work to 

maintain a viable workforce necessary to carry out management activities.

• As recognized throughout the PLRMP, fishing, hunting, and wildlife viewing 

generates economic activity for regions and counties throughout the state. In 

particular, northeast Oregon serves as an appealing destination for both Oregon 

residents and out-of-state visitors (nonresidents).
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

7

The State appreciates that Goal 3 includes “Desired Conditions” relating to economic 

measures internal to the FS. In the current context, maximizing outputs from Federal 

dollars is critical to success at the landscape-scale. 

The State notes that the description and “Desired Conditions” for Management Area 

(MA) 4A General Forest do not include the word “timber”. The State also notes that 

according to the “Desired Conditions”, this General Forest allocation is “maintained 

through ecological processes, as well as management activities.” Since this is the only 

land allocation expressly identified as suitable for timber production, the State asserts 

that this specific resource should be mentioned in addition to “a variety of...human 

needs”.

 The State recommends that DEIS/PRLMP be amended to strengthen the context, 

breadth of analysis and outputs specific to the fulfilling Goal 3: Promote Economic 

Well-being, including:

• Adequately recognizing the relationship between National Forest management 

and wood products manufacturing in Goal 3.3.1 Forest Products. Suggested 

revisions include:

 “Wood products manufacturing remains a primary driver for local 

economies.”

 “A predictable supply of timber outputs...contributes to maintaining the 

viability of a local forest products industry.”

 Provide details regarding the sawlog, non-sawlog and biomass components 

of the current timber harvest.

 The State recommends that there be an explicit use of “predictable and sustainable 

timber supply” in the description and desired conditions of MA 4A General Forest 

(p. 91 of PRLMP).

 The State recommends that DEIS/PRLMP include a broader set of social and 

economic factors for the purposes of analysis and corresponding outputs to 

complement the array of ecological outputs (i.e., Table 26 of PRLMP). For example:

• Breakdown of sawlog, non-sawlog and biomass component of the TSPQs. 

• Acres of harvest type (i.e., thinning, variable retention, regeneration). 

• Analysis of impacts of proposed plan to “jobs in the woods” related to habitat 

restoration (fire resilience, forest health, invasive weeds, aquatic / watershed 

function)—types, numbers, and contributions of those jobs to economy. 

• Projected impact for available workforce. 

• Contribution of recreation (i.e., fishing, hunting, wildlife viewing, hiking, etc.) 

to local economies. One resource is a report by ODFW and Travel Oregon; 

available at ODFW’s website: 

http://www.dfw.state.or.us/agency/docs/Report_5_6_09--Final%20(2).pdf
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

8

AQUATICS AND RIPARIAN HABITAT

7. Aquatic and Riparian Strategy. The State appreciates the attention paid to protecting 

valuable array of aquatic resources in the DEIS/PRLMP. The DEIS/PRLMP makes 

numerous references to a variety of protection strategies, including the Aquatic 

Conservation Strategy (ACS), Aquatic Restoration and Conservation Strategy (ARCS), 

INFISH, and PACFISH. The State believes the DEIS/PRLMP are not clear about which 

aquatic strategy(s) is being proposed for use in guiding protection of watershed 

conditions, riparian areas, and aquatic species. The State could not determine what 

elements of each of those strategies were combined, updated, changed, or deleted to 

create what is referred to as “a new regional ARCS” in the PRLMP. As such, the State 

does not currently understand ARCS to a degree adequate to determine our view of the 

FS’s proposed riparian approach.

The State notes that the multiple components of ARCS (Riparian Management Areas; 

Key Watersheds; Mid-Scale Analysis; and Watershed Restoration) are the same 

components of the Aquatic Conservation Strategy in the Northwest Forest Plan, which 

has been a topic of focus regarding successful implementation of forest management 

efforts. Based on the information provided in the DEIS/PRLMP, the State assumes that 

this planning effort is using general regional policy direction for Plan revisions and is 

thus proposing to use an Aquatic Conservation Strategy without further evaluation 

within the Planning Area, adjustment or revisiting the scientific rationale. The State 

notes that PACFISH and INFISH were interim guidelines provided as direction to eastside National Forests. Based on the information included in the draft documents, it 

appears that the PRLMP would make these interim guidelines permanent, yet the State 

is not under the impression these or other components of the interim guidelines / 

screens have undergone public / NEPA review since their interim adoption.

The State offers that recent science6 is being used to evaluate the efficacy of different 

riparian buffers within the context of the Bureau of Land Management (BLM) Western 

Oregon Planning Process. ODF is also undergoing a Riparian Rule Analysis for private 

forest lands based on recent scientific findings7. The State recognizes that the “Viability 

Rule” in the 1982 Planning Rule provides specific direction to the FS as opposed to 

either the BLM or ODF. However, the State is not clear from the DEIS or PRLMP whether 

use of the 300/150/100-foot riparian buffers are intended to provide additional 

conservation measures beyond water quality. The State notes that the proposed 

riparian buffers account for 29% of MA 4A General Forest acres. This constitutes a 

significant amount of the landbase that reduces the amount of acres available for 

timber production. In addition, if active vegetation management within riparian areas is 

completely prohibited—even if carried out for conservation-based or habitat restoration 

reasons—this could impede attainment of conservation values and limited timber as a

restoration by-product. As drafted, the DEIS/PRLMP does not adequately juxtapose the 

 6 http://fes.forestry.oregonstate.edu/sites/fes.forestry.oregonstate.edu/files/PDFs/Riparian%20paper%20Jan%2023.pdf 7 http://www.oregon.gov/odf/privateforests/pages/monitoringripstream.aspx
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

9

value-add of the proposed riparian approach or others on the tradeoffs and range of 

options between conservation and potential timber production.

The State supports the concept of key and priority watersheds in the PRLMP for more 

accelerated conservation outcomes. However, the State cannot determine what aquatic 

and riparian management prioritization scheme was used to identify key/priority 

watersheds in the DEIS/PRLMP. For example, the lists of key/priority watersheds in the 

DEIS (Volume 3, Appendix B, Tables B-5, B-6, B-7, pp. 331-337) differ from the list 

included in the project record. The State could also not determine which aquatic focal 

species were used to identify individual watersheds. Federal- and state-listed aquatic 

species are facing threats to their populations and/or habitats. Implementation of 

appropriate conservation measures to address the threats may prevent declines of atrisk species and reverse declines in these resources where possible.

The State supports alternatives that have comprehensive outcomes for maintaining and 

restoring water quality and quantity to support a healthy ecosystem, as well as 

protecting and restoring other aquatic and riparian habitat values (e.g., structure and 

processes/functions, Oregon’s native fish and wildlife species). This includes restoring 

natural recruitment of large wood to stream channels, promoting short- and long-term 

shade function, sediment and erosional buffering function, thermal heterogeneity, 

physical habitat complexity, and habitat connectivity. In pursuing these outcomes, the 

State believes active vegetation management can play a role in achieving desired 

ecological conditions, as long as management is governed by an overarching riparian / 

aquatic conservation purpose or directive and associated risks are managed through 

“Standards and Guidelines” and best management practices that contain measureable 

objectives at the landscape-level, project-level, and site-specific-level.

 The State recommends FS clarify their process for choosing a riparian protection 

strategy, and more clearly and completely describe the “new regional ARCS” in 

PRLMP.

 The State recommends PRLMP provide more certainty on how ARCS will achieve 

the intended desired conditions, including:

• Communicating more clearly how ARCS will be implemented across the 

landscape to ensure the PRLMP complies with the federal Clean Water Act and 

its implementation through State water quality standards and other 

approaches.

• Addressing the potential role of and ability for vegetation management in 

riparian areas to assist in attaining conservation outcomes, where overarching 

management direction is conservation-driven and timber is allowed as a 

secondary by-product thereof.

 The State recommends FS clarify their process for selecting Key/Priority 

watersheds and identify which focal species are used to select each Key/Priority 

watershed in PRLMP.
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

10

• The State recommends that one criteria for selecting Key/Priority watersheds 

should be the presence of one or more Endangered Species Act (ESA)-listed 

species or state sensitive species in them.

 The State recommends FS provide more certainty on its intended desired 

conditions for Key/Priority watersheds, and communicate its 

integration/implementation with the “new regional ARCS” across the landscape 

more clearly in PRLMP.

8. Oregon Fish Passage Laws. The State could not find any mention and/or reference to 

Oregon fish passage laws (Oregon Revised Statute (ORS) 509.580 to 509.910) in the 

DEIS/PRLMP. The State believes PRLMP must address state fish passage laws. Each 

crossing of a stream or waterbody containing, or historically containing, native 

migratory fish could trigger Oregon fish passage laws that require ODFW engagement 

and approval. Trigger events include installation of structures of relevance to fish 

passage (e.g., culverts, artificial obstructions), major replacement or upgrade work, a 

fundamental change in permit status (eg. new water right, renewed hydroelectric 

license), or abandonment of an artificial obstruction. Further details concerning triggers 

can be requested from ODFW. The approval includes ODFW review of stream crossings 

or site-specific details pertaining to stream crossing method, design, timing, location, 

and placement details. The goal of these fish passage laws is to ensure the steam 

crossing designs are compliant with ODFW fish passage design criteria, and fish passage 

is unobstructed at all crossing locations. 

 The State recommends PRLMP best management practices related to roads specify 

that new, replacement stream-crossing structures will be consistent with ODFW 

fish passage laws. 

 Oregon laws regarding fish passage may be found in ORS 509.580 through 910 

(http://www.leg.state.or.us/ors/509.html) and in Oregon Administrative Rules 

(OAR) 635, Division 412 (http://www.tate.or.us/OARs/412.pdf). 

9. ESA Conservation and Recovery Plans. The State cannot determine whether recovery 

actions for mid-Columbia River Steelhead have been addressed in the PRLMP. The 

Oregon Middle Columbia River Steelhead Conservation and Recovery Plan (Oregon MidC Plan) identifies numerous actions to protect and restore natural ecological processes 

that support the viability of summer steelhead populations within the Blue Mountains 

National Forests. The Oregon Mid-C Plan addresses legal requirements for recovery 

planning under the federal ESA and Oregon’s Native Fish Conservation Policy. Perhaps 

more importantly, in addition to meeting legal requirements, the plan provides an 

informed, strategic approach to recovery that is based on science, supported by 

stakeholders, built on existing efforts, and includes new recovery actions. The Oregon 

Mid-C Plan is linked to an adaptive management framework that will evolve over time 

with new information, including assessment of the recovery actions taken. 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

11

Implementation of the Oregon Mid-C Plan will require the contribution of federal, state, 

tribal, and local partners. 

The State also supports and encourages the FS to integrate recovery strategies and 

actions into the PRLMP related to recovery plans or related documents for other ESAlisted species. This includes the Draft ESA Recovery Plan for Snake River Spring/Summer 

Chinook Salmon and Snake River Steelhead and Bull Trout Draft Recovery Plan and other 

ESA Recovery Plans as they come on-line. Habitat on the Blue Mountains National 

Forests plays a key role in the protection and restoration of these species.

 The State recommends PRLMP integrate and address protection and restoration 

recovery priorities/actions included in the Oregon Mid-C Plan and other ESA 

Recovery Plans or related documents to guide landscape-level, project-level, and 

site-specific actions.

• The Oregon Mid-C Plan is available at ODFW’s website: 

(http://www.dfw.state.or.us/fish/CRP/mid_columbia_river_plan.asp)

• The Draft Recovery Plan for Snake River Spring/Summer Chinook Salmon and 

Steelhead is available at NOAA Fisheries West Coast Region website: 

http://www.westcoast.fisheries.noaa.gov/protected_species/salmon_steelhea

d/recovery_planning_and_implementation/snake_river/current_snake_river_r

ecovery_plan_documents.html

• The Bull Trout Draft Recovery Plan is available at the U.S. Fish and Wildlife 

Service Pacific Region website: 

http://www.fws.gov/pacific/bulltrout/Recovery.html

10. Management Indicator Species and Focal Species. The State supports including 

Management Indicator Species (MIS) and Focal Species in the PRLMP. However, the 

State believes there is considerable confusion regarding MIS/Focal Species in 

DEIS/PRLMP. The State cannot determine whether or not aquatic species have been 

identified as MIS/Focal Species. For example, there are no aquatic species included in 

the list of focal and management indicator species (Table 1, page 31) in the PRLMP. 

However, aquatic focal species are discussed and referred to in other parts of the 

DEIS/PRLMP. The project record also includes references to aquatic focal species. In 

many cases, the State also cannot determine how management actions will be directed 

at maintaining MIS/Focal Species and their habitats. For example, there does not appear 

to be Fish/Wildlife Emphasis Areas (e.g., Management Areas) designated for MIS/Focal 

Species in the PRLMP. The PRLMP states that additional information about Focal Species 

and their conservation strategies is available in the project record, which is not included 

in the DEIS/PRLMP. Again, federal- and state-listed aquatic species are facing threats to 

their populations and/or habitats. Implementation of appropriate conservation 

measures to address the threats may prevent declines of at-risk species and reverse 

declines in these resources where possible. 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

12

 The State recommends that PRLMP include aquatic MIS/Focal Species, and that 

any federally listed or state-sensitive aquatic species be included as MIS. 

• Federally listed aquatic species include: Snake River spring/summer Chinook 

ESU, Snake River fall Chinook ESU, Lower Snake summer steelhead DPS, midColumbia summer steelhead DPS, bull trout DPS, and Snake River Sockeye ESU 

in Oregon. 

• Western brook lamprey (Lampetra richardsoni) and Pacific lamprey (Lampetra 

tridentata) are both state vulnerable species, and should also be included as 

MIS given their unique life history, habitat requirements, state status, and 

tribal significance. Freshwater mollusks should also be considered for inclusion 

in this context. 

 The State recommends FS communicate more clearly how MIS/Focal Species are 

used to guide protection and conservation strategies and desired conditions in 

PRLMP, and also recommends including information about Focal Species and their 

conservation strategies in PRLMP. 

WILDLAND FIRE 

11. Transference of risk to private forestlands. The State recognizes that forest ecosystems 

in the Blue Mountains experienced more natural wildfire under historical conditions, 

and that fire as a driver of the ecological health of these systems. Decades of 

management under fire-exclusion policies have resulted in significant change in 

condition of federal forests and fire regimes in northeast Oregon. This condition has 

major implications for a host of resources important to the State, including public 

safety, adjoining private lands, and habitats. The State believes that restoring firetolerant forest landscapes will contribute to providing public health benefits, clean 

water, fish and wildlife habitat, recreational opportunities, and other crucial ecosystem 

services. In particular, today’s intermixed land ownership patterns require public 

agencies with different missions to manage wildfire in a coordinated approach. The 

State is proud to partner with the FS to implement the Blue Mountain Cohesive Wildfire 

Strategy in the Planning Area. We would like to increase state-federal engagement and 

coordination in other areas related to use of prescribed fire and wildland fire. 

 The State recommends including “transference of risk” to adjoining private 

forestlands under Goal 3.2 Land Ownership (p. 68 of PRLMP). The PRLMP should 

include context and objectives to reduce the potential for wildfire and 

insect/disease to cross property lines. 

 The State recommends the development of a specific “Standard & Guideline” for 

snag retention to reduce the transference of risk of wildfire to adjoining private 

forestlands. Include a site-specificity clause that would allow managers to consider 

removing a percentage of snags (for both >21” and 12-21” classes) within 500 feet 

of private forestland. 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

13

 The State recommends PRLMP integrate fish and wildlife habitat objectives and 

mitigation actions into fire restoration/rehabilitation programs and actions 

intended to manage fuels or salvage burned-over areas.

WILDLIFE 

12. Big Game Habitat Management Areas. The largest population of Rocky Mountain Elk in 

Oregon inhabits the Blue Mountains National Forests. The PRLMP correctly points out 

that elk are also important both economically and socially within the planning area, and 

appropriately identifies mule deer and Rocky Mountain elk as MIS. However, the State 

cannot determine how MIS status for deer/elk is used to guide conservation strategies 

and desired conditions for deer/elk in the PRLMP. For example, important big game 

habitats or special management considerations (e.g., road closures) are not specifically 

identified in the PRLMP. 

The State saw little reference in the PRLMP to the relationship between management 

actions and subsequent distributions of elk and mule deer on neighboring private lands. 

The State believes that FS management actions influence the distribution and 

abundance of deer and elk, and that private landowners are directly affected by 

management actions occurring on the Blue Mountains National Forests. There appears 

to be an increase of big game (especially elk) moving from public to private lands. 

ODFW’s ability to achieve big game Management Objectives and help private 

landowners protect their land from deer and elk damage is largely determined by the 

extent that habitat can be secured and enhanced on federal lands. Reducing disturbance 

and improving habitat also tends to keep deer and elk on public land and available to 

hunters that may not have access to private property. The State believes the PRLMP 

should include measures that promote security habitats and foraging areas for deer and 

elk, and addresses road closures, especially in Management Areas (MAs) that are 

adjacent to private lands or where there is potential to have adverse effects on adjacent 

private lands. 

The elk nutrition and elk habitat use models can help managers evaluate the nutritional 

and habitat conditions of Blue Mountains landscapes/alternatives and how likely elk are 

to use these landscapes. The models also project the effects of land management 

activities, like road closures and thinning, on elk. The State believes these models 

represent “best available science” and have the potential to better inform the effects 

analysis in the DEIS and alternative selection in the PRLMP.

 The State recommends PRLMP include specific Management Area designations for 

important big game habitats to ensure that specific management actions (e.g., 

road closures, road density limitations, cover, and forage) will be implemented to 

improve/enhance habitats across the landscape.
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

14

 The State recommends PRLMP include an analysis of how FS management actions 

will impact the Blue Mountains National Forests’ ability to keep deer and elk on 

public lands (and away creating private land damage), including the role of habitat 

improvements and road closures. 

 The State recommends Blue Mountains Elk Nutrition and Habitat models 

developed by the FS Pacific Northwest Research Station be utilized in DEIS/PRLMP. 

13. Bighorn Sheep. The largest population of Rocky Mountain bighorn sheep in Oregon 

inhabits the Blue Mountains National Forests. The State is concerned about the risk that 

domestic sheep may transmit disease(s) to bighorn sheep. Disease can significantly limit 

bighorn sheep populations. 

 The State recommends using “Risk of Contact” model utilized on Payette National 

Forest to delineate unsuitable rangelands for domestic sheep grazing/trailing in 

PRLMP. 

14. Wild Horses. The State is concerned about wild, free-roaming horses in certain portions 

of the Blue Mountains National Forests. There is a wild horse management plan on the 

Malheur National Forest. It is vital that the FS and ODFW work together to achieve 

desired outcomes on wild horse management. 

 The State recommends PRLMP support management of wild, free-roaming 

horses—including herd reductions—and that management activities related to 

wild horses should be done in coordination with ODFW to protect the natural 

ecological balance of all fish and wildlife species. 

15. Invasive Species. Invasive plants continue to cause changes in vegetative communities 

and loss of wildlife habitat and forage, and are a serious threat to the Blue Mountains 

National Forests, as well as adjacent non-federal lands. The State believes the FS should 

consider creating and implementing comprehensive invasive species detection, 

monitoring, and control strategies for FS lands that also consider potential impacts on 

adjacent private and public lands. 

 The State recommends PRLMP include an early detection and rapid response 

program for new invasive species, and include the full range of tools, such as 

herbicides and biological agents, to eradicate and/or manage invasive plant 

species. 

 The State recommends PRLMP integrate and implement current Invasive Plant 

Treatment EIS’s across all three Blue Mountains National Forests. 
State of Oregon comments on Blue Mountains DEIS and PRLMP 08/15/2014

15

OTHER RESOURCES TO CONSIDER 

A. Oregon Conservation Strategy. The State supports and encourages the FS to integrate 

the Oregon Conservation Strategy (OCS) in the PRLMP. The OCS provides an excellent 

opportunity for aligning the PRLMP with eco-regional and statewide conservation goals. 

The OCS could be used to help the FS make strategic decisions on conservation issues 

and for guidance on the types of actions most likely to benefit Oregon’s priority species 

and habitats. The OCS is available at ODFW’s website: 

http://www.dfw.state.or.us/conservationstrategy/ 

B. ODFW Wildlife Species Management Plans. The State supports and encourages the FS to 

integrate ODFW wildlife species management plans in the PRLMP. ODFW wildlife 

species management plans identify important ODFW wildlife management policies and 

strategies, and could be used by the FS to guide management actions related to specific 

species, such as Rocky Mountain elk, mule deer, bighorn sheep, wild turkey, and other 

species. ODFW wildlife species management plans are available at: 

http://www.dfw.state.or.us/wildlife/management_plans/ 

C. Centralized Oregon Mapping Products and Analysis Support System. The State supports 

and encourages the FS to integrate the Centralized Oregon Mapping Products and 

Analysis Support System (COMPASS) in the PRLMP. COMPASS is the first-of-its-kind 

online data and planning tool that provides spatial fish and wildlife habitat maps to 

chart Oregon’s crucial habitat landscapes. Some examples of data layers that can be 

found on COMPASS include aquatic and terrestrial species of concern, terrestrial species 

of economic and recreational importance, wetlands and riparian areas, priority fish 

barriers, big game winter range, landscape connectivity and large natural areas, etc. 

COMPASS can be accessed at ODFW’s website: 

http://www.dfw.state.or.us/maps/compass/index.asp 

D. Executive Order 13443: Facilitation of Hunting and Wildlife Conservation. The State 

encourages the FS to address President Bush’s Executive Order in the PRLMP when 

discussing forest management actions that may affect hunting and fishing opportunities 

on the Blue Mountains National Forests. 

STATE OF WASHINGTON

DEPARTMENT OF FISH AND WILDLIFE

2315 N Discovery Place• Spokane Valley, Washington 99216-1566 • (509) 892-1001 FAX (509) 921-2440

August 14, 2014

Blue Mountains Forest Plan Revision Team

Post Office Box 907

Baker City, Oregon 97814

Forest Plan Revision Team:

The Washington Department of Fish and Wildlife (WDFW) has enjoyed a long standing 

and valued relationship with the United States Forest Service (USFS) and the Forest 

Supervisors and staff within the state. In southeast Washington, we regularly work in 

partnership with the Umatilla National Forest; and that cooperation demonstrated itself 

during the development of the Blue Mountains Revised Forest Plan and Draft 

Environmental Impact Statement (DEIS). Forest Supervisor, Mr. Kevin Martin and his 

staff met with regional WDFW staff and I this spring to provide an overview of both the 

development process and the document contents and WDFW appreciates the effort and the 

hard work the USFS and the Umatilla National Forest has put into the development of the 

Revised Forest Plan and DEIS.

The comments provided by WDFW are designed to assist the Forest Plan Revision Team 

(FPRT) in improving the document and are also in the context of WDFW's mission: "To 

preserve, protect and perpetuate fish, wildlife and ecosystems while providing sustainable 

fish and wildlife recreational and commercial opportunities," within the state of 

Washington and across all ownerships. Land management decisions on federally owned 

and managed land affect fish and wildlife species and their habitats and thus can have an 

impact on our ability to fulfill our mission. This clearly speaks to the need for our 

continued cooperation and partnership.

WDFW would encourage the FPRT to retain the use of "Standards and Guidelines" as used 

in the 1990 Forest Management Plans. The use of "Desired Conditions" in the current plan 

revision and DEIS could be perceived as not providing specific parameters and 

requirements for action and/or the desire to meet a future condition might never be met but 

still be acceptable within the plan. Given this, we would recommend that when standards 

are stated, the word "should" be replaced with "shall." Examples of this will follow in the 

comments text within specific sections of the document.

Comments on specific sections of the document are as follows:
WILDLIFE

Bighorn Sheep

WDFW, the USFS, and the Oregon Department of Fish and Wildlife (ODFW), have 

committed considerable amounts of money, time, and other resources to the restoration of 

bighorn sheep in southeast Washington and northeast Oregon. WDFW greatly appreciates 

the science based approach outlined in this plan to ensure the continued recovery of this

iconic species; particularly efforts to address pack goats and domestic allotments in the 

proximity of suitable bighorn habitat. The following are suggestions that would further 

improve the recovery of this species.

The selected alternative should identify and map habitat that is determined to be unsuitable 

for domestic sheep grazing. Land managers need this tool when making decisions related 

to restocking or converting allotments. WDFW recommends that currently unoccupied, but 

available bighorn sheep habitat be classified as unsuitable for domestic sheep grazing in 

the selected alternative. This will allow for recovery and future population expansion.

Volume 2, Chapter 3, Page 235: The first paragraph under the Bighorn Sheep title 

references historic Rocky Mountain bighorn distribution. This citation fails to capture that 

Rocky Mountain bighorn sheep historically resided in southeast Washington, and should be 

corrected to reference Washington's role in historic population distribution.

Volume 2, Chapter 3, Page 237; Table 315: should be corrected to show that the Wenaha 

herd also resides in Washington. This herd uses Washington summer range extensively in 

Crooked Creek and Butte Creek. Washington shares management authority over this herd 

with Oregon and this should be properly reflected.

Volume 2, Chapter 3, Page 241: The information on this table indicates that the model 

predicts one bighorn sheep to domestic sheep contact per 100 years for the Wenaha and 

slightly less for the Black Butte herd. These herds are separated by a minimum of 11 and 

12 miles, respectively (Table 317 and 318). Although we support the quantitative approach 

to assessing risk, there are limitations to that method which could be improved upon by 

utilizing additional measures. For example, the North End allotment was stocked in 2013 

for the first time in many years with a new permittee. In March of 2014, 2 domestic sheep 

strays turned up north of the allotment in the Wenaha-Tucannon Wilderness area, within 

the core range of the Wenaha bighorn sheep herd. It is possible that these strays originated 

from the North End allotment, and some formal measures should be identified to reduce 

the risk of contact in future years. WDFW recommends the FPRT incorporate the 

following standards into the plan to ensure prevention measures and response measures are 

adequate to prevent contact between bighorn sheep and domestic sheep and goats.

RNG-9: Standard

Domestic sheep or goat grazing shall not be authorized or allowed on lands where 

effective separation from bighorn sheep cannot be reasonably maintained.
This standard does not define what "effective separation" between domestic and bighorn 

sheep means. It should clarify that in determining "effective separation" a quantitative risk 

assessment such as the one referenced in the August 19, 2011 USFS Washington Office 

Directive from the Deputy Chief, National Forest System, must be used. 

RNG-11: Standard 

The use of recreational pack goats shall not be authorized or allowed within or 

adjacent to source habitat for bighorn sheep. 

Defining adjacency needs to be addressed through a quantitative approach, such as 

incorporating the O'Brien et al. methodology (Incorporating foray behavior into models 

estimating contact risk between bighorn sheep and areas occupied by domestic sheep. 

2014. Wildlife Society Bulletin. 3 8(2) 321-331). 

RNG-12: Standard 

An effective monitoring program shall be in place to detect presence of bighorn sheep 

in identified high-risk areas when authorized domestic sheep or goats are present on 

adjacent or nearby allotments. 

WDFW recommends that you define "effective monitoring." The standard should require 

that monitoring occur prior to the turn out date of domestic sheep or goats. The monitoring 

timeframe should be based on weather and terrain. The Forest Service should coordinate 

with both Oregon and Washington respective state agencies on monitoring and data 

sharing. 

We also recommend that high-risk areas be identified and that they be modeled and 

mapped as part of the forest plan revision process and incorporated into the final forest 

plans. 

Lastly, an effective monitoring program should describe how domestic strays will be 

monitored. 

RNG-13: Guideline 

Trailing of domestic sheep or goats should not be authorized or allowed within 7 miles 

of bighorn sheep home ranges 

WDFW recommends that this Guideline be changed to a Standard, and that the word 

"should" be replaced with "shall". 

WDFW was unable to determine where the 7 mile figure originated. The separation 

distance should be biologically justified, such as quantifying foray distances, contact 

probabilities, and connectivity of suitable habitat between domestic locations and bighorn 

sheep herds.
RNG-15: Standard

Permitted domestic sheep and goats shall be counted onto and off of the allotment by 

the permittee. A reasonable effort to account for the disposition of any missing sheep 

must be made by the permittee. 

WDFW recommends that all sheep permitted to be on the forest be marked in a manner 

that is identifiable from a reasonable distance. The ability to quickly react to a stray in 

bighorn sheep suitable habitat should not be hindered by ownership or identification 

questions. 

WDFW also recommends that a new Standard be created that formalizes a response plan 

for each active domestic sheep allotment. This response plan would be utilized when strays 

move into bighorn sheep areas or when bighorn sheep disperse into the proximity of an 

occupied allotment. The response plan should identify personnel, agencies, and funding 

availability to quickly respond to a "contact" situation. Any plan should recognize the 

urgent nature of these contact situations and minimize delays that might reduce the 

opportunity to prevent potential contact. WDFW will readily work with the USFS, to 

review any response plan for allotments that affect Washington bighorn sheep herds (Black 

Butte, Mountain View, and Wenaha). 

RNG-17: Standard 

Authorized domestic sheep or goats shall be individually marked in a manner that 

allows immediate identification of ownership at a distance during the grazing season 

at all times while on NFS lands. 

Including this standard in the adopted forest plans is essential to managing viable 

populations of bighorn sheep across NFS lands in the Blue Mountains. If a domestic sheep 

is located off an allotment, it is essential that the responsible permittee can be identified. 

RNG-18: Standard 

Implement emergency actions when bighorn sheep presence is detected within 7 miles

of active domestic sheep or goat grazing or trailing. Actions to be taken shall ensure 

separation between bighorn sheep and domestic sheep or goats. 

WDFW recommends that the 7 miles distance must be biologically justified in the forest 

plan analysis; see comments to RNG-13. 

An emergency action plan must be part of any EA developed for domestic sheep/goat 

allotment adjacent to source habitat/core home ranges. This emergency action plan must be 

incorporated into Annual Operating Instructions (AOI) for grazing allotments and trailing 

permits. 

RNG-19: Guideline 

To maintain separation, when bighorn sheep are found within 7 miles of an active 

domestic sheep and goat allotment, implementation of emergency actions for 

domestic sheep and goat grazing could include: 

Reroute (move) domestic sheep or goats away from the risk.
Inform the appropriate state agency of the bighorn sheep location, domestic strays into 

bighorn habitat, or if a contact potentially occurred. Knowing of potential or known 

contact is essential for monitoring populations, continuing research efforts, and 

understanding possibly changes in population size. 

Elk

WDFW is concerned about the lack of road density limits in the MA-4 category, 

particularly following forest restoration activities that will reduce the cover for elk at large 

scales. High road densities (>2 miles/square mile), will likely redistribute elk to secure 

habitat, if available at the scale necessary for elk. WDFW is particularly concerned about 

the summer and fall time periods when summer nutrition is critical and fall hunting 

pressure will be intense (page 55, Land Management Plan). 

Dry forests that will receive restoration activities (Ponderosa pine habitats) will increase 

the available winter range for elk. Over the snow travel by A TV's and UTV's with tracks 

has been rapidly growing in popularity. While these areas may not have enough snow for

snowmobiles, these new machines will use these areas extensively, causing disturbance to 

wintering elk. WDFW would like to see wintering elk populations protected from this 

growing recreation activity. WDFW recommends that the Final Plan adopt the portion of 

Alternative A that identifies big game winter range as a management area, and this layer is 

updated upon completion of restoration activities in consultation with State Fish and 

Wildlife Agencies. WDFW also recommends the final plan limit motorized recreation 

within big game winter range. 

WLD-HAB-13 G-16: "Motor vehicle use within elk winter range should (Shall) not be 

authorized or allowed between December 1 and April 30" We recommend this Guideline 

be changed to a STANDARD. 

Volume 2, Chapter 3, page 294: The plan states that elk populations are predominantly 

driven by management activities of the state wildlife agencies. While WDFW readily 

acknowledges that Fish and Wildlife Agency management activities influence population 

structure and trend, habitat is still the major contributor to a population's status. The main 

drivers of elk populations are cow survival and calf recruitment, both of which are driven 

by habitat. This is especially true considering that WDFW antlerless elk harvest is 

extremely limited on National Forest lands within Washington. The quality of summer 

habitat (Blue Mountains elk nutrition and habitat models) has been found to be a very 

important requirement for elk population reproductive success. The main two metrics in 

this model are cover and road proximity. The reduction of cover in large portions of the 

Forest will make road density that much more important in helping elk meet their 

nutritional needs. If security cover is reduced below a threshold, elk may move to low 

quality habitat or off the Forest, which would further require us to address depredation 

concerns by reducing the elk population. 

The following are comments provided from the Oregon Department of Fish and Wildlife 

and they are provided verbatim because they so adequately address the issue of ungulate 

security cover.
Security cover for elk or mule deer is not defined under the Proposed Forest Plan and 

there is no established criteria/protocol to measure it across the landscape or on the 

individual project basis. WDFW recommends utilizing the cover standard from the 

1990 Forest Plan, where "At least 30% of your forested areas should be in a cover 

condition at any point in time." "Optimum habitat for deer and elk requires hiding 

cover. Hiding cover is defined as vegetation capable of hiding 90% of a standing adult 

deer or elk from the view of a human at a distance equal to or less than 61 meters (200 

ft.). Since deer are smaller, the height and density of vegetation suitable for cover may 

be less than that required by elk. In fact, hiding cover suitable for elk will probably be 

more than adequate to meet the needs of mule deer in the managed forests" (Wildlife 

Habitats in Managed Forests-the Blue Mountains of Oregon and Washington Page 

109). Cover, whether it is security or hiding cover, needs to be well distributed across 

the landscape and available at the subwatershed and watershed levels. WDFW 

recommends adding the definition of hiding cover as a "Standard" in the revised Forest 

Plan.

To further address the above concern, WDFW recommends that the Forest Plan incorporate 

the Elk Nutrition and Habitat Model into the forest restoration activity planning and that 

the management proposals provide for adequate security and nutritional needs for the 

number of elk identified by Oregon (ODFW) and WDFW in their respective population 

objectives. Adopting appropriate road density standards within MA-4A lands will 

contribute significantly towards accomplishing this goal. This is particularly important 

when evaluating Figure 54 (Volume 2, Chapter 3, Page 303), which shows only 25% of the 

current hiding cover available for elk by Decade 5.

Blue Mountains Elk Initiative:

The Blue Mountains Elk Initiative (BMEI), with help from its numerous cooperators, is the 

longest running elk initiative in the United States. Despite this, it is not mentioned 

anywhere in the Forest Plan Revision. BMEI has been instrumental in protecting, 

enhancing and conserving thousands of acres of wildlife habitat over the last 26 years and 

the quality of work that has been instituted should be acknowledged in the Forest Plan 

Revision. Research, Elk Habitat/Nutrition Modeling, and the application of "Best Available 

Science" in individual project development and implementation, are just a few of the 

important BMEI products that have helped USFS and private land managers design and 

implement wildlife friendly projects. WDFW recommends continued USFS support for 

BMEI. Such partnership and collaborative efforts are essential to moving forward with elk 

and elk habitat management into the future.

Volume 2, Chapter 3, Page 327: Within the first paragraph of this section is a list of 

primary big game species hunted within the planning area. WDFW recommends that 

white-tailed deer be added to this list, as white-tailed deer comprise 42.4% of our general 

season deer harvest within Game Management Units overlapping USFS lands.

Volume 1, page 78: Regarding effects from Alternative E and F on areas suitable for motor 

vehicle route designation; Alternatives E and F allocate less acres to MA 3C wildlife 
corridors compared to Alternative C. WDFW prefers Alternative C. However, if 

Alternative E or F is chosen then we recommend that wildlife corridors be added.

Focal Species/Management Indicator Species:

WDFW appreciates the efforts the USFS has taken to assess the viability of the various 

focal species selected. However, we are concerned that only 7 of 23 focal species on the 

Umatilla National Forest will see a decrease in viability concern. The viability concern for 

most species is predicted to maintain at a static level. In several cases, other management 

activities may offset the increase in source habitats. WDFW believes management 

activities of all sorts must complement the efforts to decrease viability concerns for the 

listed focal species.

WDFW would also like to see a standardization of Management Indicator Species (MIS) 

and analysis methodologies across all alternatives. This would enable the reviewer to more 

accurately compare the impacts to species from the various alternatives.

Throughout the alternatives listed, numerous indicator species have been selected to assess 

the effects that proposed management activities will have on suites of wildlife species. 

According to CFR 219.19(a)(6), "population trends of the management indicator species 

will be monitored and relationships to habitat determined." Within the document, we were 

unable to identify specific monitoring plans for the identified management indicator 

species. The Washington Department of Fish and Wildlife is willing to partner with the 

USFS in developing protocol and in monitoring species when possible and WDFW 

recommends that Standards be developed to direct monitoring of the management indicator 

species.

The Management Indicator Species (MIS) selected for the dry forest type is the white 

headed woodpecker which requires management of more open stands with larger trees and 

sparser understory. However, the USFS states that population trend data is not available for 

this species. If the white headed woodpecker is to be a MIS for the dry forest type we 

recommend that woodpecker population data be collected and used for monitoring instead

of using acres treated to infer progress towards Desired Conditions.

Range/Grazing:

Volume 2, Chapter 3, Page 349, Pollinator Species: The last paragraph on this page 

describes the effect of grazing on bumblebee presence, "Forage utilization rates 

approaching 50 percent showed very little to zero bumblebee abundance" (Kimoto 2010). 

Although the populations of Spalding's catchfly are adequately addressed in this document 

on the Umatilla Forest, it is concerning that grazing utilization rates proposed within the 

plan would likely have such a negative effect on Bombus spp. without further evaluation. 

Pollinator species are critical to the healthy function of ecosystems and should be given 

further review to ensure long-term declines in plant species do not occur as a result of 

planned activities.

Page 71, Land Management Plan: The desired conditions for livestock grazing identify 

"maintaining or achieving ecological desired conditions". And while we believe as a whole 
this standard is acceptable, WDFW would ask that the goal for sensitive areas like springs, 

headwater streams, and "prairie" systems be to improve the ecological condition.

Page 125, LMP, RNG-1, G-43: Change to STANDARD and modify. Grazing after wild 

land fire shall be deferred until vegetation recovers to a condition where grazing will not 

cause the percent composition of native species to be reduced (cause a downward trend in 

key species). This generally will be a minimum of 2 years, but could be longer depending 

on the extent and severity of the fire and other factors.

Page 125, LMP, RNG-3, G-45: WDFW recommends change to STANDARD and modify, 

that water developments "Shall" provide for small mammal and bird escape.

RNG-4, G-46: Change to STANDARD. In areas classified as less than fully capable or 

suitable, only limited grazing shall be authorized or allowed only after the limitations of 

the site are considered in designing the site-specific allotment management plan.

Page 125, LMP, RNG-5: WDFW applauds the USFS for attempting to ensure grazing 

practices improve ecological function (as a desired condition), over time. Utilization 

should be monitored and measured using an accepted science based monitoring protocol 

that compares the utilization to reference vegetation for accurate utilization rates. Ocular 

estimates should not be used in sensitive areas.

Volume 1, page 132: WDFW is concerned that the proposed utilization rates are high and 

could move the condition towards a higher departure from the Historic Range of 

Variability (HRV). For clarity, WDFW recommends that the use of the leader growth from 

that growing season is what is measured.

Volume 2, Suitability: WDFW notes that only 42% of the acreage within active grazing 

allotments are classified as suitable for livestock grazing and RNG-4, G-46 allows that 

some of these areas may experience limited grazing. We recommend that the guideline be 

clarified such that it would only allow grazing in suitable areas.

WDFW supports the use of standards for forage utilization. Currently, only Alternative C 

sets such standards. Therefore, WDFW supports Alternative C, unless these same standards 

were added to the preferred alternative.

Currently, the USFS utilizes end of season utilization surveys for monitoring. However, 

this method does not allow for adaptive management within the grazing season. WDFW 

recommends that utilization be evaluated at sensitive sites at intervals that will allow 

livestock to be moved within the allotment prior to overutilization occurring.

RIPARIAN MANAGEMENT AREA

Page 138, LMP, page 294 Appendix A; MA 4B, RMA-5, S-42: Pumps shall be screened to 

prevent entrainment of fish. We recommend that this standard include wording that the 

screen shall meet state and federal screening criteria.
Pages 141 LMP, 131 DEIS vol. l, 299 Appendix A; MA4B, RMA-RNG-2, G-115: Change 

to STANDARD. Vegetative utilization in riparian areas. The guideline states that 

herbaceous maximum utilization is 25% in bull trout spawning and rearing habitat and 

35% in anadromous species habitat. There is an additional guideline that states that the 

minimum residual stubble height at the green line will be 4 to 6 inches. WDFW 

understands this is for roughness to filter sediment and nutrients, and that the utilization is 

measured by weight. However, grazing to 4 to 6 inches of stubble height could exceed 

utilization standards for some riparian species, and not meet these standards. To address 

this concern we offer the following potential revised standard)

(Herbaceous utilization at the greenline shall be subject to the same standard as the rest of 

the RMA. No vegetative species shall be utilized more than 25% in bull trout spawning 

and rearing habitat, or 35% in anadromous species habitat, maintaining a minimum 

residual stubble height of 6 inches on species where this is compatible with the utilization 

standard.)

Page 141, LMP, MA 4B, RMA RNG-4, G-117: Change to STANDARD. Livestock trailing 

and bedding in RMA. We recommend that loading should not be allowed in an RMA. 

Alternative C, WDFW appreciates that the plan classifies riparian areas and sub watersheds 

with habitat for ESA listed fish species as generally unsuitable for "cattle" grazing, but feel 

this should be changed to "livestock" grazing. 

Volume 1, Table S-1, page iv: Road densities should remain a standard.

FOREST/SILVICULTURE

Volume 1, page viii: WDFW understands that Desired Conditions could guide forest 

management, but would prefer that Old Forest Management Areas be managed with 

specific standards used to achieve Desired Conditions. Alternative C is preferable, but if 

Alternative E is chosen, WDFW would recommend adding the Old Forest Management 

Areas.

ROADS/TRAVEL MANAGEMENT

Under the Preferred, Alternative E, MA4A General Forest Designations would have open 

road densities of 2.4 miles of road per square mile. This is significantly higher than the 

preferred 1 mile of road per square mile that is the threshold above which elk displace to 

avoid disturbance. Therefore, WDFW would prefer Alternative C in this case, or would 

recommend changing the standard in Alternative E to reduce road densities in forage, cover 

areas, and winter range.

Lastly, The Forest Plan does not address a Travel Management Plan. WDFW strongly 

recommends at a minimum, that the plan include standards and guidelines that will be used 

to develop a future Travel Management Plan. A comprehensive Travel Management Plan is 

critical to maintaining ecological integrity on the forest and will be crucial for meeting 

desired future conditions.
We appreciate the opportunity to provide comments on this forest plan revision and more 

importantly the long-standing cooperative relationship between WDFW and the Umatilla 

National Forest which serves to benefit fish and wildlife in Southeast Washington. If you 

have any questions regarding these comments please feel free to contact me.

Sincerely,

Steve Pozzanghera, Regional Director 

WDFW's Eastern Region (Region 1)

cc: Jeff Davis, Washington Department of Fish and Wildlife 

Nate Pamplin, Washington Department of Fish and Wildlife 

Kevin Martin, Supervisor, Umatilla National Forest
Baker County

1

HAND DELIVERED

August 13, 2014 

Forest Plan Revision Team 

Blue Mountains National Forests 

P.O. Box 907 

Baker City, OR 97814 

http://www.fs.usda.gov/goto/BlueMountainForestPlanRevisionComments 

RE: Forest Service Notice of Proposed Rulemaking and Request for Comments 

Concerning Blue Mountains National Forests Proposed Revised Land 

Management Plan and Draft Environmental Impact Statement

Dear Sir/Madam:

The following comments are submitted to the U.S. Forest Service (USFS) on behalf of the Baker 

County Board of Commissioners (“the County”) in response to USFS’ published notice of 

proposed rulemaking and request for comment regarding the Blue Mountains National Forests 

proposed revised Land Management Plan (RLMP) and accompanying draft Environmental Impact 

Statement (DEIS) (collectively, “Plan”). See http://www.fs.usda.gov/detail/wallowawhitman/landmanagement/planning/?cid=stelprd3792957. Of the three affected forests, Baker 

County’s comments focus on proposed changes to the Wallowa-Whitman National Forest (WWNF) 

plan. WWNF comprises 33 percent of the County’s area; thus its management and use is of great 

importance to our citizens. The County appreciates the opportunity to provide comments as a 

government body with special coordination privileges. Below, we have specified areas of the 

RLMP and DEIS that are not consistent with the Baker County Natural Resources Plan. We 

respectfully request a response that, consistent with the statute surrounding government-togovernment coordination, USFS provide us with a response to each of our concerns, including 

proposed reconciliation between discrepancies (USFS regulations8

; NFMA9; NEPA10). 

Given the scope and number of concerns outlined in our submission, the County urges USFS to 

abandon this planning effort and instead revert to amending the existing plan, taking into account 

new science11. The draft RLMP is flawed for two fundamental reasons: 1) USFS failed to consult 

with the County Commission, and its Natural Resources Advisory Committee (NRAC), when 

developing the plan, which would have provided a means for avoiding many potential conflicts; 

and 2) the science purported to support many of the proposed actions does not reflect current 

scholarship. The plan revision effort should involve coordination with affected counties so that the 

civil society and communities associated with the national forests are represented in the plan 

 8 “In the event of conflict with Agency planning objectives, consideration of alternatives for resolution within 

the context of achieving NFS goals or objectives for the unit would be explored.” 36 CFR § 219 National 

Forest System Land Management Planning; Response to Comments; Final Rule and Record of Decision; 77 

Federal Register 68 (April 9, 2012), p. 21197. 9 NFMA: “[T]he Secretary of Agriculture shall develop, maintain, and, as appropriate, revise land and 

resource management plans for units of the National Forest System, coordinated with the land and resource 

management planning processes of State and local governments and other Federal agencies.” 10 NEPA requires that EISs “shall discuss any inconsistency of a proposed action with any approved state or 

local plan and laws (whether or not federally sanctioned). Where an inconsistency exists, the [EIS] should 

describe the extent to which the agency would reconcile its proposed action with the plan or law.” 11 The County notes that there is no scientific basis for retaining the standards found in the “Interim Management 

Direction Establishing Riparian, Ecosystem and Wildlife Standards for Timber Sales” (“Eastside Screens”). Eastside 

Screens should be abandoned in light of more up-to-date science and the fact that their implementation has had 

deleterious effects on our economy and social structure.
2

revision. Planning efforts should also establish a mechanism by which such involvement is ensured 

to continue. The County notes that the public-comment period that preceded development of the 

RLMP (in which “purposes and needs” were established) did not include adequate consideration of 

the local government’s concerns. We would welcome the opportunity for the District Ranger and 

Forest Supervisor to meet with the County Commission and NRAC to lay out a process whereby 

the County may actively contribute to and engage in the revision process. 

The overall planning effort is flawed not only in the range of alternatives, but in the pre-determined 

definitional changes and parameters that the RLMP proposes for every one of the alternatives. 

Although we have provided (in the Standards and Guidelines portion of our comments) 

amendments to “Alternative E,” this does not imply agreement with the planning effort as a whole. 

It is only meant to point out some of the tremendous weaknesses of the proposed standards and 

guidelines. We reiterate that USFS should consult with the County and its NRAC to address the 

numerous and serious flaws we have identified.

Amongst our concerns with the planning effort is the proposal to address three forests with one 

plan. Each of these forests represents vast acreages whose variances will be difficult enough to 

address in individualized plans. The needs of citizens affected by each forest also vary, pointing to 

the necessity of three separate plans. Other problems with the planning effort include (but are not 

limited to) the Plan’s impossibly small acreages determined to be “suitable” for productive and 

recreational uses; its proposed expansions of no-management or limited-management areas; its 

proposal to expand USFS’ authority over water, beyond its legal jurisdiction; and its desired 

conditions and objectives, many of which exceed USFS’ authority and conflict with Baker 

County’s Natural Resources Plan (see Appendix A).

I. Contents:

a. P. 3 – Overarching Concerns

b. P. 16 – Standards and Guidelines Comments

c. P. 45 – Wildlife Concerns

d. P. 50 – Access Concerns

e. P. 59 – Timber Concerns

f. P. 67 – Mining Concerns

g. P. 70 – Grazing Concerns

h. P. 82 – Water/Watershed/Riparian Area Concerns

i. P. 87 – Climate Change Concerns

j. P. 89 – Special Land Designations Concerns

k. P. 91 – Appendix A – Baker County Natural Resource Plan

l. P. 92 - Wallowa County Plan – Grazing Utilization Standards for Late 

Spring/Summer 

II. Introduction 

a. Baker County Board of Commissioners

The Baker County Board of Commissioners (Board) is charged with governing the County 

in the best interest of all citizens, its economic base and the natural environment. The citizens of 

the County rely on both public and private land for natural resources, recreation, and the ability to 

continue our way of life--especially agriculture and livestock grazing, mining, and timber harvest. 

The WWNF comprises approximately 33 percent of the County’s landmass. Therefore, all 

decisions on the WWNF will affect Baker County’s economy, customs, culture, and enjoyment of 

the land. 

The Board recognizes the importance of private property rights, access rights of way, water rights, 

multiple uses for all public lands within Baker County, and the quality of the natural resources, and 
3

that these uses are critical to the economic stability and wellbeing of our citizens. Our Baker 

County Natural Resources Plan commits to the below principles. These principles are consistent 

with federal law and, as such, should be followed by USFS in its development of the WWNF plan 

revision:

1. Revitalization and maintenance of multiple uses on all public lands in Baker County.

2. Multiple use shall be inclusive rather than exclusive, thereby avoiding pitting one use 

against the other. 

3. All plans should mitigate based on multiple use rather than by a resource-by-resource 

issue.

4. Maintain flexibility in all plans to allow for extraction of natural resources from public 

lands and to continue to use existing resources in accordance with all laws.

5. Protect and preserve the following rights of all County’s citizens, including: 

a. Private property interests, such as water rights and access to lands, which have 

ties to public lands,

b. Traditional economic structures in the county that form the base for economic 

stability,

c. Historical custom, culture and values of the local people, and 

d. Enjoyment of the natural resources of the County.

III. Overarching Concerns with the Plan

a. Too closely reflects 2012 planning rule

i. While USFS states the Plan is based on the 1982 planning rule, it reflects 

many attributes of the flawed 2012 planning rule (demonstrated below). 

We do not believe the 2012 rule, which is currently in litigation, should 

serve as the basis of this Plan.

b. The DEIS does not follow USFS’ Multiple Use mandate. The concept of “multiple 

use” management is a mandate imposed on USFS by Congress, codified in agency 

regulations, and affirmed by the courts. USFS must actively promote the 

stewardship role delegated to it by Congress in legislation spanning more than a 

century and consistently upheld by the courts. The Plan fails to adequately do so.

i. Page iii of the RLMP states, “Public concern is heightened because the 

management to approach ecological resilience will determine the 

ecosystem services the Blue Mountains national forests provide.” The 

public in Baker County really is concerned. Mismanagement and no 

management—in violation of USFS’ multiple-use mandate—has left 

hundreds of thousands of acres in poor health and susceptible to insects 

and fire. The “management to approach ecological resilience” we see in 

the Blue Mountain Revision is in fact a blueprint for a future Forest with 

less access, more wilderness, more wildlife corridors and non-motorized 

areas, wider “riparian” buffers on ephemeral streams, and less timber 

management. Like the 2012 planning rule, the Plan places priority on 

things such as climate change, forest restoration and conservation, wildlife 

conservation, watershed protection, and other uses that ignore the needs of 

citizens of Baker County and the American people.

ii. This is in violation of the multiple-use statutes: National Forest 

Management Act (“NFMA”), the Multiple Use Sustained Yield Act 

(“MUSYA”), the National Environmental Protection Act (“NEPA”) and 

the Forest and Rangeland Renewable Resources Planning Act of 1974. 

1. The Plan must meet requirements under NFMA, 16 U.S.C. §§ 

1600-1614, as well as allow the agency to meet its obligations 

under the MUSYA, 16 U.S.C. §§ 528-531. NFMA provides that 
4

“[i]n developing, maintaining, and revising plans for units of the 

National Forest System . . . the Secretary shall assure that such 

plans—(1) provide for multiple use and sustained yield of the 

products and services obtained therefrom in accordance with the 

[MUSYA], and, in particular, include coordination of outdoor 

recreation, range, timber, watershed, wildlife and fish and 

wilderness. . . .” 16 U.S.C. § 1604(e). The MUSYA provides that 

“[i]t is the policy of the Congress that the national forests are 

established and shall be administered for outdoor recreation, 

range, timber, watershed, and wildlife and fish purposes.” Id. § 

528. MUSYA, in defining “Multiple use,” states that “the various 

renewable surface resources of the national forests” are to be 

“utilized in the combination that will best meet the needs of the 

American people.” NEPA, as recognized in the DEIS, is “An act 

to declare a national policy which will encourage productive and 

enjoyable harmony between humankind and the environment” and 

to “stimulate the health and welfare of humanity...”

iii. The Forest Service has failed to meet the goals set out in the Use Book of 

1905, which states, “The timber, water, pasture, mineral, and other 

resources of the forest reserves are for the use of the people; Forest 

reserves are for the purpose of preserving a perpetual supply of timber for 

home industries, preventing destruction of forest cover which regulates the 

flow of streams, and protecting local residents from unfair competition in 

the use of forest and range. They are patrolled and protected, at 

Government expense, for the benefit of the community and the home 

builder. We know that the welfare of every community is dependent upon a 

cheap and plentiful supply of timber; that a forest cover is the most 

efficient means of maintaining a regular stream flow for irrigation and 

other useful purposes; and that the permanence of the livestock industry 

depends upon conservative use of the range. The injury to all persons and 

industries which results from the destruction of forests by fire and careless 

use is a matter of history in older countries, and has long been the cause of 

anxiety and loss in the United States. The protection of forest resources 

still existing is a matter of urgent local and national importance.” This 

was true in 1905 and is still true today.

iv. Furthermore, as appropriately concluded by the U.S. Court of Appeals for 

the Seventh Circuit, USFS does not have the discretion to ignore the 

multiple-use mandate and focus solely on environmental or recreational 

resources. The court specifically held that “the national forests, unlike 

national parks, are not wholly dedicated to recreational and environmental 

values.” Cronin v. United States Department of Agriculture, 919 F.2d 439, 

444 (7th Cir. 1990). 

v. The County REQUESTS that, in order to show a balance of multiple uses 

and truly recognize the “interdependency of social and economic 

components with national forest management,” the “purpose and needs” 

on p. I of Vol. I include: “Protect the industries that depend on natural 

resources on the Forests;” and “Protect local communities, watersheds and 

multiple users from catastrophic wildfire.” 

vi. We do not believe that Alternative C should have been included, as it does 

not represent a multiple-use alternative. Its “protections” (severely 

reducing access, logging and grazing) are, in actuality, threats to the 
5

ecosystem. Paradoxically, the DEIS heralds this alternative at the same 

time that it recognizes the threat it poses:

1. Vol. 2 p. 36 states, “Based on relative differences between 

protection scores among alternatives, alternative C provides the 

greatest degree of protection, lowest risk of management effects to 

species viability from roads, grazing and timber production, and 

likely provides the most opportunity for natural processes to 

restore riparian and aquatic habitats throughout the range of each 

species. This alternative also poses the greatest risk of impacts 

from wildfire by allowing unnatural fuel conditions to continue to 

build in dry forest landscapes, relative to other alternatives” 

(emphasis added). 

c. Lack of Diversity in Alternatives May Violate NEPA 

i. As illustrated in our review of alternatives, below, the degree of diversity 

in the alternatives does not appear to meet NEPA’s requirement for a 

diverse range of alternatives. This is exemplified in the following ways:

1. The fact that a new, expansive definition of “riparian areas” is 

applied consistently to every alternative. 

2. The fact that “desired conditions” are consistent for every 

alternative.

3. The fact that, in every alternative, timber management levels fail 

to bring forests to “desired conditions” within 50 years.

d. USFS should complete forest-specific plans. 

i. In our experience, agreement on land management is best obtained at the 

local level, which allows for variation in ecology, community perspective, 

and desired outcomes. While the Blue Mountains have much in common, 

there are many important differences. For example, we have found that 

moist mixed conifer restoration is likely to look very different on the 

Malheur National Forest than it is on the Wallowa-Whitman National 

Forest: the moisture gradients, harvest history, vegetation compositions, 

and collaborative engagement are dissimilar between the two forests, even 

though they are both part of the Blue Mountains ecosystem. Given these 

and other differences, attempting to craft three land management plans out 

of a single environmental impact statement is fraught with peril, and 

threatens to stall forest restoration across the entire region. 

ii. We strongly encourage USFS to reconsider revising all three forest plans 

at the same time with the same process. Instead, we ask USFS to consider 

a forest-by-forest approach that would allow each associated community to 

work directly with their local USFS personnel to develop a plan that best 

meets the needs of those communities. 

e. DEIS socio-economic evaluations and expectations are downplayed.

i. USFS’ expectations for social and economic contributions of the WWNF 

are too low.

1. USFS has standards and guidelines with specific measures for 

ecological aspects. There are no equivalent standards or guidelines 

to measure socio-economic vitality. WWNF only “contributes to” 

economic well-being but is not required to meet any standards.

2. In the “Proposed Monitoring Question” table (p. 310 Vol 3), there 

are 36 questions dedicated to ecological status and only one 

dedicated to economics.
6

3. Under the “Vision” section with regard to “Social and Economic 

Expectations,” p. 15 RLMP, USFS states: “Public land 

management inevitably involves conflicting public desires, values, 

and preferences. The public expects a diversity of uses from 

National Forest System lands. People frequently disagree about 

how the national forests should be managed. Interests and opinions 

are often held strongly, which can lead to a decision-making 

process characterized by conflict and controversy. This increases 

the complexity of national forest management.” This is 

unacceptable for the “vision” of the social and economic 

expectations. The County asserts that language should be added 

that reestablishes that the laws governing the WWNF require that 

the forest be used for production to the benefit of the people.

4. In Volume 1 Introduction (p. 2), the document begins by stating 

the intent is to “provide” biodiversity, clean and cold water, and 

vegetation for habitat, and to “sustain” ecological processes. 

However, instead of “providing for” or “sustaining” the social and 

economic wellbeing of the local communities (via access and 

productive uses such as mining, grazing and logging), the 

document states the Plan will merely “contribute to” the 

aforementioned. 

5. RLMP p. 70-73. All productive uses (Forest Products, Grazing, 

Special Uses, Mineral and Geological Resources, Water Use) have 

stipulations in their economic “Desired Conditions” that 

ecological “desired conditions” also be met. However, in the 

“Promote Ecological Integrity” section, none of the “desired 

conditions” for wetland function, special habitats, etc. contain 

language stating that socio-economic wellbeing of the dependent 

communities must also be met. Such language should be included 

in all desired conditions.

ii. USFS underestimates its ability to contribute to socio-economic health and 

instead focuses on ecology only.

1. The Vision portion of the RLMP (p. 66) also states “Many of the 

factors that contribute to community resiliency are beyond the 

control of...the Forest Service. This limits the ability to improve 

community resiliency through the management of the national 

forests.” USFS denies it has the ability and responsibility to 

provide for socio-economic viability in our communities.

2. Even in the “Promote Social Well-Being” portion of the Vision 

(Part I), the document focuses on scenery, wildlife, “restoration 

efforts,” old forests, avoiding sedimentation, and minimizing 

roads. It does not recognize that our logging, mining and ranching 

families are the fiber of the society USFS refers to in the term 

“social well-being.” Our economic viability and customs (also not 

mentioned in the “Cultural Resources” section, p. 59) are 

inseparable from “social well-being.”

3. The RLMP section titled “Promote Economic Well-Being” (p. 66) 

leads with “Facilities and Infrastructure,” then “Land Ownership” 

(acquisition of land by USFS). The administrative facilities of 

USFS should not lead the “Economic Well-Being” section. Land 

acquisition by USFS is an inappropriate second category in a 
7

section that should be focusing on the true economic drivers on the 

WWNF: logging, mining, grazing, and access.

iii. Underestimates socio-economic impacts of proposed new regulations on 

access, timber, mining, grazing (see more in comments on individual 

resource areas.)

1. Vol I Page 126 states “There would be no adverse effects to 

human health and no alternative has been determined to 

disproportionately affect minority or low income populations”. We 

disagree. Our rural citizens are largely low income (18 percent 

being below the poverty line, per Vol 1 p. 111), and it is largely a 

result of inability to access WWNF resources. For example, Baker 

County’s economy has been devastated by lack of timber harvest. 

Most of our sawmills are gone. Forest Service actions have 

definitely adversely affected our county. The RLMP proposes to 

worsen these effects. 

f. “Unconstrained budget” alternative should have been considered. 

i. USFS should have included as an alternative the Unconstrained Budget 

Alternative (Alt. K). A full analysis of Alternative K would be beneficial 

because it would provide a baseline from which to evaluate all other 

alternatives. Fully developing Alternative K would provide the most 

accurate information concerning the costs of undertaking a particular 

action versus the benefits received from the action. 

ii. USFS has constrained its alternatives based on potential budgets, but this 

is not required under the 1982 rule. Currently, USFS is in litigation 

concerning this issue. USFS should not include budget constraints in its 

alternative analyses.

iii. The DEIS states “It is not realistic or reasonable to ignore expected 

funding levels... The forest plan does not influence or control the budgets 

for the national forests...” (Vol I p. 15). The latter part is true--and budgets 

may increase. Also, while USFS may not have influence over 

congressionally appropriated budgets, it does have influence over activities 

such as logging on the WWNF, which could easily provide the funding 

needed for road maintenance, etc. while achieving healthy forest 

conditions.

g. The Plan should not require use of “best available scientific information.”

i. Neither NFMA nor NEPA require use of the “best available science.” The 

Ninth Circuit Court of Appeals (Lands Council v. McNair) affirmed that 

these statutes do not require it. Additionally, case law has established that 

the agency can make natural resource management decisions based on its 

discretion in weighing various multiple use objectives. See Seattle 

Audubon Society v. Moseley, 830 F.3d 1401, 1404 (9th Cir. 1996).

ii. Although the agency acknowledges (p. 4, RLMP) that “What constitutes 

best available science might vary over time and across scientific 

disciplines,” the term “best available science” opens the agency up to 

endless litigation. 

iii. The RLMP says “the NEPA document should identify methods used, 

reference scientific sources relied on, discuss responsible opposing views, 

and disclose incomplete or unavailable information, scientific uncertainty, 

and risk...” There will be no way for the agency to defend itself when a

special interest group claims that USFS did not “discuss responsible 

opposing views.” What qualifies as a “responsible opposing view”? That 
8

will undoubtedly be a point for legal challenge. Also, “unavailable 

information” may well be “available” according to these groups, and they 

can sue accordingly.

iv. Finally, sound national forest planning and management that complies 

with NFMA, the MUSYA, and other applicable laws must 

reflect more than “western” or European culture academic science and 

scientist opinion. Native American and other traditional local knowledge, 

along with other practical expertise, coordination, collaborative consensus 

reached through the planning process regarding application of science, and 

other considerations are critical to environmentally, economically, and 

socially sound forest planning and plan implementation.

h. Document lacks Science-backed Data

i. The preferred alternative proposes stricter regulations on timber, grazing, 

mining, and access with no sound scientific basis. In many cases, the 

restrictions will in fact have a negative effect—not only on the County’s 

economy, customs and culture, but on the environment. The studies cited 

are biased against human uses of the resources.

ii. Council on Environmental Quality (CEQ) regulations require that, when 

preparing an EIS, the agency shall “identify any methodologies used and 

shall make explicit reference by footnote to the scientific and other sources 

relied upon for conclusions in the statement.” 40 C.F.R. § 1502.24. Many 

of the guidelines detailed in the DEIS lack this required scientific 

justification. Therefore, the DEIS does not satisfy the requirements of 

NEPA.

1. For example, guideline G-115, which establishes maximum 

utilization standards for livestock grazing within riparian 

management areas, contains no reference to scientific literature or 

other sources of authority that might explain how the USFS 

established the utilization percentages provided in Table A-55. 

DEIS Vol. 3 at 299. Indeed, the USFS acknowledges that all 

utilization standards established in the Proposed Plan and DEIS 

are based on an assumption that 40 percent utilization is necessary 

to achieve the desired conditions for the plan’s ecological goals. 

DEIS Vol. 1 at 129.

iii. Much of the “science” used to justify current and desired conditions is 

based on the Interior Columbia Basin Ecosystem Management Project 

(ICBEMP), which does not represent the most current or relevant 

information about the condition of the Blue Mountains forests; violates the 

multiple-use mandate of USFS; and has been improperly implemented 

without due process under NEPA. 

1. The body of science used for ICBEMP was published in 1996 and 

in many cases was based on research that is significantly older. 

While some of these conclusions may still be valid, there is little 

discussion or application of more contemporary research that has 

taken place in our ecosystem since 1996, and little explanation 

why ICBEMP does or does not still represent the forefront of 

knowledge about the Blue Mountains. Since 1996, many 

researchers have begun to work extensively across the Blue 

Mountains, gathering and publishing information about old growth 

forests, wildlife needs, aquatic systems, landscape process, and the 

socioeconomic dynamic. We encourage you to work with Baker 
9

County and other local governments to obtain this science and 

implement it in the plan revision.

2. In a U.S. congressional hearing held on March 10, 1998, 

representatives stated that ICBEMP was not authorized by 

Congress. That year, a federal appropriations bill required that any 

further implementation of ICBEMP be preceded by in-depth 

reporting to Congress of the expected cost and effects of its 

implementation, with targeted focus on local socio-economic 

effects. Ultimately, a final record of decision was never issued on 

the ICBEMP. Its implementation, or use of its contents, remains 

premature and inappropriate.

iv. The majority of forest management studies are decades old and have 

newer, more relevant alternatives. See “Science is Outdated” Section of 

Timber Concerns.

v. The science used in the range portion is unbalanced. 

1. Decisions surrounding bighorn and domestic sheep are being made 

on the basis of inadequate science, as stated by both Congress and 

a federal judge. 

2. The science surrounding effects of livestock grazing, generally, is 

one-sided.

vi. USFS should not base decisions on climate change. This area of science is 

far too uncertain to be making damaging decisions such as: Management 

strategies including “reducing potential increases in stream temperatures 

through riparian buffers. Reducing the risk of water quality degradation by 

(1) Decreasing road density (2) closing, realigning or obliterating roads. ... 

“reducing barriers to species movement (close roads, destroy fences)...” 

These proposed actions have the potential to devastate our communities, 

while the matter of “climate change” is uncertain and completely out of 

USFS’ hands.

i. USFS did not adequately consider County’s input.

i. Baker County appreciates the importance of coordinated management of 

National Forests across the Blue Mountains but notes that the social and 

ecological conditions under which management will be addressed are not 

homogeneous. As management will take place at a much finer scale, (e.g., 

a watershed or a cluster of adjacent watersheds), Baker County notes that 

it is imperative that the plan provide sufficient flexibility that local social 

and ecological conditions will be considered in laying out alternative 

approaches. Coordination with the County is crucial to this effort.

ii. Public lands dominate the landscape in Baker County, with approximately 

52% of the land in the County managed by a public agency. Therefore, 

decisions made by the agencies managing our public lands directly affect 

Baker County’s residents, custom and culture, economy, and valued way 

of life. Baker County citizens and elected officials have an in-depth 

knowledge and vested interest in the land, the economy, and the customs 

and culture of the County. In recognition of this, many federal and state 

acts or mandates require agencies to coordinate their proposals to be 

consistent with local plans, including our Natural Resource Plan, and 

policies. 

iii. Baker County opposes any USFS action without the County having 

waived the opportunity to coordinate.
10

iv. Vol 3 Page 13 describes county commissioners as “Co-conveners” who 

helped develop this plan. However, the preferred alternative does not 

reflect the County’s input.

v. P. 2 of the RLMP should include local governments as well as tribes in the 

following: “The revised forest plans will continue to honor American 

Indian reserved rights through consultation and coordination, and will 

maintain a government-to-government relationship with federal recognized 

tribal governments.”

j. “Alternative A- No Action” is not well defined.

i. This basic flaw in the planning document is demonstrated in the Standards 

and Guidelines portion (Vol 3 p. 256). The S&G designators in the lefthand column (example: WLD-HAB-1 G-1) imply that there is a 

corresponding standard or guideline that exists in the current plan, unless a 

proposed Standard/Guide is labeled “New.” However, there are no such 

corresponding standards or guides that currently exist. The County has 

been informed by USFS that these designators simply refer to USFS’ 

interpretation of a conglomeration of existing standards/guides found in 

the 1990 plan, amendments, and PACFISH/INFISH. Thus, if a commentor 

were to request “Alternative A – no action” as his preferred alternative, it 

is essentially left to USFS to define what the commentor meant (unless the 

commentor specified an existing S/G in the current plan, 

PACFISH/INFISH or an amendment). This fact was not explained in the 

document, and will obfuscate the comment process. Such leeway given to 

the USFS in interpreting comments is unacceptable.

k. Some of the “Desired conditions” are not consistent with the County plan

i. For any of the “desired conditions,” we are concerned that USFS may 

attempt to achieve them in a manner inconsistent with our plan. To resolve 

this, each of the desired conditions should include a requirement for 

coordination with the County. Page 5 of the RLMP states, “Desired 

conditions ...attempt to paint a picture of what we (the public and Forest 

Service) desire the forests to look like and/or the goods and services we 

desire them to provide.” The affected counties should have elevated status 

above the “public” when determining desired conditions. 

1. REQUEST that each of the desired conditions state “Coordination 

with the affected county or counties will be done to ensure 

progress is made toward desired conditions in a fashion that is 

consistent with county land use plans.” 

ii. We do agree, as stated on p. viii of RLMP (“Comparing Alternatives”) that 

the “Desired conditions are broad and may only be achievable over long 

periods of time.”

l. Maps provided in the DEIS are inadequate in size/detail. 

i. The maps provided were so small in scale that there was no way to use 

them, even in areas where residents know the ground. This makes 

substantive public and county input difficult. We believe this is done 

intentionally, since we have made this very complaint with many USFS 

documents in the past. 

ii. The “new and improved” interactive maps would not load on many 

computers. Where they would load, the layers took up to 15 minutes. 

iii. No consideration was given to citizens who do not have computers. 
11

iv. Good quality maps, showing topographical lines, township range and 

section, and drainages would have solved the map problem. Forest maps 

should have been considered.

m. Wilderness and Other Special Designation Concerns:

i. New special designations are not appropriate within Baker County. They 

lead to concerns with public safety, economic productivity, and 

recreational enjoyment.

n. Many proposed “Guidelines” more closely resemble “standards.” 

i. Many guidelines in Alternative E were so prescriptive that they no 

deviation from those “guidelines” could be done without violating the 

spirit of the guideline. Such “guidelines” are better labeled “standard.”

ii. USFS seems to differentiate between the words “should” and “shall.” 

Many of Alt C’s “shall” provisions are simply converted to “should” and 

listed as a “guideline.” We question whether these two words would be 

treated differently in court. 

o. Wildfire not adequately addressed:

i. The socio-economic impacts of wildfire that will result from any of the

alternatives are underestimated/not fully explored in the DEIS. None of the 

alternatives would bring substantive relief to the catastrophic wildfires 

Baker County is experiencing.

ii. Proposed reductions in fuel-reducing activities such as logging and grazing

will worsen catastrophic fire threat.

iii. USFS demonstrates its lack of appropriate emphasis on wildfire in Volume 

1 “Introduction,” which begins by stating USFS’ intent is to “(1) protect

plants and animals (2) address management of fire (3) protect watersheds 

(4) address climate change and (5) recognize the interdependency of social 

and economic components.” While plants, animals and watersheds will be 

“protected,” USFS states fire management, a huge problem on the WWNF, 

will only be “addressed”. This places it on the same level as discussions on 

climate change, which will also be “addressed”--even though climate 

change is beyond the control of USFS. Reducing the threat of wildfire, on 

the other hand, is very much within the agency’s capability--and 

responsibility.

iv. The “Minimum Impact Suppression Tactics” (MIST) approach is overly 

restrictive and does not allow all available tools to be used to stop 

devastating wildfires. We believe that, by proposing to implement MIST in 

special designation areas as well as riparian areas, USFS puts at risk Baker 

County citizens’ health, safety and wellbeing.

p. Wildlife populations should not be a focus. 

i. USFS exceeds its authority and violates Multiple Use statutes by focusing 

on wildlife populations (see “Wildlife” section for more details). USFS 

defines “species of concern” too broadly. 

ii. In addition, USFS attempts to give itself authority to curtail all other uses 

when “species of concern” are present. This is exemplified by the 

proposed creation of “wildlife corridors,” which we oppose. Even if we 

were to accept the premise that species protection takes priority over all 

other multiple uses, USFS’ “hands-off” approach will be ineffective in 

“protecting” species. It will, in fact, have results such as catastrophic 

wildfire, vegetation overgrowth, and loss of private ranchlands important 

to wildlife.
12

q. USFS attempts to exceed its authority and violate Multiple Use statutes in its 

proposals to regulate water and water uses within the planning area. 

i. USFS exceeds its authority:

1. The State of Oregon is responsible for regulating and allocating 

water use. USFS’ calling for “Connectivity” between watersheds, 

for example, is outside the agency’s authority. So is USFS’ focus 

(p. 24 of RLMP) on “Instream flows, including water yield, 

timing, frequency, magnitude, and duration of runoff...” 

2. P. 73 of RLMP states: “Desired condition: Water is available in 

sufficient quantity downstream to meet human needs as well as the 

needs of aquatic species considering the range of possible climate 

change scenarios.” This should include “recognizing the State’s 

primacy over the regulation of these waters, as well as existing 

water rights.”

ii. In addition, USFS proposes to take water use away from human use for the 

“benefit” of wildlife’s only. This is not only a false choice (precluding 

human use of water does not protect wildlife), but is also in violation of 

USFS’ Multiple Use mandate.

1. Example: “Key watersheds” cover large area and focus only on 

wildlife use. Natural ecosystems, including “key watersheds,” 

must also provide benefits to humans.

2. Removing “human intervention” should not be a goal, as stated in 

“All Watersheds - Desired Condition” (p. 23 of RLMP): “The 

watershed-scale processes that control the routing of water, 

sediment, wood, and organic material operate at levels that result 

in self-sustaining riparian and aquatic ecosystems that do not 

require human intervention or restoration.” Increasing productive 

uses (timber harvesting, mining, grazing), should be included as 

part of the desired condition.

r. USFS “Ecological Integrity” Goal Is Not in Keeping with Baker County Plan 

i. USFS’ first goal in the plan (see p. ix, Vol 1) – “to promote ecological 

integrity” – may not be consistent with the County’s goals. From a lay 

perspective, the goal as presented is a series of disconnected sentences that 

use terms and jargon that are nonsensical while at the same time having an 

authoritative tone. For example, the goal states: “Ecological integrity is a 

condition that sustains the wholeness or completeness of ecosystem 

structure, composition, and function.” And, the definition provided in the 

Glossary (Volume 3, page 17) states: “In general, ecological integrity 

refers to the degree to which all ecological components and their 

interactions are represented and functioning; the quality of being 

complete; a sense of wholeness.” Such language opens the door for legal 

challenges by “environmental” groups.

ii. A quick search of definitions of “ecological integrity” provided several 

that would be more appropriate:

1. For example, the Washington State Department of Natural 

Resources defines ecological integrity as: “The structure, 

composition, and function of an ecosystem operating within the 

bounds of natural or historic range of variation.” 

2. Parks Canada, on their website, defines ecological integrity as: 

“...a condition that is determined to be characteristic of its natural 

region and likely to persist, including abiotic components and the 
13

composition and abundance of native species and biological 

communities, rates of change and supporting processes.” 

3. And finally, from the Simon Fraser University website (probably 

the most appropriate given the interest in achieving a resilient 

forest): “... the abundance and diversity of organisms at all levels, 

and the ecological patterns, processes, and structural attributes 

responsible for that biological diversity and for ecosystem 

resilience.” (Coast Information Team, 2004).

iii. Other terms used in the same paragraph - ecological function, ecological 

structure – are just as ambiguous. The definition of “ecological function” 

in the glossary refers you to “Ecological Processes”, which is defined as: 

“The flow and cycling of energy, materials, and organisms in an 

ecosystem.” How does “watershed function, species diversity, productive 

capacity, disturbance processes, and invasive species”, which are cited as 

descriptors of the National Forests’ contribution to ecological function, 

relate to the ecological processes as defined in the glossary? “Ecological 

structure” is not defined in the glossary. 

s. Indicators of Sustainability Are Misidentified

i. In the explanation following Goal 1, it is stated: “Landscape patterns, 

special habitats, and snags and down wood are also indicators of 

sustainability in the Blue Mountains”. These may be valid descriptors of 

different elements of ecosystems, but they would never qualify as 

“indicators of sustainability”. Further, the definition of “sustainability” 

provided in the Glossary does not relate at all to these metrics. 

t. USFS Goals Are Inconsistent

i. The Goals that are listed in the Summary are not repeated in the body of 

the Plan. However, in the “Purpose and Need” section, different goals are 

cited, which are stipulated in legislation. These two statements of goals 

should be reconciled or the plan should limit its focus to one set of goals.

u. “Ecosystem Services” Portion Could Be Improved

i. Another term used in the proposed Revision to the Forest Plan is 

“ecosystem services.” It is defined in the Glossary (Volume 3, page 18) as 

“The combined resources and processes of natural ecosystems that provide 

benefit to humans, including, but not limited to, the production of food and 

water, the control of climate and disease, cycling of nutrients and crop 

pollination, spiritual and recreational benefits, and the preservation or 

maintenance of biodiversity.”

ii. A better, more comprehensive list of the services provided by ecosystems 

is provided in the Millennium Ecosystem Assessment (2005 and 2012). 

This could be included in a table in the proposed Revisions to the Plan to 

convey the diversity of these services and clearly link them to the various 

benefits local residents realize from the Forests.
14

Baker County Suggestions on Standards and Guidelines

(Vol 3 p. 256)

Note: As stated on p. 1 of these comments, Baker County requests that USFS abandon this 

planning effort and instead revert to amending the existing plan, taking into account new science. 

In light of our opposition to the current planning effort, we have provided below our comments on 

the proposed (Alt E) standards and guidelines. We have offered modifications to Alt E to 

demonstrate some of the changes we would require in this section. We reiterate, however, that even 

if our suggested standards and guidelines were adopted we would not support this flawed planning 

effort. 

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 257

WLD-HAB6

Standard Activities that have 

potential to cause 

abandonment or destruction of 

known denning, nesting, or 

roosting sites of threatened, 

endangered, or sensitive 

species shall not be authorized 

or allowed within 1,200 feet of 

those sites.

No corresponding 

alternative

There is no scientific basis for this 

standard. USFS proposes to deviate from 

its multiple use mandate by banning any 

activity with “potential” to cause nest 

abandonment or destruction for 

threatened, endangered, or even 

“sensitive” species. “Sensitive species” 

are identified at the discretion of the 

regional forester with a very low bar for 

qualification, including “predicted” 

downward trends in population or habitat 

capability (see more detailed comments 

on “Sensitive species” in the Wildlife 

Concerns section of our comments). 

p. 259

WLD-HAB12 

S-7

Standard Where mechanical 

treatment activities occur 

within dry or cool moist forest 

habitat, all snags 21 inches 

d.b.h. and greater and 50 

percent of the snags from 12 

to 21 inches d.b.h. shall be 

retained, except for the 

removal of danger/hazard 

trees. Snags shall be retained 

in patches.

Alt E modified: convert 

to Guideline

Setting these conditions as a 

“STANDARD” is too prescriptive. Does 

not allow latitude to consider alternative 

management options that may be more 

appropriate in certain conditions. 

REQUEST the conditions cited in 

Alternative B be framed as 

GUIDELINES.

p. 294 

MA 4B 

RMA-4

G-103

Guideline Water drafting sites 

should be located and 

managed to minimize adverse 

effects on stream channel 

stability, sedimentation, and 

in-stream flows needed to 

maintain riparian resources, 

channel conditions, and fish 

habitat.

Alt E modified: 

Guideline “Water 

drafting sites should be 

located and managed to 

minimize adverse 

effects on stream 

channel stability, 

sedimentation, and instream flows needed to 

maintain riparian 

resources, channel 

conditions, and fish 

habitat, so long as such 

management does not 

interfere with existing 

water rights.

USFS must bear in mind that it does not 

hold federally reserved rights of water 

use for purposes of maintaining riparian 

resources, channel conditions, or fish 

habitat. These are secondary purposes of 

the agency for which it must apply for 

water rights. (USFS does hold federally 

reserved rights to carry out two primary 

functions: to furnish a continuous supply 

of timber for the people, and to conserve 

water flows.)
15

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 294 

MA 4B 

RMA-FIRE1

G-104

Guideline Disturbed areas, 

such as firelines, drop-points, 

camps, roads, and trials, 

should be restored by actions 

such as scattering slash piles, 

replacing logs and boulders, 

scarifying soils, recontouring 

terrain, and reseeding with 

native species.

Alt E modified:

Guideline Disturbed 

areas, such as firelines, 

drop-points, and camps 

established for 

firefighting purposes

should be restored by 

actions such as 

scattering slash piles, 

replacing logs and 

boulders, scarifying 

soils, recontouring 

terrain, and reseeding 

with native or desired 

non-native species.

Camps, roads and trails should not 

necessarily be “restored” (destroyed), 

especially if they preexisted firefighting 

efforts. Roads and trails

Desired non-native species may at times 

be the best choice for reseeding in order 

to stabilize the area and prevent noxious 

weed/annual grass invasion. 

p. 259 

WLD-HAB13

G-16

Guideline Motor vehicle use 

within elk winter range should 

not be authorized or allowed 

between December 1 and 

April 30

No corresponding 

guideline

How is “elk winter range” defined? Elk 

wander into high-use areas, and this 

could affect roads in the Valley. Elk are 

approaching twice their management 

objectives in several units within the 

planning area and should not be 

considered a focus species. Additionally, 

the new research report “Habitatnutrition Relations of Elk During Spring 

through Autumn in the Blue Mountains 

of Eastern Oregon” by Rachel C. Cook,

John G. Cook, Robert Riggs, Larry L. 

Irwin (2014) identifies summer nutrition 

as the most critical habitat need, not road 

issues. 
16

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 260

WLD-HAB14

New

Guideline In greater sagegrouse habitat, developing 

new roads, motor vehicle 

trails, and artificial water 

impoundments should be 

avoided. During the breeding 

season, seasonal closure of 

open motor vehicle routes 

within 2 miles of known leks 

(protected activity centers) 

should be considered.

Alt E modified: 

Guideline In greater 

sage-grouse habitat, 

developing new roads, 

motor vehicle trails, 

and artificial water 

impoundments should 

be avoided, unless

necessary to utilize 

existing rights. During 

the breeding season, 

seasonal closure of 

open motor vehicle 

routes within 2 miles of 

known leks (protected 

activity centers) should 

be considered, except 

for permitted grazing 

and mining purposes or 

fuel-reduction 

activities. Road 

closures will require 

approval of affected 

counties.

The guidelines for WLD-HAB-14-17 

cite different distances (2 miles and 3 

miles) from leks that different activities 

can be undertaken. Appears arbitrary 

without an authority cited. In the absence 

of credible science Baker County 

proposes either abandoning these 4 

conditions, or adopting Alt E modified.

WLD-HAB-15-17 should clarify that 

these limitations have no bearing on 

lands adjacent private or state lands.

p. 260

WLD-HAB15

New

Guideline Surface occupancy 

for mineral or fossil fuel 

exploration or extraction 

should not be authorized or 

allowed within 3 miles of 

occupied greater sage-grouse 

leks (protected activity 

centers).

Alt E modified:

Guideline Surface 

occupancy for mineral 

or fossil fuel 

exploration or 

extraction should be 

authorized in 

coordination with 

affected counties with a 

goal of avoiding greater 

sage-grouse leks 

(protected activity 

centers) where 

possible.

p. 260

WLD-HAB16

New

Guideline Power lines, 

communication towers, 

meteorological towers, and 

other tall structures should not 

be constructed within 2 miles 

of greater sage-grouse leks 

(protected activity centers).

Alt E modified:

Guideline Power lines, 

communication towers, 

meteorological towers, 

and other tall structures 

should be constructed, 

after coordinating with 

affected counties, with 

a goal of avoiding

greater sage-grouse 

leks (protected activity 

centers) where 

possible.
17

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 260

WLD-HAB17

New

Guideline Construction of 

wind turbines should not be 

authorized or allowed within 2 

miles of greater sage-grouse 

leks (protected activity 

centers).

Alt E modified:

Guideline Wind 

turbines should be 

authorized, after 

coordinating with 

affected counties, with 

a goal of avoiding 

greater sage-grouse 

leks (protected activity 

centers) where 

possible.

p. 260

WLD-HAB18

G-7

Guideline Bat maternity and 

roost sites should not be 

disturbed.

Alt E modified: Bat 

maternity and roost 

sites should not be 

disturbed when 

practical.

p. 261

WLD-HAB19

G-4

Guideline Greater than 50 

percent of post-fire source 

habitat should be retained and 

should not be salvage logged, 

except in the wildland urban 

interface.

Alt E modified: 

Guideline 

Coordination with 

affected counties shall 

determine where 

salvage logging occurs.

What is the scientific basis for this 

guideline? There is need to assess 

ecological benefits against the lost 

income from salvage logging. Reduction 

in the percentage of post-fire areas being 

retained to 25% to 30% would not make 

an appreciable difference.

p. 261

WLD-HAB20

G-4

Standard Salvage logging 

shall not occur within burned 

source habitat areas less than 

100 acres, except for the 

removal of danger/hazard 

trees.

Alt E modified: 

Guideline Site-specific 

information and 

coordination with 

affected counties shall 

determine where 

salvage logging occurs.

The STANDARD is too restrictive. 

There is no legitimate rationale for 

imposing this restriction at the scale of 

100 acres. Salvage logging could be an 

ecological and economic benefit if 

managed carefully.

p. 261 

WLD-HAB21

G-6

Guideline Where salvage 

logging occurs, all snags 21 

inches d.b.h. and greater and 

50 percent of the snags from 

12 to 21 inches d.b.h. should 

be retained except for the 

removal of danger/hazard 

trees. Snags should be retained 

in patches.

Alt E modified: 

Guideline 

Coordination with 

affected counties shall 

determine where 

salvage logging occurs 

and to what degree 

snags are retained.

Setting arbitrary (from an ecological 

perspective) size limits to salvage 

logging constrains management options 

that could have positive benefits 

ecologically as well as economically. To 

avoid major insect build-up on fire 

stressed trees and the resulting increase 

in mortality in green timber stands, 

aggressive salvage is needed. Modify 

WLD-HAB 19-21 guidelines to allow 

100% salvage logging after all fires.
18

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 261 

WLD-HAB22

New

Guideline Following wildfires 

greater than 10 acres in greater 

sage-grouse habitat at high 

risk of annual grass invasions, 

seeding with an appropriate 

mixture should be 

accomplished to reduce the 

probability of cheatgrass 

establishment.

Alt E modified: 

Guideline Following 

wildfires greater than 

10 acres in greater 

sage-grouse habitat at 

high risk of annual 

grass invasions, 

seeding with an 

appropriate mixture,

which may include 

desirable non-native 

plants, should be 

accomplished to reduce 

the probability of 

cheatgrass. Livestock 

grazing should be used 

as a tool to establish 

desired plant 

communities.

We agree with this guideline, and add 

that non-native grasses sometimes have 

the best chance of establishing 

themselves in lieu of cheatgrass. Also, 

grazing is an effective tool in restoring 

burned areas. Evidence of such successes 

is seen in some of the literature. A fire 

science brief from 2011 indicated that a 

study of successful seeding treatments 

found that 83 percent had used nonnative species (i.e., grasses and cereal 

grains) (Evaluating the Effects and 

Effectiveness of Postfire Seeding 

Treatments in Western Forests

Joint fire science programs. Fire Science 

brief. Fire Science Brief Issue 147 

December 2011 Page 1 

www.firescience.gov)

There is ample evidence that non-native 

seeds are and can be successful in 

reducing the invasion of noxious weeds, 

in particular the invasive annuals such as 

medusa head, venenata and cheatgrass. 

We need to be aggressively moving to 

block those annuals from spreading. 

Native seedings are much more 

expensive with much lower success 

rates. 

p. 262

WLD-HAB25

G-12

Guideline Where 

management activities occur 

within riparian habitat, the 

quantity, stature, and health of 

shrubs should not be reduced 

or degraded.

No corresponding 

guideline

Existing standards and guides address 

this issue. According to USFS, riparian 

areas are in an upward trend in the 

planning area.

p. 262

WLD-HAB26

G-14

Guideline Roads and trails 

should not be constructed 

within high elevation riparian 

areas.

No corresponding 

guideline

Baker County believes enough of our 

national forests have been placed offlimits to access. We see little difference 

between the preferred alternative 

(“should not”) and Alt. C (“shall not”). 

Alt. C is not a multiple-use alternative 

and should not be used as a model for the 

preferred alternative. 

This is a safety issue as well. Prohibiting 

road and trail construction in “high 

elevation riparian areas” (which is not 

well-defined) is not supported by science 

and may diminish our ability to reduce 

fuel loads and fight fire. 

p. 263

WLD-HAB28

G-13

Guideline Vigor and areal 

extent of seed producing 

grasses and forbs should not 

be reduced.

No corresponding 

guideline

This is too subjective (seed producing 

grasses and forbs should not be reduced). 

This could be a desired condition but not 

a hard and fast guideline.
19

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 263

PL-TES-1 

New

Standard Livestock grazing 

shall not be authorized or 

allowed during the Silene 

spaldingii active growth 

period (generally between 

May 15 and August 30) in 

pastures that exhibit low 

departure from the desired 

condition, unless the grazing 

management history 

demonstrates that livestock 

avoid Silene spaldingii 

occupied habitat.

No corresponding 

standard

This is duplicative given the guideline 

that calls for avoiding ESA plants if 

possible. 

This guideline is inappropriate for a 

plant that grows and thrives following 

disturbance. 

Further, “low departure” is not defined. 

Removing livestock based on this 

subjective measure is unacceptable. 

There is no proof backed by research that 

demonstrates removing grazing during 

the growing season for Spalding’s 

catchfly will increase the population of 

the plant, therefore these standards 

should not be considered a conservation 

measure.

Entire pastures should not be off-limits 

to grazing; this could mean thousands of 

acres unnecessarily closed to grazing. 

The issue should be addressed at the 

project level through formal 

consultation (ESA Section 7). USFS 

should not presume grazing “guilty until 

proven innocent.” 

Additionally, placing timing restrictions 

(May 15-Aug 30) severely limits the 

flexibility to responsibly manage the 

range resource as whole. This time 

period constitutes 5 out of the 7 months 

that are the grazing season on most 

general forest management areas. This is 

also in direct conflict with pastures that 

have riparian areas that need special 

consideration and should be grazed 

earlier in the season before the weather is 

hot. It also creates scenario where 

grazing will be prohibited altogether 

when Spalding’s catchfly is paired with 

ESA threatened/endangered fish 

spawning limitations (steelhead no cattle 

entry prior to 7/15, and chinook/bull 

trout no entry after 8/15). 

The single-purpose management 

approach proposed by this standard is 

outside USFS’ authority and is not 

supported by range science. Amongst 

USFS’ multiple-use mandate is to 

provide an environment that encourages 

species diversity. Livestock grazing 

contributes to that environment. 
20

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 264

PL-TES-2 

New

Standard Livestock grazing 

shall not be authorized or 

allowed in pastures occupied 

by Silene Spaldingii that 

exhibit moderate or greater 

departure from desired 

condition.

No corresponding 

standard

This standard is unnecessary –see above 

comment. Departure from desired 

condition may not be a result of grazing, 

and it should not be made the automatic 

scapegoat. Grazing can and should be 

managed to contribute to, not detract 

from, desired conditions.

p. 264

PL-TES-3 

New

Guideline Domestic livestock 

grazing should not be 

authorized or allowed in the 

fens/bogs sensitive plant 

habitat groups. 

No corresponding 

standard/guide

This “guideline” is far too restrictive and 

has the qualities of a standard. There is 

no way to allow departure from this 

“guideline” while still meeting its 

“intent.” 

p. 264

PL-TES-4 

New

Guideline Maximum forage 

utilization of key species 

should not exceed 30 percent 

in occupied habitat of 

threatened, endangered, and 

sensitive plant species, except 

where an approved 

conservation strategy, 

conservation agreement, or 

recovery plan approves an 

alternate use level.

No corresponding 

standard/guide

This is, again, a standard in the name of 

a guideline. The broad-stroke assumption 

that 30 percent utilization will benefit 

these species is non-scientific. See 

comments on utilization in our “Grazing 

Concerns” section.

Because “sensitive species” is such an 

overly broad category, this “guideline” 

has the potential to place the 30% 

standard on huge areas, thereby greatly 

harming the grazing industry in the 

County. (See “Wildlife Concerns” 

section of our comments for why 

“species of concern” category should be 

eliminated.)

Requiring an “approved” conservation 

strategy, agreement or recovery plan for 

“sensitive species” places a huge burden 

on the agency and threatens its ability to 

continue its multiple-use mandate. 

Litigation could stall plans/agreements 

for years. If this guideline is included, 

grazing must be allowed to continue 

during development of such 

agreements/plans.

p. 264

PL-TES-5 

New

Guideline New water 

developments and salting 

should not be authorized or 

allowed within one-quarter 

mile of occupied habitat of 

threatened, endangered, or 

sensitive plant species.

No corresponding 

standard/guide

To disallow new water developments 

impinges on water rights and the 

authority of the State of Oregon to 

allocate water resources. Placement of 

salt and water development is an 

important management tool that should 

not be restricted. 

There is no scientific justification for a 

quarter-mile buffer around species, 

particularly “sensitive” species that can 

be designated at-will by a regional 

forester. 

Other standards and guidelines are in 

place to protect ESA species; thus this 

guideline is duplicative. 
21

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 265 

PL-TES-6

New

Guideline Timber harvest and 

associated vegetation activities 

should avoid the occupied 

habitat of threatened, 

endangered, and sensitive 

plant species (minimum 100 

foot buffer), unless the 

silvicultural prescription will 

benefit the species or its 

habitat.

Alt E modified:

Guideline Timber 

harvest and associated 

vegetation activities 

should avoid the 

occupied habitat of 

threatened or 

endangered species, 

unless the silvicultural 

prescription will 

benefit the species or 

its habitat.

ESA Formal consultation will address 

this on a project-specific basis, making 

this guideline unnecessary. Remove 

“sensitive species” as this category is too 

broad and should be eliminated from the 

document altogether. Remove arbitrary 

100-foot buffer. We agree that

silvicultural management will often 

benefit the species and habitat.

p. 265 

PL-TES-7

New

Guideline Slash piles and 

other fuels should be managed 

to avoid the occupied habitat 

of threatened, endangered and 

sensitive plant species 

(minimum 100 foot buffer).

Alt E modified:

Guideline Slash piles 

and other fuels should 

be managed to avoid 

the occupied habitat of 

threatened and 

endangered plant 

species.

ESA Formal consultation will address 

this on a project-specific basis, making 

this guideline unnecessary. Guideline 

should not have prescriptions such as 

100 foot buffer. Sensitive plants should 

be removed; category is too broad.

p. 265 

PL-TES-8

New

Guideline Wildlife fire 

(planned and unplanned) 

suppression lines should not 

be constructed within 

occupied habitat of threatened, 

endangered, and sensitive 

species.

No corresponding 

standard/guide

Catastrophic wildfire is one of the 

primary threats to many endangered 

species, as well as to other multiple uses 

of the forest. Restrictions that limit 

wildfire prevention or suppression 

activities should not be implemented.

p. 265 

PL-TES-9

New

Guideline New road 

construction should be 

designed to avoid the occupied 

habitat of threatened, 

endangered, and sensitive 

plant species (minimum 25-

foot buffer). 

Alt E modified: 

Guideline New road 

construction should be 

designed to avoid the 

occupied habitat of 

threatened or 

endangered, plant 

species except where a 

road or trail would help 

prevent or suppress 

wildfire or where 

needed to utilize a prior 

existing right. 

ESA Formal consultation will address 

this on a project-specific basis, making 

this guideline unnecessary. The 25-foot 

buffer is without scientific basis. 

Remove “sensitive species” as this 

category is too broad and should be 

eliminated from the document altogether.

p. 266

PL-TES-10

New

Guidance All new trail 

construction should be 

designed to avoid the occupied 

habitat of threatened, 

endangered, and sensitive 

plant species (minimum 25-

foot buffer).

Alt E modified: 

Guideline New trail 

construction should be 

designed to avoid the 

occupied habitat of 

threatened or 

endangered, plant 

species except where a 

road or trail would help 

prevent or suppress 

wildfire or where 

needed to utilize a prior 

existing right. 

ESA Formal consultation will address 

this on a project-specific basis, making 

this guideline unnecessary. The 25-foot 

buffer is without scientific basis. 

Remove “sensitive species” as this 

category is too broad and should be 

eliminated from the document altogether.
22

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 266 

PL-TES-11

New 

Guideline Land exchanges 

should avoid the disposition of 

occupied habitat of threatened, 

endangered, and sensitive 

plant species.

No corresponding 

Guideline

Baker County’s private lands are 

generally better managed than federal 

lands. The federal government should 

not limit itself from opportunities to 

dispose of the lands it currently manages.

p. 266

FIRE-2

S-8

Guideline Minimum Impact 

Suppression Tactics (MIST) 

should be utilized in sensitive 

areas, such as designated 

wilderness areas, designated 

wild and scenic river 

corridors, research natural 

areas, botanical areas, riparian 

management areas, cultural 

and historic sites, developed 

recreation areas, special use 

permit areas that have 

structures, and historic and 

recreational trails. MIST 

techniques should also be used 

for post fire restoration 

activities.

No corresponding 

Guideline

MIST is overly restrictive and does not 

allow all available tools to be used to 

stop devastating wildfires. We believe 

that, by implementing MIST in special 

designation areas as well as riparian 

areas, USFS would put at risk Baker 

County citizens’ health, safety and 

wellbeing. 

p. 266

FIRE-3

G-28

Guideline Mechanical fireline 

should not be constructed in 

areas with greater than 35 

percent slope or on highly 

erodible soils unless potential 

adverse effects can be 

mitigated.

Alt E modified: 

Guideline Mechanical 

fireline should not be 

constructed in areas 

with greater than 35 

percent slope or on 

highly erodible soils 

unless potential adverse 

effects can be mitigated 

or unless circumstances 

preclude other means 

of suppressing 

unwanted wildfire.

p. 266

FIRE-4

New

Guideline Greater sagegrouse habitat should be 

identified in fire management 

plans and should be given high 

priority for protection.

Alt E modified:

Guideline Greater 

sage-grouse habitat 

should be identified in 

fire management plans 

and should be given 

high priority for 

protection, second to 

human safety and 

property.”

While we recognize the intent of 

preventing an ESA listing of the Sage 

grouse, we also point out that provisions 

such as this are short-sighted in that they 

place all focus on one species. Singlespecies focus will only serve to create 

imbalance in forest management, in the 

long-term.

p. 268 NOX2

G-29

Changed to 

Standard

Standard Materials used for 

construction or restoration 

projects on National Forest 

System lands shall be free of 

invasive species.

Alt E modified: convert 

to Guideline

This should remain a guideline. While 

avoiding invasive seeds is good practice, 

making this a standard will create a legal 

liability for USFS while doing nothing to 

improve enforcement of the guideline.
23

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

NOX-3

G-36

Changed to 

Standard

Standard All activities shall 

be conducted to minimize or 

prevent the potential spread or 

establishment of invasive 

species.

Alt E modified: convert 

to Guideline

This should remain a guideline. While 

avoiding invasive seeds is good practice, 

making this a standard will create a legal 

liability for USFS while doing nothing to 

improve enforcement of the guideline.

p. 268

FOR-1

S-11

Standard Clearcutting,

shelterwood, and other evenaged regeneration harvest

methods shall be used only

when an interdisciplinary

team/line officer has

determined that protection can 

be assured for resources, such

as soil, watershed, fish,

wildlife, recreation, aesthetics,

and the regeneration of the

timber resource. It shall also be 

determined as the optimal

harvest method.

No corresponding S/G Each of these STANDARDS (FOR-1-5) 

imposes restrictions that could foreclose 

management options that would 

contribute to the recovery of historic 

range of variability and forest resilience. 

They appear to be arbitrary and provide a 

back door to prescriptive governance 

over forest management. FOR-2, in 

particular is far too prescriptive.

They are not appropriate for our forests, 

the bulk of which are at high risk of 

destruction by catastrophic wildfire. 

Their implementation would necessarily 

drastically reduce the amount of timber 

harvest in Baker County, resulting in 

damaging social, economic and 

environmental effects.

p. 269

FOR-2

S-12

Standard Forest openings 

created by the application of 

even-aged regeneration 

harvest methods shall be 

limited to a maximum size of 

40 acres. Exceptions are 

permitted on an individual 

basis after a 60-day public 

notice period and review by 

the regional forester. This 

maximum size opening 

limitation does not apply to 

areas harvested after large 

scale disturbances resulting 

from wildfire, insects, disease, 

windthrow, or other 

catastrophic events.

No corresponding S/G

p. 269

FOR-3

S-13

Standard Cut blocks, patches, 

or strips created by the 

application of even-aged 

regeneration harvest methods 

shall be shaped and blended 

with the natural terrain.

No corresponding S/G

p. 269

FOR-4

S-14

Standard Areas that are 

harvested using even-aged 

regeneration harvest methods 

on lands identified as suitable 

for timber production shall be 

capable of being adequately 

restocked within five years of 

final harvest. Adequately 

restocked is based on national 

forest or regional stocking 

standards.

No corresponding S/G
24

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 270

FOR-5

G-37

Standard Stands shall 

generally have reached the 

culmination of mean annual 

increment of growth as per 

NFMA sec.6 (m) prior to 

harvest. This does not 

preclude the use of thinning or 

other stand improvement 

measures or salvage or 

sanitation harvesting of timber 

stands that are substantially 

damaged by fire, windthrow, 

or other catastrophic events or 

that are in imminent danger of 

insect or disease outbreaks. 

Exceptions: after 

consideration of multiple uses, 

include other activities, such 

as cutting for experimental 

and research purposes, 

removing particular species of 

trees, improving wildlife 

habitat, range, or recreation 

resources.

No corresponding S/G

p. 271

FOR-9

G-41

Guideline Timber harvest

should not cause irreversible

damage to soil, slope, or other

watershed conditions.

No corresponding S/G This guideline is unnecessary. Timber 

projects that abide by other standards 

and guidelines will not do “Irreversible 

damage” to said resources. This term is 

subjective in the first instance, and 

should not be included. The closest 

Baker County’s forests will come to 

being “irreversibly damaged” is when 

they are affected by catastrophic wildfire 

that sterilizes the soil.

p. 271

FOR-10

G-42

Guideline Timber harvest on

lands not suitable for timber

production should occur only 

to meet multiple-use purposes

other than timber production.

Alt E modified:

Guideline Timber

harvest may occur on

lands not suitable for

timber production in 

order to meet multipleuse purposes other than

timber production.
25

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 272

RNG-2

G-44

Guideline New fences should 

be designed to accommodate 

wildlife movement. In greater 

sage-grouse habitat, fence 

construction within 1 mile of 

known leks (protected activity 

centers) and seasonal high use 

areas should not be authorized 

or allowed. Fence construction 

on the crest of low hills should 

not be authorized or allowed 

unless the fence is marked 

with anti-strike markers.

Alt. E Modified: 

Guideline New fences 

should be designed to 

accommodate sage 

grouse movement near 

leks. In greater sagegrouse habitat, new 

fence construction 

within 1 mile of known 

leks (protected activity 

centers) and seasonal 

high use areas should 

not be authorized or 

allowed unless they 

contribute to improved 

grazing management. 

New fence construction 

on the crest of low hills 

should not be 

authorized or allowed 

unless the fence is 

marked with anti-strike 

markers.

Designing fences “to accommodate 

wildlife movement” may be an overlybroad statement if the goal is simply to 

accommodate sage grouse where they 

will be flying frequently. Fences are an 

important aspect of proper grazing 

management and should be constructed 

where needed after coordination and 

consultation with affected permittee(s) 

and the County.

p. 272

RNG-3

G-45

Guideline All new water 

developments should provide 

for small mammal and bird 

escape.

Alt E modified: 

Guideline All new 

water developments 

should provide for 

small mammal and bird 

escape,

and should be installed 

and funded by USFS 

after consultation with 

affected permittee.

Ranchers perform important stewardship 

activities but are not responsible for 

bearing the cost of accommodating 

wildlife.

p. 272

RNG-4

G-46

Guideline In areas classified 

as less than fully capable or 

suitable, only limited grazing 

should be authorized or 

allowed only after the 

limitations of the site are 

considered in designing the 

site-specific allotment 

management plan.

Alt E modified

Guideline In areas 

classified as unsuitable,

only limited grazing 

should be authorized or 

allowed only after the 

limitations of the site 

are considered in 

designing the sitespecific allotment 

management plan, and 

after coordination with 

the county.

“Less than fully capable or suitable” is 

too vague.
26

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 273 RNG5 (Table): Guideline for 

utilization levels. Season-long 

grazing regimes on areas with 

low departure from desired 

condition: 35% utilization 

allowable. Season-long 

grazing regimes on areas with 

moderate or greater departure 

from desired condition: 30%.

Management regimes with 

deferment/rest/rotation that 

have low departure from 

desired conditions: 40%. 

Those with moderate or 

greater departure from DC: 

35%.

Alt E modified: 

Guideline

Scientifically-sound 

utilization levels and 

monitoring techniques 

should be agreed upon

by County and, when 

possible, the permittee. 

(See Appendix B for 

suggested utilization 

levels.)

Ocular measurement is too subjective. 

Coordination with county and 

consultation with permittee should 

determine science-based monitoring 

method. 

Low-moderate-greater departure from 

desired condition is not defined. 

Coordination with county should define 

this, as well as what the desired 

conditions are.

Utilization levels are too low and are not 

based on a balanced consideration of 

range science. These levels will 

encourage wildfire in many cases and 

will detract from healthy grass and forbs 

growth. Furthermore, utilization should 

not be a number, but rather a range of 

use to achieve proper use that effectively 

addresses the needs of the plant 

community and the season of use it is 

applied to (i.e., 40-60%). See more in 

our Grazing Concerns section.

The document states repeatedly that 

there are upward trends in range health. 

This has been the case even as utilization 

levels have well exceeded 40%. 

p.273 RNG6 G-47Guideline Upland shrub 

utilization should not exceed 

40 percent as determined by 

any science-based method.

Alt E modified: 

Guideline 

Scientifically-sound 

utilization levels and 

monitoring techniques 

should be agreed upon 

by County and, when 

possible, the permittee. 

(See Appendix B for 

suggested utilization 

levels.)

Utilization level is too low and not based 

on a balanced consideration of range 

science. See above comments. This level 

will encourage wildfire in many cases 

and will detract from healthy grass and 

forbs growth. 

Also, we assume the language “as 

determined by any science-based 

method” refers to monitoring methods. 

Not all methods are created equal. Even 

proven techniques can fail if they are 

used on inappropriate sites.
27

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 274 RNG7 NewGuideline Grazing utilization 

within occupied greater sagegrouse habitats should not 

exceed 40 percent at any time 

during the grazing season and 

will be determined specifically 

for each greater sage-grouse 

habitat, i.e., grazing utilization 

measured as an average of the 

entire pasture or grazing unit 

will not be used to determine 

compliance with this 

guideline.

No corresponding S/G. We do not believe that setting a 

prescriptive utilization level is suitable 

for a guideline. See above comments on 

the inappropriateness of applying one 

utilization number, versus a range, to 

broad areas.

If sage grouse exist in areas currently 

grazed at levels above 40%, we question 

the wisdom in reducing those levels. The 

proposed percentage is presumably 

drawn from Holechek, whose research 

took place largely in AZ and NM and is 

not appropriate. 

Also, if 40% utilization is reached in a 

“a” sage-grouse habitat, how may 

grazing continue on other parts of that 

pasture without fencing? This aspect of 

the guideline is not practical. 

p. 274 RNG8

New

Guideline During greater 

sage-grouse breeding season, 

livestock turnout and trailing 

should avoid concentration on 

known greater sage-grouse 

leks (protected activity 

centers).

Alt E modified: 

Guideline When 

considering changes to 

historic turnout or 

trailing practices, sage 

grouse leks should be 

avoided during the 

breeding season, if 

possible.

Most trails and turnout areas are 

historical. If leks have established under 

those conditions, changing practices 

should only serve to alter conditions and 

thus threaten leks. Heavily grazed areas 

are often optimum lek sites.

p. 274 

RNG-9

S-2

Standard Domestic Sheep or 

goat grazing shall not be 

authorized or allowed on lands 

where effective separation 

from bighorn sheep cannot be 

reasonably maintained.

No corresponding S/G. Decisions requiring bighorn sheep 

(BHS)/domestic sheep separation should 

not be made by USFS.

See our comments on BHS in the 

Grazing Concerns section.

p. 274 

RNG-10

S-3

Standard The use of domestic 

goats or sheep for 

manipulation of vegetation (ie 

noxious weed control, fuels 

reduction) shall not be 

authorized or allowed within 

or adjacent to source habitat 

for bighorn sheep.

No corresponding S/G. This is duplicative of the above.

Livestock grazing has long been 

recognized as an effective tool for 

controlling invasives (Launchbaugh 

2007). See above comments for why 

complete separation is unnecessary. 

Furthermore, “adjacent to source habitat” 

is a vague an potentially vast area.

p. 275 RNG12

New

Standard An effective 

monitoring program shall be 

in place to detect presence of 

bighorn sheep in identified 

high-risk areas when 

authorized domestic sheep or 

goats are present on adjacent 

or nearby allotments.

No corresponding S/G. Who will do this monitoring? Funding 

for monitoring is already inadequate. 

Will grazing be disallowed if an 

“effective” monitoring program is not in 

place? 

“High-risk” area is not defined. How 

would sheep being adjacent to high-risk 

areas be a problem, and what is the 

meaning of “adjacent to”? We cannot 

meet these vague standards.
28

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 275 RNG13

New

Guideline 

Trailing of domestic sheep or 

goats should not be authorized 

or allowed within 7 miles of 

bighorn sheep home ranges.

No corresponding S/G. There is no scientific basis for this buffer 

zone, especially for the trailing of sheep, 

where there won’t be prolonged contact 

(the most likely to result in disease 

transfer).

p. 275 RNG14

New

Standard 

When effective monitoring has 

not been conducted for 

bighorn sheep presence, 

domestic sheep or goat 

grazing shall not be 

authorized.

No corresponding S/G. See notes on RNG-12

p. 275

RNG-16

New

Standard When permitted 

sheep are found to be missing, 

the Forest Service shall be 

notified within 24 hours.

Alt E modified 

Guidance When 

permitted sheep are 

found to be missing, 

the Forest Service shall 

be notified within 24 

hours.

While it is reasonable to ask a rancher to 

report missing sheep within 24 hours, 

these areas are remote and this may not 

be possible. This should be recast as 

guidance.

p. 276 RNG17

New

Standard 

Authorized domestic sheep or 

goats shall be individually 

marked in a manner that 

allows immediate 

identification of ownership at 

a distance during the grazing 

season at all times while on 

NFS lands.

No corresponding S/G. This is a very unreasonable request. 

Sheep are required to have a paint brand, 

registered with the state, in order to be 

on USFS land. This should be sufficient.

p. 276 RNG18

New

Standard 

Implement emergency actions 

when bighorn sheep presence 

is detected within 7 miles of 

active domestic sheep or goat 

grazing or trailing. Actions to 

be taken shall ensure 

separation between bighorn 

sheep and domestic sheep or 

goats.

No corresponding S/G. No scientific basis for this buffer. 

Making it a standard to “ensure” 

separation automatically means the 

sheep industry is doomed.
29

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 276 RNG19

New

Guideline To maintain 

separation, when bighorn 

sheep are found within 7 miles 

of an active domestic sheep 

and goat allotment, 

implementation of emergency 

actions for domestic sheep and 

goat grazing could include: 

Reroute (move) domestic 

sheep or goats to a new 

routing path that will take 

them away from the likely 

bighorn movement; this may 

involve rerouting within the 

permitted allotment, 

movement to a different 

allotment, or, if the situation 

cannot otherwise be resolved, 

moving the permitted sheep 

off of the national forest until 

the situation can be resolved 

Inform the appropriate state 

agency of the bighorn sheep 

location 

No corresponding S/G. This is entirely unreasonable. See notes 

above. This would eliminate the sheep 

industry on USFS land, as alternative 

pasture is not likely to be found for 

thousands of sheep. If this were to be 

implemented, we would demand that 

alternative allotments be found for those 

sheep in a timely manner that does not 

put undue pressure on producers.

p. 277

KW-1 S-15

Standard There shall be no 

net increase in the mileage of 

Forest Roads in any key 

watershed unless the increase 

results in a reduction in roadrelated risk to watershed 

condition. Priority should be 

given to roads that pose the 

greatest relative ecological 

risks to riparian and aquatic 

ecosystems.

Alt E modified: 

Guideline Any

increases in the mileage 

of Forest Roads in any 

key watershed should 

not result in substantial 

road-related risk to 

watershed condition.

“Priority should be given to roads that 

pose the greatest relative ...risks...” 

Does this imply that roads will be 

decommissioned? No road 

decommissioning should take place 

without coordination with the affected 

county. We suggest removing this 

sentence.

p. 278

KW-2 S-16

Standard Hydroelectric and 

other surface water 

development authorizations 

shall include requirements for 

in-stream flows and habitat 

conditions that maintain or 

restore native fish and other 

desired aquatic species 

populations, riparian 

dependent resources, favorable 

channel conditions, and 

aquatic connectivity.

No corresponding S/G. USFS asserts that surface water 

development authorizations “shall 

include requirements” for in-stream 

flows, habitat conditions, connectivity, 

etc.—without giving specifics as to what 

those “requirements” would be. This is a 

terribly vague standard that also usurps 

the State’s authority over water rights. 

Furthermore, USFS cannot control every 

variable regarding desired fish 

populations. No matter the conditions or

the design and function of surface water 

developments, fish may or may not 

thrive based on a large number of 

variables outside USFS’ control.

Terms such as “favorable channel 

conditions” are far too subjective to be 

included in a standard.
30

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 278

KW-3 S-17

Standard New hydroelectric 

facilities and water 

developments shall not be 

located in a key watershed 

unless it can be demonstrated 

that there are minimal risks 

and/or no adverse effects to 

the fish and water resources 

for which the key watershed 

was established.

No corresponding S/G. The concept of “Key Watersheds” is 

flawed. Watersheds were not 

“established” by USFS, nor can USFS 

declare that fish habitat is the sole 

“purpose” of a watershed. USFS should 

be focusing on multiple uses that will 

benefit the human population. This 

includes both keeping water resources 

healthy and allowing for new energy 

sources that will benefit Baker County 

residents.

Page 

279WR-3

Guideline Hydrologic 

connectivity and sediment 

delivery from roads and trails 

should be minimized. This 

includes roads inside and 

outside of riparian 

management areas.

Alt E modified

Guideline Hydrologic 

connectivity and 

sediment delivery from 

roads and trails should 

be analyzed in 

coordination with the 

county on a sitespecific basis, and 

addressed where 

necessary.

This guideline is not acceptable. Not all 

roads inside riparian corridors are 

problem roads. Almost none of the roads 

outside riparian corridors (exception 

would be in areas of very steep ground) 

are problem roads. This guideline needs 

to be rewritten to indicate that 

hydrologic connectivity should be 

evaluated on a site specific basis. 

P. 279

OF-1

G-59

Guideline Management 

activities within and outside 

old forest stands should 

generally emphasize retaining 

old trees of desirable species. 

For most species, old trees are 

generally considered to be 

greater than 150 ears in age 

and may exhibit certain old 

tree characteristics. However, 

these old tree characteristics 

may vary by site and should 

be further developed on a 

project-specific basis.

Alt E modified: 

Guideline 

Management activities 

within old forest stands 

should generally 

emphasize retaining old 

trees of desirable 

species. For most 

species, old trees are 

generally considered to 

be greater than 150 ears 

in age and may exhibit 

certain old tree 

characteristics. 

However, these old tree 

characteristics may 

vary by site and should 

be further developed on 

a project-specific basis.

“Within and outside” old forest stands is 

too broad. 

On page iii-iv (Vol 1), for Alternatives 

D-F, the document states there will no 

longer be designated old forest 

management areas. This is a good thing. 

Timber management activities should 

take place in these areas. However, the 

document describes a “legacy tree” as a 

live tree over 21 inches—then states in

this guideline that these will be 

protected. That puts us back where we 

started.

The definition of a legacy tree should be 

changed to include only trees over 21 

inches dbh that are healthy, produce 

cones and are without disease or dead 

top.

p. 279

OF-2

New

Guideline New motor vehicle 

routes should not be 

constructed within old forest 

stands.

No corresponding S/G. “Old forest stands” is a vague term and 

could conceivably cover very large 

areas. This guideline could therefore 

prevent road construction important to 

the protection of the forest (wildfire 

suppression and logging) and economic 

activities, including preexisting rights.

p. 281

MA 1A 

WIL-5 G-64

Guideline 

States no tethering of animals 

within 200 feet of lakes.

Alt E modified 

Guideline 

States no tethering of 

animals within 50 feet 

of lakes.
31

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 282

MA 1A 

WAW-WIL1 S-20

(Wildernesw

ithin 

WWNF)

Standard Visitors must obtain 

and possess an entry permit

No Corresponding S/G No permits should be required to access 

wilderness except in the case as happens 

on wild and scenic rivers where permit 

fees are used to provide sanitary 

facilities for rafters and other river users.

p. 282 

MA 1A 

WAW-WIL2 S-21

Standard

Campfires not authorized 

within 100 feet of lakes

Alt E modified 

Standard

Campfires not

authorized within 50 

feet of lakes

p. 283

MA 1A 

WAWWIL-4 S-23

Standard

Grazing of horses shall not be 

allowed with 200 feet of any 

lake in the Eagle Cap 

Wilderness Area

Alt E modified 

Standard

Grazing of horses shall 

not be allowed with 50 

feet of any lake in the 

Eagle Cap Wilderness 

Area

p. 283

MA 1A 

WAW 

WIL-7 S-27 

Standard 

Party size no more than 6 

allowed 

Alt E modified

Standard 

Party size no more than 

12 allowed 

Should be the same as #S-26 Party size 

12. However, if no permits are required, 

this becomes irrelevant.

MA 1A 

WIL-FIRE1 G-65

Standard

All firelines should be restored

Alt E modified 

Guideline Firelines 

should remain open for 

firewood collection and 

restoration work

p. 285

WIL-ST-1

G-71

Guideline Existing and 

proposed uses that could 

compromise wilderness 

eligibility prior to 

congressional designation 

should not be authorized.

No corresponding S/G If existing uses would threaten an area’s 

designation as wilderness, that area 

obviously should not have qualified as a 

recommended/study area.

On p. 190, Vol. 1, report findings reveal 

that additional wilderness designation is 

not necessary within the Blue Mountain 

national forests.

MA 2A 

WSR-3 G73 

Guideline 

Must use designated stock 

facilities only for hitching 

horses 

Alt E modified 

Guideline allow 

hitching of horses 

within 50 feet of water 

areas

This is not workable because there are 

not enough stock facilities thru out the 

areas. Must be allowed to hitch horses 

within 50 feet of water areas 

MA 2A 

WSR-6 G76 

Guideline 

Timber harvest roads should 

not be constructed in wild and 

scenic river corridors.

Alt E modified

Guideline 

Timber harvest roads 

should not be 

constructed in wild and 

scenic river corridors 

except for purposes of 

fuel reduction or 

existing rights.
32

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 287

MA 2A 

WSR-8 G78 

Guideline 

The construction of roads and 

river crossings that are visible 

from the river corridor should 

not be allowed 

Alt E modified

Guideline 

The construction of 

roads and river 

crossings that are 

visible from the river 

corridor should not be 

allowed, unless 

necessary to satisfy 

existing rights.

p. 287

MA 2A 

WSR-11 S36 

Standard

Oil and gas leasing shall not 

be allowed with 1320 feet of 

high water mark 

Alt E modified

Guidance

Oil and gas leasing 

shall be allowed at 

distances that do not 

inhibit WSR purposes, 

on a site-specific basis 

and in coordination 

with the County. 

p. 288

MA 2B 

RNA-1 

New

Standard

Management activities that 

modify ecological processes 

shall not be allowed

No corresponding S/G Baker County opposes the creation of 

RNAs, for the very reason that they 

restrict “management activities that 

modify ecological processes.” Such 

activities are necessary for the safety and 

wellbeing of our residents, as well as 

their very way of life. Losing activities 

such as logging, mining and grazing 

detracts from our economy and our 

safety, in light of the increased risk of 

catastrophic wildfire. 

As stated by the USFS website, “RNAs 

are protected against human activities 

that directly or indirectly modify their 

ecological integrity...” 

(http://www.fs.fed.us/rmrs/researchnatural-areas/about/). We disagree with 

this designation, which is an effective 

Wilderness designation, but without the 

deliberation of Congress. The USFS 

websites states, “It has been especially 

challenging to secure RNA designations 

in the most productive forest and 

rangeland ecosystems where commodity 

uses have been concentrated.” This is as 

it should be; the national forests were 

established by the Organic 

Administration Act (OAA) of 1897, 16 

U.S.C § 475, for two primary purposes: 

to conserve water flows, and to furnish a 

continuous supply of timber for the 

American people. Research in RNAs 

should be geared toward the achievement 

of those dual goals. Such has not been 

the case.
33

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 288

MA 2B 

RNA-2 G86

Guideline changed to 

standard

Mineral exploration shall 

minimize impacts to research 

areas

No corresponding S/G The County opposes such restrictions; 

see comment on RNA-1.

p. 288 MA 

2B RNA-3 

G-87

Guideline changed to 

standard

Removal of common mineral 

material shall not be allowed

No corresponding S/G The County opposes such restrictions; 

see comment on RNA-1.

p. 289

MA 2C 

Botanical 

areas

MA 2C 

BOT-3

G-93

Guideline 

Silvicultural treatments should 

be allowed only when 

designed to enhance the 

special features of botanical 

areas.

No corresponding S/G Baker County disagrees with these 

guidelines, as they all negatively affect 

our residents’ use and enjoyment of the 

WWNF. Botanical areas represent 

another special designation that has the 

potential to severely restrict Baker 

County residents’ use, enjoyment, and 

safety by minimizing uses such as timber 

p. 289 management, grazing, and mining.

MA 2C 

BOT-4

G-94

Guideline Firewood 

collection should not be 

authorized or allowed within 

botanical areas.

No corresponding S/G

p. MA 2C 

BOT-6

G-96

289

Guideline Removal of 

common mineral material 

should not be authorized or 

allowed within botanical areas

No corresponding S/G

p. 290

MA 2C 

BOT-7

G-97

Guideline Botanical areas 

should be managed as 

avoidance areas for utility 

corridors.

No corresponding S/G

p. 291

STA EXP-4

New

Standard Vehicle access shall 

only be allowed on designated 

routes, unless necessary to 

meet research needs or 

objectives

Alt E modified: 

Guideline Vehicle 

access shall only be 

allowed on designated 

routes, unless necessary 

to meet research needs 

or objectives, fight fire, 

or satisfy existing 

rights.

p. 291

STA EXP-4

New

Standard Starkey EFR shall 

be closed to public access 

from fall until spring to protect 

deer and elk from harassment 

and stress during winter, with 

specific dates established 

periodically as consistent with 

research objectives.

No corresponding S/G WWNF deer and elk populations are 

thriving. No such restrictions are 

necessary.

p. 291

STA EXP-4

New

Guideline Existing old growth 

should be retained and 

additional stands that are the 

closest to old growth structure 

should be retained at a rate of 

20 percent of the land area.

Alt E modified: 

Guideline Existing old 

growth should be 

retained.

“Stands that are the closets to old growth 

structure” – this is an impossibly vague 

guideline that should be deleted.
34

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 292

MA 3A/B

BACK-1

S-58

(Backcount

ry 

nonmotoriz

ed and 

motorized)

Standard Silvicultural 

treatments shall generally be 

limited to small diameter 

material and may take place 

only for the following reasons: 

To improve habitat for species 

with viability concerns, restore 

terrestrial or aquatic 

ecosystem composition and 

structural characteristics, or to 

maintain existing unique or 

important wildlife features or 

plant communities. 

Appropriate administrative use 

When cutting, sale, or removal 

of timber is incidental to the 

implementation of another 

suitable management activity

No corresponding S/G The two “backcountry” designations 

proposed by USFS violate the agency’s 

multiple-use mandate, as exemplified by 

this standard. To limit timber 

management to solely “ecosystem” 

purposes is blatantly against USFS’ 

primary purpose of providing a steady 

supply of timber to the American people. 

The MA 3A/B designations should be 

discarded altogether.

p. 293

MA 3A/B

BACK-2

S-59

Standard New road 

construction shall be limited to 

that required for designated 

special uses or required by law 

to provide access to nonFederal land or valid existing 

rights.

No corresponding S/G See comment on MA 3A/B

BACK-1 S-58

p. 293

MA 4B

RMA-1

G-101

(Riparian 

Managemen

t Areas)

Guideline When riparian 

management areas are 

functioning properly, project 

activities should be designed 

to maintain those conditions. 

When riparian management 

areas are not properly 

functioning, project activities 

should be designed to improve 

those conditions.

Project activities in RMAs 

should not result in long-term 

degradation to aquatic and 

riparian conditions at the 

watershed scale. Limited short 

term or site-scale effects from 

activities in RMAs may be 

acceptable when they support, 

or do not diminish long-term 

benefits to aquatic and riparian 

resources.

USFS proposes to unilaterally turn 

riparian areas (or, in many cases, nonriparian areas that nonetheless fall under 

the proposed RMA definition) into nonmultiple-use areas. While we understand 

and agree that properly functioning 

riparian areas are in the best interest of 

Baker County residents, we simply 

observe that none of the standards or 

guidelines for RMAs make mention of 

USFS’ mandate to provide social and 

ecological benefits to the people. This 

oversight must be righted in future 

planning efforts. 
35

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 294

MA 4B

RMA-2

S-41

Standard Herbicides, 

insecticides, pesticides and 

other toxicants, and other 

chemicals shall be applied 

only to maintain, protect, or 

enhance aquatic and riparian 

resources or to restore native 

plant communities.

Alt E modified: 

Guideline Herbicides, 

insecticides, pesticides 

and other toxicants, and 

other chemicals shall 

be applied only to 

maintain, protect, or 

enhance aquatic and 

riparian resources or to 

restore native and 

desired non-native 

plant communities.

p. 294

MA 4B

RMA-4

G-103

Guideline Water drafting sites 

should be located and 

managed to minimize adverse 

effects on stream channel 

stability, sedimentation, and 

in-stream flows needed to 

maintain riparian resources, 

channel conditions, and fish 

habitat.

Guideline Water 

drafting sites should be 

located and managed to 

minimize adverse 

effects on stream 

channel stability and 

sedimentation.

Regulating in-stream flows is the state’s 

responsibility and beyond the authority 

of USFS.

p. 295

MA 4B

RMAFIRE-1

G-104

Guideline Disturbed areas, 

such as firelines, drop-points, 

camps, roads, and trails, 

should be restored by actions 

such as scattering slash piles, 

replacing logs and boulders, 

scarifying soils, recontouring 

terrain, and reseeding with 

native species

Guideline Disturbed 

areas, such as firelines, 

drop-points, camps, 

roads, and trails, should 

be restored by actions 

such as scattering slash 

piles, replacing logs 

and boulders, 

scarifying soils, 

recontouring terrain, 

and reseeding with 

native and desired nonnative species

p. 297

MA 4B 

RMA-FIRE10

S-45

Standard Minimum Impact 

Suppression Tactics (NWCG 

2006) techniques for wildfire 

suppression activities shall be 

used in riparian management 

areas.

No corresponding S/G. As noted above, we do not believe use of 

MIST in RMAs is appropriate.

p. 297

MA 4B 

RMA-FIRE11 S-46

Standard To minimize soil 

damage when chipping fuels 

within RMAs, chip bed depth 

on dry soils shall be limited to 

7.5 cm or less (Busse et al. 

2005)

Alt E modified: 

Guideline To minimize 

soil damage when 

chipping fuels within

RMAs, chip bed depth 

on dry soils shall be 

limited to 7.5 cm or 

less (Busse et al. 2005)
36

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 297

MA 4B 

RMA-FOR1

G-112

Guideline Silvicultural 

treatments should occur on 

RMAs only as necessary to 

maintain, restore or enhance 

conditions that are needed to

support aquatic and riparian 

dependent resources.

No corresponding S/G See comment on MA 4B

RMA-1 G-101

p. 298

MA 4B 

RMA-FOR2

S-47

Standard Firewood collection 

shall not be authorized or 

allowed in the active 

floodplain or within primary 

source areas for large woody 

debris. Active floodplain is the 

area bordering a stream that is 

inundated by flows at a 

surface elevation defined by 

two-times the maximum 

bankfull depth (ie, bankful 

depth measured at thalweg). 

No corresponding S/G This standard is a demonstration of the 

DEIS’ numerous proposals to implement 

incomprehensible, unknowable standards 

that will serve only to incriminate Baker 

County residents.

p. 298

MA 4B 

RMA-RNG1 S-48

Standard New livestock 

handling and/or management 

facilities shall be located 

outside RMAs, except for 

those that inherently must be 

located in an RMA and those 

needed for resource 

protection.

Alt E modified: 

Guideline New 

livestock handling 

and/or management 

facilities should be 

located outside RMAs, 

except for those that 

inherently must be 

located in an RMA and 

those needed for 

resource protection.
37

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 299

MA 4B 

RMA-RNG2 G-115

Guideline (Table A-55a)

Maximum utilization within 

RMAs for both Woody 

vegetation and herbaceous 

vegetation (percent of mean 

annual vegetative production): 

25% within bull trout 

spawning and rearing reaches. 

40% for all other watercourses 

including anadromous fish 

reaches.

In addition, the minimum 

residual stubble height 

(applies at the greenline) for 

all alternatives is 4-6 inches. 

The max bank alternation is 20 

percent

Alt E modified: 

Guideline 

Scientifically-sound 

utilization levels and 

monitoring techniques 

should be agreed upon 

by County and, when 

possible, the permittee. 

(See Appendix B for 

suggested utilization 

levels.)

The plan states that riparian areas and 

rangeland are on an upward trend. If this 

is the case, why does USFS propose to 

decrease utilization standards?

Utilization: Utilization levels are too low 

and are not based on a balanced 

consideration of range science. These 

levels will encourage wildfire in many 

cases and will detract from healthy grass 

and forbs growth. Furthermore, 

utilization should not be a number, but

rather a range of use to achieve proper 

use that effectively addresses the needs 

of the plant community and the season of 

use it is applied to (i.e., 40-60%). See 

more in our Grazing Concerns section.

Bull trout: p. 308 Vol 1 states there are 

53 subwatersheds containing bull trout 

(640,000 acres, 36 percent of forest 

area). This is a huge area. The 25% 

utilization level, in most cases, will make 

it uneconomical for most operators in 

bull trout “habitat” to turn out at all. 

There is no scientific basis for this 

standard.

Stubble height: While USFS should 

monitor stubble height for green line,

grass and forb height must be determined 

by species, ecological site, site potential 

and weather. Many sites have mixed 

grass species due to many factors and the 

attribute must be carefully defined prior 

to any assessment. A bluebunch site 

may achieve a mature height of 10-12 

inches, but some sites with a mixture of 

grass species achieve a mature height of 

7-8 inches. Other sites achieve even 

less. The same pattern is true for forb 

species. Further, mixing the different 

forb species will not accurately assess 

forb height, rendering the information 

arbitrary and ineffective at providing an 

assessment. 

Stream bank alteration: While bank 

alteration should be used to monitor 

conditions, the 20% bank alteration 

standard has no scientific basis and 

should not be included in the forest plan. 
38

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 300

MA 4B 

RMA-RNG3 G-116

Guideline During allotment 

management planning, 

removing existing livestock 

handling or management 

facilities from RMAs should 

be considered.

No corresponding S/G Riparian area conditions are currently 

trending up. This is unnecessary, and 

will only serve to detract from activities 

crucial to proper livestock management, 

and thus range health. Removal of these 

facilities threatens to add cost and 

difficulty to producers, which could in 

turn result in their inability to utilize 

their grazing rights.

p. 300

MA 4B 

RMA-RNG4 G-117

Guideline Livestock trailing, 

bedding, watering, loading, 

and other handling in RMAs 

should be minimized.

No corresponding S/G RMAs are defined so broadly that this 

guideline will necessarily eliminate large 

portions of producers’ ranges. 

p. 300

MA 4B 

RMA-RNG5 G-118

Standard Trampling of 

federally listed threatened or 

endangered fish redds by 

livestock shall be avoided.

No corresponding S/G This is duplicative and unnecessary. 

Other S/Gs address the protection of 

ESA species. Furthermore, making this a 

standard implies a zero-tolerance policy 

that will completely preclude livestock 

access to waterways that may harbor 

redds. 

p. 300

MA 4B 

RMA-RD-1 

S-49

Standard Side-casting 

(placement of unconsolidated 

earthen waste materials 

resulting from road 

construction or maintenance) 

in RMAs shall be avoided.

Alt E modified : 

Guideline Sidecasting (placement of 

unconsolidated earthen 

waste materials 

resulting from road 

construction or 

maintenance) in RMAs 

should be avoided 

when feasible, 

considering added costs 

of moving materials, 

and with the 

requirement that valid 

existing rights be

satisfied.

Such a requirement could make road 

construction and maintenance 

prohibitively expensive. USFS proposes 

to add costs to this activity at the same 

time that it cites inadequate budgets to 

maintain existing roads.

p. 300

MA 4B 

RMA-RD-2 

S-50

Standard Fill material shall 

not be placed on organic 

debris in RMAs

Alt E modified : 

Guideline Fill material 

should not be placed on 

organic debris in 

RMAs when feasible, 

considering the 

associated costs. Valid 

existing rights must be 

satisfied.

See above comment.
39

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 301

MA 4B 

RMA-RD-3 

S-51

Standard Disruption of 

natural hydrologic flow paths, 

including diversion of 

streamflow and interception of 

surface and subsurface flow 

shall be minimized or avoided 

when constructing or 

recontruscting roads or 

landings either inside or 

outside of RMAs.

Alt E modified: 

Guideline Disruption 

of natural hydrologic 

flow paths, including 

diversion of streamflow 

and interception of 

surface and subsurface 

flow should be 

minimized when 

constructing or 

recontruscting roads or 

landings in RMAs.

Placing this in the RMA category 

implies it will apply to RMAs only. Why 

state “either inside or outside of RMAs”?

p. 301

MA 4B 

RMA-RD-4 

G-120

Guideline Wetlands and 

unstable areas should be 

avoided when reconstructing 

existing roads or constructing 

new roads and landings. 

Minimize impacts where 

avoidance is not practical.

Alt E modified: 

Guideline Wetlands 

and unstable areas 

should be avoided 

when constructing new 

roads and landings. 

Minimize impacts 

where avoidance is not 

practical.

If existing roads are in “wetlands or 

unstable areas,” their reconstruction will 

necessarily fall in those areas. If those 

roads needed where they are, measures 

can be taken to minimize their effects on 

said areas.

p. 301

MA 4B 

RMA-RD-5 

S-52

Standard New or replaced 

permanent stream crossings 

shall accommodate flows at 

least 20 percent greater than 

the 100-year flood event, 

including associated bedload 

and debris.

Alt E modified: 

Guideline New or 

replaced permanent 

stream crossings shall 

accommodate flows 

such that they can 

accommodate 100-year 

flood events.

Allowing for flows at least 20 years 

greater than the 100-year flood event is 

excessive and will add unnecessary cost 

and/or could preclude crossing 

construction.

p. 301

MA 4B 

RMA-RD-6 

S-53

Standard Where physically 

feasible, construction or 

reconstruction of stream 

crossing shall avoid diversion 

of streamflow out of the 

channel and down the road in 

the event of crossing failure.

Alt E modified 

Guideline Where 

physically feasible, 

construction or 

reconstruction of 

stream crossing shall 

avoid diversion of 

streamflow out of the 

channel and down the 

road in the event of 

crossing failure.

p. 301

MA 4B 

RMA-RD-7 

S-54

Standard In fish bearing 

streams, construction or 

reconstruction of stream 

crossing shall provide and 

maintain passage for all fish 

species and all life stages of 

fish.

Alt E modified: 

Guideline In fish 

bearing streams, 

construction or 

reconstruction of 

stream crossing should 

provide and maintain 

passage for all fish 

species and all life 

stages of fish.
40

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 306

MA 4B 

RMA-HYD1 S-56

Standard Authorizations for 

all new and existing special 

uses, including, but not limited 

to water diversion or 

transmission facilities (e.g., 

pipelines and ditches), energy 

transmission lines, roads, 

hydroelectric, and other 

surface water development 

proposals, shall result in the 

reestablishment, restoration, or 

mitigation of habitat 

conditions and ecological 

processes identified as being 

essential for the maintenance 

or improvement of habitat 

conditions for fish, water and 

other riparian dependent 

species and resources. These 

processes include in-stream 

flow regimes, physical and 

biological connectivity, water 

quality, and integrity and 

complexity of riparian and 

aquatic habitat.

No corresponding S/G The placement of this standard in the 

“hydropower” section is inappropriate 

and appears intended to cloak the broad 

scope of the standard. Authorizations of 

all new and existing special uses

includes almost any conceivable activity 

on the forest, including existing water

rights that are perfected via a special use 

permit (for maintenance of pipelines and 

ditches, for example). 

“...shall result in the reestablishment, 

restoration, or mitigation of habitat 

conditions and ecological processes 

identified as being essential for the 

maintenance or improvement of habitat 

conditions for fish, water and other 

riparian dependent species and 

resources.”

Comment: Who will “identify” the 

ecological processes that are “essential” 

for the said purposes? This is completely 

subjective, which makes all activities on 

RMAs that require special use permits 

subject litigation. “...essential 

maintenance or improvement” implies 

conditions could be good, but 

improvements COULD be made. The 

possibility for “improvement” is 

limitless. Must all new and existing uses 

result in the “improvement” of habitat 

conditions?

“These processes include in-stream flow 

regimes, physical and biological 

connectivity, water quality, and integrity 

and complexity of riparian and aquatic 

habitat.”

Comment: regulation of these features is 

not within the authority of USFS. 

“Integrity and complexity of riparian and 

aquatic habitat”- this is 

incomprehensible. It holds no meaning, 

yet it is cast as part of a standard. 

The entire standard should be discarded.
41

Reference USFS Preferred Alternative 

(Alt. E)

BC Preferred 

Alternative

Comments

p. 306

MA 4B 

RMA-HYD2 S-57

Standard New support 

facilities shall be located 

outside of RMAs. Support 

facilities include any facilities 

or improvements (eg, 

workshops, housing, 

switchyards, staging areas, and 

transmission lines) not directly 

integral to the production of 

hydroelectric power or 

necessary for the 

implementation of prescribed 

protection, mitigation or 

enhancement measures.

Alt E Modified: 

Guideline New support 

facilities not directly 

integral to the 

production of 

hydroelectric power 

should be located and 

operated in a manner 

that does not 

compromise riparian 

areas. Riparian areas 

should be determined 

on a site-specific basis.

RMAs are defined so broadly as to make 

the construction of support facilities 

impossible within a reasonable distance. 

This may inadvertently prevent efficient 

hydropower production, or any 

hydropower production at all. This will 

certainly be the case if structures such as 

transmission lines are considered to be 

“support facilities” not integral to the 

production of hydropower.

Wildlife Concerns

The interrelationship between wildlife and humans in Baker County has been ongoing for over a 

hundred and fifty years. Hunting and fishing are significant economic drivers in our economy. 

They are also woven into the social fabric of our citizens and are a significant part of the culture 

and custom of Baker County. Our challenge as a County is to preserve and enhance our wildlife 

resources while maintaining historic and contemporary uses of these resources. Our objectives are 

to involve local stakeholders in the development of wildlife plans, including for ESA species; to 

encourage the maintenance and improvement of wildlife habitat on public lands; and to identify 

acceptable habitat where ESA species can be conserved without substantial conflict to other natural 

resource users. Any proposed management plan of a listed species will require coordination with 

the County to ensure that it is consistent with the Natural Resources Plan.

I. Focus on Wildlife Populations is Inappropriate

Wildlife management is the prerogative of the State of Oregon. The DEIS not only proposes to 

manage wildlife to the degree that usurps the State’s jurisdiction; it violates its multiple-use 

mandate in prioritizing wildlife “protection” over all other uses.

We agree with language on p. 29 of the RLMP, which states that NFMA “requires land and 

resource management plans to contribute to the diversity of plant and animal communities, based 

on the suitability and capability of the land area, while meeting overall multiple-use objectives” 

(emphasis added). We disagree with the statement that “a species-specific approach is warranted” 

in cases where “ecosystem diversity does not provide the ecological conditions necessary to sustain 

populations of certain species.” This is in direct conflict with the previous statement regarding 

NFMA requirements. Single-species management is not a wise—or legal—approach to national 

forest management. Focusing on habitat diversity, rather than focusing on species’ populations, 

provides for a more workable management approach and allows USFS to address those issues over 

which it has the ability and authority to control.

The states have primary jurisdiction over non-ESA protected wildlife and therefore should 

be the entity that manages wildlife. Coordination with the states through Memoranda of 

Understanding (MOUs) should be the primary tool used for coordinating wildlife management with 

local land managers and stakeholders.

II. Species “Viability” Language Is Inappropriate

The Plan incorrectly includes language that requires USFS to “maintain a viable population of each 

species of conservation concern” (RLMP p. 113). (Also see Vol 2 p.30 – “Species Viability –
42

Overview”). Nowhere in statute is this “viability” requirement mandated; wildlife management is, 

again, the responsibility of the states. 

In the case of bighorn sheep management (noted in detail in the grazing section), USFS has taken 

to the extreme the species-viability “mandate” that it has self imposed, threatening the domestic 

sheep industry due to its sole focus on preserving bighorn sheep. If this zero-tolerance “viability” 

policy were to be applied to other species, productive multiple uses such as logging, mining and 

grazing could potentially be curtailed altogether. 

The broad definition of “species of conservation concern” allows for an indefinite number of 

species to be considered “of concern” by USFS. The definition of “species of concern” (Vol 3, p. 

54) includes any species that has been petitioned for listing under the ESA. Any species, regardless 

of its actual population status, can be petitioned for listing; thus this category could be exceedingly 

large.

The 2008 Planning Rule (while not adopted) correctly recognized that “NFMA does not mandate 

viability of species.” See 73 Fed. Reg. at 21472; see also id. at 21494. Rather, “species diversity 

appropriate to the area covered by a plan is NFMA’s goal.” Id. at 21472. These findings should be 

presented in the Plan. Further, the 2008 Planning Rule acknowledged that “viability would place an 

impractical burden on the [Forest Service].” Id. Maintaining species viability was determined to be 

a technical impossibility because the cause of decline of some species is outside the Forest 

Service’s control. Id.; see also id. at 21496. Further, maintaining species viability for all species 

was determined to be impractical because of the large number of species present on units of the 

NFS. Id. at 21472. The Forest Service determined that focus on viability diverted attention and 

resources away from an ecosystem approach to land management that, in the Forest Service’s view, 

“is the most efficient and effective way to manage for the broadest range of species with the limited 

resources available for the task.” Id. The viability provision is dangerous, ineffective, violates 

states’ rights, and should be removed from the Plan. 

III. “Protections” of “Species Of Concern” Are Misplaced, and Category Is Too 

Broad

The DEIS describes the “protections” USFS proposes for numerous categories of species beyond 

just ESA species. This is beyond USFS’ authority and creates a scenario where any species could 

be considered as “of concern.” Meanwhile, most of the “protections” proposed by USFS serve to 

restrict other uses, including management activities such as timber harvesting and livestock 

grazing. This not only harms our economy and detracts from our citizens’ social well-being, it 

threatens the 

The RLMP states as a desired condition: “The natural range of habitats for native and desired 

nonnative fish, wildlife, and native plant species, including threatened and endangered species, 

species identified as regional forester’s sensitive species, and focal species, is of adequate quality, 

distribution, and abundance to contribute to maintaining native and desired nonnative species 

diversity...Management activities improve the conservation status of species identified as being 

focal species or of local or regional conservation concern” (emphasis added) (RLMP p. 30). Not 

only are there too many categories of “species of concern,” but the for qualification in these 

categories is exceedingly low, as described below.

1. Focal Species Similar to Discredited “Management Indicator Species” Concept

The USFS’ use of “focal species” is inappropriate as it very closely resembles the discredited 

Management Indicator Species (MIS) concept. The theory of monitoring focal species to provide 

insight into the integrity of ecological systems and the status of other species has been discredited. 

The Forest Service has admitted that “[t]he theory of MIS has been discredited since the 1982 

rule.” See 76 Fed. Reg. at 8499 Supporting that admission, the Forest Service states:
43

[e]ssentially, monitoring the population trend of one species should not be extrapolated to form 

conclusions regarding the status and trends of other species. In addition, population trends for most 

species are extremely difficult to determine within the 15-year life of a plan, as it may take decades 

to establish accurate trend data, and data may be needed for a broader area than an individual 

national forest or grassland. Id. 

Because the theory of monitoring focal species has been discredited and does not provide reliable 

information on the integrity of ecological systems and the status of other species, the theory should 

not be employed as part of the Plan. Rather than concentrating on species populations, especially 

those of focal species, the Plan should concentrate on habitat diversity, which is more consistent 

with USFS’ requirement to provide for “diversity of plant and animal communities.” 16 U.S.C. § 

1604(g)(3)(B). 

Note the similarities of its definition to MIS definition: Focal species (Vol 3 p. 23): A group of 

species that serve as an umbrella function in terms of encompassing habitats needs for other 

species, are sensitive to the changes likely to occur in the area, or otherwise serve as an indicator of 

ecological sustainability (Lambeck et al. 1997, Noss et al. 2007 and Andelman et al. 2001). 

Management Indicator Species (Vol 3 p. 31): In the original forest plans, a species selected because 

its welfare is presumed to be an indicator or other species using the same habitat. A species whose 

condition can be used to assess the impacts of management actions on a particular area.

2. “Sensitive Species” Category Is Overly Broad

Throughout the document, protections for “sensitive species” are proposed. The category is far too 

broad and at the sole discretion of the regional forester, leaving too much room for arbitrary 

“listings” of species. The glossary (Vol 3 p. 51) defines “Sensitive species” as: “Plant or animal 

species identified by a regional forester for which population viability is a concern either: 1) 

because of significant current or predicted downwards trends in population numbers or density; or 

2) because of significant current or predicted downward trends in habitat capability that would 

reduce a species’ existing distribution. Those species that have appeared in the Federal Register as 

proposed for classification or are under consideration for official listing as endangered or 

threatened species, that are on an official state list, or that are recognized by the regional forest as 

needing special management to prevent placement on federal or state lists.”

Thus, a species could be listed as “sensitive” at the sole discretion of the regional forester based on 

subjective “predicted” trends in population or habitat. By this definition, any species could be 

listed. The “sensitive species” category should be eliminated, and the focus should instead be 

placed on fostering resilient habitats.

3. Threatened and Endangered Species Protected by ESA Consultation

The DEIS focuses considerable attention on treatment of ESA species and is overly 

prescriptive for a programmatic document. The DEIS should instead include broad statements that 

projects within the planning area will comply with ESA requirements. ESA Section 7 consultation 

is required for every federal action; therefore every project within the planning area will necessarily 

be analyzed for ESA compliance.

IV. Wildlife Corridors Inappropriate

The inclusion of “wildlife corridors” exemplifies the DEIS’ implication that multiple uses by 

humans are in conflict with the preservation of wildlife habitat. The DEIS states “Areas where 

most types of active management are generally not suitable will provide varying amounts of 

wildlife habitat connectivity” (Vol. 1 p. 15). We can assure you that lack of active management 

does not necessarily coincide with wildlife habitat. Quite the opposite, in fact: wildlife are 

abundant on our private and state forests that are well-managed. Our county’s long heritage of 
44

hunting and fishing, logging, mining and grazing alongside wildlife is indication enough that 

“wildlife corridors” are unnecessary. 

The Forest Service states their desire for management strategies to increase the adaptive capacity of 

terrestrial ecosystems in the face of climate change. Enhancing landscape connectivity is one 

method that is mentioned. The document states that by closing roads in the corridors, the adaptive 

capacity of terrestrial ecosystems will be enhanced. Animals currently move from one part of the 

North Fork John Day Wilderness to the next without problems. There is no justification for the 

corridors to connect the two parts of the wilderness. In fact, court cases since the Wilderness Act 

was passed have decided, without exception, that there can be no buffers around the wilderness 

areas.

V. Management Restrictions Will Harm Species and Multiple Uses

1. Effects of Reducing Logging

Reducing logging via the proposed standards and guidelines below will only worsen the wildfire 

threat to wildlife and reduce forage opportunities due to canopy cover and overcrowding. 

2. Effects of Reducing Grazing

Ranching on both public and private land “has been found to support biodiversity that is of 

conservation concern” (Knight, 2007). In the West, where productive, private lands are 

interspersed with large areas of arid, less desirable public lands, biodiversity of species depends 

greatly on ranchland. According to Rick Knight, a biology professor at Colorado State University, 

ranching on both public and private land “has been found to support biodiversity that is of 

conservation concern” because it “encompasses large amounts of land with low human densities, 

and because it alters native vegetation in modest ways.” 12 Knight also noted that other uses – such 

as outdoor recreation and residential use – are not as conducive to the support of threatened or 

endangered species. Areas with flourishing and diverse plant and wildlife populations are often 

found in their present state because of, and not despite, the practice of grazing (NRCS, 2004). Wild 

birds, animals and rodents seek out and thrive in the shelter provided by natural ranch features, like 

diverse plant cover and windbreaks, as opposed to row-to-row crops or bare landscapes. Large 

animals such as elk and deer are known to thrive in areas where cattle graze.13 Grazing improves 

wildlife habitat by increasing the quality and accessibility of grasses and forbs (Neel 1980, Derner 

et al.1994, Evans 1996). See more benefits of grazing in the “Grazing Concerns” section of these 

comments. 

VII. Monitoring Timeframe Is Unrealistic

Page 113 of the RLMP (Table 29, 3) states “Status of select set of the ecological conditions 

required under §219.9 to contribute to the recovery of federally listed threatened and endangered 

species, conserve proposed and candidate species, and maintain a viable population of each species 

of conservation concern.” The “Proposed Monitoring Question” is, “What is the condition and 

trend in habitats for aquatic focal species (steelhead, spring Chinook salmon, bull trout, and 

redband trout)?” The timeframes given are Annual, 5 year.

Comment: These timelines are inappropriate. Monitoring protocols need to be understood by the 

authors. Trend cannot be determined on an annual or even 5-year basis. 

 12 “Ranchers as a Keystone Species in a West that Works.” Richard L. Knight. Rangelands Oct. 2007. 13 Texas A&M University-Kingsville (2005). Cattle Management to Enhance Wildlife Habitat in South Texas. Wildlife 

Management Bulletin of the Caesar Kleberg Wildlife Research Institute, Management Bulletin No. 6, 2005.
45

Access Concerns

Importance of Access to Baker County

All roads in the forest were built for a purpose and those purposes still exist. The roads represent a 

very significant investment as well as a necessary route for commerce. Roads also serve as a 

necessary firebreak and a means for rapid response to fires before they become conflagrations. 

Roads are crucial to the health and safety of our citizens. The roads provide much needed access 

for mining and private land forest management interests such as water and grazing rights and 

access to lands that have ties to public lands.

The forest lands must be managed with timber and thinning activities and the only way this can be 

done is with the use of our current (and possibly enhanced) roads systems. These roads give us the 

opportunity for jobs in Baker County. Keeping access open for the timber, mining and grazing 

industries will keep our towns and county economically sound for generations to come.

Additionally, our County’s landscape is a recreational haven for residents and visitors alike. 

Families who live in Baker County, often times for generations, perceive recreation as a “right to 

enjoy” the surroundings of home. In a nutshell, “it’s why we live here.” Recreation is also the a 

critical economic drawing point for the County, attracting visitors who come to view wildlife, fish, 

hunt, ski, snowmobile, hike, camp and generally enjoy the beauty of Baker County. Tourism is one 

of the largest economic drivers in Baker County- in fact, only agriculture generates more dollars 

for this County. Direct travel spending is estimated to be over $45 million per year, per Dean 

Runyan Associates for 2006. Tourism accounts for approximately 630 jobs throughout the County. 

For these reasons, the road system needs to remain intact. If an environmental reason exists for 

modifying a road, local input needs to be obtained and a mutually beneficial solution coordinated. 

County’s Access Requirements

Road closures on and affecting access to public lands in Baker County require an appropriate 

County and public review processes, noticing, appeal periods, and a genuine good faith effort to 

incorporate the suggestions and concerns put forth by the public. In order to protect Baker County 

citizens’ rights and recreational interests and access to and on public lands, road closure proposals 

on public lands within Baker County, as well as the creation of Wilderness or Wilderness Study 

Areas that would be managed as wilderness areas, National Monuments, “Wild and Scenic”, or any 

other labels that would no longer allow unrestricted use of public lands within Baker County, shall 

be coordinated with Baker County and the provisions and goals set forth in this Natural Resources 

Plan. 

We have a goal of minimizing actions that diminish the quantity or quality of outdoor recreational 

experiences available to visitors. Enhancing trail systems for OHV use is part of that goal. Also, 

ensuring adequate access for those with limited mobility is important, as these individuals 

constitute a large segment of both the tourist and local populations in Baker County. 

USFS Has Misled Baker County Residents

Baker County residents have been told at every meeting that the EIS does not close roads. Page 63 

states, “While the Forest Plan would not change designations of roads and trails for motor vehicle 

use, it would provide direction for future planning”. Page 63 states, “The number of acres suitable 

for motor vehicle use and the desired future condition for road density is those areas will influence 

the future transportation system”. Page 63 states, “An area determined to be unsuitable for motor 

vehicle use is expected to have no future road or motor vehicle trail construction”.

This need not be the case. Page v11” states that the “Desired conditions are broad and may only be 

achievable over long periods of time”. Baker County agrees with this approach. We believe that 

with proper Forest management, coordinated with Baker County and the County Resource 
46

Management Plan, access and recreation opportunities can be improved, access for the citizens can 

be maintained and rural communities can survive and even grow. 

DEIS Downplays Socio-Economic Importance of Access

In Volume 1 Introduction, the document begins by stating the intent of the EIS. Last on the scale of 

importance, is recognizing the interdependency of social and economic components. The Forest 

Plan should protect our custom and culture, which is strongly based in access and use of the 

National Forests, in the same manner it protects the environment. Access and recreation on 

National Forest system lands is critically important to the citizens of Baker County and the 

surrounding areas. Activities such as camping, hunting, fishing, wood cutting, gathering of 

mushrooms and berries are not possible without roaded access. 

Page 181 Goal 1: Promote Ecological Integrity “This goal and the desired conditions are 

interrelated with the social and economic components of sustainability”. Designating areas 

unsuitable for access, since this will greatly diminish the economic component of sustainability of 

the recreation activities within the National Forest. The “good will” the Forest is striving for will 

not happen.

Goal 2 talks about “....natural resources related work, including ... recreation”. Most of the 

recreational activities that take place on the National Forest involve the local citizens. It is mostly 

during hunting season that people come to the forest from other areas. Our citizens are not 

wealthy, they do not vacation in the Bahamas, rather they use the national forests. Page 85 states, 

there is a “potential for FS actions to disproportionately affect minority and low-income 

populations (Executive Order 12898)”. Closing roaded access to the National Forest will cause this 

effect. Motorized access is vital to the use of the forests.

DEIS Proposes Actions That Require Site-Specific Analysis

Because the USFS strongly suggests in several places throughout the Proposed Plan and DEIS that 

it intends to take certain action under the Plan, it should include additional site-specific evaluations 

of the environmental impacts of these plans or move those actions.

For example, one of the objectives listed in the Proposed Plan would require that “[w]here open 

motor vehicle route density exceeds desired conditions, implement route closures and/or 

decommissioning or consider designating routes for other uses.” Proposed Plan at 107. The Forest 

Plan also establishes as one of its guidelines (OF-2) that “[n]ew motor vehicle routes should not be 

constructed within old forest stands.” Proposed Plan at 129. 

Statements in the DEIS often include a great deal of specificity regarding what actions would be 

undertaken by the USFS if the Proposed Plan is implemented. For example, implementation of 

Alternative E would involve “replacing undersized culverts, out-sloping roads, hardening surfaces 

to reduce erosion, occasionally relocating or decommissioning roads to address the roads with a 

focus on watersheds with threatened and/or endangered aquatic fish species.” DEIS Vol. 1 at 37.

Additionally, the USFS states that, with the exception of the no-action alternative, “[a]ll 

alternatives . . . propose management direction that would result in the closure or decommissioning 

of open motor vehicle routes in order to meet desired conditions.” Id. at 80. 

The Proposed Plan goes too far in its plans to close roads within the Blue Mountains Forest. It 

should do no more than lay out the desired conditions and identify issues of concern and a number 

of possible ways to mitigate those concerns. 

“Preferred” Alternative Limits Access

Baker County is opposed to Alternative E management areas featuring backcountry non-motorized 

(228,100 acres) and additional motorized (425,200 acres) and connective wildlife corridors 

(28,100), along with additional wilderness proposals. 
47

Volume 1 Chapter I, on page 8, states that one of the Decision Criteria is “Minimizing conflicts 

between revised forest plans and travel management decision and contributing to economic and 

social needs of people, cultures and communities”. However, it does not appear that the EIS 

accomplishes this. Page 10, under Issues-Access states, “It will provide direction for future 

planning or motor vehicle routes and areas. The forest plan designates areas where the dominant 

uses are non-motorized”. Baker County reminds the Forest Service that wilderness areas, such as 

Monument Rock, are rarely used. More non-motorized areas are not needed.

Page iii Issue 6, states, “Public concern is heightened because the management to approach 

ecological resilience will determine the ecosystem services the Blue Mountains national forests 

provide”. The public in Baker County really is concerned. The “management to approach 

ecological resilience” we see in the Blue Mountain Revision means a blueprint for a future Forest 

with less access, more wilderness, more wildlife corridors and non-motorized areas, wider 

“riparian” buffers on ephemeral streams. 

Wildlife Corridors Are Restrictive and Unnecessary

Page 15 under Wildlife Habitat Connectivity, states, “Alternatives E and F also have minor 

acreages identified for management connections of wildlife habitat”. Baker County does not 

consider 28,100 acres as a “minor acreage”. Page 222 MA3C (wildlife corridors) states that both 

summer and winter vehicle use is restricted to designated routes. Baker County does not agree that 

these corridors are necessary. Page 305 states, “the population of Rocky Mountain elk is expected to 

remain stable during the life of the plan for any of the alternatives”. Elk are an indicator species. 

With or without corridors, wildlife will be unaffected. 

On page 37, the document also talks about the corridors. Under Issues: Alternative E “designates a 

small amount of wildlife corridor (MA 3C) linking high quality unroaded wildlife habitats which 

would allow the “suitable use” of motor vehicle use in summer and winter on designated routes”. 

The document does not define “suitable use”, which is a concern. The corridor between the two 

portions of the North Fork John Day Wilderness is not necessary. The roads in this area are used by 

miners, local residents looking for wood or recreating on the forest. Animals can move from one 

portion of the existing wilderness to the other, without giving them their own corridor. This 

corridor idea is without merit. The animals have riparian areas for use as movement corridors. Page 

231 Chart shows 362,500 acres locked up in the riparian stream buffers. Page 12 states, “riparian 

and aquatic habitat conditions are currently trending upward at the scale of the plan area 

following 15 plus-years of management under the 1990 Forest Plan”.

Volume 1 Chapter 3 on page 59 begins an extensive discussion of roads and access. The EIS 

indicates that the Forest Service wants management strategies that will increase the adaptive 

capacity of terrestrial ecosystems in the face of climate change. Enhancing landscape connectivity 

is one method that is mentioned. The document states that by closing roads in the corridors, the 

adaptive capacity of terrestrial ecosystems will be enhanced. Restricting access to 1 mile of road 

per section, is proposed for these areas. The corridors are not needed by wildlife, and corridors 

represent just one more buffer around the wilderness, which court cases have consistently affirmed 

is not legal under the Wilderness Act. Alternative E management areas feature, in addition to 

connective wildlife corridors, backcountry non-motorized (228,100 acres) additional motorized 

(425,200 acres) and additional wilderness proposals.

RS2477 Roads

Baker County is asserting the County’s right to roads granted to the counties under RS2477. Page 

15 under RS2477 states, “This includes rights of way under RS2477 that have been adjudicated 

through the Federal Court system or otherwise formally established”. The EIS states that the only 

means of obtaining the existence is through a judgment under Quiet Title, however the law does 
48

not require this action. Once the County asserts its right to a road under RS2477, no further action 

is needed, unless the Forest Service wishes to pursue other actions.

Hydrologically Connected Roads

Volume 1 Chapter 2 on page 36, under Alternative E, states that the desired condition is to reduce 

hydrologic connectivity as opposed to using road density, so that roads contributing the most 

sediment to the aquatic and riparian system will be addressed, (focusing on ESA streams). At first 

look, this approach appears to have merit. However, further in the document it is disclosed that the 

term “hydrologically connected” means road segments within 300 feet of a waterway. “Research 

has shown that effective vegetated filter strips need to be at least 200 to 300 feet wide to effectively 

capture sediment mobilized by overland flow from outside the riparian management area”.

(Rieman et al, 2001) This study took into account geology and slope, which is not discussed in the 

EIS. 

There is nothing magic about 300 feet; Page 264 states, “Effects of roads to watersheds function 

can be reduced by considering location, design, and management to disperse road runoff (Furniss 

et al 1991). Also, page 264 states, “Haupt and Kidd (1995) suggested that 30-foot wide riparian 

buffers were sufficient to prevent road related sediment delivery to streams”. In contrast Ketcheson 

and Megahan (1996) suggested that 330 feet buffers may be insufficient to prevent sediment 

delivery to streams depending on the geology (extreme cases such as steep slopes, soil composition 

and lack of vegetation). 

The answer lies in between these two studies. Determination of where roads are hydrologically 

connected should be made on a case by case basis, instead of what is described on page 264, 

“Riparian roads, as used in this analysis, are approximated by miles of road within 300 feet of any 

stream channel”. Page 264 clearly states that sediment input into water ways is dependent upon 

topography and the natural conditions of the site. Rarely, if ever, would a road 200-300 feet from a 

waterway cause adverse impacts on water quality.

“Any stream channel”, means even an ephemeral channel. Page 306 Roads, states, “There are 

10,600 miles of existing roads and an average road density of 3.2 miles per sq mile An estimated 

4,226 miles of hydrologically connected roads occur”, and these will be proposed for closing 

under the EIS.. Page 8 states, “The FS has a long history of science-based decision making”. The 

300 foot criteria for hydrologically connected roads is not based on science.

Page 314 states, “Road decommissioning would have a similar positive effect ...with two main 

differences (1) existing studies appear to consistently show that a high % of road-related sediment 

is produced by a relatively small % of the road network... and it has been shown that road 

decommissioning will not have as much influence on improving watershed condition as would 

focusing on the roads that have the greatest effect”. Page 315 states, “Road decommissioning is 

more expensive, per mile, than treating hydrologically connected roads, with a cost factor that may 

be as high as 10 or more, making it likely that an emphasis on road decommissioning would result 

in a slower rate of improvement”. Again, Alternative E should not take a blanket approach to close 

all roads within 300 feet of waterways. Instead, roads should be evaluated on a site specific basis 

and those roads causing problems should be treated so they no longer are a risk to water quality.

Page 37 states that open road density would change from a standard/guideline to a desired 

condition, which is good, because the document states that desired future conditions will be 

achieved over the long term. However, the document is confusing, in that on page 36, Volume I 

Chapter 1, the document states that instead of using road density, the Forest Service will use 

hydrological connectivity to decide which roads to close in general habitat. Page 37 states, 

“Alternative E takes a different approach by moving away from road densities in general forest 

(MA4A) and instead focusing on the roads that are causing the biggest problems”. The problem is, 

the Forest Service is proposing under Alternative E to not only close all the roads within 300 feet 
49

of waterways, but will also close good rocked high and dry roads to reach specified road densities 

in specific areas. Page 243 “Approximately 80 percent of road-related sediment is coming form 

approximately 20 percent of the roads”. It is clearly evident that only a small percentage of roads 

cause most of the damage. Improving these few roads will solve the problem of road related 

sediment into into waterway, without closing hundreds of miles of road. 

Road Density Should Be Flexible

Page 80 states, “Proposed open route densities for all alternatives are meant to be an upper limit. 

It is not the intent to increase open road densities to that upper limit...rather in area that currently 

have open road densities above the level proposed by desired conditions, it is expected that open 

routes would be closed..” Baker County recommends flexibility here. Areas with higher than 

desired road densities located adjacent to areas such as wilderness or roaded back country, should 

be cut some slack. Wildlife can use the areas adjacent to the areas with higher road densities if they 

are looking for solitude. 

County Opposes Backcountry Designation

Baker County is opposed to the designation of non-motorized backcountry. Page 198 states, “Nonwilderness uses adjacent to wilderness may have a negative effect on the quality of wilderness 

recreation experience”, and the Forest Service intends to restrict uses adjacent to the Wilderness 

that might impact a person’s “wilderness experience”. Court cases over the years have determined 

that the Forest Service may not establish buffers around the wilderness areas, however, that is 

exactly what they are trying to do. 

This is nothing more than designating wilderness without going to Congress. These nonmotorized 

backcountry areas are more buffers around the existing wildernesses, and this is not legal. Nonmotorized back country should be eliminated from Alternative E. 

On page 3, the document states that “Both summer and winter vehicle use would be considered 

unsuitable in non-motorize areas (MA3B”). While Baker County does not agree that any 

nonmotorized backcountry is needed, this explanation in the document is flawed. The text should 

read 3A, not 3B.

Page 37 states that open road density in MA 3C (motorized backcountry) would be no greater than 

1 mile/section. The Forest Service knows this is an impossible desired condition. It takes more than 

a mile of road to cross one section, due to topography. The existing motorized backcountry areas 

should not have further road closures. Page 221 describes MA3A (backcountry motorized) access 

stating it “may be restricted seasonally, by route designation or by area restrictions”. This is a 

change from the 1990 Forest Plan where there were no restrictions on road use in back country. 

There are opportunities for recreation, wood cutting and resource development in these areas, but if 

there can only be one mile of road, it will be difficult, if not impossible to do much of anything.

Page75 discusses that “cross-country motor vehicle travel is unsuitable in any area in any 

alternative” (this should read any action alternative). Also, this is not consistent with page 81, 

Alternative E which designates one existing off-road vehicle area as open to cross country 

motorized travel. 

Elk Habitat Does Not Require Low Road Density

Page 37 states that open road density would be no greater than 1.5 miles/section in winter elk 

habitat. Baker County is opposed to this low density, because it simply is not needed. Winter elk 

habitat is snowed in during the winter months when elk are vulnerable, and vehicles do not bother 

them. The other part of this equation, is that the elk do not even use a lot of designated habitat. 

They come down to the haystacks or winter at the elk feeding stations along the Elkhorns (their 

populations are flourishing, it should be added). Each time the Blue Mountain Plan is revised, more 
50

areas are designated as closed to motorized vehicles. Baker County envisions that next go-round, 

elk winter range will be designated as some sort of non-motorized area. 

Road Decommissioning More Expensive than Maintenance

Page 48 Alternative A indicates 444 miles of road are currently maintained. Under Alternative E, 

only 359 miles of road will be maintained due to budget shortfalls projected to be about $200,000. 

Page 63 “cost of maintaining the transportation system and the desire to reduce motor vehicle route 

density (and therefore access). Page 68 states, “The cost of road maintenance and the budget trend 

make it likely that future road closures will be necessary”. Page 80 states, “If maintenance funding 

decreases, roads determined to be unsafe and of low priority for maintenance would likely have to 

be closed”. Baker County wonders where the money would come from to close all these roads if 

budgets were cut. It would appear that the money might be better spent maintaining roads for the 

public to use. Page 276 states, “Alternative E includes desired conditions for road density in 

watersheds with anadromous fish and bull trout”. This is nonsense. As long as roads are not 

adversely affecting water quality, the number of road in a watershed is irrelevant. 

Closing Roads Will Increase Impacts on Remaining Roads

Page 68 states, “Much of the deferred maintenance will fall on maintenance level 1 and 2 roads, 

which represent 93% of the road network”...Wildlife soil water quality and spread of noxious 

weeds are negatively affected by the degree and public use of the transportation system”. Page 263 

states, “erosion has been found to increase with the amount of traffic (Reid and Dunne 1984. These 

are very interesting statements in the EIS. The complaint is that a lot of traffic on a few roads is bad 

for the environment, however, the entire EIS is focused on closing roads, which forces everyone to 

travel on the same few roads. This really makes little sense.

Reclassifying Roads to Justify Unnecessary Closure

Page 73 states, “It is assumed that open motor vehicle route density desired conditions would be 

met by reclassifying maintenance level 2 roads to maintenance level 1 (custodial care) roads 

through individual project planning”. This is a very sneaky approach. By reclassifying good rocked 

roads as maintenance level 1, these roads are closed by definition. Page 67 states, “It is important 

to understand that some roads require annual maintenance while other roads, due to stability of 

the roadbed, are rarely maintained”. Reclassifying and closing perfectly good roads that are used 

by the public is not the answer. There is no science behind this strategy and it hurts the people of 

Baker County.

Additional Trail Systems Needed

Page 65 states, “The Blue Mountain national forests trail system has remained relatively the same 

for the past 20 years” . Page 66 states that currently, “There are relatively limited opportunities 

for motor vehicle use on system trails”. It seems that there is a need for additional trail systems and 

this direction should be a part of Alternative E.

Winter Travel Excessively Regulated 

Page 78 states, “There would be no desired conditions standards or guidelines for over the snow 

travel. This will be determined by site specific project decisions”. However, the EIS does have 

direction for winter recreation. Page 259 WLD-HAB-13 G16 “Motor vehicle use within elk winter 

range should not be authorized or allowed between Dec1 and April 30”. Page 202 Alternative E: 

Wildlife corridors (MA3C) will have all cross country snowmobile traffic prohibited. Page 199 

Recreation states, “Winter recreation, such as cross country skiing and snowmobiling, can stress 

wintering animals during deep snow periods....” Page 199 states, “Over the snow trails provide 

some animals with access to areas they usually cannot use during the winter..”
51

Page 391 “winter recreation has significant tourism effects for the communities of the Blue 

Mountains”. Page 391states, “Snowmobiling is a controversial topic. with parties interested in 

maintaining or expanding snowmobiling, and other parties seeking to restrict or eliminate it”. In 

Baker County, snowmobiling is not controversial at all. The winters are long here, and 

snowmobiling is a fun and exciting winter activity. Areas such as Anthony Lakes provide sledding 

and skiing opportunities, leaving the trails available for snowmobiles. The Poker Runs bring in 

much needed revenue to businesses during the slow winter months.

BLM Roads Discussion Irrelevant

Under cumulative effects, on page 81, the EIS talks about the “cumulative effect of reduced motor 

vehicle access on Bureau of Land Management lands..” This is untrue. Most roads on public land 

were constructed before 1976, when FLMPA repealed RS2477. These are county roads and will 

not be closed. BLM has not produced a TMP restricting travel that Baker County is aware of.

Mining Rights Must Be Protected

Volume 2 Chapter 3 page 198 Road and Trails states, “No new road construction is anticipated for 

any of the alternatives. Mining access would be the exception, and this should be stated.

Conclusion

In conclusion, it is evident that as is stated on page 80, “Implementation of all alternatives, would 

affect access over time. In every alternative, open motor vehicle route density would exceed desired 

conditions, which makes it likely that site-specific project level decisions would result in road 

closure or decommissioning as the FS attempts to achieve or move toward the desired condition”.

Page 180, under Goals and Desired Conditions states, “The goals and desired conditions for the 

action alternatives were developed collaboratively”. Baker County cannot help but wonder who 

collaborated with the Forest Service on designating areas unsuitable for motorized travel. It 

certainly was the not the citizens of Baker County. 

The blueprint for future access, revealed with the Blue Mountain Revision, is clear. Page 69, states 

there are currently 1,315,750 acres (75% of the Forest) which is suitable for motor vehicle use. 

Over the long term, the plan is to see all roads within 300 feet of streams closed, all high and dry 

roads that exceed the desired densities closed, leaving a few roads open for access, with accelerated 

resource impacts by funneling all vehicles onto a few roads. 

Page 32 describes multiple use management as, “The management philosophy articulated by the 

Multiple-Use Sustained Yield Act of 1960. This law provides that the renewable resources of the 

national forests are to be managed in the combination that best meets the needs of the American 

people. It further stipulates that the FS is to make judicious use of the land for some or all of these 

resources and related services over areas large enough to ensure that sufficient latitude exists to 

subsequently adjust management in conformity with changing needs and conditions”. Page 81 

states that “people are a part of the ecosystem and are essential to the vitality and resiliency of the 

ecosystem. They are the stewards, producers, distributors and users whose actions and activities 

shape Forest Service policy and management”. 

If this is true, then Baker County proposes that Alternative E be modified to accommodate the 

people who use the National Forests. Let our citizens’ needs shape Forest Service policy and 

management. Let there be a balance between protection of the resources and the needs of the 

people. Page 387 states, “Where motor vehicle use is deemed suitable, it is because that recreation 

activity does not interfere with the purpose for which the area was designated”. Thus, designations 

of new wilderness, non-motorized back country, and wildlife corridors should not be included in 

Alternative E. If not designated, then these areas will again be deemed suitable for motorized 

access.
52

Timber Concerns

Importance of Timber to County

Agriculture and forest production are the predominant land uses in Baker County. According to 

Baker County Assessor’s records, there are approximately 146,386 irrigated acres and 1,129,662 

non-irrigated acres that are, or could be, used for agricultural production. Of those acres, 377 

irrigated acres and 399,097 non-irrigated acres are on public land.14 There are an additional 

673,681 acres of timber, 628,681 acres of which are on public land. 

Forest products have historically been a mainstay of Baker County’s economy, and they continue 

to play an important but changing role. The value of timber sales in the County fluctuates from 

year to year with the market, and the role that forest products play and the type of forest products 

sold have changed over the past 25 years in Baker County, as is the case across the Pacific 

Northwest. Between 1986-2008, timber harvest peaked at a high of 97,197,000 board feet in 1988, 

and had a low of 11,726,000 board feet in 2007. Baker County is similar to the statewide trend, 

where the majority of timber harvested is now coming from private land, whereas in the past the 

vast majority used to be from public land. The change is shown in the difference between peak 

harvest at 83,803,000 board feet in 1987, and the smallest harvest in 2005 of 213,600 board feet. 

As the railroad made transport possible, Baker County’s first sawmill opened in 1889. As major 

changes swept the industry, Baker County’s last lumber mill closed in 1996, but there are still 

several wood products mills in operation. 

County’s Timber Management Requirements

Sound science and common sense support the premise of active forest management on the public 

forested lands in Baker County. Forest management practices on public land shall include a stable 

timber-harvesting program which is essential to maintain healthy forest ecosystems and to provide 

employment and economic security to individuals and businesses in Baker County. Investment in 

equipment and technology cannot be made without a stable program.

A management policy of no action or arms-length management is unacceptable, irresponsible, and 

potentially disastrous. What is needed is a cooperative, hands-on, proactive approach to forest 

management that uses timber harvesting as a tool to accomplish overall forest health and to ensure 

a healthy and vibrant forest for current and future generations. 

Forest management shall follow the mandates of the 1897 Organic Act and adhere to the MultipleUse/Sustained Yield Act of 1960 as well as the later acts: National Forest Management Act; 

National Environmental Policy Act; and the Endangered Species Act. 

The BC Natural Resource Plan requires that Federal non-wilderness timberlands be managed for 

sustained timber production to promote forest health and to protect and maintain sustained 

economic returns. It also requires coordination with Baker County so that, when forest-fire and 

pest-caused tree stand mortality occurs, trees may be harvested before additional loss of economic 

value occurs. 

Status of Timber’s Economic Contributions

Timber harvest is very important to the residents of Baker County and to the economy of this area. 

Page 17 of the glossary defines economic well being as “A condition that enables people to work, 

provide income for their families, and generates economic wealth to local communities, the region 

and the nation”. Because of USFS’ treatment of forest management, such is not the case now. The 

 
53

Forest Plan should protect our custom and culture and our livelihoods in the same manner it claims 

to “protect” the environment.

USFS does not recognize its role in the diminished socio-economic health of our County due to 

severe reductions in timber harvesting and resulting mill closures, and other social and economic 

losses. We agree with the DEIS’ statement that “With historically high unemployment rates and 

many small communities poorly positioned to attract new industries providing family wage jobs, 

logging and wood processing jobs are essential to maintaining and improving social and economic 

conditions” (Vol 1 p. 5). We wish the DEIS reflected that reality by encouraging a real timber 

industry.

The DEIS downplays the effects that logging reductions have had on the County. Vol 1 p. 111 

states, “Many people in the timber industry are adapting their skills and infrastructure to support a 

restoration-based economy.” This is a misstatement. A few logging companies have bid on these 

stewardship projects, but it cannot be said that many people have done this. It is difficult to comply 

with all the requirements, and usually the projects are broken into small uneconomical units so 

everyone gets a little piece of the action. This is not a real job by any means. 

Volume 1, page ii, Issue 2, under the heading, Economic and Social state, “one concern is the issue 

of maintaining the infrastructure in local communities (e.g. mills, roads, equipment, and skilled 

labor force). For Baker County, this statement is a joke. All our mills have been closed, our Forest 

roads have been closed, clearly evident in areas such as Bald Angel and South Fork watershed, and 

our communities are struggling. 

Vol. Page ix, “Goal 2 states, National forests contribute to community resilience by providing jobs, 

ecosystem services, scenery, and recreational opportunities”. Goal 2 appears to be mere platitudes, 

these word sound good, but have nothing to do with reality. The town of Unity is a good example. 

This town is surrounded by National Forest system lands. There used to be a saw mill, a shake mill 

and a pole mill. Now there are no mills, and there are no timber sales. Today, there are no jobs on 

the National Forest. The Ranger Station has long been closed. Nowhere do we see in the Blue 

Mountain Revision a statement admitting this past mismanagement of the Forest. This is an 

important disclosure for this document.

According to Boise Cascade Company, none of the alternatives in the DEIS will fully meet the 

needs of the local communities. The preferred alternative will slightly increase the outputs of the 

local national forests, but it will not allow the local mills to function at capacity. Boise Cascade 

will still be importing wood from outside of our region in order to maintain their current capacity 

(where only their plywood mill is functioning at 100% capacity, and the others are functioning at 

73% and below). According to Boise Cascade, securing a sustainable supply of wood from the 

local forests that would actually meet their needs (about 100 million board feet from each forest) 

would allow them to add an additional 100-150 jobs to our mills in Umatilla and Union 

County. This is of importance to Baker County, as would be the logging and related jobs provided 

by increased timber production. Mills could reenter Baker County if our forests were properly 

managed.

Vol. I Page ix, Goal 2 talks about “....natural resources related work, including restoration, 

ranching and recreation”. The importance of the timber industry should be added. Timber 

production is not done for “restoration’s” sake alone.

Status of Timberland in Planning Area

Over-mature, overstocked, stagnant conifer forests cover much of the public land in the County. 

Within the WWNF are many stands of over-mature and stagnant trees that are stressed and subject 

to insects, disease and fire. Varying tree stands may have a different rotation age, stocking density, 

species diversity, access availability, or environmental and economic viability. However, all public 

lands provide products that may be suitable for harvest. 
54

The RLMP recognizes the overstocked nature of the forest: “Based on forest inventory and the 

forest vegetation simulator fire/fuels modeling, 40 to 60 percent of the dry upland forest now has 

the potential for high severity fire as a result of the abundance of multi-storied stands with high 

stocking levels.” (RLMP, p. 34). “Recent plan modeling of the potential mortality from 

disturbances from insects and disease indicates that approximately 30 percent of the forest stands in 

the Blue Mountains have the potential to have more than 25 percent of their total volume killed in 

the next 10 years.” (RLMP, p. 35)

All Alternatives Fail to Make Adequate Progress Toward Desired Conditions

None of the alternatives offers a sufficiently aggressive timber management program in order to 

meet desired conditions. Vol 2 Page 163 states, “None of the alternatives would achieve the desired 

conditions for stand densities at year 50. Under all of the alternatives, the percent of the landscape 

in open forest would remain above the desired condition range at year 50 due to mortality from 

wildfire, insects, and disease exceeding growth rates. With little active management occurring in 

the cold upland forest potential vegetation group under all of the alternatives which would alter 

structural stages, species composition, and stand densities mortality from insects, disease and 

wildfire would be expected to continue to result in stand-replacing events consistent with the 

historic disturbance regime.

Fails to Meet Productive Capacity Goals

(RLMP p. 32): “Gross growth was estimated to be 1.7 billion board feet per year. Mortality was 

estimated to be 774 million board feet per year. Net growth for eastern Oregon was estimated at 

791 million board feet of timber. High net growth rates can contribute to problems with 

overstocking and increased fire hazard. The current removal rate for timber volume in the Blue 

Mountains is far less than net growth.”

Comment: The Allowable Sale Quantity (ASQ) in alternative D (most aggressive presented) is 

236 million board feet per year (Page169 RLMP). That removal rate is less than 30% of the net 

growth per year. Again, the pace and scale of restoration is in reverse. Long-term sustained yield is 

not being approached (Page170 – RLMP). 

The ASQ presented for the preferred alternate (E) is less than 20% of the annual net growth. 

Increased pace and scale of restoration in reverse. Long-term sustained yield is not being 

approached (Page170 – RLMP) 

Fails to Meet Scenic Stability Goals

(RLMP p. 51): “Existing Condition: In many areas the long-term stability of scenery resources is 

at risk of large scale impacts due to conditions exacerbated by past wildfire suppression and harvest 

practices. The resultant conditions of homogenous, overly dense forests of nonfire-resistant species 

heavily laden with fuels put scenery resources at risk from uncharacteristically large, standreplacing wildfires and insects and disease disturbances.”

Comment: To reduce the risk of losing long-term stability of scenery resources, a much more 

aggressive approach is needed than is shown in these alternatives or documents.

Fails to Meet Fire Condition Class Goals

This is exemplified by each alternative’s projected failure to meet desired fire regime condition 

classes over time. The desired conditions are: for “landscapes that exhibit a moderate or high 

degree of departure (Condition Class II or III), the degree of departure is decreased to low or 

moderate (Condition Class I or II.) After 20 years, the best projected progress toward this desired 

condition is offered by Alternative D—and it only achieves 38 percent of the goal. Alternative E 

would make less than one-third of the progress desired, with all forests continuing as “moderately 

departed.” 
55

All forest lands should be managed similarly to wildland-urban interface lands: (RLMP p. 63): 

“Vegetation treatments within the wildland-urban interface areas are based on wildfire protection 

objectives, which may over-ride ecological desired conditions. Vegetative structure would result in 

fire intensity that allows for safe and effective suppression actions within wildland-urban interface 

areas. In general, vegetation density would be more open, with lighter fuel loadings, in comparison 

to areas outside wildland-urban interface. Fire risk within wildland- urban interface areas would be 

managed so as not to limit the ability to use fire for resource restoration in areas adjacent to 

wildland-urban interface areas.”

Alt. E’s Proposal to Use Prescribed Fire Will Be Unsuccessful

USFS states that Alt. E will have almost the same beneficial ecological effect as Alt. D--which 

proposes more acres of mechanically treated forests—due to the use of prescribed fire in Alt. E. 

Alt. E proposes to treat the same amount of acres as Alt. D, except half of those acres will be via 

prescribed fire instead of mechanical treatment. Currently, due to conditions, USFS has a surplus of 

acreage that is slated for prescribed fire treatment. Proposing to treat additional acres with 

prescribed fire will only exacerbate the backlog and lead to even less work getting done on the 

forest.

USFS Science is Outdated/Inaccurate 

The discussion of lack of large trees on the Forest has never been substantiated scientificially.

A quick assessment of References cited (Volume 3, pp 63-147), provides a metric for assessing 

how current and relevant the science cited is in the proposed revisions to the Forest Plan. Of the

approximately 1250 references cited only 17 were published in 2012 or 2013; 10% were published 

in the last five years; and 35% in the past 10 years. Nearly two-thirds of all citations are more than 

10 years old. A substantial number of the publications cited were not from peer-reviewed 

publications; many are to government documents. 

The science referenced appears to be outdated and does not provide the most current scholarly 

understanding and/or guidance to address the management needs in the Forest Plan. A specific 

example of the gap between current science is how the word “resilience” is used throughout the 

proposed revisions to the Forest Plan. 

Resilience is defined on page 13 (but is not included in the Glossary) as: 

“... the ability of a social or ecological system to absorb disturbances while retaining the same 

basic structure and ways of functioning, the capacity for self-organization, and the capacity to 

adapt to stress and change (FSM 2020 interim directive).” (Emphasis added) 

The Resilience Alliance (2010. Assessing resilience in social-ecological systems: Workbook for 

practitioners. Version 2.0) defines resilience as:

“The capacity of a system to absorb disturbances and reorganize while undergoing change so as to 

retain essentially the same function, structure, identity, and feedbacks.” 

The Alliance goes on to point out in the workbook that: 

“Natural resource management issues are not just ecological or social issues, but have multiple 

integrated elements. These systems, in which cultural, political, social, economic, ecological, 

technological, and other components interact, are referred to as social-ecological systems. Social–

ecological systems emphasize the ‘humans-in-nature’ perspective in which ecosystems are 

integrated with human society.”

The Goals of the Forest Plan that are cited in the Summary (p ix) address “... cultural, political, 

social, economic, ecological, technological, and other components [that] interact ...”. Thus, in 

current resilience-thinking, the Plan should view the Blue Mountain Forests as social-ecological 
56

systems, and provide adequate attention to the role societies across the Blue Mountains play in the 

management of these forests. Management without considering the whole integrated socialecological system will simply not achieve the resilience that is sought. 

To provide a means for examining the state of resilience within the social-ecological system, the 

IUCN Commission on Ecosystem Management Thematic Group on Resilience examines 11 

attributes that play a role in fostering resilience in complex systems such as Forests (Basic 

Resilience Assessment: A Practitioners Guideline For Learning About Resilience.... In prep). Of 

the 11 attributes, seven link resilience to the forest management alternatives that are described in 

the Proposed Revisions and provide a basis to monitor the state of resilience in the forests:

• Diversity – maintaining diversity across the social and ecological components of the 

system, e.g., institutional engagements, governance, business models as well as species, 

habitats, and spacial distributions.

• Ecological variability – fostering different ecologies within an area, such as grasslands 

within and around forested areas.

• Modularity – maintaining a system of firebreaks; a patchwork of timber stands at different 

stages of maturity.

• Tight Feedbacks – this is reflected in an ability to monitor and act on changes in 

ecosystem health in a timely manner.

• Social Capital – In the context of the Forest Plan Revision, acknowledging the important 

role the forest Collaboratives play in the Umatilla, Malheur and Wallowa-Whitman 

National Forests in developing and implementing site-specific management actions, and 

promoting Coordination Agreements with County governments will contribute to increased 

resilience.

• Innovation – The Plan should express willingness to try new management ideas, 

experiments in adaptive management; consider means for fostering local knowledge and 

locally developed rules to be used for system management as an alternative to centralized 

command and control management. To create blends of traditional and modern 

management practice. 

• System reserves – Setting aside “no harvest areas” provide sources of seeds for 

regeneration in managed areas and an ability to assess the impacts of different treatments 

on forest health/resilience. 

The eight papers that address resilience that are cited were published between 1973 and 2007. Four 

citations deal with the theory behind resilience in social-ecological systems and the practice of 

management for resilience; four report on resilience in the context of studies about Redband Trout. 

None address resilience in the context of forest management. 

Hindrances to Forest Management

“Unsuitable” Acres

USFS proposes to harvest less than 3% of acres “suitable” for timber production on all three forests 

(1.8% on WWNF.) Meanwhile, the plan states that “The potential for fires with uncharacteristically 

severe effects exist on approximately 60% of the three national forests.” Plan does not treat enough 

acres to increase forest resiliency to wildfire. Under the most aggressive alternative (D), 52% of the 

WWNF is vulnerable to catastrophic wildfire. 

Riparian Management Areas

Currently, riparian areas may be managed based on site-specific analysis. Logging may take place 

within 25 feet of streams. This DEIS offers no such flexibility. Furthermore, it proposes to 
57

drastically increase riparian zones by changing the buffer to 100 feet on seasonally flowing streams 

and small wetlands, whether or not the streams are fish bearing.

Legacy Trees/ Old Forest

On page iii-iv (Vol 1), for Alternatives D-F, the document states there will no longer be designated 

old forest management areas. This is a good thing. Timber management activities should take place 

in these areas. However, the document describes a “legacy tree” as a live tree over 21 inches—then 

states in guideline OF-1 (Vol 3 p. 279) that these will be protected. That puts us back where we 

started. The definition of a legacy tree should be changed to include only trees over 21 inches dbh 

that are healthy, produce cones and are without disease or dead top.

Page 12 (Vol 1), under Old Forest, states that the Forest Service shall determine how much old 

forest the Blue Mountains national forests should have in the future. The EIS needs to explain just 

how the Forest Service will do this. If stands of timber that are ready for harvest can be 

subjectively eliminated from a sale, this is not acceptable. This definition must be based on science 

and must be consistent throughout the forest. Determination of old forest should involve county 

coordination. 

Page 161 states, “Within the WAW 32% of all upland forest potential vegetation groups (cold 

moist and dry) are currently in old forest structural stages.” This is a huge percentage of our 

forests and would unnecessarily reduce timber harvests. Insects, disease, and fire will devastate 

these stands. 

Page 256 (Vol 3) WLD-HAB-2 G-2 states “The extent of existing late old structure stands within 

the moist and cold old forest types that are 300 acres or larger should not be reduced or 

fragmented”. Alternative E should include management of these timber stands.

Wildlife “Protections” 

Volume 2 p. 267 states that “Trees with nest cavities and large snags are also provided protection.” 

Other measures say after a fire, if you do log keep the snag classes. These restrictions are arbitrary, 

and could cause safety concerns for loggers. 

WLD-HAB-19 G 4 states, “Greater than 50% of post fire source habitat should be retained and 

should not be salvage logged, except in the urban interface”. This is a waste of timber. It will 

quickly rot and will fall, making the area unusable for wildlife. 

WLD-HAB-20 G 5 states there will be no logging in areas less than 100 acres after a fire. There is 

no basis for this decision. 

Threats to Access 

Logging cannot happen without roads. (See Access Concerns)

Recommendations

Recognizing the importance of local timber-related businesses in Baker County, we strongly 

support management alternatives that increase supplies of wood products that will be predictable 

and available on a steady basis. Baker County has lost all commercial-scale sawmill and logging 

infrastructure, as have most communities in Northeast Oregon. This loss has had a negative effect 

on the net values of the forest products to private timberland owners as well as government timber. 

We therefore feel that the number-one goal of the Forest Plan should be to ensure that the existing 

forest industry infrastructure be maintained at least at current levels and provide incentives to 

foster development of new forest-related industry. Any further degradation of the industry will 

have a negative effect on the ability of the National Forest and the private timberland owners to 

conduct forest management. 
58

Professional foresters in Baker County contend that when timberland owners lose value related to 

their forest lands, they lose interest in managing that land and in many occasions the best value of 

the land is to sell it into subdivided parcels. When this occurs we not only lose the ability to 

manage the forests but we also lose valuable wildlife habitat. Therefore, what happens on the 

national forest also affects the private forests.

from the areas to be managed, such as: proposed designated roadless areas, wilderness study areas, 

stream buffers, and wildlife corridors. As these designations effectively remove forest from 

management, they should be kept to a minimum and only designated with the County’s approval. 

Professionalism in forest management is not limited to employees of the US Forest Service. Nongovernment foresters are aware of the best science to manage our forests in a manner that improves 

forest resilience and health, while providing a sustained flow of commercial forest products. It is 

essential if private landowners are to maintain and sustain the benefits they derive from their 

resource. 

Mining Concerns

Importance of Mining to Baker County

Mining is an important resource in Baker County. According to the Northwest Mining Association, 

the State of Oregon is home to over 300 medium to large-scale mining operations. Approximately 

20 operations in Baker County are large enough that they are administered by the Oregon 

Department of Geology and Mineral Industries (DOGAMI). Currently, there are over 1,200 mining 

claims filed in Baker County on USFS and Bureau of Land Management (BLM) managed lands, 

and these claims are owned by both local and out of area miners. In addition, there are many 

patented mining properties and other lands that are mineral in character where small-scale mining 

takes place. 

Baker County is one of the most mineralized counties in Oregon. Mineral production has provided 

an important contribution to the economy of not only Baker County but also the State. All lands not 

lawfully withdrawn from mineral exploration and/or development must remain available for such 

use. The mining industry makes up an important part of the property tax base of Baker County and 

the payrolls and expenditures for equipment, materials and supplies are important to the economic 

stability of the county. Mining is one of the historical uses of the federally managed lands within 

Baker County and predates the establishment of the Forest Service and the Bureau of Land 

Management and maintenance of such use is statutorily compatible with multiple use principles. 

Ashgrove Cement is Baker County’s largest mining employer, employing 120 people. In addition, 

there are 10-20 medium scale mines, and an additional 20 large-scale mines, providing family 

wage jobs, and producing gold, rock, sand, gravel, building stone and perlite. Jobs in the Oregon 

mining industry are high paying- 21% higher than the average wage in the state. Mining creates 

new wealth, which expands when resources are processed and manufactured into useful products. 

Indirect jobs created by mining range between 3:1 and 6:1. In 2010, about 200 small-scale mines 

will be producing gold in Baker County. If each of the small mines only recovered 1⁄2 ounce of gold 

per day, that value of $100,000 per day would provide purchasing power for fuel, oil, tires, parts, 

equipment, labor and materials. The total business impact will be significant, if through 

coordination, Baker County is able to work with the USFS and BLM, and these agencies approve 

the 100 or more mining Plans of Operation that have been backlogged for so many years.

County’s Requirements for Minerals Management

It is the policy of Baker County, Oregon that all exploration, development and mining on lands in 

the county with mineral or energy potential shall be governed by scrupulous adherence to all laws 

which pertain to mining and energy development and production, beginning with the Congressional 

Act of July 26, 1866. 
59

We also require that the directions and policies of the Land Management Agencies do not interfere 

with citizens’ rights of access, property and occupation while prospecting and developing mineral 

and energy resources. The Congressional Act of July 26, 1866 and the General Mining Law of 

1872 granted all American Citizens the right to go into the public domain to prospect for and 

develop minerals located there. Every mining law or act enacted since then has contained a 

“savings clause” that guarantees that the originally granted rights have never been rescinded. We 

recognize that mineral development can occur concurrently or sequentially with other resources 

uses. We require that all project planning address the need for maintaining mineral and energy 

related access in mineralized areas. It is also our policy to encourage value-added mineral and 

energy industries. 

DEIS Threatens and/or Discounts Existing Rights

Lack of References to Mining Laws 

Vol 1, Page 16 lists applicable laws governing forest management. The General Mining Law and 

the National Minerals Policy Act are left out; they should be included.

Vol 2, Page 441 states, “A determination that resource values exceed the known mineral value 

could result in a recommendation to withdraw an area from mineral entry”. In order to meet the 

requirements of the Baker County NRP, no areas should be recommended for withdrawal without 

coordination with the County. Mineral extraction can and should take place alongside other 

multiple uses, thereby attaining the “resource values” mentioned above without excluding mining.

Failure to Recognize Legal Protections of Mining

Vol 1, Page 190 states, “Commercial use in wilderness is controlled by special use permits and the 

operation plans that are required under special use permits”. There is a need to add that mining can 

take place under plans of operation.

Vol. 1 Page 205 states, “Grazing would be allowed as a permitted activity. Mining would be 

allowed to continue unless the area is withdrawn from mineral activity”. This is not correct, valid 

existing rights will continue even after land withdrawal.

Vol 1, Page 209 states, “Prospecting for new claims within wilderness has largely ended.” This 

statement is incorrect. 

Access

Given the DEIS’ emphasis on road decommissioning, disallowing new roads, and not maintaining 

existing roads, we are concerned about the effects on mineral rights.

Vol 1 Page 240 states, “Little, if any, future road construction is likely for any of the alternatives. 

Alternatives B, C, E and F include objectives for decommissioning roads, although at low 

levels...No road construction on soils are expected for any of the alternatives.” The document 

should acknowledge valid existing rights and mining, which may require new roads.

Water Quality Inaccuracies 

Page 317 Vol 1 states that at Ashgrove, “mercury laden residue enters the river”. This statement 

should be removed. It is not true. 

Wildlife

The DEIS assumes mining will be incompatible with other uses, such as wildlife habitat. Vol 2, 

Page 199 states “Mining is not always compatible with wildlife”. Page 199 Some mining activities 

use or produce toxic material.” This ignores the benefits that mining can produce, such as keeping 

fish spawning habitat churned and soft. 

Socio-Economic Impacts Are Underestimated
60

Vol 1, Page 88 discusses economic and employment contributions of recreation, timber production, 

and forage production, but not mining. This is an oversight.

Vol 1, Page 107 indicates there is 1 mining job in the WWNF. We who live here know this is not 

correct.

Vol 1, page 94 states that “mineral production affects very few people and businesses.” This is 

incorrect. Not only are minerals crucial to every person in the country, but miners in Baker County 

spend money for fuel, food and other supplies to support their mining operations. Even for small 

mining operations, fuel bills are usually in the hundreds of dollars each month they are in the field. 

Ash Grove Cement is one of the major employers in Baker County, not to mention the aggregate 

industry. 

On table 54 page 107 of your proposed plan you indicate there is only 1 mining job. There are a lot 

of miners out there that would probably disagree with your narrow interpretation of mining. 

Vol 3 Page 236, locatable minerals are excluded from the “suitability” matrix. Why?

Vol 3, p. 252, where Goods and Services are addressed, locatable minerals should be added. The 

Objective should be to approve Plans of Operation within one year of submittal.

Grazing Concerns

Importance of Grazing in Baker County

Livestock production has customarily been and continues to be a significant contributor to the 

economic stability of Baker County. With over $40 million in annual sales, livestock production 

totals 63% of all agricultural sales in Baker County.

Livestock producers who graze on public land have been issued grazing permits based on 

ownership of private land. The ownership of private land involved in livestock production that is 

adjacent to public land gave that producer the right to obtain a grazing permit on those public 

lands. This right was defined in the Taylor Grazing Act of 1934. 

In Baker County, many livestock producers rely on these grazing permits through the U.S. Forest 

Service. 

In 2009, the Whitman Ranger District of the Wallowa Whitman National Forest had 51 designated 

cattle allotments that total 749,946 acres. The carrying capacity of these allotments equals 31,810 

AUMs (Animal Unit Months). The seasons of use vary on these allotments, but most extend from 

June 1-September 30, although some begin as early as April 15 and some end as late as October 

31.15 The preservation of these permits will continue to be an important factor in sustainable 

livestock production in Baker County.

Baker County Requirements for Grazing

We require preservation and protection of livestock production and practices, a significant part of 

our heritage and contributor to our economic base. We call for management on USFS land that uses 

livestock grazing to improve the range conditions for livestock and wildlife. We promote grazing 

as a primary tool to create healthy forests and to prevent the spread of wildfires. We require 

managing rangelands to maximize production. Noxious weeds will be controlled through grazing, 

herbicide applications and other measures on all lands in Baker County. Sagebrush and juniper 

control will be allowed and encouraged with herbicide applications, mechanical treatment or fire. 

Grazing decisions will be based on sound science as supported by proper monitoring, reporting and 

data analysis. Grazing decisions to conserve an endangered species will be made only if grazing 

 15 Range Management Specialist, Whitman District, Wallowa Whitman National Forest 11/17/2009
61

can be proven to be detrimental to the species on that allotment. Grazing decisions after a wildfire 

will be based on sound science on an individual allotment basis.

Grazing’s Treatment in DEIS

Throughout the DEIS, grazing is treated as an overall negative. Nothing could be farther from the 

truth. Language in the “Vision” portion (p. 16 of the RLMP) exemplifies the bias against grazing. It 

says grazing “the potential to impact the condition” of resources. It also mentions the perceived 

conflict between domestic and bighorn sheep. However, aside from grazing supporting “traditional 

lifestyles and local economies,” this section says nothing of the positive effects of grazing on the 

environment. Language should be added: “Livestock grazing is crucial to reducing the severity and 

frequency of unwanted wildfire. Well-managed grazing promotes healthy soils, root systems, 

forage growth, and wildlife diversity. It can and should be used as a tool to control invasive 

species, and to promote range health, generally.” 

Grazing’s Environmental Importance

We believe the research included in the document was one-sided. When conflicting scientific 

information exists, the agencies may only rely upon a particular scientific conclusion after having 

considered and addressed contrary conclusions. See Hughes River Watershed Conservancy v. 

Glickman, 81 F.3d 437 (4th Cir. 1996), appeal after remand, 165 F.3d 283 (4th Cir. 1999) 

(upholding an agency decision to rely on the conclusions of a scientific study after considering and 

responding to contrary findings of a similar study); Roanoke River Basin Ass'n v. Hudson, 940 F.2d 

58, 64 (4th Cir. 1991) (stating that an agency is required to address specific concerns and explain 

why it found them unpersuasive). 

The USFS does not explain its reasons for finding such contrary scientific opinions unpersuasive. 

Indeed, it did not even acknowledge that contrary opinions exist. Therefore, the USFS has not 

fully satisfied NEPA requirements concerning the environmental impacts of the Proposed Plan. 

Below are references to several studies that should have been considered. It is not a comprehensive 

literature review, but is meant to give examples of the one-sided nature of the studies USFS chose 

to include.

a. The western ecosystem evolved with large-herbivore grazing, and losing public lands 

grazing would severely damage ecological balance (Burkhardt, 1995).

b. Ranching on both public and private land “has been found to support biodiversity that 

is of conservation concern” (Knight, 2007). In the West, where productive, private 

lands are interspersed with large areas of arid, less desirable public lands, biodiversity 

of species depends greatly on ranchland. According to Rick Knight, a biology 

professor at Colorado State University, ranching on both public and private land “has 

been found to support biodiversity that is of conservation concern” because it

“encompasses large amounts of land with low human densities, and because it alters 

native vegetation in modest ways.” 16 Knight also noted that other uses – such as 

outdoor recreation and residential use – are not as conducive to the support of 

threatened or endangered species.

a. Vol 2 p 197 states, “Domestic livestock grazing directly competes with 

wildlife for the use of available forage. Grazing results in plant defoliation, 

mechanical changes to soil and plant material, and nutrient redistribution 

(Belsky and Blumenthal 1997). These and other factors also influence 

successional trends.”

b. This publication was refuted by Borman, MM 2005, Forest stand dynamics 

and livestock grazing in historical context. Conservation Biology. Belsky 

describes all the bad effects of grazing and ignores the changes in management 

 16 “Ranchers as a Keystone Species in a West that Works.” Richard L. Knight. Rangelands Oct. 2007.
62

over past 100 yrs. Borman describes that overgrazing a century ago did what 

Belsky reports, but those effects are not true in proper grazing of current times.

c. The document often refers to grazing as having negative effects on riparian areas. 

However, in another publication by Borman et. al., it was found that “grazing can often 

be compatible with improving deteriorated riparian conditions and with maintaining 

those functioning properly.” Borman, M.M., Massingill, C.R. and Elmore, E.W. 1999. 

Riparian area responses to changes in management. Rangelands, 21(3): 3-7.

d. Areas with flourishing and diverse plant and wildlife populations are often found in 

their present state because of, and not despite, the practice of grazing (NRCS, 2004). 

Wild birds, animals and rodents seek out and thrive in the shelter provided by natural 

ranch features, like diverse plant cover and windbreaks, as opposed to row-to-row 

crops or bare landscapes. Large animals such as elk and deer are known to thrive in 

areas where cattle graze.17

e. Grazing improves wildlife habitat by increasing the quality and accessibility of grasses 

and forbs (Neel 1980, Derner et al.1994, Evans 1996).

f. Grazing stimulates plant and root growth and allows sunlight to get through to the 

growth points. Hoof movements soften the hardened earth so that seeds can germinate 

and grow and water can penetrate (Savory, 2010). Well-managed grazing encourages 

healthy root systems and robust forage growth. 

g. For those concerned by carbon emissions, livestock grazing is a contributor to carbon 

sequestration: well-managed grazing’s impacts on soil and plant composition can 

create a “carbon sink” effect (Derner et al., 2002).

h. Improving range science and management practices are bettering the condition of the 

range (CAST, 1996). 

i. Ranchers are often first responders to wildfire, and grazing greatly reduces the risk of 

catastrophic wildfire (Davies, 2010). 

j. Grazing can be used to control invasive weeds (Olson and Lacey 1994, Walker et 

al.1994). Other research suggests that livestock grazing helps prevent invasion by nonnative grasses, which threaten plant biodiversity on the land.18 Ranchers’ brush control 

also benefits wildlife, helping more grass to take root and decreasing the spread of 

cheatgrass, a highly flammable invasive weed. A study in the Journal of Rangeland 

Management concluded that “from an ecological standpoint we can argue that if we 

remove the grazing infrastructure from public rangelands, we would see some adverse 

consequences. We’d see less variety and too much ground cover, for example, as well 

as more cheatgrass and the potential for more range fires.”19

k. Ranchers’ water improvements provide habitat where none existed before (Marty, 

2006). The improvements ranchers make to water sources – building, maintaining and 

protecting reservoirs and stock ponds, for example – can improve and, in some cases, 

create, wildlife habitats.20

l. Grazing makes productive use of a renewable, otherwise unusable resource—grasses 

and shrubs out on the range—turning them into a high quality source of protein and 

fiber for a growing population. This is particularly significant given the fact that 

thousands of acres of open space are lost in the United States each day (USDA Forest 

Service, 2006). 

 17 Texas A&M University-Kingsville (2005). Cattle Management to Enhance Wildlife Habitat in South Texas. Wildlife 

Management Bulletin of the Caesar Kleberg Wildlife Research Institute, Management Bulletin No. 6, 2005. 18 Ranching as a Conservation Strategy: Can Old Ranchers Save the New West? Mark W. Brunson and Lynn Huntsinger. 

Rangeland Ecology Management 61:127-147 March 2008. 19 “Vegetation Change after 65 Years of Grazing and Grazing Exclusion.” Barry Perryman. Journal of Rangeland 

Management Dec. 2004. 

20 http://cesantaclara.ucdavis.edu/files/33367.pdf
63

m. Losing grazing on public lands would likely force many privately-held ranch lands to 

be converted to other uses, such as intensive farming and development. Furthermore, 

as a stipulation of their federal permits, many ranchers provide public access across 

their private land, and keep the boundaries free of fences. A study by Mark W. 

Brunson and Lynn Huntsinger published in the journal Rangeland Ecology 

Management explained that “Saving ranches has become a focus not only of rural 

traditionalists and livestock producers but also of conservationists, who prefer ranching 

as a land use over exurban subdivisions.” 21 Page 157 of the DEIS acknowledges “The 

open space offered by National Forest System lands becomes increasingly important 

especially as private lands are developed for home sites. This is applicable to Baker 

County. P 331 Vol 2 also acknowledges: The pressure for development of this land 

into smaller and smaller parcels will continue to reduce the quality and availability of 

big game winter habitat. 

n. Many ranchers across the West are purposefully implementing grazing practices to 

improve habitat and help prevent the addition of species such as the Greater Sagegrouse (GSG) to the Endangered Species List. (According to the Natural Resources 

Conservation Service, ranchers have, among other efforts, invested approximately $70 

million in GSG conservation efforts and instituted improved grazing systems on over 2 

million acres over that past three years, which is expected to increase GSG populations 

by 8 to 10 percent.22) 

USFS Did Not Consider Economic Implications of Reducing AUMs 

The USFS has not sufficiently addressed the economic impacts of its Proposed Plan. Under the 

NFMA, The USFS is required to promulgate regulations “under the principles of the Multiple-Use 

Sustained-Yield Act of 1960, that set out the process for the development and revision of [] land 

management plans.” 16 USC § 1604(g). These regulations must include “specifying guidelines for 

land management plans . . . which insure consideration of the economic and environmental aspects 

of various systems of renewable resource management.” Id. at §1604(g)(3)(A).

USFS regulations developed pursuant to the NFMA require land management plans to account for 

“[s]ocial, cultural, and economic conditions relevant to the area influenced by the plan,” as well as 

the “[m]ultiple uses that contribute to local, regional, and national economies in a sustainable 

manner.” 36 C.F.R. § 219.8(b)(1), (3). The Proposed Plan does not truly account for economic 

and social impact to local communities it will affect.

The United State Supreme Court has emphasized that NEPA “[does] not require agencies to elevate 

environmental concerns over other appropriate considerations.” Baltimore Gas & Elec. Co. v. 

Natural Res. Def. Council, Inc., 462 U.S. 87, 97 (1983); See Stryckers' Bay Neighborhood Council 

v. Karlen, 444 U.S. 223, 227 (1980). Additionally, the Second Circuit has found that 

environmental considerations are not the only factors to be considered when conducting a NEPA 

analysis, stating that “the Act mandates no particular substantive outcomes.” City of New York v. 

U.S. Dep't of Transp., 715 F.2d 732, 748 (2d Cir. 1983). 

Many of the land use restrictions that would be put in place by the Proposed Plan would impose 

significant restrictions and loss of forage for the livestock industry. For example, the Proposed 

Plan would result in significant changes to the number of acres classified as riparian habitat 

conservation areas and riparian management areas. DEIS Vol. 1 at 309. Increasing the size of 

 21 Ranching as a Conservation Strategy: Can Old Ranchers Save the New West? Mark W. Brunson and Lynn Huntsinger. 

Rangeland Ecology Management 61:127-147 March 2008. 22 Natural Resources Conservation Service, USDA (2013). Sage Grouse Initiative: Tracking Success. Report.

http://static.sagegrouseinitiative.com/sites/default/files/sgi-tracking_success-final_low_res-020613.pdf
64

these areas restricts the ability to utilize them for livestock purposes. The USFS should prepare a 

more extensive analysis of the economic and social effect of its proposed land uses.

Many of the land use restrictions that would be put in place by the Proposed Plan would impose 

significant restrictions and loss of forage for the livestock industry. For example, the Proposed 

Plan would result in significant changes to the number of acres classified as riparian habitat 

conservation areas and riparian management areas. DEIS Vol. 1 at 309. Increasing the size of 

these areas restricts the ability to utilize them for livestock purposes. The USFS should prepare a 

more extensive analysis of the economic and social effect of its proposed land uses.

Under the preferred alternative (Alternative E), allowable utilization of available forage on suitable 

grasslands would be reduced from 50 – 55 percent to 35 – 45 percent. DEIS Vol. 1 at 149. The 

USFS asserts that “[t]his would be a modest change with a limited effect since utilization in the 

uplands does not exceed 35 to 40 percent in most active allotments.” Id. The DEIS does not 

document or state which allotments it believes fall into this category or what the economic effect of 

this reduction would be in those areas.

If these restrictions go into effect, lands suitable for grazing would be severely reduced. The USFS 

has not addressed how these restrictions related to areas occupied by bull trout will impact the 

economic and social well-being of the communities that rely on lands for grazing purposes. 

As another example, the USFS notes that “[t]he effect of [a larger elk population] could increase 

the grazing pressure on forage and browse plants, especially when the increased wild ungulate 

population is added to permitted livestock.” DEIS Vol. 1 at 156. The result of this will likely be 

“and a slow decline in permitted livestock (or in the case of some of the alternatives, a rapid and 

significant decrease in permitted livestock).” Id. However, the DEIS does not indicate how this 

possible rapid decline in permitted livestock will affect livestock operations in terms of lost 

productivity, the local communities, or their social structure.

AUM reductions can have devastating ranch-level effects (See Torell et al, Ranch-Level Economic 

Impacts of Altering Grazing Policies on Federal Land to Protect the Greater Sage-Grouse, 2014). 

USFS is required by law to do a thorough review of such effects, as well as an analysis of the 

“mutliplier effect” that will result from lost AUMs in local communities and beyond.

Utilization Concerns

Vol 3 p. 319 states, “It is assumed in this document that, in general, utilization of 40 percent or less 

of the forage on the landscape would result in proper management...” This “assumption” is 

seriously flawed. At current grazing levels, which are currently as high as 60 percent, USFS admits 

in this very document that rangelands are generally trending upwards. The new guidelines 

presented on pages 273 and 299 of Vol 3 propose a more one-size-fits all set of standards than what 

exists today. They propose to eliminate the varying levels of grazing management (intensive, 

extensive, stewardship), and also eliminate the “forested,” “grasslands,” and “shrublands” 

identifications, all of which get different treatment under existing guidelines. Thus, the new 

guidelines are less adaptable to variations in rangelands and in preferred management regimes. The 

preferred alternative proposes utilization levels of 40% (max) across the board--up to 10% lower 

than existing levels on riparian areas, and up to 20% lower than existing levels on upland areas. 

Not only that, Alt E proposes a 4-6 inch stubble height on riparian management areas, and a 20% 

maximum “bank alteration” level. 

The document states repeatedly that there are upward trends in range health in the planning area. 

This has been the case even as utilization levels have well exceeded 40% on both riparian and 

upland areas.

The DEIS’ utilization levels are not based on a balanced consideration of range science. The 

proposed levels are generally too low and will encourage wildfire in many cases. They will also 
65

detract from healthy grass and forbs growth. Furthermore, utilization should not be a number, but 

rather a range of use to achieve proper use that effectively addresses the needs of the plant 

community and the season of use it is applied to (i.e., 40-60%). Focusing on a single number is 

impractical, as grazing use is measured on average use not a specific number. A Single number 

goal merely invites conflict and argument (litigation). The same applies to stubble height. If the 

existing plant community identified is not capable of 4-6 inches of growth in the absence of 

grazing, how would stubble height be measured and also grazing use?

Utilization and stubble height should guide management, not be objectives in themselves. J. Wayne 

Burkhardt wrote in Rangelands 19(3), June 1997: 

As interest and concern about the environment and public lands has markedly increased in recent 

years, there has been an increasing effort to manage livestock grazing on the basis of utilization 

standards or limits.

This deceptively simple concept has become popular with environmental reformers opposed to 

public land grazing and with agency administrators caught up in the political crossfire of land use 

reform. Grazing use levels or “proper use factors” have long been part of the “tools” used by 

rangeland managers. Recently though, the tendency has been to base grazing management 

decisions solely on achieving predetermined use levels at “key sites” on pastures or allotments. 

This approach may provide simple and efficient “grazing administration” but it does not result in 

effective grazing management. 

Burkhardt ends this article by stating: 

The across-the-board application of conservative use standards to public land grazing is poor 

resource management and poor public policy. It puts the public land grazing permittee in an 

impossible position, reduces management agencies to policing operations and gives the radical 

environmentalists a wonderful tool to beat up the agencies and the ranchers. It is poor public policy 

that puts renewable resources off limits to the production of food and fiber and shifts that 

production to non-renewable resource based technology.

Bill Krueger wrote in Stubble Height and Utilization Measurements: Uses and Misuses, May 1998, 

“The most prominent area of agreement was that utilization is a land management tool, not a land 

management objective”. 

In another part of the paper he states: “Another concern about the accuracy and use of utilization 

data is that often the personnel using the methods are inadequately trained.”

Stubble height comes into the conversation, as stubble heights are based on height weight curves 

and set on desired percent utilization. A University of Idaho study on stubble height is states: 

“Clary and Leininger (2000) proposed a 10 cm (4 in) residual stubble height as a “starting point for 

improved riparian grazing management.” However, they acknowledged that in some instances, 7 

cm ( 2.75 in) may provide adequate riparian protection and in others 15 to 20 cm (6 to 8 in) may be 

required to limit streambank trampling or to reduce willow browsing. The criteria could vary 

depending upon local environmental variables, condition and trend of the stream, species 

composition on the greenline and the season, frequency and duration of livestock use. Thus, stubble 

height criteria not only can but should be adjusted through adaptive management, based on riparian 

conditions and trend (see Process for Adaptive Management). 

McLean, A. & S. Wikeem in a JRM paper titled: “Influence of season and intensity of defoliation 

on bluebunch wheatgrass survival and vigor in southern British Columbia”. (Journal of Range 

Management, 28 (1), 21-26.), they showed that with Bluebunch wheatgrass the most damage 

occurring with spring defoliation to a stubble height of 5 cm. Spring defoliation leaving 10-15 cm 

showed less damage. Fall defoliation to a stubble height of 5 cm and season-long grazing to a 
66

height of 20 cm showed no damage. Indicating that not all grazing intensities have the same effect 

and that basing utilization limits based on what fish was in the stream makes no sense. 

Bluebunch wheatgrass is generally the most sensitive species to grazing intensity, therefore looking 

at these numbers even Bluebunch wheatgrass can be grazed at 10 cm successfully in most 

instances. Rotational grazing as a possible management tool needs a place in this forest plan.

Different papers by Richards and Caldwell (1985) and Busso et al (1990) point out “Synchoronous 

tiller development increases the susceptibility of bunchgrasses to a greater loss of active shoot 

meristems when grazed after internode elongation. This also contributes to wide variations in 

grazing tolerance with the progression of phonological plan development. For example, the 

grazing sensitive bluebunch wheatgrass is quite tolerant of defoliation in the early spring when 

culmless, because active intercalary and apical meristems are located at or below ground level. 

However, defoliation tolerance decreases rapidly following internode elongation. 

As such, utilization standards and stubble heights should not be defined as standards or guidelines 

in the forest plan. The forest plan should lay out the desired conditions and then identify topics or 

issues of concern and possibly ways to mitigate it.

USFS should review and include in future decision-making the following materials:

J. Wayne Burkhardt. Grazing Utilization Limits: An Ineffective Management Tool. Rangelands 

19(3), June 1997.

Heitschmidt, R. et al. 1998. Stubble Height and Utilization Measurements: Uses and Misuses. 

Bulletin WCC-40, USDA Agricultural Research Service, Ft. Keogh Livestock and Range Research 

Laboratory, Miles City, MT 59301. 

University of Idaho Stubble Height Study Report. By: University of Idaho Stubble Height Review 

Team. July 2004.

Borman, M.M., Massingill, C.R. and Elmore, E.W. 1999. Riparian area responses to changes in 

management. Rangelands, 21(3): 3-7.

Pieper, R.D. (1994). Ecological implications of livestock grazing. in: M. Vavra, W.A. Laycock, & 

R.D. Pieper (Eds.), Ecological implications of livestock herbivory in the West (pp. 177-211). 

Society for Range Management. **

McLean, A. & S. Wikeem. (1985). Influence of season and intensity of defoliation on bluebunch 

wheatgrass survival and vigor in southern British Columbia. Journal of Range Management, 28

(1), 21-26. ***

“Desired Condition” May Exclude Non-native Desired Species 

USFS’ “desired condition” for ranges could put a great portion of WWNF grazing areas into 

“moderate or greater departure from desired condition,” category--thereby putting in place lower 

utilization standards. The following, from Vol 1 p. 130, could be interpreted in a way that puts 

areas with non-native (but desirable) grass species, which are now in “satisfactory” condition, in 

“unsatisfactory” condition purely because of the type of species: 

The desired conditions are defined by layers of management direction. A desired condition is 

identified where HRV objectives with the Public LURs definitions of satisfactory condition (i.e., 

fair range forage condition with an upward trend or better) are met by attaining a mid-seral 

ecological status with an upward trend or higher condition based on the PNC...(emphasis added).

The above indicates that “mid-seral ecological status” should be attained to meet “desired 

conditions.” What the layman may not know is that “mid-seral” status applies only to native 

grasses. Many past restoration efforts have rightly involved seeding of non-natives. This “desired 

condition” is unacceptable.
67

Endangered Species “Protections”

All the above is before taking into account endangered species “protections” (which are more 

likely to result in wildfire and overgrown forests than in “protection”). Examples: 

• Utilization in ESA species habitat, generally, is 30%. Since an endangered species can 

inhabit a small portion of a very large pasture, that could well mean 30% on thousands of 

acres that have no endangered species habitat. 

• Utilization in bull trout habitat would be just 25% max. If the anadromous fish and bull 

trout restrictions proposed here are put in place, grazing on the three national forests will 

be reduced by over half. Thus, while USFS claims that Alt E will have the same number of 

acres “suitable for grazing,” this cannot be true. 

• From May 15 to Aug 30, grazing in any pasture with silene spaldingii would be generally 

prohibited altogether. Again, in the absence of fences, this could effectively mean no 

grazing on thousands of acres where silene spaldingii are nowhere in sight.

The above does not even account for the thousands of acres that will be lost to grazing due to 

bighorn sheep (BHS) restrictions (see BHS section below).

Effects of Other Proposed Plan Components on Grazing

Lack of Fuels Management

Every alternative would restrict timber management to where harvest levels were even lower than 

the current, inadequate levels. Lack of timber management increases fire threat, which can put 

ranchers out of business or force them off their ranges for years at a time. Heavy canopy cover also 

reduces forage (understory) growth.

RLMP p. 15, “Vision,” states that conditions including “increasing vegetative density” may “put 

the ecosystem at high risk of uncharacteristically large and sever fires...” USFS should recognize 

in this section that management decisions to reduce grazing and logging have contributed to this 

problem. 

Lack of Access

The proposed reduction in road densities (including nonmotorized backcountry and general lower 

road density across the board) poses a threat to ranchers’ access, and increases the likelihood that 

wildfire will get out of control.

Economic Effects Underestimated

Vision (RLMP p. 71) “Grazing...contributes to local ranching operation sustainability and local 

community growth while maintaining or achieving ecological desired conditions” (emphasis added. 

Grazing’s economic contributions are given less importance than ecological “desired conditions.” 

Either add that “local ranching operation sustainability and local community growth must be 

maintained or achieved,” or take out the reference to ecological desired conditions.

While on p. 113, Vol x, the DEIS states “The amount of cattle grazing... would be generally the 

same for Alternative A,B,D,E and F,” this is not born out in the document. In fact, Vol. 2 p. 34 

states it outright: The degree to which alternatives would result in watershed and riparian 

improvements through reduced livestock grazing in both riparian areas and uplands, and active 

restoration of roads and upland vegetation, will likely benefit aquatic species...” Furthermore, 

Table 57 (DEIS Vol. 1 at 113) displays the permitted AUMs under each proposed alternative. It 

shows that all alternatives would result in a reduction in total AUMs. Even under Alternative A—

the “no action” alternative—there would be a reduction in total AUMs for cattle and sheep of 

13,923 AUMs for the WWNF. Such discrepancies should not exist in the planning documents of 
68

major agency action like the planning of national forest management. Nor should there be a 

reduction in total AUMs in the “no action” alternative. 

Bighorn Concerns

Domestic sheep and bighorns have co-existed in many of the same areas for decades without any 

apparent problems; or that the most common respiratory diseases in bighorn can’t be tied to a 

single, identifiable pathogen in domestic sheep; or that there are bighorn die-offs in areas far 

removed from any domestic sheep. And never mind what will happen when sheep are removed 

from the landscape—from increased wildfire threat to decreased open space provided by private 

ranches.

Bighorn management should be a state issue. Science surrounding disease transfer is inconclusive. 

(p. 16 RLMP)

Such decisions are based on the concept of “species viability,” which is found in USFS 

regulations, but nowhere in USFS’ authorizing statutes. “Viability” is an undefined term that 

provides too many opportunities for draconian decisions such as the proposed BHS-related 

standards found here.

Several national and state livestock associations are currently litigating USFS for its use of what 

industry has called “spurious” science and modeling. The industry groups charged that USFS failed 

to provide adequate science relating to disease transmission between bighorn sheep and domestic 

sheep, as well as an accurate risk-assessment model. For example, USFS assumes that domesticbighorn interaction will result in disease transmission 100 percent of the time. This assumption is 

based on a study where researchers took cultures from known-infected domestic sheep and placed 

them directly in the trachea of bighorn—obviously not reflective of a real-life scenario on the 

range.

The arbitrary buffer zones put in place or proposed by USFS in various areas, ranging from 7 to 9 

miles, is not explained or supported by science.

In 2009, a federal judge directed USFS not to use the model that is driving its BHS/domestic 

policy, declaring that the agency had violated FACA with their proceedings. In 2012, when it was 

apparent that USFS was continuing to make decisions based on their model, Congress stepped in. 

Congressional appropriators put a yearlong hold on any domestic sheep removals from the Payette 

and directed USFS to work with USDA’s Agricultural Research Service disease experts to come up 

with a more solid scientific basis for their bighorn decisions. 

BHS die-offs are caused by many factors, yet USFS puts sole focus on domestic/BHS interaction. 

Yet, BHS herds that haven’t had contact with domestic sheep for 30 years have been having 

pneumonia outbreaks and die-offs. Other wildlife as well as some BHS themselves are carriers of 

the pathogens causing die-offs in non-resistant BHS. Stressors such as depredation are thought to 

play a large role. In short, the approach of zero-tolerance for domestic/BHS interaction is in 

violation of USFS’ multiple-use mandate and should be abandoned.

It should be noted that the pathogens responsible for the BHS die-offs are endemic—meaning they 

aren’t going away. The state of OR should be concerned with finding BHS that are survivors, and 

promoting their reproduction.

Sage grouse Concerns

The County does not believe that livestock grazing and sage-grouse conservation are mutually 

exclusive. To the contrary, a robust grazing program actually ensures the health of sage-grouse 

habitat. Nevertheless, the proposed revisions appear to put sage-grouse conservation on a higher 

footing than livestock grazing and forage production, which would be a violation of the multipleuse statutes governing USFS. 
69

The County urges USFS to recognize its responsibility to support existing grazing levels 

and increase the productivity of the range in conjunction with seeking to conserve sage-grouse 

habitat and populations. The DEIS spends an inordinate portion of the analysis on grazing in 

comparison to primary threats to the birds’ survival in Oregon (predation, wildfire, habitat 

fragmentation). Unlike some land management activities, grazing is most often beneficial to sagegrouse habitat. Nevertheless, the “preferred” alternative focuses on reductions to and restraints on 

livestock grazing that could have debilitating effects on permittees’ ability to keep their operations 

running (and thus continue providing benefits to sage grouse). This alternative actually jeopardizes 

habitat by increasing wildfire risks (increased fuel loads and continuity of fine fuels), which U.S. 

Fish and Wildlife (FWS) identified as a primary threat. Reducing forage productivity and 

availability on USFS land could also result in additional habitat loss on private land, as well as 

increasing urbanization. The negative effects on sage-grouse populations resulting from restricting 

grazing outweigh any potential benefits. USFS proposed amendments would undercut a balanced 

grazing program in favor of overly restrictive management standards. 

Water/Watershed/Riparian Area Concerns

Baker County’s watersheds provide water for urban and rural families and are essential for healthy 

and sustainable agriculture, livestock, industry, fish and wildlife. These watersheds provide 

recreation opportunities for residents and tourists, serve cultural needs, and provide habitat for 

native plants, wildlife, and fisheries. The health of the County’s watersheds directly affects the 

current and future availability and quality of the water resources and water-dependent natural 

resources in the County, and the ability of watersheds to adapt to climate variability (i.e., periods of 

drought, periods of high rainfall, rain-on-snow events). 

Baker County supports the development and pursuit of watershed improvement goals, objectives, 

programs and projects by County, State, and Federal Agencies and the many corporations and 

private landowners/managers in the County (Appendix I). The County supports these objectives 

because of the benefits residents of Baker County and of the State of Oregon receive from good 

watershed management. Further, the County supports the objectives of the Oregon Plan for Salmon 

and Watersheds as they apply to Baker County and landowner-sponsored projects funded by the 

Oregon Watershed Enhancement Board that help implement that plan in Baker County.

1. Maintain site-appropriate ground and canopy cover in grasslands, shrublands and 

forestlands, including wetlands and riparian areas, to: a) dissipate rainfall energy and 

promote infiltration of rainfall and snowmelt; and b) minimize erosion, sedimentation and 

runoff that exceeds natural levels.

2. Improve natural water storage capacity of degraded watersheds by improving ground cover 

of uplands, rehabilitating gullied slopes, and reconnecting entrenched perennial, 

intermittent and ephemeral stream channels with their floodplains.

Water rights in Baker County date back to the early 1860’s. The dates on priorities (filing dates) 

trace the mining ventures and settlement of farms in the Baker Valley, with the better alluvial soils, 

and non-intermittent stream flows holding the oldest water rights. Oregon water law is based on 

two legal principles – appurtenance to the land, and first-in-time, first-in-use priority. Baker 

County policy is to protect the legal concept that water is appurtenant to the land, and to not allow 

any diminution of water quantity in water rights.

USFS Attempts to Exceed Its Authority over Water

The USFS must stay within the bounds of its own management jurisdiction. The agency holds 

federally reserved rights to fulfill its two primary purposes: to furnish a continuous supply of 

timber for the people, and to conserve water flows. In order to fulfill secondary purposes such as 

wildlife protection and instream flows, USFS is required to apply for water rights in accordance 

with the procedures of the Oregon water code.
70

USFS’ calling for “Connectivity” between watersheds, for example, is outside the agency’s 

authority. So is USFS’ focus (p. 24 of RLMP) on “Instream flows, including water yield, timing, 

frequency, magnitude, and duration runoff...” 

A standard for riparian management areas in Alt. E (Vol 3 p. 306 – RMA-HYD-1 S-56) states: 

“Authorizations for all new and existing special uses, including, but not limited to water diversion 

or transmission facilities (e.g., pipelines and ditches), energy transmission lines, roads, 

hydroelectric, and other surface water development proposals, shall result in the reestablishment, 

restoration, or mitigation of habitat conditions and ecological processes identified as being essential 

for the maintenance or improvement of habitat conditions for fish, water and other riparian 

dependent species and resources. These processes include in-stream flow regimes, physical and 

biological connectivity, water quality, and integrity and complexity of riparian and aquatic habitat” 

(emphasis added).

The proposal to regulate—via denial of special use permits–in-stream flows, physical and 

biological connectivity, water quality, and “integrity and complexity of riparian and aquatic 

habitat” is far beyond USFS’ authority. 

On page 2, the EIS states the Forest Service will “provide clean and cold water.” There is no way 

USFS can commit to providing cold water in south-facing flashy watersheds such as the North 

Fork Burnt River. These streams come out fast in the spring, then there are low flows during the 

hot summer months. These waters were never naturally cold, and no matter what the Forest Service 

says, these waters will remain warm.

USFS Inappropriately Focuses on Wildlife, Discourages Human Use and Management

USFS propsoses to violate Multiple Use statutes in its proposals to regulate water and water uses 

within the planning area. It would take water use away from human use and focus on wildlife 

“benefit” only.

o Example 1: “Key watersheds” cover large area and focus only on wildlife use. 

“The role of key watersheds is to serve as habitat refugia for existing populations 

and to provide sources of individuals that are able to colonize new habitats as 

conditions improve. The management emphasis in all key watersheds is to protect 

existing populations and their habitats while incurring the lowest level of risk to 

those populations...” (RLMP p. 22)

o Example 2: “Desired Condition: Networks of watersheds with good habitat and 

functionally intact ecosystems contribute to and enhance conservation and 

recovery of specific threatened or endangered fish species and provide high water 

quality and quantity. The networks contribute to short-term conservation and longterm recovery at the major population group, core area, or other appropriate 

population scale.” Increasing production of timber, minerals, and forage for 

livestock should be included as desired conditions.

o Removing “human intervention” should not be a goal, as stated in “All Watersheds 

– Desired Condition” (p. 23 of RLMP): “The watershed-scale processes that 

control the routing of water, sediment, wood, and organic material operate at levels 

that result in self-sustaining riparian and aquatic ecosystems that do not require 

human intervention or restoration.” Productive uses (timber, mining, grazing) 

should be included as part of the desired condition.

• RLMP p. 23 states: “The alteration or removal of vegetation or 

ground cover by activities such as fire, timber harvest, the use of 

mechanized equipment, livestock grazing, and the construction of 

roads alters hydrologic pathways in ways that can result in 

increased hillslope and stream channel erosion rates.” This 
71

statement is true for wildfire, but not true for managed timber 

harvest, use of most roads, and grazing. “Alteration or removal of 

vegetation” can be a positive for “hydrologic function”--not just a 

negative. In fact, it is necessary to prevent catastrophic wildfire. 

Riparian Management Areas 

RMAs constitute 29 percent of the general forest area for the three forests. These areas should be 

governed by adaptive management, instead of by the restrictive regulations put forth in the 

preferred alternative. As addressed below, riparian areas are defined too broadly; pose a threat to 

multiple uses; and pose a threat to the resources.

1. RMAs Are Defined Too Broadly 

Riparian management areas “ include traditional riparian corridors, wetlands, intermittent 

headwater streams, and other areas where proper ecological function is critical to maintenance of 

the streams’ water, sediment, woody debris and nutrient delivery system”. Page 231 Chart shows 

362,500 acres locked up in the riparian stream buffers. This chart should show the acres for 

alternative A (without the 100 foot buffers on ephemeral streams.)

We question USFS’ excessive buffer widths, which appear to be dictated by the Region’s Aquatic 

and Riparian Conservation Strategy (ARCS). ARCS adopted the buffer widths originally imposed 

by PACFISH/INFISH, which were intended to be interim measures until better science was 

available. They were based largely on conditions farther west, which are much wetter. This, 

combined with the fact that they were made very wide as a “precautionary” measure in the absence 

of adequate scientific data, makes them inappropriate for use in this plan revision.

Page 309 of “RMA widths and extent are similar to RHCAs except that a width of 100 feet would 

apply to all seasonally flowing streams and small wetlands, whether or not the streams are fish 

bearing.” Vol I Page 31 indicates a buffer width of 100 feet on dry streams would apply throughout 

the entire plan area in the preferred alternative. There is no science behind the increase in buffer 

from 50 feet to 100 feet along ephemeral streams. Ephemeral streams are not riparian, nor do they 

flow water that needs to be cooled. They have no riparian vegetation, and have narrow floodplains. 

The additional 50 feet of buffer is not necessary, and would put off-limits a huge area now 

available for timber harvest. Under the current 1990 forest plan riparian areas are in good shape. 

There is no rationale for increasing the buffer along ephemeral drainages, which are actually nonriparian, by an additional 50 feet. Oregon’s private timber lands are in excellent shape, despite the 

narrower buffers. Decreasing the area available for harvest is not justified. 

Volume 1 Chapter 3 states on page 273, “Both agencies recognize that stream shade provided by 

riparian vegetation has the most widespread achievable effect on reducing stream temperatures”.

The Forest Service is not correct that stream shade can reduce stream temperatures. Stream shade 

can only function to maintain the water temperature. 

2. Riparian Areas Not In Need of Additional Regulation In Volume 1 page 25, the DEIS

indicates that the 1990 Forest Plan RHCA buffers have resulted in healthy, functioning 

riparian areas throughout Baker and Grant Counties. 

Page 309, states “RMA widths and extent are similar to RHCAs in the 1990 Forest Plan, and 

riparian areas have been on an upward trend since the 1990 Forest Plan and the INFISH and 

PACFISH amendments.” No changes in stream buffers are evidently needed.

Vol 2 Page 12 “riparian and aquatic habitat conditions are currently trending upward at the scale of 

he plan area following 15 plus-years of management under the 1990 Forest Plan”.

Monitoring Problems 
72

On Page 110/111 of the RLMP, USFS proposes a monitoring plan framework for the action 

alternatives. Among the problems with this section:

1. “Status of selected watershed conditions” will be considered in the monitoring plan. 

However, DEQ does not regularly remove streams from the 303d list without someone 

initiating the process after many years of monitoring and then the process could take years. 

This is not a valid monitoring protocol.

2. USFS attempts to determine trends in 3-5 years on matters such as watershed condition; 

riparian vegetation condition; invasive species; and aquatic habitat. No trends will be 

detectable in a 3-5 year timeframe.

Other Concerns

Page 271states, “sediment is a natural function in lower gradient streams.” The DEIS should reflect 

the fact that sediment is also a natural function of south facing high gradient streams.

Page 27 lists hydrologic unit code: 4th-code HUC a sub basin 450,000 acres; 5th-code HUC a sub 

basin 40,000-250,000; 6th

-code HUC a sub basin 10,000-40,000 acres.

Where do 250,000-450,000 fall?

Vol 3 Page 12 defines “Channel” as “the deepest part of a stream...” This is not how the term is 

used in the rest of the document. 

Vol 3 Page 182-183: hydrologic function should be “within the natural range of variability.” Does 

USFS know what this is? If so, they should disclose to the County. 

Climate Change Concerns

Climate change is an inevitable constant. It is also very unpredictable. We are very 

concerned about relying on the idea of climate change when promulgating rules that may affect 

management for years to come. The climate changes on natural cycles – warming, cooling, lengths 

of seasons etc. – and will continue fluctuating in the future. We strongly recommend the USFS 

develop a plan that allows local land managers the flexibility to make decisions based on the 

current conditions on the ground and in collaboration with state/local authorities, livestock 

permittees, and other vested stakeholders. We encourage the USFS to utilize the parameters of the 

National Environmental Policy Act (NEPA) process already in place that allow for categorical 

exclusions and streamlined local environmental assessments in case of changing conditions. 

USFS Attempts to Predict the Unpredictable

On page16 of the RLMP, USFS states, “Average temperatures in the Pacific Northwest have 

increased by about 1 degree Celsius (1.8 degrees Fahrenheit) since 1900, and the rate of warming 

during the last 50 years is nearly twice the rate of the previous 100 years (ISAB 2007). The rate of 

warming is expected to increase in the 21st century. Mean annual temperatures are expected to rise 

by 0.3 degrees Celsius (0.5 degrees Fahrenheit) per decade through 2050 in response to continued 

increases in atmospheric greenhouse gases (Mote et al. 2008).”

The United Nation’s climate change chief, Rajendra Pachauri, has acknowledged a 17-year pause 

in global temperature rises, confirmed recently by Britain’s Met Office. Even if temperatures had 

increased, “climate change” is far too unpredictable to be the basis of forest planning decisions. 

Plans should simply employ adaptive management to accommodate changes in climate. For 

example, plans should allow for future new water storage facilities in the event that increased rains 

and decreased snowpack make water retention necessary. 
73

USFS Attempts to Control the Uncontrollable

USFS describes “control of climate” as one of the forests’ “ecosystem services.” Controlling the 

climate is most certainly outside the capacity of USFS, even when considering all national forests 

combined. (Volume 3, page 18: “The combined resources and processes of natural ecosystems that 

provide benefit to humans, including, but not limited to, the production of food and water, the 

control of climate and disease, cycling of nutrients and crop pollination, spiritual and recreational 

benefits, and the preservation or maintenance of biodiversity.”

USFS Proposes Damaging Decisions Based on Climate Change

Vol I Page 60: Management strategies include “reducing potential increases in stream temperatures 

through riparian buffers. Reducing the risk of water quality degradation by (1)Decreasing road 

density (2) closing, realigning or obliterating roads. 

Vol I Page 59 states: “Management strategies to increase the adaptive capacity of terrestrial 

ecosystems in the face of climate change include: conserving species (whatever the climate does, 

this is not USFS’ role, but the role of the state).”

Vol I Page 61 proposes “reducing barriers to species movement (close roads, destroy 

fences)...decreasing road density”

Recommendation in the Event of Climate Change

If USFS’ predictions of climate warming and increased precipitation is true, then this will

exacerbate the already overstocked dense timber stands with the potential of more catastrophic 

wildfires. Even more aggressive timber management would be necessary. This is not mentioned in 

the DEIS. In fact, the above proposals to destroy roads and “protect” species will only serve to 

diminish timber management.

Special Land Designations Concerns

Page iii Issue 6, states, “Public concern is heightened because the management to approach 

ecological resilience will determine the ecosystem services the Blue Mountains national forests 

provide”. The public in Baker County really is concerned. Mismanagement and no management 

have left hundreds of thousands of acres in poor health and susceptible to insects and fire. The 

“management to approach ecological resilience” we see in the Blue Mountain Revision means a 

blueprint for a future Forest with less access, more wilderness, more wildlife corridors and nonmotorized areas, wider “riparian” buffers on ephemeral streams, less timber management. 

For the WWNF alone, the preferred alternative (E) proposes 20,300 acres of recommended 

wilderness areas; 104,500 acres of “backcountry” non-motorized use acres and 145,500 additional 

“backcountry” motorized use acres; 6,500 acres as “wildlife corridors;” over 52,900 acres of Wild 

and Scenic Rivers (existing and proposed); 8,000 in Research Natural Areas; and 362,500 acres 

locked up in Riparian management areas.

Socio-Economic Effects of Special Designations

Wilderness areas and similar designations (nonmotorized backcountry; wildlife corridors; Wild and 

Scenic; research natural areas) are lousy neighbors, shedding disease, insect infestations and 

wildfires onto neighboring private and public land. The designated areas that we now have are 

currently underutilized. With more designations, we would lose even more use of the Natural 

Resources needed to create jobs and recreational opportunities. We would lose the revenue that 

derives from these resources, which is desperately needed by Baker County’s economy. 

Research shows that the economic benefits that may result from special land designations usually 

does not outweigh the harm. According to research by Utah State University, Wilderness 

designations are “significantly associated with lower per capita income, lower total payroll, and 
74

lower total tax receipts in counties” (Steed, 2011). The research found that wilderness impacts both 

households and counties. Average household income within Wilderness Counties was estimated to 

be $1,446.06 less than Non-Wilderness Counties. Total payroll in Wilderness Counties was also 

estimated to be $37,500 less than in Non-Wilderness Counties. County Tax Receipts in Wilderness 

Counties was estimated to be $92,910 dollars less than in Non-Wilderness Counties (id.).

The Forest Revision Plan should protect the customs and culture of the area it is affecting. The 

customs and cultures of hunting, fishing, camping, wood gathering, collection of mountain berries 

and mushrooms is what our National Forest has been used for over the past 150 years. Designating 

more wilderness will detract from those customs and our culture.

For these reasons, wilderness areas and all such lands designated backcountry, Research natural 

areas, or wild and scenic rivers, where wise management of the resources are disallowed or 

discouraged are not desirable. 

Citations

Steed, B. et al. 2011. The Economic Costs of Wilderness. Issue Brief. Jon M. Huntsman 

School of Business, Utah State University.
75

Appendix A:

Baker County Natural Resource Plan 

[Please refer to page 16, where we address how the revised Forest Plan is consistent with the Baker 

County Natural Resource Plan.]

Appendix B:

Wallowa County plan – Utilization Standards for Late Spring/Summer

Allowable Use of Available Forage in Riparian Areas

Range Resource Management Level Grass and Grasslike species

Shrubs

Satisfactory 

Condition

Unsatisfactory 

Condition

Satisfactory 

Condition

Unsatisfactory 

Condition

Livestock use managed within current grazing 

capacity by riding, herding, and salting. Cost 

effective improvements only to maintain stewardship 

of range

40 0-30 30 0-25

Livestock managed to achieve full utilization of 

allocated forage. Management system designed to 

obtain distribution and maintain plant vigor include 

fencing and water developments

45 0-35 40 0-30

Livestock managed to optimize forage production and 

utilization. Cost-effectiveness culture practices 

improving forage supply forage use and livestock 

distribution may be combined with fencing and water 

development to implement complex grazing systems.

50 0-40 50 0-35

Allowable Use of Available Forage in Upland Areas

Range Resource Management 

Level Forest Grassland Shrubs

Satisfactory 

Condition

Unsatisfactory 

Condition

Satisfactory 

Condition

Unsatisfactory 

Condition

Satisfactory 

Condition

Unsatisfactory 

Condition

Livestock use managed within 

current grazing capacity by 

riding, herding, and salting. 

Cost effective improvements 

only to maintain stewardship 

of range

40 0-30 50 0-30 40 0-25

Livestock managed to achieve 

full utilization of allocated 

forage. Management system 

designed to obtain distribution 

and maintain plant vigor 

include fencing and water 

developments

45 0-35 55 0-35 45 0-30

Livestock managed to 

optimize forage production 

and utilization. Costeffectiveness culture practices 

improving forage supply 

forage use and livestock 

distribution may be combined 

with fencing and water 

development to implement 

complex grazing systems.

50 0-40 60 0-40 50 0-35

Umatilla County Commissioners



Morrow County

Morrow County

Dear Ms. Stadler,

Morrow County appreciates this opportunity to comment on the Blue Mountains National 

Forests Proposed Revised Land Management Plan and Draft Environmental Impact 

Statement ("BMPR"). 

We are aware of the positive things happening such as the region's Eastside Restoration 

Strategy, the Southern Blues Collaborative Forest Landscape Restoration Project on the 

Malheur, and other collaborative group activities. These recent efforts are encouraging and 

we will do everything possible to help them succeed. 

However, the pace to agree and implement this plan has been dreadfully slow. Access is 

being reduced or prevented, and the cutting of these trees is limited - impacting economic, 

social, recreational and community benefits in Morrow County. Finally, and most sadly, 

this natural resource is left to bum and decay as its highest/best use. 

We conclude the alternatives do not adequately address moving to solution and a plan must 

be rewritten as sited in the attached 23 page comment letter. 

Time and talk, proposed rules and regulations and process are being substituted for genuine 

purpose, management and action. 

Morrow County respectfully submits these comments for consideration. 

Sincerely,

[NOTE: The letter that follows from Eastern Oregon County was also attached to this letter.]
Eastern Oregon Counties Association

Baker Deschutes Gilli am Gra nt Harney Malheur Morrow Sherman Umat illa Union Wallowa

August 6, 2014 

Ms. Sabrina Stadler 

Blue Mountains Plan Revision Team 

P.O. Box 907 

Baker City, OR 97814 

Dear Ms. Stadler: 

We appreciate this opportunity to comment on the Blue Mountains National Forests 

Proposed Revised Land Management Plan and Draft Environmental Impact Statement 

("BMPR"). The Eastern Oregon County Association (EOCA) is an organization of eleven 

eastern Oregon county governments. Our members are the elected representatives of the 

citizens of the region most directly affected by the decisions that are being made about 

the national forests in this plan revision. Our comments are submitted by the Association 

on behalf of the individual county governments and our citizens. They are applicable to all 

three national forests, unless otherwise noted. 

Many of our member counties have been working with the Planning Team, as Cooperating 

agencies, since the very beginning of the BMPR process ten years ago. The eastern 

Oregon economy is largely resource-dependent and relies on access and productivity 

associated with public lands that dominate our landscape. Our communities are tied to 

the land culturally and economically. Our future economic and social well-being is 

dependent on wise stewardship of these lands. Thus, we have an enormous stake in the 

future of the three Blue Mountain national forests.

GENERAL COMMENTS

The Pace of Restoration 

There are signs of good things happening on the ground in the national forests today such 

as the region's Eastside Restoration Strategy, the Southern Blues Collaborative Forest 

Landscape Restoration Project on the Malheur, and other collaborative group activities. 

These efforts recognize that these forests desperately need active management, at the 

landscape scale, to restore ecological resiliency and ensure the social and economic 

vitality of eastside communities. These recent efforts are encouraging and we will do 

everything possible to help them succeed. 

Although we have been involved in the shaping of the proposed plan revision over the 

past decade, as we have communicated repeatedly, we continue to believe strongly that 
the proposed plan inadequately addresses the real and urgent needs of both the natural 

resource and surrounding communities. The plan is constrained by too much of a "more

of the same" approach to management where the land base available for active, 

restorative management is whittled down by almost endless exceptions, withdrawals, and 

prohibitions. 

There are urgent ecological, social, and economic needs to dramatically accelerate the 

pace of forest restoration activities. We must learn the lessons from Arizona and 

Colorado, as well as from closer to home, of the consequences of inaction before we too 

lose both the resource and the benefits it provides to our economy and communities. This 

is the single, overarching concern that we have with the proposed plan. 

The poor health condition and high fire susceptibility of the forests is well known, but a 

couple of comments from the planning documents highlight the problems:

• "Based on forest inventory and the forest vegetation simulator fire/fuels modeling, 40 

to 60 percent of the dry upland forest now has the potential for high severity fire as a 

result of the abundance of multi-storied stands with high stocking levels." - Plan Doc, 

p. 34.

• "Recent plan modeling of the potential mortality from disturbances from insects and 

disease indicates that approximately 30 percent of the forest stands in the Blue 

Mountains have the potential to have more than 25 percent of their total volume killed 

in the next 10 years" - Plan Doc, p. 35.

The perpetuation of these conditions threatens the achievement of virtually every Desired 

Condition in the plan. 

The lack of progress in reaching critical Desired Conditions via any of the Alternatives is 

a pervasive problem throughout the analysis, indicating to us none of the Alternatives 

are sufficient in addressing the issues identified in the scoping process. The evidence 

presented within the planning document itself supports this conclusion. 

As one example, consider the Desired Condition relating to fire regime condition classes. 

The desired condition is, "in landscapes that exhibit a moderate or high degree of 

departure (Condition Class II or Ill), the degree of departure is decreased to low or 

moderate (Condition Class I or II)." The following two charts use data from Table 114 (Vol. 

1, p. 218) to illustrate the lack of timely progress in achieving this Desired Condition for 

the critical dry upland forests under all Alternatives - after 20 and even after 50 years. 

The existing condition on each of the forests is "moderately departed" which is defined as 

departure scores between 33 and 66. Across all forests, the average departure score is 59. 

The Desired Condition is to get the departure score below 33 over time, moving the 

acreage from moderate to low departure (Condition Class II to Condition Class I).
After 20 years, the Alternatives result in only modest, at best, movement towards this 

goal. Alt. D makes the most progress, moving the average departure score from 59 to 49. 

This 10 point movement represents only a 38% achievement of the goal of getting 

departure scores below 33. The preferred alternative, Alt. E, makes less than one-third of 

the progress needed. All forests continue to be classified as "moderately departed." This 

means that, twenty years from now, these forests will be nearly as vulnerable to 

catastrophic wildfire loss as they are today.

Even after 50 years, progress towards the goal is unacceptable (see chart below). The 

Desired Condition is met for only one forest (Malheur) under Alt. D. In 50 years, the 

Preferred Alternative only achieves 71% of the stated goal. As the document itself states, 

"None of the alternatives would achieve the desired conditions for stand densities at year 

SO. Under all of the alternatives, the% of the landscape in open forest would remain 

above the desired condition range at year 50 ." (Vol. 2, Ch. 3, p. 163). 

We simply do not have 50 -100 years to return our forests to a healthy, resilient state. 

Clearly, more proactive, aggressive approach is needed than has been identified in any of 

the alternatives presented.
The primary reason for the lack of progress in achieving Desired Conditions is the lack of 

active management. This is the result of two factors: (1) allocation of land to Management 

Areas in which active management is prohibited, or at best severely constrained, and {2) 

budget constraints used in the development of alternatives. 

Under the Preferred Alternative, annual active forest restoration activities occur on only 

2.6% of the general forest area (MA4) annually. More relevant, is that active management 

- including harvest, planting, non-commercial thinning, and fuels management - occurs on 

only 1.5% of the entire 4.9 million acre land base annually. It is no wonder that so little 

progress is made given the low level of active management envisioned under this 

proposed plan. 

The slow pace of restoration envisioned in the alternatives also ignores the likelihood that 

re-treatment in some form will be needed on a cycle of between 20 and 30 years. 

Realistically, between 3.5 and 5.0 percent of the landscape should be treated annually to 

maintain landscapes at the desired densities, harvesting every 20 to 30 years. This is to 

maintain landscapes at acceptable densities once they are achieved. Only Alt. D comes 

close to the bottom end of the range needed to successfully manage stand densities 

within the desired range. In reality, we should be treating more than 5 percent in order to 

eliminate the large accumulation of overstocked stands.
A comparison of planned harvest levels with annual growth provides another example of 

the low level of management under all of the Alternatives and also raises questions about 

the ability to achieve many of the most critical Desired Conditions related to forest health 

and resiliency. 

The three national forests currently carry an inventory of 45 billion board feet (Bbf) (Vol. 

2, Ch. 3, p. 101} and annual gross growth of 1.3 Bbf. Mortality is estimated at 500 million 

board feet (MMbf) or 38% of gross growth. This leaves net growth of 800 MMbf annually 

across all acres. Net annual growth on the Acres Suitable for Timber Production is 

estimated at 207 - 469 MM bf, depending on Alternative, as shown in the table below.

Recent harvest levels (2007-2009) have averaged 72 MMbf across all three forests; 44 MM 

bf counting only sawtimber products (Table 40, Vol. 1, Ch. 3, p. 98}. The Timber Sale 

Program Quantity (TSPQ) under the Alternatives range from 47 to 243 MMbf. The 

Preferred Alternative proposes a TSPQ of 162 MM bf, representing less than half the net 

growth on the acres suitable for timber production and only 20 percent of net growth 

over all acres. Alt. D, in spite of its higher TSPQ, still only harvests 52 percent the net 

growth on the acres suitable for timber production under this alternative.
The implications of harvesting far under growth are clear. Biomass will continue to 

accumulate and the forest, overall, will grow more overstocked, not less. As stated in the 

Environmental Consequences section,

"[t]he consequences of not harvesting or reducing biomass by fire would be 

an increased risk of mortality from uncharacteristic wildfire, insects, and 

disease. The increased would be primarily due to growth exceeding 

mortality (from insects and disease and fire), making it difficult to achieve 

desired stand densities." (Vol. 2, Ch. 3, p. 172).

Given this, it is difficult to understand how any of the Alternatives can make progress 

toward the desired conditions that relate to lower stand densities. It calls into question 

even the modest improvements in fire regime condition class departure scores described 

above. We don't see how progress is being made in improving fire resiliency if biomass 

accumulations persist. 

It could be that the VDDT model, which we understand has a probabilistic wildfire 

component, is predicting large increases in catastrophic wildfires, and insect/disease 

outbreaks that is setting stands back to earlier structural stages. If so, this environmental, 

social, and economic impact is not adequately disclosed or analyzed in the DEIS and as a 

result, the public is being mislead about the consequences of the alternatives. 

We ask that the Planning Team take a look at this question and provide an explanation 

that satisfactorily addresses this issue. 

Departure from Non-declining Flow Policy is Warranted and an Analysis is Required 

In order to significantly accelerate the pace of forest restoration, the agency should and 

we argue they must - analyze an alternative that considers a departure from agency's 

policy of nondeclining flow (NDF) of timber harvest. The nondeclining flow policy is a key 

component of the 1982 Planning Rule. Section 219.16 states,

"for the base sale schedules, the planned sale for any future decade shall be 

equal to or greater than, the planned sale for the preceding decade, 

provided that the planned sale is not greater than the long-term sustainedyield capacity consistent with the management objectives of the 

alternative."

The planning rule states that "Alternatives with sale schedules which depart from the 

principles of [nondeclining flow] and which will lead to a better attaining of the overall 

objectives of multiple-use management shall be evaluated when any of the following 

conditions are indicated:
(i) None of the other alternatives considered provides a sale schedule that 

achieves the assigned goals of the RPA Program as provided in Sec. 

219.4(b);

(ii) High mortality losses from any cause can be significantly reduced or 

prevented or forest age-class distribution can be improved, thereby 

facilitating future sustained-yield management; or

(iii) Implementation of the corresponding base sale schedule would cause 

a substantial adverse impact upon a community in the economic area in 

which the forest is located.

(iv) It is reasonable to expect that overall multiple-use objectives would 

otherwise be better attained."

However, as explained on p. 350 of Appendix B, the agency has not identified a need for 

considering a departure:

"the base schedule is a timber sale schedule formulated on the basis that 

the quantity of timber planned for sale and harvest for any future decade 

is equal to or greater than the planned sale and harvest for the preceding 

decade, and that this planned sale and harvest for any decade is not 

greater than the long-term sustained yield capacity ... This definition

expresses the principle of nondeclining flow. ... the first decade allowable

sale quantity must meet the nondeclining flow requirements unless 

departure from the base schedule is determined to be warranted. The 

need for considering departures has not been identified at this time ... "

Given the poor condition of the resource outlined by the plan, we find it very difficult to 

believe that the agency has appropriately analyzed this issue as required by the planning 

rule. It is clearly evident that conditions ii, iii, and iv listed above are, in fact, indicated and 

therefore, the Forest Service not only should, but must, evaluate at least one Alternative 

that considers a departure from NDF.

• First, an accelerated restoration program that goes beyond the limitations 

imposed by NDF could significantly reduce mortality losses from fire, insects, 

and disease. Condition ii is met. The plan clearly outlines the problem in 

multiple places; for instance:

"Recent plan modeling of the potential mortality from disturbances from 

insects and disease indicates that approximately 30 percent of the forest 

stands in the Blue Mountains have the potential to have more than 25 

percent of their total volume killed in the next 10 years" - Plan Doc, p. 35.
"[t]he consequences of not harvesting or reducing biomass by fire would be an increased 

risk of mortality from uncharacteristic wildfire, insects, and disease. The increased would 

be primarily due to growth exceeding mortality (from insects and disease and fire), making 

it difficult to achieve desired stand densities." {Vol. 2, Ch. 3, p. 172).

• Secondly, a departure can avoid substantial adverse impacts upon the local 

community that will otherwise result from further closure of local mills and loss of 

infrastructure and jobs. Condition iii is met. As we will show later, the regional 

infrastructure cannot be maintained at the levels of harvests proposed under any of 

the alternatives. This will have a substantial adverse impact upon a community in 

the economic area in which the forest is located.

• Thirdly, it is reasonable to expect that overall multiple-use objectives would be 

better attained. It has been clearly shown that the current Alternatives, including 

the preferred alternative fail to achieve the major desired conditions (the current 

terminology for "multiple use objectives") within any sort of reasonable time frame. 

Condition iv is met.

Thus, according to the 1982 Rule, the Forest Service must consider a departure from NDF 

in the Blue Mountain Plan Revision. Yet, it hasn't. 

Furthermore, the agency, in not considering a departure, is being inconsistent with plan 

revision efforts in at least one other region. Northern Region forests are incorporating 

consideration of a departure from nondeclining flow in their plan revisions, including the 

Clearwater-Nez Perce NF in ldaho.23 The rationale for this is the urgent need to "kick-start" 

forest restoration efforts. 

A departure from nondeclining flow is in fact warranted. Such a departure is consistent 

with the urgent need to thin forests and achieve forest health-related Desired Conditions 

within a reasonable time frame of 20 to 25 years instead of 50 to 100 years under the 

preferred alternative. This would allow harvest levels to increase temporarily under an 

accelerated restoration strategy and decline in future decades once the forests have 

reached Desired Conditions. 

The departure analysis must be completed in conjunction with an alternative that is not 

bound by budget constraints (see below). Our understanding is that because of budget 

assumptions, Alternative D is the only alternative, where the NDF policy is constraining 

timber production levels. In other cases, budget constraints are hit first.

 23 Proposed Action for the Forest Plan Revision, Nez Perce-Clearwater National Forests. July 2014.
Budget-Constrained Alternatives in Violation of Planning Rule 

All of the alternatives, except Alt. D, are constrained by current/expected budgets or in 

the case of Alt. E and F, modest increases over existing budget levels. We believe this is 

counter to the direction of the 1982 Planning Rule which states that,

"Alternatives shall be distributed between the minimum resource 

potential and the maximum resource potential to reflect to the extent 

practical the full range of major commodity and environmental resource 

uses and values that could be produced from the forest. Alternative shall 

reflect a range of resource outputs and expenditure levels." [emphasis 

added]

In constraining the alternatives to a narrow range of expenditure levels, the agency has 

failed to meet the requirement of the Planning Rule to investigate a full range of uses and 

values and reflect a range of outputs and expenditure levels. 

It is worth noting that forests in the Northern Region have been directed to analyze each 

alternative with and without budget constraints so that the needs of the resource can be 

adequately represented. To quote the Nez Perce-Clearwater Proposed Action, "this will 

allow for analysis to display the ecological and socioeconomic effects of a range of harvest 

levels, while also disclosing the funding levels needed to best meet desired conditions 

across the plan area. "24

To correct this, we request that the agency analyze each alternative with and without 

budget constraints. Without such an analysis, the agency decision-makers and the public 

cannot be adequately informed about the resource trade-offs and other impacts of the 

decisions that are being made. 

We also point out that the proposed plan and accompanying analysis fails to meet a 

number of other requirements of the 1982 Planning Rule, including but not limited to the 

following:

• Monetary benchmarks which estimate the maximum net present value of those 

resources that have an established market value ...

• Demonstration that the alternatives represent the most cost efficient combination 

of management prescriptions examined that can meet the objectives established 

in the alternative.

• Identification of the alternative that comes nearest to maximizing net public 

benefits.

 24 Proposed Action for the Forest Plan Revision, Nez Perce-Clearwater National Forests. July 2014.
Access

Access to national forest lands is a right of every American citizen and is highly valued by 

our constituents, many of whom are third and fourth generation eastern Oregonians with 

a deep heritage and cultural ties to the federal forestlands. Maintaining access to the land 

for a variety of purposes is a primary concern. 

The plan documents are quick to point out all kinds of real and perceived problems 

caused by roads. It fails to provide an objective, balanced discussion by also pointing out 

the many benefits of a well-planned and maintained road system. If roads are in poor 

condition it is because of the collapse of the timber sale program that used to provide the 

funds to maintain them. Spending scarce taxpayer dollars to obliterate roads, when there 

are so many more pressing and obvious resource restoration needs makes no sense. 

We are concerned that the proposed plan, while it may not in itself close or 

decommission a road, does in fact set the table for widespread road/trail closures and 

decommissionings in the future. These must not be done in a vacuum. Public participation 

and collaboration with local elected representatives is essential. 

H.R. 4272, introduced in the House by Congressman Greg Walden would require the 

Forest Service to consult with and obtain concurrence from each affected county on 

proposed travel management actions affecting motorized or non-motorized access to 

National Forest System lands. This includes actions such as the decommissioning of roads 

and trails, a change in the status of a road as open or closed, or a change in forest road 

densities. 

The Forest Service should follow the lead of this legislation and build an open, 

transparent, and participative public process around travel management. County 

governments should be consulted and agreements should be required. We ask the agency 

to modify the Alternatives to reflect this approach to access-related issues. 

Grazing 

We are very concerned over the impact of the plan's directions, standards, and guidelines 

on cattle and sheep grazing. The underlying premise seems to be that all grazing is bad 

and the more there is, the worse conditions get. We disagree and point to many examples 

where range conditions have improved over the last 20+ years through improved practices 

rather than elimination of grazing. 

Some of the claims and statements about the current grazing situation just don't pass the 

sniff-test. For example, in the Analysis of the Management Situation, it is stated that 

"grazing on national forest lands directly provide about three percent of the forage needs 

of the local cattle inventory" (p. 148). The total grazing land within the plan area
is approximately 3,395,000 acres (Vol. 1, p. 135). If this area is only providing 3% of local 

forage needs, then it is quite obviously wildly under-utilized. The figure implies that over 

113 million acres of similar lands, grazed at the same level of intensity, would be required 

to provide all of the local cattle inventory's forage needs (3,395,000 + 0.03 = 113,166,667 

acres). This is almost twice the size of the entire State of Oregon! 

This statement either needs to be corrected or the agency needs to provide an 

explanation of how the 3% figure was arrived at. As is, it gives the uninformed public the 

misleading impression that grazing on national forest lands is an insignificant use that 

could be easily eliminated. 

The presentation and analysis of the grazing issue and environmental impacts is very 

confusing to say the least. For example, we believe that the impact of the lower (25%) 

utilization standards in riparian areas with bull trout spawning and rearing reaches under 

Alt. E - and anadromous fish reaches under Alt. F - on livestock grazing could be very 

significant but the analysis seems to show no impact at all. 

The stricter guidelines in Alt. E and F would apply to 53 subwatersheds containing bull 

trout (640,000 acres, 36% of forest area) and 88 watersheds inhabited by anadromous fish 

(905,000 acres, 50% of forest area) (Vol. 1, p. 309). Yet, the permitted cattle AUMs for Alt. 

E and F are the same as Alt. A for all 3 forests.

• How can this be if Alt. E and F have lower utilization standards in riparian areas 

across 36% to 50% of the forest as compared to Alt. A?

• How can Alt. F have the same cattle AUMs as Alt. E if it has the additional low 

utilization standards on anadromous fish reaches as well as bull trout reaches?

Cattle AUMs for Alt. C are said to decrease due to riparian buffers being designated as 

unsuitable for grazing. Alt. D has higher cattle AUMs due to smaller riparian buffers. Yet, 

the change in utilization within bull trout and anadromous fish reaches under Alt. E and F 

have no effect on cattle AUMs. How can this be? 

There are also inconsistencies in the descriptions of the alternatives relative to riparian 

grazing standards, particularly between Alt. E and F. The description of Alt. E on Vol. 1 p. 

38 states that utilization guidelines place additional limits on grazing in subwatersheds 

with bull trout and anadromous fish reaches. The description of Alt. Fon p. 40 says the 

same riparian grazing proposals are made for Alt. E and F. The text on p. 309 (Vol. 1) also 

indicates that the stricter restrictions apply to both bull trout and anadromous fish 

reaches in both Alt. E and F. However, elsewhere in the document, the guidelines differ 

between Alt. E and F. Table 83, (Vol. 1, p. 134) shows different guidelines for maximum 

utilization within riparian management areas for Alt. E and F. The 25% utilization guideline 

for Alt. E is only applicable to bull trout reaches; the standard for other watercourses 

including anadromous fish reaches is 40%. Alt. F has different utilization standards 
including 30% in bull trout reaches and 35% in anadromous fish reaches. The table 

accompanying Guideline G-115 for the preferred alternative (Alt. E) on page 141 of the 

Proposed Plan has yet a different set of utilization standards than is shown for Alt. E in 

Table 83. Further, the Guideline G-115 on page 141 differs from the Guideline G-115 for 

Alt. E on page 299 of Vol. 3. This version also shows that the lower utilization standard 

only applies to bull trout reaches, not anadromous fish reaches. Which is the Forest 

Service proposing? How can the public make any sense out of this? 

The obvious inconsistencies and lack of adequate explanation do not provide us with any 

reason to believe this issue has been correctly analyzed. 

The lack of clarity extends into the socio-economic analysis of grazing. The estimated 

employment contribution from Range (# of jobs) increases between Alt. A and Alt. E on 

the Malheur (Vol. 1, Table 58, p. 114} even though AUMs for cattle and sheep are exactly 

the same in each Alternative (Vol. 1, Table 57, p. 113}. On the Wallowa, AUMs are the 

same between Alt. A and E and the number of jobs are the same as well. We find these 

inconsistencies hard to rationalize. 

The plan documents also provide inconsistent AUM numbers in different parts of the 

report. For example, Plan Table 26 (objectives) indicates preferred alternative Objectives 

of 35,800 AUMs and 80,500 AUMs (cattle and sheep) for the Umatilla and WallowaWhitman, forest respectively. However, Table 57 (Vol. 1, p. 113} shows totals of 34,600 

and 81,500 AUMs for the same forests under Alt. E. It is also not clear how many AUMs 

the forests are currently providing so it is hard to determine the impacts of the 

alternatives. Different "current" numbers are cited in different parts of the documents. 

We are also concerned that the ever more restrictive limitations and standards on grazing 

are not justified. The agency's own analysis of the situation indicates that current 

standards are working:

"Measures more restrictive than those of the 1990 forest plans were 

implemented in 1995 with the intent of protecting, conserving, and 

managing riparian habitats for protected resident anadromous fish 

species. Monitoring of the effectiveness of these measures began in 2001 

as required by the PACFISH/INFISH biological opinion (PIBO}. To date, 

repeat PIBO sampling has been completed on more than 200 monitoring 

reaches in the Blue Mountains ... monitoring information combined with 

long-term camera point monitoring and professional observation, 

indicated that there has been recovery in many areas for many of the 

parameters most closely associated with livestock grazing effects ... " (Vol. 

1, p. 135)
The analysis goes on to point out that improvement has not occurred at all sites or for all 

parameters but, "at the scale of the Blue Mountains, favorable trends have been observed 

in 18 of 24 aquatic and riparian habitat variables measured at managed sites ... " (Vol. 1, 

p. 135) and, "with specific areas of concern remaining, many riparian areas and wetlands 

have improved relative to reference conditions (and relative to the early 1990s). It is 

believed that recovery is continuing at a relatively slow but steady rate" (Vol. 1, p.136). 

If the current standards and management practices under PIBO are working, what is the 

justification for imposing stricter grazing standards now? If the agency is concerned about 

the relatively slow pace of improvement in this case, why is it so seemingly so 

unconcerned about the slow pace of forest restoration, which is a much more substantial 

and urgent issue? 

The 40% utilization standard seems to be based on Holechek et al. (2006). This paper is 

based on arid and semi-arid lands and is not an appropriate scientific basis for these 

forests. It is not "best science." The current 45% utilization standard should be maintained 

without a clear scientific rationale, based on relevant local research, for reducing the 

standard. 

We could find no scientific justification for the 25% utilization standard in riparian areas. 

What is the scientific basis for asserting this standard? We believe the standard may be so 

low that grazing will become uneconomic and grazing numbers will fall far more than is 

characterized in the analysis. 

According to a BLM paper by E. Crowley (2002) titled, "Guidelines for Establishing 

Allowable Levels of Streambank Alteration," the science around the relationship between 

streambank alteration and stability is not well-established and few guidelines exist that 

establish the amount of streambank alteration a stream can tolerate. Greenline, woody 

species regeneration, and stubble height or utilization are the typical monitoring 

methods. Research has established some utilization and stubble height criteria. 

"Managing Grazing of Riparian Areas in the lntermountain Region" (lntermountain 

Research Station GTR-INT-263, 1989) is a guidance document for planning riparian 

procedures on national forests in the lntermountain Region but says it is applicable to 

other regions as well. In summary, it says that the level of utilization on a site, including 

riparian areas, is the most important consideration. To achieve protection, the report 

recommends a minimum herbage stubble height at the end of the growing season of 4-6 

inches in height. Special situations such as critical fisheries habitat might require stubble 

heights of greater than 6 inches. It goes on to recommend maximum utilization of 65% in 

the spring, 40-50% in summer, and 30% in the fall. These recommendations seem to 

generally support a higher maximum utilization than the 40% guideline in the DEIS.
The same report also says that an inventory of 250 miles of national forest riparian areas, 

no single grazing strategy (guideline) was found to be effective in every riparian situation. 

So, one could easily argue that these guidelines should be interpreted as flexible guides, 

not fixed standards, and applied with site specific characteristics in mind. 

Another Forest Service report (PNW-GTR-362, 1995) suggests "warning signs" for riparian 

grazing that allow higher utilization. This report suggests a 3-inch stubble height for "the 

most palatable species" as a warning sign, with 3/4-inch stubble height or drying of the 

vegetation as a second warning sign upon which the livestock should be removed. This 

would seem to indicate that the DEIS guidelines might be excessive. 

In sum, EOCA suggests that the FS needs to provide a better scientific basis for the 

utilization standards proposed in the alternatives. 

Relative to sheep grazing standards in relation to bighorn sheep, we have the following 

concerns. On Vol. 1, p. 144, after citing various studies, the document states, " it is 

recommended that site-specific solutions for each bighorn sheep population and 

domestic sheep allotment be developed based on a management strategy appropriate for 

the complexity of the situation." Further, it states that each of the alternatives takes this 

approach. 

Despite this, all of the Alternatives impose eight new guidelines (RNG-12 - RNG-19) that 

impose a number of onerous new requirements on permittees in addition to current 

protections. Some of the new Guidelines are vague - RNG-17 requires that domestic 

sheep and goats be individual marked in a manner that allows immediate identification 

"at a distance." How is "at a distance" defined? Do they need to be identifiable from a 

mile away, from an airplane? How will such unclear language be interpreted in a court 

case? 

While we appreciate that these are Guidelines rather than Standards, and thus allow for 

some flexibility, overall this approach seems to violate the recommendation for

"site-specific solutions." Rather than imposing these guidelines at the forest plan level, we 

suggest that they be alternative solutions considered as individual allotments are 

reviewed. 

Insufficient Evaluation of Social Effects 

The evaluation of consequences to Social and Economic Contributions to Well-Being 

(Issue 2) is described as follows: "The evaluation of effects focuses on the economic 

contribution of the alternatives on local economies, the effect of changes in management 

activities on goods and services, and the resulting impacts on users and their values." 

However, the last point is not fully addressed by the key indicators of jobs, income, and 

harvest levels that come out of this section, nor by the discussion of impacts to non 

market values.
This section includes a discussion of effects on Social Values, but the selected resource 

and socioeconomic indicators used to compare the alternatives are inappropriate for the 

types of social issues raised repeatedly by the Counties (e.g., poverty, drug and alcohol 

abuse, crime, domestic violence), or values related to living in cohesive rural communities. 

It seems likely that these issues would have also been raised during the public scoping 

process and may be glossed over due to how public comments were coded. The work by 

James Kent and Associates is the source of the identification of Social Values. They 

grouped 1,700 public comments into 10 value types, including economic values and 

cultural values. Unfortunately, no information is provided as to the content of those 

comments; only a count by type is provided. 

While it's understandable that a coding/grouping process would be used to capture public 

comments, we are concerned that the process used in this instance has obscured 

comments related to the values attached to the culture of the local communities the 

forests support. 

As such, the indicators identified to evaluate impacts to cultural values seem inadequate 

to capture the variety of cultural values that were likely expressed. Alternative impacts on 

these values are described using the percent of the national forest available for summer 

motor vehicle use (Table 71) and acres of vegetation management activities for fuel 

treatments and timber harvest (Table 72). Motor vehicle access is used because gathering 

food, firewood and other supplies and reaching important places are facilitated by access. 

Acres of vegetation management are used because firewood gathering is often a side 

product of vegetation management activities. Vegetation management also often 

enhances habitat for large vertebrate species, such as deer and elk. 

While access is certainly a critical issue, it seems likely that measuring motor vehicle use 

and vegetation management does not reflect the full spectrum of cultural values that 

were likely intended by the comments. We know that residents value "communities which 

are relatively safe and family-oriented" (James Kent and Associates 2006) but 

consequences for these types of cultural values are not discussed. Effects to other cultural 

values deserve consideration as well in the evaluation of alternatives. Unfortunately, 

effects on community cultural values are not being appropriately measured by the 

selected indicators.

Cumulative Effects – Socio-Economic Analysis

Three statements are made regarding cumulative effects on mill infrastructure and 

employment within the three socio-economic impact zones:

• Malheur - "The higher levels of timber harvest and resulting employment 

under alternative D and E may be enough to support existing and possibly 

expand wood manufacturing infrastructure." Vol. 1, Page 122.
• Umatilla - (re alternatives D and E) - "The increase in timber harvest can 

contribute to the maintenance and expansion of wood products 

manufacturing infrastructure." Page 123.

• Wallowa-Whitman (re: alternative D, nothing about E)- "The increase in 

timber harvest can contribute to the maintenance and expansion of wood 

products manufacturing infrastructure." Page 124.

The CEQ defined a cumulative effect as "an impact on the environment which results from 

the incremental impact of an action when added to other past, present, and reasonably 

foreseeable future actions regardless of what agency (Federal and non-Federal) or person 

undertakes such other actions" (40 CFR 1508. 7). 

The Ninth Circuit has established that a cumulative effects analysis (CEA} must include 

detailed information; a clear analysis of effects on resources, not just a description of 

actions; and an explanation of the rationale behind the conclusions in a CEA.25 "General 

statements about 'possible' effects and 'some risk' do not constitute a 'hard look' absent a 

justification regarding why more definitive information could not be provided."26 The fact 

that the DEIS just says levels of timber harvest "may be enough" and "can contribute" 

does not sound to us like a "hard look." 

Further, these general assertions are unsupported by the facts. The study by Adams and 

Latta (2007), which is cited in the DEIS at page 122, forecasts significant declines in 

harvests from forest industry and non-industrial private lands over the next several 

decades. Under the base case scenario, harvests in eastern Oregon decline to about twothirds of recent historical levels by 2023. According to the study, the forecasted decline in 

harvest volume precipitates mill closures, which are concentrated in the Blue Mountain 

region. 

We previously provided the planning team with an estimate that 243 MMbf/year of 

appropriately sized sawlogs needs to be harvested from the three national forests just to 

keep the currently operating regional mills running. A 339 MMbf/year supply of sawlogs is 

needed to support re-opening two idled mills in Grant County. 

A recently released study by American Forest Resource Council and Associated Oregon 

Loggers527 provides similar figures showing that 335 MMbf of sawtimber from the three 

national forests is needed to sustain 10 local mills (including the two idled mills) at 79% of 

full capacity and 405 MM bf is needed to sustain all mills at full capacity.

 25 Schultz, 2012. History of the Cumulative Effects Analysis Requirement Under NEPA and Its 

Interpretation in U.S. Forest Service Case Law. 26 9th Circuit Court decision in the Neighbors of Cuddy Mtn. v. U.S. Forest Service (1998).

27 Forest Sector Infrastructure in Northeast Oregon's Blue Mountains, AFRC & AOL, July 29, 2014.
None of the alternatives comes close to this level of harvest. The Preferred Alternative has 

a combined TSPQ of just 100 MMbf. According to the AFRC/AOL analysis, this will result in 

the permanent closure of 5 mills and leave the remaining 5 mills running at just 60% of 

full capacity. 

In case there is a worry that AFRC/AOL is "padding the numbers," both the numbers and 

the dire consequences of a continuing shortfall of federal timber are echoed in a 2013 

report on eastern Oregon primary wood products industry by Larry Swan, USDA Forest 

Service State & Private Forestry:

"The consequences of losing primary processing infrastructure, such as 

sawmills and manufacturers that use processing residuals, are evident in 

states such as Colorado, New Mexico, Arizona and Utah. The industry 

practically disappeared by the mid- to late-1990s, and as a consequence 

it became very difficult to conduct ecosystem restoration and fuels 

reduction projects of any scale unless heavily subsidized. Tens of millions 

of public funding have been expended over the last 15 years with limited 

success to recreate primary processing infrastructure to help manage 

public and private forest lands. Many critics point to the lack of funding 

as the primary reason that progress has been so slow. Others note that 

private capital tends to follow sustainable and consistent supply. 

Although longer-term contracts have begun to be issued by the Forest 

Service, indications are that it will take much longer to build an 

experienced workforce, and for business owners to gain sufficient 

experience and financial stability to begin to make a minimal impact on 

the backlog of ecosystem restoration and fuels reduction needs of the 

region. A similar scenario could unfold rather quickly in some areas of 

Eastern Oregon."28

In our opinion, it is reasonably foreseeable that the industry infrastructure in the Blue 

Mountains will continue to shrink under all Alternatives given dwindling supplies from 

private lands and modest increases in harvesting from the three forests. Unsupported 

statements such as those cited above indicate that the Forest Service has not completed a 

rigorous analysis and is not taking a hard look at the cumulative social and economic 

impacts of the plan revision.

 28 Larry Swan, Eastern Oregon Primary Wood Products Processing Facilities and Operations. Working Draft, November 

2013. USDA Forest Service State & Private in cooperation with Oregon Business Development Dept.
Cumulative Effects and the BLM Sage Grouse Plan Amendments

The Oregon Sub-Region Greater Sage-Grouse Draft Resource Management Plan 

Amendment and Environmental Impact Statement is listed in Appendix C as a plan that 

was considered in the cumulative effects analysis. However, it is not clear how the plan 

was specifically factored into the analysis of cumulative economic effects. Since the Blue 

Mountain Forests Plan socio-economic impact zones partially overlap with the primary 

study area for the Sage-Grouse RMP DEIS, we would expect the EIS to take a hard look at 

the cumulative economic impacts from implementation of the Sage-Grouse Draft 

Resource Management Plan Amendment and the Blue Mountain Forest Plan Revision, 

regardless of how significant the impacts are determined to be. 

We are especially concerned that the cumulative effects of the revised forest plans and 

BLM sage grouse amendments on livestock grazing have not been analyzed

COMMENTS ON THE PREFERRED ALTERNATIVE

We are opposed to the Preferred Alternative (Alt. E) for the following reasons:

(1) Our primary concern with the proposed land management plan revision is that it does 

not adequately address the magnitude of the forest health issue before us and has not 

kept pace with the new restoration efforts that are just now getting underway. We are 

concerned that, as written, the proposed plan could become an impediment to more 

aggressive, active management that we recognize is needed. It does this by setting aside 

too many acres under passive management and setting targets for accomplishments that 

are too low in relation to the need because it is constrained by budgets and "more of the 

same" thinking. The following points elaborate on the details of our concerns.

(2) In Management Areas 1B and lC, the Preferred Alternative sets aside more than 

93,000 acres for possible addition to the existing 760,000 acres of 

Congressionally-designated Wilderness areas, an expansion of more than 12 percent. 

Currently, designated Wilderness Areas encompass nearly 16 percent of the Plan Revision 

project acreage. Including the 217,000 acre Hell's Canyon Wilderness in the HCNRA, the 

acreage devoted to this single-use jumps to nearly 1 million acres or 18 percent of the 

area of the Blue Mountain forests. Adding another 93,000 acres raises this above 1 million 

acres and almost 20 percent of the forests' land base including the HCNRA.

Yet, no justification for this additional withdrawal from multiple-use management to 

single-use, Wilderness designation is presented. In fact, the analysis completed in 2010 by 

the planning team argues against these additional designation of Wilderness.
The Wilderness Needs Assessment, summarized in Vol. 3, Appx. F, concluded the 

following:

• Recreational use in Wilderness Areas accounts for only 8 percent of the overall use 

of the Blue Mountains, and only 4 percent of the use of the national forest lands in 

the general vicinity.

• Trend data shows that aging populations and shifts in the type of activities 

younger people are interested in will result in a 2 to 8 percent increase in demand 

for activities during the next 15 years. This increase will primarily be in day use 

from nonwilderness areas.

• Current wilderness areas in the Blue Mountains reach capacity only in specific 

areas during brief high use periods.

Further, the Analysis of the Management Situation states, "Although social desires exist 

for more wilderness areas across the Blue Mountains, there is not a social need to 

designate additional wilderness because the current wilderness areas are not exceeding 

capacity ... Wilderness use is unlikely to exceed the capacity of the existing wilderness 

areas and is not likely to result in a need for more wilderness in the next 15 years." 

In regard to other reasons for additional Wilderness designation, the Needs Assessment 

found:

• No recommendations for additional designated wilderness are needed to provide 

refuge for native species.

• Wilderness designation is not needed for "preservation of landform types and 

ecosystems."

There is no indication in the documents that the majority, or even a large minority, of 

public comments supported more Wilderness. The DEIS merely says that there were 

comments both in favor and against creation of new wilderness areas. 

We also point out that there is already 14,600 acres in the Homestead Wilderness Study 

Area, mostly on BLM lands, that has been sitting in limbo since 1992 awaiting a 

Congressional decision. Additional land that is set-aside for Congressional action will 

almost certainly remain in a similar limbo for decades. 

For these reasons, we do not support the designation of any area as Preliminary 

Administratively Recommended Wilderness Area (PARWA) because there is no need for it. 

Setting aside these lands for possible, eventual Congressional designation as Wilderness 

eliminates the possibility of active management to restore resilient, healthy forest 

conditions, manage wildfire and insect/disease outbreaks.
We ask that no acres be included in Management Areas 1A and 1B in the final decision. 

(3) For the same reasons, we do not support the designation of Backcountry Motorized 

and Nonmotorized areas (Management Areas 3A and 3B). Under the Preferred 

Alternative, this area, totaling 653,400 acres, represents a near tripling of the acres 

designated as backcountry under the No Action Alternative A. In our opinion, all of the 

acres within this designation should be returned to General Forest (MA 4A and 4B) 

because neither Backcountry designation does anything to further the effort to restore 

the resource to a resilient, healthy condition. Nor does it provide any significant economic 

or social benefit to the surrounding communities. Instead, it is another hindrance to 

active management on another 13 percent of the land base.

The Backcountry Nonmotorized designation, MA 3A, totaling 228,200 acres in the 

Preferred Alternative is especially troublesome. Acres designated as such rise from 77,295 

acres under Alt. A to 228,200 acres under Alt. E. Based on the description of the MA and 

the suitability matrix, this designation is essentially de facto Wilderness, only designated 

by the agency decision-makers instead of Congress. Although the MA is "suited" for 

timber harvest it is unclear how any harvest can be done without motorized equipment 

and with the prohibition against new road construction under the Standards. Standard 

"MA 3A/B BACK-2 5-59" limits new road construction to that "required for special uses" or 

to provide access to non-federal lands required by law. 

The lack of the Backcountry designation will not diminish the dispersed recreational 

opportunities that are available on these lands, ranging from semi-primitive to primitive 

experiences. 

We ask that no acres be designated as Backcountry and included in Management Areas 

3A and 3B in the final decision. 

(4) Management Area 4B - Riparian Management Areas - constitute 792,900 acres, or 16% 

of the project area. However, in reality, the proportion is much higher because the 

acreage associated with MA 4B includes only those acres that fall within General Forest 

(MA 4A). Given that, riparian area management constrains management in 29% of the 

general forest area.

While we do not question the need for RMAs of some sort, we do question the scientific 

basis of the riparian buffer widths dictated by the Region's Aquatic and Riparian 

Conservation Strategy (ARCS). ARCS adopted the buffer widths originally imposed by 

PACFISH/INFISH which were intended to be interim measures until better science was 

available. As such, they were very conservative, erring on the side of greater protection of 

riparian values. These buffer widths were based largely, if not entirely, on the much 

wetter conditions west of the Cascades.
The 2008 ARCS document provides no scientific rationale or research-based support for 

these buffer widths either in the westside or in the much drier terrain east of the 

Cascades. The brief, 2-1/2 page "Scientific Basis" in the ARCS document does not discuss 

any studies that address the stream buffer widths imposed by the strategy. To our 

knowledge, ARCS has never been subject to outside peer scientific review or public 

comment, yet it has become guidance for all national forest planning in the region. All 

national forest planning efforts are required to adopt the ARCS, including its specific, 

prescribed wording, into the preferred alternative. In the BMPR, only Alt. D departs from 

this directive. 

Rather than a "one-size-fits-all" strategy, there are clear differences in the riparian ecology 

and conditions between eastside and westside forests that should be taken into account 

by the agency. Recognizing the differences in eastside conditions, Washington State's 

forest practice rules have narrower riparian buffers and different leave tree requirements 

on the eastside vs. the westside. Oregon's forest practice rules also have different 

streamside tree retention requirements on the eastside vs. westside, again in recognition 

of the different conditions. 

We request, prior to finalization of the plan revision, that a science-based justification for 

the riparian buffer widths prescribed by the ARCS be added to the plan documents to help 

the public understand how this decision represents the best available science. If it does 

not, the Alternatives should be modified so that riparian management areas are designed 

based on best available science. 

(5) With regard to the management strategies within Riparian Management Areas, a more 

proactive approach is needed to treat overstocked conditions within RMAs to reduce the 

long-term risk of loss from catastrophic fires, insects, and disease. Management of 

vegetation within riparian areas through thinning has mostly been ignored over the last 

20 years and the buildup in fuels has made them more susceptible to loss. Recent 

experience here and elsewhere has shown that fires can burn just as hot through riparian 

zones as they do through upland forests. These areas are more sensitive and their loss has 

a greater overall ecological impact, including harm to threatened and endangered fish 

species. Therefore, it is even more important to protect the riparian areas from large scale 

disturbances.

The Tanner Gulch Fire, which occurred on the upper Grande Ronde River watershed of the 

Wallowa-Whitman forest in 1989, should have served as a wake-up call. This 

high-intensity burn is judged to have killed the entire 1989 adult spring Chinook salmon 

run in the upper Grande Ronde and eliminated much of the steelhead smolt production. 

Mudslides along small, burned-over creeks led to a major debris torrent in the Grand 

Ronde measured as far as 36 miles downstream. Ten years after the fire/flood event, this 

degraded stream was just starting to recover.
Yet the agency has not learned the lesson and continues to manage under a short-sighted 

strategy in which near-term risks from active management overwhelm thinking, 

preventing action, and the long-term risks of catastrophic loss are ignored. 

We request that adaptive management of riparian management zones be made a core 

part of the strategy for management of MA 4B. This includes adaptations to the 

designation of RMAs and active treatment to restore sustainable conditions based on 

evolving science and controlled experimentation. 

(6) We disagree with the timber salvage standards and guidelines under the preferred 

alternative (as well as Alts. B & F) that restrict timber salvage to less than 50 percent of 

post-fire source habitat, prohibit it entirely in burned areas less than 100 acres, and 

prohibit salvage of snags greater than 21-inches (WLD-HAB-19, 20, & 21).

These arbitrary limitations have not been adequately justified. When we have large, 5,000 

acre plus fires, which we are increasingly likely to experience in the future, the agency 

needs the flexibility to respond appropriately to provide for recovery of the resource as 

well as provide badly needed timber to area mills. To avoid a major insect build-up in firestressed trees, aggressive salvage is needed. 

(7) The TPSQ under Alt. E is inadequate to support the existing industry infrastructure. We 

have previously provided an estimate that 243 MMbf/year of appropriately sized sawlogs 

needs to be harvested from the three national forests just to keep the currently operating 

mills running. These include Boise at Elgin, Pilot Rock, and Mt. Emily, Blue Mountain 

Lumber in Pendleton, Malheur Lumber in John Day, and Guy Bennett Lumber in Clarkston. 

As previously discussed, an estimated 335 to 405 MMbf/year would be required from the 

forests to allow re-opening of the D.R. Johnson mills in John Day and Prairie City, restoring 

family-wage jobs where they are badly needed. An additional, predictable supply of 

sawtimber volume is needed to promote rebuilding of an industry in Harney, Baker, and 

Wallowa County, where it has already disappeared. This need is not even addressed.

These estimates take into account the long-term log supply available from private lands. 

They are consistent with the log supply requirements in a recent report on the primary 

wood processing facilities in eastern Oregon, prepared by Larry Swan, USFS State & 

Private Forestry. This information should have been included in the Affected Environment 

discussion. 

The plan document states in multiple places that the agency understands the importance 

of retaining the regional industry infrastructure and workforce in order to accomplish the 

needed restoration work on the forests and provide an outlet for the products resulting 

from treatments. Yet, the TSPQ for the Preferred Alternative falls far short of the need.
In the case of the Malheur forest, the TSPQ under Alt. E (56 MMbf) falls short of the 75 

MM bf promised by the Regional Forester in 2012.

CONCLUSION

The Eastern Oregon County Association and its member counties cannot support any of 

the Alternatives because, as the analysis itself shows, they do not make adequate 

progress toward achieving the key Desired Conditions either environmentally, socially, or 

economically. The pace and scale of restoration activity is simply insufficient to reverse 

the decline in resource conditions and to achieve key Desired Conditions within any 

reasonable timeframe. If implemented, we fear continued and increasing losses to 

catastrophic wildfire, insects, and disease causing degradation to fish and wildlife habitat 

as well as losses to economic and cultural resources. Our quality of life will be greatly 

diminished. We will see our logging, trucking, and milling infrastructure continue to 

shrink, losing half to two-thirds of its remaining capacity. With it, jobs will be lost, families 

and communities will be dislocated, and the ability to provide labor and capital to assist 

the agency in managing the resource will dissolve away. 

We do not believe this plan revision process can be salvaged by tweaking an alternative 

here or there or by beefing up the analysis or clarifying the documentation. The plan 

revision process has been on-going for 10 years. Much of the basic work is now 8-10 years 

old. In many ways, it seems that the science and our approaches to land management 

(e.g. collaboratives, stewardship projects, etc.) have moved beyond where we were 10 

years ago. The plan revision process, however, has not kept up and has not re-examined 

early assumptions, analysis, and directions in light of the progress made in the meantime. 

The proposed plan is a step backwards that we cannot afford to make. 

The agency must go back to the drawing board and start fresh with a re-examination of 

the basic Plan Components, such as the Goals and Desired Conditions, Management 

Areas, and Objectives. It must do this in light of new science and new approaches, and 

changed circumstances. It must learn from this process but design a new way forward; 

one that will work for the environment, economy, and communities. 

We, as the elected representatives of the communities most affected, want to continue to 

participate in that process. The resource is too important to our citizens to accept 

anything less than a plan that we can be confident will move us in the right direction.
Union County

August 6, 2014 

Ms. Sabrina Stadler 

Blue Mountains Plan Revision Team 

P.O. Box 907 

Baker City, OR 97814 

Dear Ms. Stadler: 

The Union County Board of Commissioners appreciate this opportunity to comment on 

the Blue Mountains National Forests Proposed Revised Land Management Plan and Draft 

Environmental Impact Statement ("BMPR"). Our comments are applicable to all three 

national forests, unless otherwise noted. 

Union County has been working with the Planning Team, as a Cooperating agency, since 

the very beginning of the BMPR process ten years ago. The eastern Oregon economy is 

largely resource-dependent and relies on access and productivity associated with public 

lands that dominate our landscape. Our communities are tied to the land culturally and 

economically. Our future economic and social well-being is dependent on wise 

stewardship of these lands. Thus, we have an enormous stake in the future of the three 

Blue Mountain national forests.

[NOTE: The remainder of the letter is a duplicate of the Eastern Oregon Counties 

letter above, with the exception of the following.]
Wallowa County Resolution

BEFORE THE BOARD OF COMMISSIONERS

IN AND FOR THE COUNTY OF WALLOWA

IN AND OF THE STATE OF OREGON

IN THE MATTER OF THE )

BLUE MOUNTAINS NATIONAL FORESTS )

PROPOSED REVISED LAND MANAGEMENT ) RESOLUTION 2014-005

PLAN DRAFT ENVIRONMENTAL IMPACT )

STATEMENT )

WHEREAS, the Blue Mountain National Forests were established from 1904 to 1907, 

under the provisions of the Act of March 3, 1891 and the Act of June 4, 1897 for the specific 

purposes of improving and protecting the forests, to secure favorable conditions of water flows, 

and, to furnish a continuous supply of timber, AND,

WHEREAS, the Blue Mountain National Forests were created with the support of the 

local population based upon the assurance to the public that the forest reservations were not in the 

nature of parks set aside for nonuse, but were established solely for the economic reasons set forth 

in the Acts of 1891 and 1897, AND,

WHEREAS, in recognition that the burdens placed upon county governments as a result of 

the creation of the national forest reserves should be shared by the nation, Congress directed that the 

receipts generated from the national forest system be shared with the counties, AND

WHEREAS, the national forests within its boundaries are the economic, recreational, social 

and cultural foundation of Wallowa County, AND,

WHEREAS, the national forests are required under the National Forest Management Act 

and the Renewable Resources Planning Acts, to develop Land and Resource Management Plans that 

reflect local conditions and in accordance with the purposes for which the forest reserves were 

created, AND,

WHEREAS, recent management of the national forests within Wallowa County have 

resulted in dramatic social, economic and forest health departures from the assumptions upon 

which the last Land and Resource Management Plan was based, AND,

WHEREAS, the departures from the Land and Resource Management Plan have been 

primarily the result of changing political theories rather than to reflect the changing forest 

conditions resulting from both natural and man-made disturbances, AND,

WHEREAS, the management strategies proposed in the Blue Mountains National Forests 

Proposed Revised Land Management Plan and Draft Environmental Impact Statement do not 

reflect the conditions on the ground or the resulting insect and fire cycles that have been 

experienced in the past on the Blue Mountain Forests, AND,

WHEREAS, Wallowa County in cooperation with the Eastern Oregon County Association 

retained forest scientists to review the proposed revised land management plan and draft

environmental impact statement and to thoroughly vet the scientific foundations of the documents, 

AND,
WHEREAS, Wallowa County has reviewed both the results of the science analysis and the 

proposed plan and finds that the plan inadequately addresses the real and urgent needs of both the 

natural resource and surrounding communities; is based upon unvalidated scientific theories; is 

unduly influenced by political pressure; and, fails to conform with the primary purposes for which the 

Blue Mountain Forests were established.

THEREFORE, BE IT RESOLVED, that the Wallowa County Board of Commissioners

finds all alternatives to be unfounded and requests that the Forest Service step back and reassess the 

conditions on the ground and develop a range of alternatives that address the on the ground conditions 

focusing on the need to improve and protect the forests; to secure favorable conditions of water 

flows; and, to furnish a continuous supply of timber.

DONE AND DATED this 11th day of August, 2014.

WALLOWA COUNTY BOARD OF COMMISSIONERS

_________________________ __________________________

Chairman Mike Hayward Commissioner Susan Roberts

_________________________ ___________________________

Commissioner Paul Castilleja Attest: David Riley, Exec. Asst.

7/14/2014

Perry Patrick

Wheeler County

PO Box 447 

Fossil, OR 97830

Dear Ms. Stadler:

Wheeler County is submitting this letter as public comment on the Blue Mountain 

Forest Plan. Wheeler County could support alternative "D", but is especially 

concerned about this, new to us, "Back Country Designation". We feel this is 

creating wilderness without congressional process and taking lands out of 

production that could ultimately support roads and schools through timber receipts.

Wheeler County also has concerns about limiting livestock grazing on public lands; 

a revenue that comes to counties in the form of "Taylor Grazing Receipts", which 

counties receive a share of the revenues.

Alternate "D" would allow for vacant and/or inactive allotments to be used with an 

end result of more revenue to counties, which would enable them to provide more 

services to the public that uses these public lands.

When a person who is on national forest lands needs emergency services, be it 

ambulance, Search and Rescue or law enforcement, the call to 911 goes to 

dispatch, who then sends out county resources that are currently getting less 

support from the forests and placing more of the burden on local general funds.

Please consider alternative "D". It gives the most support to local Timber 

dependent communities.

Sincerely,

Patrick C. Perry

Wheeler County Judge

Allison O'Brien

U.S. Department of the Interior

Regional Environmental Officer

620 SW Main Street

Suite 201

Portland OR 97205

August 13, 2014

Sabrina Stadler

Blue Mountains National Forest

1550 Dewey Ave. 

Baker City, OR 97814

Dear Ms. Stadler:

The Department of the Interior has reviewed the U.S. Forest Service Draft 

Environmental Impact Statement for the Proposed Revised Land Management 

Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests, Oregon. 

The Department has no comments on the document at this time.

We appreciate the opportunity to comment.

Sincerely

Allison O’Brien

Regional Environmental Officer

Unites States

Department of 

Agriculture 

Forest Service Region 1

Nez Perce National 

Historic Trail

12730 Highwya 12

Orofino, ID 83544

File Code: 2350-1

Date: July 14, 2014

Sandi McFarland 

Administrator 

Nez Perce National Historic Trail

12730 US Hwy 12 

Orofino, ID 83544

Sabrina Stadler, Forest Plan Revision Team 

Blue Mountains National Forests 

P.O. Box 907 

Baker City, Ore on 97814 

Dear Ms. Stadler, 

The Nez Perce National Hjstoric Trail is potentially impacted by your draft Proposed Revised Land 

Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests. 

The Nez Perce National Historic Trail is not assessed in this plan revision even though the Trail 

crosses both Wallowa Valley Ranger District lands and the Hells Canyon National Recreation Arca. 

This revision considers the Nez Perce National Historic Trail has already assessed under the 2003 

Hells Canyon National Recreation Arca Comprehensive Management Plan (HCNRACMP). The 

HCNRACMP did not fully assess the Nez Perce National Historic Trail. That Plan addressed the 

section of the Trail as a nonnal forest system trail not a congressionally designated trail under the 

National Trails System Act of 1968 (as amended). 

Neither the HCNRACMP nor this document addresses the Nez Perce National Historic Trail Auto 

Tour routes or recreational facilities located on the Wallowa-Whitman National Forest. 

I am attaching our comment response for your review. 

If you have any further questions please contact Julie Molzahn, Nez Perce National Historic Trail 

Comprehensive Management Plan Coordinator at 406-826-4352 or jmolzahn@fs.fed.us.

SANDI MCFARLAND 

Administrator 

Nez Perce National Historic Trail 

CC: Aaron Mahr, Superintendent Intermountain National Trails Office Tami DeGrosky, 

Superintendent Nez Perce National Historic Park 

Attachment
Nez Perce National Historic Trail Response

To Blue Mountain National Forests

Proposed Land Management Plan Revision

7.14.14

Summary 

Page 3- This page indicates that because the Hells Canyon National Recreation Area (HCNRA) 

Comprehensive Management Plan was completed in 2003 that resources located with the in 

HCNRA will not be further addressed. The 2003 HCNRA Comprehensive Management Plan does 

not address the Nez Perce National Historic Trail (NPNHT) nor does it refer to the 1990 NPNHT 

Comprehensive Plan to incorporate the Plans direction by reference. This Plan revision will need to 

address the NPNHT. We are requesting that a Management Area be established for the NPNHT like 

this Plan revision has developed for the Oregon National Historic Trail (ONHT). The NPNHT is 

designated across the Wallowa Valley Ranger District before it enters into the HCNRA so the 

assumption that the NPNHT is only in the HCNRA is erroneous. The NPNHT also have auto tour 

routes that travel across the HCNRA and Wallowa Valley Ranger District that need to be assessed. 

Page 7 - please list the NPNHT and ONHT specifically has the two National Historic Trails located 

within these Forests under the Special Area Description. 

Page 56 last paragraph- Add the NPNHT and ONHT Auto Tours has dispersed facilities along with 

Scenic Byways. 

Page 57 paragraph 4- specifies NPNHT and ONHT under the discussion about destination trails or 

add a discussion about the significance of National Historic Trail to Backcountry Recreation 

section. 

Page 60-62 Roads and Trails Access- please add NPNHT to this discuss in the first paragraph on 

page 60 where there Is a discussion of routes significant to Nez Perce and Umatilla Tribes. 

Page 68 Landownership- the NPNHT and ONHT are areas where purchasing parcels for trail 

protection is a priority. Please add a discussion about acquiring lands for the protection of these 

national historic trails. 

Page 76 Management Area Designation- please changes this table to include NPNHT acreage in 

HCNRA since that plan did not address the NPNHT. Drop the reference that the NPNHT is not 

included in the acreage because it is addressed in the HCNRA. The NPNHT starts outside the 

HCNRA as stated above. 

Page 85 Table 21- National designated trails- please add NPNHT trail mileage and for each national 

historic trail the mileage includes their accompanying auto tours which are not address for either 

NPNHT or ONHT in this document.
General Concern- there is no Standards or Guidelines for Management Area 2G National Trails so 

this could allow non-compatible uses such as timber harvesting within trail corridors and use of 

heavy equipment on the trails. The NPNHT is hiking and equestrian use only however this is not 

mentioned anywhere in this document or the HCNRA Comprehensive Plan. 

Please develop Management Area standards and guidelines for National Trails and include NPNHT 

in this discussion. This is Management Area description below is one that the NPNHT developed 

with the Shoshone National Forest revised LRMP for the NPNHT Management Area similar to your 

plans 2G. . I am including as an example for you to consider: 

The Nez Perce (Nee-Me-Poo) National Historic Trail (NPNHT} is managed to protect its historical 

values while providing recreation opportunities in a natural appearing landscape consistent 

with The 1990 Nez Perce National Historic Trail Comprehensive Plan and any revisions therefore 

after (USDA Forest Service 1990).

Desired conditions

The NPNHT protects the historical values for which the NPNHT was designated while 

providing a high quality scenic, primitive hiking and pack and saddle stock experience. 

Activities within the NPNHT corridor will not preclude further management options 

for the NPNHT. A variety of compatible recreation opportunities are provided. Access 

to the NPNHT is primarily by foot and horseback. Roads and motorized trails are not 

present except at designated crossings. 

The NPNHT corridor Is characterized by a predominantly natural appearing 

environment. Improvements such as trailheads, trails, signs, bridges, and fences that 

enhance the recreation opportunities may be present. Evidence of past and present 

resource management may exist, but blends with the natural appearance of the 

landscape. Vegetation alterations may be present to enhance viewing opportunities.

On page 144 there is a sentence indicating no specific standards and guidelines are including in 

the plan for Management Area 2G National Trails. Why is there a designated Management Area 

with no standards and guidelines to protect values? This list also includes Management Area 2F 

Scenic Byways and All-American Roads. 

Additionally of concern is that there are no Standard and Guidelines for Management Area 2F 

Scenic Byways and All-American Roads. There needs to be some description and discussion of the 

protection or preservation of scenic integrity and recreation opportunities along these roads. 

Additionally we would like to request that the NPNHT and ONHT Auto Tour routes be added to this 

Management Area designation. 

Volume 1 

Page 52, Tables 4 and 5 do not include the NPNHT mileage under MA2G 

Page 69, paragraph 1, Please add a sentence about the 1877 Nez Perce War and Flight beginning 

in the Joseph, Oregon area which the Chief Joseph band leaving their homelands.
Volume 2 

Page 48 paragraph 1, 4th sentence- There is a discussion on how several alternatives will not allow 

any additional trail construction because of wildlife concerns. The NPNHT has not been fully 

mapped, designated and constructed on the Wallowa Valley Ranger District into the HCNRA. 

Please clarify if this direction will impact future development of the NPNHT. 

Page 388-390, Recreation Settings- Include a discussion of the NPNHT, associated interpretive site 

within the Wallowa Whitman, and Auto Tours in this section as part of existing condition. 

Page 415, Table 386 Designated Trails- Please drop the language about NPNHT covered under 

HCNRA and add it to this table and the discussion about Nationally Designated Trail on this page. 

Page 422, Scenery Resource discussion- Please add NPNHT and ONHT in this discussion about 

specific sites that have scenic attributes to be preserved. These are Congressional designated trails 

which should be considered as high under the scenic integrity measure. 

Page 426- Heritage Program discussion- There Is no mention of the NPNHT or ONHT in this 

discussion has existing historic resources to be managed. Please add both Trails to this discussion 

and assess the plans effects on their historical character. 

Volume3 

Glossary, page 33-Add National Trails System Act and National Historic Trails to this page 

Appendix A, page 159, Table A-1, Management area designation- This table is showing no acreage 

for either Management Area 2F Scenic Byways and All-American Roads and Management Area 2G 

National Trails. How can a designated management area have no acreage? Are these truly 

protective and manageable areas? 

Page 216, MA 2F Scenic Byways and All American Roads - Please consider adding NPNHT and 

ONHT Auto Tours to this management area and discussions. Please consider developing standards 

and guidelines for this management area. 

Page 216-217, MA 2G Nationally Designated Trails- Please add NPNHT to this management area 

and discussions •. Please consider developing standards and guidelines for this management area. 

Page 369, Appendix C, Cumulative Effects - list of associated plans-Land Management Plansplease add:

• 1990 Nez Perce National Historic Trail Comprehensive Plan

• 1999 Management and Use Plan Update Final Environmental Impact Statement, Oregon 

National Historic Trail and Mormon Pioneer National Historic Trail, U.S. Department of 

Interior National Park Service

Maps- Please add NPNHT to all the Plan maps associated with recreation, trails and roads.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

REGION 10

1200 Sixth Avenue, Suile 900

Seattle, WA 98101-3140

OFFICE OF

ECOSYSTEMS, TRIBAL, AND 

PUBLIC AFFAIRS

August 15, 2014

Ms. Sabrina Stadler 

Forest Plan Revision Team Leader 

Blue Mountains Forest Plan Revision 

P.O. Box 907 

Baker City, Oregon 97814

Re: EPA Region10 Comments on the Draft Environmental Impact Statement and Proposed Revised Land 

Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests 

(EPA Project 10-015-AFS)

Dear Ms. Stadler: 

We have reviewed the above-mentioned Draft Environmental Impact Statement (DEIS) and Proposed 

Revised Land Management Plan (Forest Plan) in accordance with our responsibilities under the National 

Environmental Policy Act (NEPA) and Section 309 of the Clean Air Act. Under our NEPA Review policy 

and procedures, we rate DEIS documents by considering both the adequacy of the document and the 

potential environmental impacts of the action. 

The DEIS documents the analysis of a No Action Alternative (Alternative A), and five action alternatives 

(Alternatives B through F). The Action Alternatives address five purposes and needs for the revised plans: 

(l) to more adequately protect and restore terrestrial plant and animal species and their habitats; (2) to 

address management of fuels and fire risk; (3) to more adequately protect and restore watersheds and 

aquatic habitats; (4) to address climate change; and (5) to recognize the interdependency of social and 

economic components with national forest management. Alternative 8 is the Modified Proposed Action, 

and Alternative Eis identified as the Preferred Alternative. Alternative E would use vegetation 

management, aquatic and wildlife habitat treatments to emphasize active restoration to a greater extent 

than Alternative 8. With regard to roads, Alternative E would focus on reducing hydrologic connectivity 

to roads as opposed to focusing on a metric related to road density. Consequently, riparian and aquatic 

habitat improvement activities and road maintenance proposals for investments in aquatic restoration 

within key and priority watersheds would be greater under Alternative Ethan under Alternative 8. 

The EPA is supportive of the overarching direction of Alternative E. We support the guidance provided 

within the 2014 revision of the Interior Columbia Basin Strategy and Aquatic Framework (IC8 

Strategy)29. Our review of the DEIS finds Alternative E to be largely consistent with this strategy. 

Although our review does not focus on Alternative D, we would like to establish that the EPA would not 

support the riparian strategy proposed under Alternative D. We agree with the conclusions reached in the 

DEIS on page 280 regarding the Alternative D riparian strategy. This alternative would likely result

 29 http:/iwww.icbemp.gov/html/lCBEMP Frameworkmemorandum-and-strategy 2014.pd
in a declining trend in overall watershed improvement and a potential for degradation of watershed 

condition, water quality, and soil quality in some areas. 

In the comments that follow, we identify areas where we believe additional infonnation, detail and/or 

standards and guidelines would improve the document and ensure consistency with the principles 

established and agreed to by the Interior Columbia Basin Deputies within the ICB Strategy. Our 

comments focus on the need for clarity regarding active management within riparian zones; the

identification and management of landslide prone sites; the management of minerals and mining, 

particularly with regard to financial assurance; and the identification of old forest. We also indicate a 

preference for the more protective forage utilization rates under Alternative F. 

Based on our review, we are rating the DEIS as EC-2 (Environmental Concerns - Insufficient 

lnfonnation). An explanation of this rating is enclosed. We support the collaborative, science-based 

approach taken by the Blue Mountains Planning Team and we encourage you to continue to engage with 

the many Forest Collaboratives working within the Blue Mountains F'orests as you finalize this EIS and 

Forest Plan. 

We appreciate the opportunity to review and comment on the DEIS, and we welcome the opportunity to 

engage with the planning team as you move forward. If you have any questions about our review, please 

contact me at (206) 553-1601, or by electronic mail at reichgott.christine@epa.gov. Or you may contact 

Teresa Kubo ofmy staff at (503) 326-2859, or by electronic mail at kubo.teresa@epa.gov.

Christine B. Reichgott, Manager 

Environmental Review and Sediment Management Unit

Enclosures
EPA Detailed Comments on the

Draft Environmental Impact Statement and Proposed Revised Land Management Plans

For the Malheur, Umatilla, and Wallowa-Whitman National Forests

August 15, 2014

Riparian Management Objectives 

Consistent with the overall direction in the Aquatic Riparian Conservation Strategy30 (ARCS), the DEIS 

and Draft Forest Plan do not identify specific metrics related to water temperature; large woody debris in 

forested systems; bank stability in non-forested systems; lower bank angle in non-forested systems; 

width/depth ratio; and pool frequency (wetted width and pools per mile).This represents a difference 

between ARCS and the Interim Objectives under P ACFISH/INFISH. The P ACFISH/INFISH strategy 

established specific riparian management objectives (RMOs) for each of these habitat components. The 

PACFISH/INFISH RMOs were established based on the best science available at the time; species 

recovery needs; and the desire to establish metrics against which to measure progress. While the 

PACFISH/INFISH RMOs may not be ecologically suited to all locations on all three Forests, we believe 

there is continued value in establishing more specific objectives related to riparian and aquatic conditions. 

Recommendation: We recommend that the FEIS and Final Plan include more specificity (quantitative or 

qualitative) with regard to objectives for water temperature; large wood; bank stability; bank angle; 

width/depth ratio and pool frequency. 

Riparian Restoration/Shade 

It is noted within the DEIS (page 267) that many riparian zones within dry upland forests are highly 

departed from the historical range of variability. Alternative E is described as providing greater emphasis 

on vegetation restoration within the riparian zone (DEIS Volume l, page 280). It would be helpful to have 

some additional specificity within the EIS and Forest Plan about what kinds of harvest treatments would 

be pursued in riparian zones. We recognize that treatments would be site specific, however a range of 

residual densities and canopy closures by site type would add to the reviewers understanding of the action 

alternatives. 

Of particular interest to the EPA is the potential for management to influence solar shading (positively or 

negatively) in the riparian zone, as well as expected recovery periods when initial treatment may reduce 

shade. Page 273 of Volume I of the DEIS states, "For 303d-listed streams in National Forest System lands 

in the Blue Mountains, 59 percent of stream miles are listed due to stream temperature." While Total 

Maximum Daily Loads (TMDLs) in Oregon and Washington identify multiple sources of temperature 

impairment, it is recognized that stream shade provided by riparian vegetation has the most widespread 

achievable effect on reducing stream temperatures by reducing direct solar radiation. In order to protect 

water quality and support TMDL implementation, the EPA supports management that emphasizes the 

protection and restoration of shade as well as healthy communities of riparian vegetation. 

Recommendation: We recommend that the FEIS and Forest Plan include additional specificity about the 

types of harvest treatments that would be pursued in riparian zones. We recommend that this

 30 U.S. Department of Agriculture, Forest Service. 2008. Aquatic and riparian conservation strategy (ARCS). Portland, OR, U.S. 

Department of Agriculture, Forest Service, Pacific Northwest Region: 49 p.
discussion include a range of residual densities and canopy closures by site type and anticipated 

timeframes for shade recovery. 

Landslides 

Landslides are recognized within the DEIS as a key disturbance that can influence watershed function. 

The DEIS also recognizes the need to buffer landslides and landslide-prone areas. The DEIS and Draft 

Forest Plan do not, however, include a discussion of landslides or landslide prone areas within the Forest 

Plan components (goals, desired conditions, objectives, standards and guidelines). Given the potential for

landslides to alter landscapes and affect infrastructure, water quality, and fish and wildlife habitat 

(particularly after fire), we recommend the Final Plan give additional consideration to the identification 

and management of landslide prone areas. A discussion of landslides as a disturbance process could be 

included within Volume 2 of the FEIS (under Aquatic Species Diversity and Viability) and within section 

1.4 of the Forest Plan (Disturbance Processes). 

Recommendation: We recommend the FEIS and Forest Plan include a discussion oflandslides as a 

disturbance process. We also offer the following Goals, Objectives and Standards as examples for Forest 

Service consideration:

• Site-specific analysis or field verification of broad-scale landslide-prone models (such as 

NetMap) shall be conducted in representative areas that are identified as landslide prone during 

site/project-scale analysis involving proposed management actions that may alter soil-hydrologic 

processes. Based on the analysis findings, design management actions to avoid the potential for 

triggering landslides (Standard).

• Field-verified high-risk landslide-prone sites are identified as not suited for timber production. 

Wood products harvested from high-risk landslide-prone sites will not contribute to the ASQ 

(Standard).

• Where proposed management actions may alter soil-hydrologic processes, representative sample 

oflandslides and landslide-prone areas should be field-verified to identify and interpret 

controlling and contributing factors of slope stability. Integrate the resulting infonnation with 

supporting data to provide a final stability assessment and identification of appropriate land 

management actions in landslide and landslide-prone areas (Guideline).

Roads 

The preferred Alternative (Alternative E) includes a desired condition for open motor vehicle route 

density depending on the management area and winter elk habitat. Overall, the desired route density is 

below current route density. Alternative E differs from the other Action Alternatives in that it focuses on 

reducing hydrologic connectivity as opposed to focusing strictly on road density. The intent is to focus on 

roads that are contributing the most sediment to the aquatic and riparian system. The EPA supports this 

approach. As noted on page 264 of Volume I of the DEIS, an analysis of National Forest System roads 

within the Umatilla National Forest in the Wall Creek watershed found that 90 percent of road-related 

sediment is produced by 12 percent of the road network. Given limited resources, we believe targeting 

erosion reduction treatments to the most critical sites is a sound approach. The EPA supports mid-scale or 

watershed analysis as a tool for identifying these restoration opportunities. We also support the use of 

tools such as the Geomorphic Road Analysis and Inventory Package (GRAIP), which was used on the 

Wall Creek Watershed. We encourage the use of GRAIP (or GRAIP Light) in those watersheds known to 

be experiencing extensive road-related runoff. We believe GRAIP is one of the most effective tools 

currently available for analyzing the impacts of road systems on erosion and sediment delivery to streams.
Forage Utilization Rates 

The EPA favors the Alternative F maximum utilization rates and minimum residual stubble height within

riparian areas because we believe the Alternative F utilization rates would potentially result in higher rates 

of animal rotation. When cattle graze, the bite size and biting rate is governed by forage quality and 

quantity. Each time cattle are turned into a new pasture, they rapidly graze the best forage leaving lower 

quality forage behind. Through defecation and urination, the remaining forage quickly loses quality and 

utilization rapidly declines. In fresh pastures, the intake rate is high, and the cows get 'full' quickly, 

thereby minimizing time spent grazing.31 Less time grazing would reduce grazing-related environmental 

impacts. As noted on page 269 of Volume I of the DEIS, Livestock grazing effects include trampling, soil 

compaction, and loss of vegetative cover. In addition, overuse in riparian zones affects the stability of 

stream channels, changes channel fonn (widening), and reduces resistance to floods. 

Recommendation: We recommend the final selected alternative incorporate Alternative F utilization 

rates and minimum residual stubble height. 

Minerals and Mining 

The proposed Forest Plan does not bring forward some of the PACFISH/INFISH standards and guidelines 

related to mining and minerals. In particular, we note the elimination of standard MM-I, which states: 

Standard MM-I. Avoid adverse impacts to listed species and designated critical habitat from mineral 

operations. If the Notice of Intent indicates that a mineral operation would be located in an RHCA and 

could affect attainment of RM Os or could adversely affect listed anadromous fish, then require a 

reclamation plan, approved Plan of Operations (or other such governing document), and reclamation 

bond. For effects that cannot be avoided, such plans and bonds must addres the following items to attain 

RMOs and avoid adverse effects on listed anad omousfish: the costs ofremovingfacilities, equipment, and 

materials; recontouring disturbed areas to approximate pre-mining topography; isolating and 

neutralizing or removing toxic or potentially toxic materials; salvage and replacement of topsoil; and 

seedbed preparation and re-vegetation. Ensure Reclamation Plan contain measurable attainment and 

bond re/ease criteria for each reclamation activity. 

The EPA has been working across multiple agencies and at multiple levels of government in order to 

ensure that mining operations are subject to adequate levels of financial assurance. We believe language 

such as that found in Standard MM-I supports that objective. 

Recommendations: We strongly encourage the Forests to continue to include standard MM-1 in the 

Forest Plan. We also recommend consideration of the standards and guidelines included within the Forest 

Plan for the Boise National Forest related to mining and minerals. Those standards and guidelines can be 

found at http://www.fs.usda.gov/lnternet/FSE DOCUMENTS/stelprdb5394129.pdf. The Mineral and 

Geology Resources section begins on page III-50. We encourage the Forests to incorporate some of the 

specificity within the Boise National Forest standards and guidelines into Forest Plan for the Blue 

Mountains.

 31 http://smallfanns.oregonstate.edu/sfn/spg09pasture
Large Old Trees 

Alternative E would manage for old forest and large diameter/old trees where they occur on the landscape 

based on a guideline that emphasizes retaining live trees with certain old tree characteristics. This would 

be a move away from screening trees from harvest based on diameter. The EPA is generally supportive of 

this direction. The view of the EPA is that while the eastside screening of trees over 21 inches has served 

to build trust among stakeholders and protect important remnant medium and large trees, a broad body of 

science now supports a more ecologically-based approach.32 As the FEIS is developed, it would be 

helpful to have additional information about how older stands/trees would be identified. The DEIS 

references the 2008 Van Pelt guidelines33 as one way old trees can be identified. The guideline within the 

Draft Forest Plan, however, indicates that old tree characteristics should be developed on a site-specific 

project basis. This leaves some question as to how the Forests will ensure the intent of the Plan is 

achieved across all three Forests. In the FEIS and final Forest Plan, we encourage the Forest Service to 

include additional infonnation about how older trees/stands will be identified.

Recommendation: Guideline OF-I related to individual old trees should better define the approach to be 

used to identify older forest. We would support language indicating that the site specific approach for 

identifying old growth should take into account geographic context; tree size; tree age; tree species; 

spatial distribution; relative abundance; the historical (and future) range of variability; forest health; and 

the potential of an area to grow large trees. 

Plan Objectives 

Starting on page 238 of Volume 3, the DEIS provides a series of tables (A-48, A-49, and A-50) that 

outline objective statements for the three Blue Mountains Forests. The objectives associated with the final 

selected Alternative will be carried forward into the final Forest Plan. These tables are a helpful tools for 

synthesizing and communicating the intent of the Forest Plan. The utility of these tables would be 

augmented by the addition of some contextual information. As an example, under Objective l. l 

(Watershed Function) the tables provide objectives related to riparian restoration. It is unclear to what 

extent the objectives overlap, or are independent of one another (i.e. the extent to which the 

accomplishment of one objective can count toward the accomplishment of another). For example, can 

miles ofrestored "floodplain connections, channel morphology, channel structure, and flow regime" count 

toward the later objective of miles of"stream morphology restored"? 

We are also interested in those objectives related to riparian restoration. We note that under Alternative E 

(the preferred alternative) there is an objective for the Umatilla National Forest to restore 165 acres 

(over IO years) of riparian/wetland species composition by "increasing natural seedling, planting, fencing, 

or modifying riparian management." For the same forest, there is also the objective of improving 525 

acres annually of stream channel and aquatic habitat function by "improving riparian habitat conditions." 

We recommend that the FEIS and Plan include additional context around these activities. We anticipate 

that the 525 acres to be improved annually would be the result of passive restoration, whereas the 165 

acre target refers more to more active restoration, however this is not immediately clear from reading the 

table or introductory text.

Recommendation: We recommend the Forest Service clarify the extent to which Plan Objectives in 

Tables A-48 through A-50 overlap or are independent of one another. We further recommend the FEIS 

clarify which objectives relate to active versus passive management.

 32 http://www.fs.fed.us/pnw/publications/MMC Synthesis 21 Nov 13.pdf 33 http://www.dnr.wa.gov/Publications/lm hep west oldgrowth guide full lowres.pdf
U.S. Environmental Protection Agency Rating System for

Draft Environmental Impact Statements

Definitions and Follow-Up Action*

Environmental Impact of the Action

LO - Lack of Objections 

The U.S. Environmental Protection Agency (EPA) review has not identified any potential environmental impacts requiring 

substantive changes to the proposal. The review may have disclosed opportunities for application of mitigation measures 

that could be accomplished with no more than minor changes to the proposal. 

EC - Environmental Concerns 

EPA review has identified environmental impacts that should be avoided in order to fully protect the environment. 

Corrective measures may require changes to the preferred alternative or application of mitigation measures that can reduce 

these impacts. 

EO - Environmental Objections 

EPA review has identified significant environmental impacts that should be avoided in order to provide adequate protection 

for the environment. Corrective measures may require substantial changes to the preferred alternative or consideration of 

some other project alternative (including the no-action alternative or a new alternative). EPA intends to work with the lead 

agency to reduce these impacts. 

EU - Environmentally Unsatisfactory 

EPA review has identified adverse environmental impacts that are of sufficient magnitude that they are unsatisfactory from 

the standpoint of public health or welfare or environmental quality. EPA intends to work with the lead agency to reduce 

these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage, this proposal will be 

recommended for referral to the Council on Environmental Quality (CEQ). 

Adequacy of the Impact Statement 

Category 1 - Adequate 

EPA believes the draft EIS adequately sets forth the environmental impact(s) of the preferred alternative and those of the 

alternatives reasonably available to the project or action. No further analysis of data collection is necessary, but the 

reviewer may suggest the addition of clarifying language or information. 

Category 2 - Insufficient Information 

The draft EIS does not contain sufficient information for EPA to fully assess environmental impacts that should be avoided 

in order to fully protect the environment, or the EPA reviewer has identified new reasonably available alternatives that are 

within the spectrum of alternatives analyzed in the draft EIS, which could reduce the environmental impacts of the action. 

The identified additional information, data, analyses or discussion should be included in the final EIS. 

Category 3 - Inadequate 

EPA does not believe that the draft EIS adequately assesses potentially significant environmental impacts of the action, or 

the EPA reviewer has identified new, reasonably available alternatives that are outside of the spectrum of alternatives 

analyzed in the draft EIS, which should be analyzed in order to reduce the potentially significant environmental impacts. 

EPA believes that the identified additional information, data, analyses, or discussions are of such a magnitude that they 

should have full public review at a draft stage. EPA does not believe that the draft EIS is adequate for the purposes of the 

National Environmental Policy Act and or Section 309 review, and thus should be formally revised and made available for 

public comment in a supplemental or revised draft EIS. On the basis of the potential significant impacts involved, this 

proposal could be a candidate for referral to the CEQ.

* From EPA Manual 1640 Policy and Procedures for the Review of Federal Actions Impacting the Environment. 

February, 1987.

Final Environmental Impact Statement, Volume 3

Chapter 4: Public Involvement; Preparers; and Distribution of the Environmental Impact Statement

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

233

Preparers and Contributors

List of Preparers

This list of preparers is limited to those people who were members of the interdisciplinary team 

working on these documents. Their preparation could not have been completed without the 

support and assistance of employees of the Malheur, Umatilla, Wallowa-Whitman National 

Forests and our colleagues in the regional office. We also recognize the forest leadership teams as 

providing guidance during this process.

Forest Supervisors

Theresa Raaf, Malheur National Forest Supervisor (former)

Steve Beverlin, Malheur National Forest Supervisor (current)

Kevin Martin, Umatilla National Forest Supervisor (former)

Genevieve Masters, Umatilla National Forest Supervisor (current)

John Laurence, Wallowa-Whitman National Forest Supervisor (former)

Tom Montoya, Wallowa-Whitman National Forest Supervisor (current)

Interdisciplinary Team Members

Name Contribution Education and Experience

Anne, Victoria Team Leader (2017) M.S. Agronomy, Soil Science, New Mexico State 

University, Las Cruces, New Mexico, 2005. 

B.A. in Photography, Minors in Business and 

Psychology, 1996. Salem State College, Salem, 

Massachusetts. 8 years with Forest Service (2.5

years as Natural Resource Specialist, 5.5 years as 

soil scientist); 6 years with BLM as NEPA 

Coordinator. 25 years in private sector as assistant 

treasurer, manager, and educational instructor.

Callaghan, Patricia Recreation B.S. in forest management and outdoor recreation 

resources management, Oregon State University; 20 

years with Forest Service on recreation, wilderness, 

rivers, outfitters and trails programs.

Campbell, Kathy Writer/ Editor B.A. in Public Relations, Walla Walla College; 25 

years with Forest Service in public affairs, forestry 

and writer editor.

Countryman, Bruce Fuels, Silviculture, 

Timber, and Range

B.S. in Forestry, University of Minnesota; 32 years 

of experience. Certified Silviculturist. 

Countryman, Katie Team Leader B.S. in Forestry, University of Minnesota; 28 years 

of experience including computer specialist, forest 

inventory coordinator, forester, analyst, NEPA team 

leader, Forest NEPA coordinator.
Final Environmental Impact Statement, Volume 3

Chapter 4: Public Involvement; Preparers; and Distribution of the Environmental Impact Statement

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

234

Name Contribution Education and Experience

Darbyshire, Robyn Ecological Resiliency B.S. Forest Science, University of Idaho; M.S. 

Forest Science, Oregon State University; 29 years 

of experience as forest silviculturist, native plant 

materials program lead, and climate change 

coordinator for the Forest Service.

Dougherty, Dennis Recreation, 

Wilderness, Access

B.A. Anthropology, University of Montana; 16

years of experience in cultural resource 

management and wilderness, recreation, and 

minerals administration.

Fargo, Peter Public Affairs M.B.A., George Washington University; B.A. 

Political Economy and Environmental Studies, 

Georgetown University; 13 years experience in 

government and business. 

Gecy, Bob Hydrology, Soils, 

Minerals, Air 

Quality, Geology

B.S. in Geology, Oregon State University; 25 years 

experience in fire management and hydrology.

Gliddon, Tim Team Leader 

Assistant

B.A. Education (Natural Science), Gonzaga 

University/Eastern Washington University. U.S. Air 

Force service specializing in personnel management 

and records management.

Grinspoon, Elisabeth Social and economic

analysis

B.A. East Asian Studies, Middlebury College, M.F., 

Yale University, Ph.D., University of California, 

Berkeley. 

Halbrooks, Blair NEPA Planner Master of Natural Resources, Virginia Polytechnic 

Institute and State University; 6 years of experience 

in natural resources and NEPA coordinator.

Jaworski, Delilah Socio-Economic 

Analysis

M.S. Environment and Development, London 

School of Economics. Nine years as social scientist 

(2 years with the Bureau of Land Management and 

7 years with the U.S. Forest Service).

Klein, E.H. “Duke” Wildlife B.S. in Wildlife Science, Oregon State University;

35 years of natural resource management 

experience in the public and private sector, both 

nationally and inter-nationally, 23 of which with the 

Forest Service as a wildlife biologist. 

Kohrman, Elaine Socioeconomic

Analysis

B.S. of Economics, Colorado State University; 18 

years with Forest Service in Wilderness 

management, economics, sociology and planning.
Final Environmental Impact Statement, Volume 3

Chapter 4: Public Involvement; Preparers; and Distribution of the Environmental Impact Statement

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

235

Name Contribution Education and Experience

Kramer, Jodi Public Affairs Degree in Public Relations, Interpretation, and 

Environmental Education Vermilion Community 

College and an AAS; 30 years with the Forest 

Service.

Laverty, Maura Range B.S. in Range Management, Washington State 

University; Certified Professional in Rangeland 

Management (SRM); 30 years of experience in 

range management with the Forest Service.

Mason, Robert Biology B.S. of Wildlife Management and Masters of 

Wildlife Management, University of Nevada at 

Reno; 28 years of experience in wildlife biology.

Mattson, Donna Scenery Bachelor of Landscape Architecture, University of 

Oregon; 24 years as landscape architect with the 

Forest Service.

McConnell, Dee Geographic 

Information Systems

Associate of Applied Science degree in 

Forest/Range Management, Treasure Valley 

Community College; 26 years of experience. 

Paulsen, Tami Public Affairs B.S. Forest Management, University of Montana;

15 years of timber, silviculture, planning and public 

affairs with BLM and FS.

Parker, Bethany Assistant to 

Interdisciplinary 

Team

B.S. Biology, Columbus State University; 3 years of 

experience in wildlife, hydrology, and planning 

with the Forest Service.

Penninger, Mark Wildlife B.S. Fisheries & Wildlife Sciences, North Carolina 

State University. Certified Professional Wildlife 

Biologist. 28 years of experience in wildlife and 

fisheries with the Forest Service.

Plourde, Christine NEPA Planner Bachelor of Landscape Architecture, University of 

Washington; 4 years experience in landscape 

architecture and planning with the Forest Service.

Ratliff, Jamie Wildlife M.S. Wildlife Science, Oregon State University; 15 

years of experience as a wildlife biologist for state 

and federal agencies.

Rathbone, Matthew Forest Vegetation, 

Timber & Forest 

Products, Old Forest

B.S. in Business Administration (Accounting), 

Bucknell University; A.A.S. in Forestry, State 

University of New York; 10 years private sector 

experience in forest management; 15 years in 

timber & silviculture with the Forest Service.
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236

Name Contribution Education and Experience

Ringle, Patricia Silviculture, Forest 

Vegetation, Old 

Forest

B.S. Forestry, Northern Arizona University; 12 

years’ experience in silviculture.

Ramsey, Katherine Aquatics, Fisheries B.S. Wildlife Management and Conservation, 

University of Wyoming; M.S. Rangeland 

Resources, Oregon State University; 30 years total 

Forest Service experience in fisheries and wildlife 

biology.

Schmitt, Dave Team Leader B.S. Range and Forest Management, Colorado State 

university; 29 years experience in Forest Service 

range, timber, silviculture, planning and as a 

District Ranger.

Stadler, Sabrina Team Leader B.S. in Wildlife Management, Humboldt State 

University; M.S. in Natural Resources & Planning 

Interpretation, Humboldt State University; 25 years 

experience in the field of natural resources.

Vester, Karl Writer/Editor B.A. Journalism, B.S. Resource Conservation, 

University of Montana; 9 years of Forest Service 

experience as a NEPA analyst and writer/editor.

Wilkins, Debbie Recreation B.S. Forest Resource, University of Idaho and B.S. 

Outdoor Recreation Management, University of 

Idaho. Worked for the Forest Service in recreation, 

lands, special uses, minerals, heritage, travel 

management for 25 years.

Yates, Eugene Botany, Invasive 

Plants

B.A. Botany, Oregon State University; 27 years of

experience as a Forest Service botanist.

Support to Interdisciplinary Team

Name Contribution Education and Experience

Boehne, Paul Fisheries B.S. Fisheries Science, Oregon State University; 

M.S- Fisheries Science Humboldt State University; 

32 years of experience as a fish biologist with 

federal and private sector.

Cole, Heidi Facilitation B.A. in speech communication; M.S. in 

environmental science and a PhD in natural 

resources; 20 years with Forest Service in public 

affairs, technology transfer, social science research 

and application. Certified professional facilitator.
Final Environmental Impact Statement, Volume 3

Chapter 4: Public Involvement; Preparers; and Distribution of the Environmental Impact Statement

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

237

Name Contribution Education and Experience

Hatfield, David Programmatic NEPA B.A. The Evergreen State College; M.S. Geology, 

Western Washington University; 32 years of 

experience with Forest Service in engineering, 

minerals, NEPA, forest planning, and business 

administration.

Howes, Steve Soils B.S. Range Management, M.S. Range Management, 

Washington State University. Regional Soil 

Scientist, Forest Service Pacific Northwest Region.

Phillips, Richard Economics B.S. Forest Management, Colorado State University, 

Graduate Studies; Colorado State University; 28 

years of experience as an economist for the Forest 

Service Pacific Northwest Region providing 

direction and social and economic analysis in 

support of forest planning, projects and programs

Distribution of the

Final Environmental Impact Statement

This environmental impact statement has been distributed to, or made electronically available to, 

over 2,000 individuals and groups who specifically requested a copy of the document or 

commented during public involvement opportunities. In addition, copies have been sent (or in 

some cases made electronically available) to Federal agencies, federally recognized Tribes, State 

and local governments, and organizations that have requested to be involved in the development 

of this analysis. These entities include the U.S. Environmental Protection Agency; U.S. Army 

Corps of Engineers; U.S. Department of the Interior; Federal Highway Administration; Advisory 

Council on Historic Preservation; USDA National Agricultural Library; State wildlife and 

fisheries management agencies; Tribes; county commissions; and local community governments. 

Due to the number of people, agencies, and organizations, a complete listing has been omitted 

from this Environmental Impact Statement, but is available upon request or on the World-Wide 

Web at the Blue Mountains plan revision Web site (https://www.fs.usda.gov/detail/wallowawhitman/landmanagement/planning/?cid=stelprdb5247447).

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Glossary and Acronyms

Many definitions in this glossary are from the following sources. Some definitions are in general 

use within the Forest Service. Terms adequately defined in general dictionaries are not necessarily 

included, though some of those that are less well known are included for the convenience of the 

reader. 

Partial Source List

• National Forest Management Act Regulations ([1982] 36 CFR 219)

• Dictionary of Forestry (Helms 1998 )

• Wildland Planning Glossary (USDA Forest Service 1976)

• Wildlife Habitats in Managed Forests, the Blue Mountains of Oregon and Washington 

(Thomas et al. 1979)

• Forest Service Manual or Forest Service Handbook

• A Glossary of Terms Used in Range Management, Second Edition (Society for Range 

Management 1974)

• Interior Columbia Basin Ecosystem Management Project DEIS (USDA Forest Service 

1997)

• Wallowa-Whitman National Forest Land and Resource Management Plan (USDA Forest 

Service 1990)

• Interior Columbia Basin Ecosystem Management Project SDEIS (USDA Forest Service 

2000)

• Interior Columbia Basin Ecosystem Management Project FEIS (USDA Forest Service 

2000)

• A Dictionary of Ecology, Evolution, and Systematics (Cambridge University Press 1982)

• Webster’s Dictionary 

• HCNRA Public Land Use Regulations (36 CFR 292.41)

• HCNRA Private Land Use Regulations (36 CFR 292.21)

A

active management: Planned, intentional actions in an area that are specifically designed to 

obtain a desired objective or result.

active restoration: Refer to restoration.

activity unit: An area on which one or more activities occurs. Activity units may be analogous to 

stand or timber sale harvest unit (polygon). An activity unit can be a polygon (acres), line (miles) 

or point (each) geospatial feature.

adaptive management: An approach to natural resource management in which decisions are 

made as part of an ongoing process. Adaptive management involves planning, implementing, 

monitoring, evaluating, and incorporating new knowledge into management approaches based on 

scientific findings and the needs of society. 

Effects are monitored for the purpose of learning and adjusting future management actions, which 

improves the efficiency and responsiveness of management.
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administrative site: Areas such as work centers, fire lookouts, permitted ranch headquarters, 

seed orchards, communication sites, utility corridors, and other areas that are occupied or used by 

the Forest Service during the administration of work associated with national forest lands.

administrative unit: A management area such as the Wallowa-Whitman National Forest, under 

the administration of one line officer. Forest Service line officers include district rangers and 

forest supervisors.

advance regeneration: (also called advance reproduction or advance growth). Seedlings or 

saplings that develop or are present in the understory.

air pollutant: Any substance in air that could, if in high enough concentration, harm humans, 

animals, vegetation, or material. Air pollutants may include almost any natural or artificial matter 

capable of being airborne, in the form of solid particles, liquid droplets, gases, or a combination 

of these. 

air quality: The composition of air with respect to quantities of pollution therein, used most 

frequently in connection with standards of maximum acceptable pollutant concentrations.

allotment (grazing): Area designated for the use of a certain number and kind of livestock 

grazing for a prescribed period. 

allotment management plan (AMP): A document that specifies the actions from a NEPA 

decision to be taken to manage and protect the rangeland resources and reach a given set of 

objectives. 

allowable sale quantity (ASQ): The quantity of timber that may be sold from the area of suitable 

land covered by the Forest Plan for a time period specified by the plan. This quantity is usually 

expressed on an annual basis as the average “annual allowable sale quantity.”

all-terrain vehicle (ATV): Off-highway-vehicles with less than or equal to a 50 inch wheel base, 

three or more low-pressured tires, handle bar steering and a seat designed to be straddled.

anadromous fish: Fish that hatch in fresh water, migrate to the ocean, mature there, and return to 

fresh water to reproduce; for example, salmon and steelhead. 

analysis file: A file containing records of the scoping and analysis processes conducted during the 

preparation of a NEPA document. The file is typically stored at the Forest Service office from 

which a final decision is issued.

animal unit: One mature cow of approximately 1,000 pounds, either dry or with calf up to 6 

months of age, or the equivalent (one horse, five domestic sheep). This concept is based on a 

standardized amount of forage consumed. 

animal unit month (AUM): The amount of forage required by one mature (1,000 lb.) cow or its 

equivalent for one month (based upon average forage consumption of 26 lb. of dry matter per 

day). Refer to head month. 

annual assessment: Yearly assessment of the degree to which on-the-ground management is 

maintaining or making progress toward the desired conditions and objectives. 

anthropogenic: Caused or produced through the agency of man; the scientific study of the origin 

of man. 

aquatic: Pertaining to water. 
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Aquatic and Riparian Conservation Strategy (ARCS): A regional strategy designed to restore 

and maintain the processes that create and maintain conditions in aquatic ecosystems on national 

forest lands in Oregon and Washington.

aquatic ecosystem: Waters that serve as habitat for interrelated and interacting communities and 

populations of plants and animals. The stream channel, lake or estuary bed, water, biotic 

communities and the habitat features that occur therein. 

assessment: The collection, integration, examination, and evaluation of information and values.

authorized grazing: Refer to grazing permit.

B

basal area: The area of the cross-section of a tree inclusive of bark at breast height (4.5 feet or 

1.37 meters above the ground) most commonly expressed as square feet per acre or square meters 

per hectare..

basalt: A finely or fine grained, dark, dense volcanic rock.

base sale schedule: A timber sale schedule formulated on the basis that the quantity of timber 

planned for sale and harvest for any future decade is equal to or greater than the planned sale and 

harvest for the preceding decade, and this planned sale and harvest for any decade is not greater 

than the long-term sustained yield capacity ([1982] 36 CFR 219.3). This definition expresses the

principle of nondeclining flow.

basin (river): (1) In general, the area of land that drains water, sediment, and dissolved materials 

to a common point along a stream channel. River basins are composed of large river systems; (2) 

in the National Hydrography Dataset (NHD), a 3rd-field hydrologic unit denoted by a six-digit 

number (HU6, formerly HUC3), or three two-digit numeric fields. For example, 17 is the numeric 

code for the Columbia hydrologic region, 1702 represents the Middle Columbia sub-region, and 

170702 is the numeric code for the John Day basin. In the Columbia Region, basin areas range 

from 2.6 to 20.8 million acres and average 8.2 million acres in size. See also: subbasin, 

watershed, and subwatershed.

benches: Mid-elevation flat or gently sloping sites. Grazing and homesteading/ranching activities 

were concentrated in these areas, which were also used by American Indians for pasturing 

livestock. Benches from 2,000 to 4,500 feet generally have potential to support the bunchgrass 

associations described for the lower and mid-position slopes. Cheatgrass brome, Kentucky 

bluegrass, and an assortment of annual and perennial forbs (including some noxious weeds) 

dominate much of the benchland, some of which was severely disturbed by early farming and 

ranching activities.

beneficial uses: Any of the various uses which may be made of the water, including, but not 

limited to, domestic water supplies, fisheries and other aquatic life, industrial water supplies, 

agricultural water supplies, navigation, recreation in and on the water, wildlife habitat, and 

aesthetics.

best management practices (BMPs): Practice or set of practices that enable a planned activity to 

occur while still protecting the resource managed, normally implemented and applied during the 

activity rather than after the activity.

best management practices (BMPs) (Watershed): A practice or a combination of practices, that 

is determined by the state (or designated area-wide planning agency) after problem assessment, 

examination of alternative practices, and appropriate public participation to be the most effective, 
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practicable (including technological, economic, and institutional considerations) means of 

preventing, or reducing the amount of pollution generated by nonpoint sources to a level 

compatible with water quality goals.

big game: Those species of large mammals normally managed as a sport hunting resource. 

Generally includes; elk, moose, white-tailed deer, mule deer, mountain goat, bighorn sheep, black 

bear and mountain lion.

biological diversity (biodiversity): The variety and variability among living organisms and the 

ecological complexes in which they occur.

biological soil crust: Thin crust of living organisms on or just below the soil surface composed 

of dense, low-growing community of various combinations of algae, mosses, liverworts, 

cyanobacteria (blue-green algae), micro fungi, bacteria, and lichens; and provide important 

components of grassland, shrub-steppe, and subalpine habitats. Also referred to as 

cryptogrammatic or microbiotic crust.

biophysical: The combination or grouping of biological and physical components in an 

ecosystem.

biotic: Living.

biomass: Dry weight of organic matter in plants and animals in an ecosystem, both above and 

below ground.

board-foot: A specialized unit of measure for the volume of rough-sawn lumber and timber in 

the United States and Canada. It is the volume of a one-foot length of a board one foot wide and 

one inch thick. It is commonly abbreviated BF. Thousand board-feet can be abbreviated MBF. 

Similarly, million board-feet can be abbreviated MMBF.

boreal: Pertaining to cool or cold temperature regions of the northern hemisphere; the northern 

coniferous zone.

broad scale: A large, regional area, such as an entire river basin and typically a multi-state area.

browse: That part of leaf and twig growth of shrubs, woody vines, and trees available for animal 

consumption.

Bureau of Land Management (BLM): An agency within the U.S. Department of the Interior 

with land management responsibility for the public domain lands.

C

candidate species: Plant and animal species that may be proposed for listing as endangered or 

threatened in the future by the U.S. Fish and Wildlife Service (USFWS) or the National Marine 

Fisheries Service (NMFS); these species have no legal protection under the Endangered Species 

Act (ESA).

canopy: In a forest, the branches from the uppermost layer of trees; on rangeland, the vertical 

projection downward of the aerial portion of vegetation.

canopy closure: The proportion of the sky hemisphere obscured by vegetation when viewed 

from a single point (Jennings et al. 1999).

canopy cover: The proportion of the forest floor covered by the vertical projection of the tree 

crowns (Jennings et al. 1999).
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capability: The potential of an area of land to produce resources, supply goods and services, and 

allow resource uses under an assumed set of management practices and at a given level of 

management intensity. Capability depends upon current conditions and site conditions such as 

climate, slope, landform, soils, and geology, as well as the application of management practices, 

such as silviculture or protection from fire, insects, and disease.

capital investment: An input that increases the stock of natural or man–made resources (assets) 

needed to maintain or increase the flow of outputs in the future. Benefits resulting from capital 

investments are normally recouped in excess of one year; activities that create or improve capital 

assets to obtain benefits occurring during several planning periods.

carrying capacity: The number of animals or plants that can be maintained over a specific period 

of time on a specified amount of land without damage to either the organisms or the habitat.

cavity: The hollow excavated in a tree that is used by birds or mammals for roosting and/or 

reproduction.

ceded lands: Lands that American Indian Tribes ceded to the United States by treaty in exchange 

for reservation of specific land and resource rights, annuities, and other promises in the treaties.

channel (stream): The deepest part of a stream or riverbed through which the main current of 

water flows.

channel morphology: The dimension (width, depth), shape and pattern (sinuous, meandering, 

straight) of a stream channel.

chargeable volume: All timber volume included in the growth and yield projections used to 

arrive at the allowable sale quantity, based on national forest utilization standards.

class I airshed: Under the Clean Air Act amendments, all international parks, national parks 

larger than 6,000 acres, and national wilderness areas larger than 5,000 acres which existed on 

August 7, 1977. This class provides the most protection to pristine lands by severely limiting the 

amount of additional air pollution that can be added to these areas.

clearcutting regeneration method. An even-aged regeneration method that removes essentially 

all trees, producing a fully exposed microclimate for the development of a new age class. 

Regeneration can be from natural seeding, direct seeding, coppice or planted seedlings (may 

include minor portions of advance reproduction). When the primary source of regeneration is 

advance reproduction, the preferred term is overstory removal. A minor live component of the 

stand may be retained for purposes other than regeneration. The retained trees, referred to as 

leave trees, should generally comprise less than 10% of full stocking of the stand. The 

management unit or stand in which regeneration, growth, and yield are regulated consists of the 

individual clearcut stand.

climax: The final or mature seral stage in secondary plant succession that persists for an 

indefinite period of time if no major disturbances occur; vegetation conceived as having reached a 

highly stable condition.

closed canopy: Greater than or equal to 60 percent canopy cover within the moist and cold 

upland forest potential vegetation groups; greater than or equal to 40 percent canopy cover within 

the dry upland forest potential vegetation group.

coarse woody material: Pieces of woody material derived from tree limbs, boles, and roots in 

various stages of decay, having a diameter of at least three inches.
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co-conveners: A group of participating county commissioners from within the Planning Area that 

have served as co-meeting managers for the land management plan revision process and assisted 

in coordinating the public involvement processes and community collaborative workshops.

Code of Federal Regulations (CFR): A codification of the general and permanent rules 

published in the Federal Register by the executive departments and agencies of the federal 

government.

cold upland forest: Forests occurring at moderate or high elevations in the subalpine zone 

characterized by cold, wet winters, and mild, relatively cool and dry summers. Late successional 

stands are typically dominated by subalpine fir, grand fir, Engelmann spruce, whitebark pine and 

lodgepole pine. Whitebark pine, lodgepole pine and western larch are more common as early 

successional species, but they often persist in older stands. Cold upland forests are adjoined by a 

treeless alpine zone at their upper edge (often separated by a narrow zone of dwarf or krummholz 

trees), and by moist upland forests at their lower elevation transition boundary. 

collaboration: Working together; to cooperate willingly with an agency or instrumentality with 

which one is not immediately connected.

commercial thinning: Any type of thinning producing merchantable material at least equal to the 

value of the direct costs of harvesting.

community resiliency: The ability of communities to adapt to changing ecological, social, and 

economic conditions.

compaction: Making soil hard and dense and decreasing its ability to support vegetation because 

the soil can hold less water and air and because roots have trouble penetrating the soil.

compatible: Capable of existing together in harmony.

comprehensive evaluation: Evaluation of current social, economic, and ecological conditions 

and trends relative to the desired conditions and objectives, undertaken prior to plan revision and 

every five years thereafter.

comprehensive management plan (CMP): The document that establishes the array, levels, and 

manner of resource uses within the Hells Canyon National Recreation Area on the WallowaWhitman National Forest. It is incorporated as a part of the 1990 Land and Resource 

Management Plan.

connectivity: The arrangement of habitats that allows organisms and ecological processes to 

move across the landscape; patches of similar habitats are either close together or linked by 

corridors of appropriate vegetation. Connectivity is the opposite of fragmentation.

conservation strategy or agreement: Plans to remove or reduce threats to candidate and 

sensitive species of plants and animals so that a listing as threatened or endangered is 

unnecessary.

consultation: (1) An active, affirmative process that (a) identifies issues and seeks input from 

appropriate American Indian governments, community groups, and individuals; and (b) considers 

their interests as a necessary and integral part of the Forest Service’s decision-making process; (2) 

the federal government has a legal obligation to consult with American Indian Tribes. This legal 

obligation is based in such laws as the Native American Graves Protection and Repatriation Act, 

the American Indian Religious Freedom Act, and numerous other executive orders and statutes. 

This legal responsibility is, through consultation, to consider Indian interests and account for 

those interests in the decision; (3) the term also refers to a requirement under Section 7 of the 

Endangered Species Act for federal agencies to consult with the U.S. Fish and Wildlife Service
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and/or National Oceanic and Atmospheric Administration -Fisheries with regard to federal actions 

that may affect listed threatened and endangered species or critical habitat.

coppice regeneration method: An even-aged method of regenerating a stand in which the trees 

in the previous stand are harvested and the majority of regeneration is from sprouts or root 

suckers. A minor live component of the stand may be retained for purposes other than 

regeneration. The retained trees, referred to as leave trees, should generally comprise less than 

10% of the growing space of the stand.

core area: The combination of core habitat (i.e., habitat that could supply all elements for the 

long-term security of species of conservation concern) and a core population (a group of one or 

more local populations that exist within core habitat) constitutes the basic unit on which to gauge 

recovery within a recovery unit. Core areas require both habitat and the species of conservation 

concern, and the number (replication) and characteristics of local populations inhabiting a core 

area provide a relative indication of the core area’s likelihood to persist. A core area represents the 

closest approximation of a biologically functioning unit.

corridor: A tract of land forming a passageway. Can refer to areas of wildlife movement, 

boundaries along rivers, or the present or future location of transportation or utility rights-of-way 

within its boundaries.

cost efficiency: The usefulness of specified inputs (costs) to produce specified outputs (benefits). 

In measuring cost efficiency, some outputs, including environmental, economic, or social 

impacts, are not assigned monetary values but are achieved at specified levels in the least cost 

manner. Cost efficiency is usually measured using present net value, although use of benefit-cost 

ratios and rates-of-return may be appropriate.

Council on Environmental Quality (CEQ): An advisory council to the President established by 

the National Environmental Policy Act (NEPA) of 1969. The council reviews federal programs 

for their effects on the environment, conducts environmental studies, and advises the President on 

environmental matters.

cover: (1) Trees, shrubs, rocks, or other landscape features that allow an animal to conceal itself 

partly or fully for protection from predators, or to ameliorate conditions of weather, or in which to 

reproduce; (2) the area of ground covered by plants of one or more species.

cover type: A category or classification of vegetation defined primarily by its vegetation species 

composition. Cover type is typically depicted in terms of a genus, species, group of species, or 

life form of tree, shrub, grass, or sedge of an area.

criteria pollutants: Air pollutants designated by the Environmental Protection Agency (EPA) as 

potentially harmful and for which ambient air standards have been set to protect the public health 

and welfare. The criteria pollutants are carbon monoxide, sulfur dioxide, particulate matter, 

nitrogen dioxide, ozone, hydrocarbons, and lead.

crown: The part of a tree containing live foliage; treetops.

cubic feet per second (cfs): A rate of the flow, in streams and rivers, for example. It is equal to a 

volume of water one foot deep and one foot wide flowing a distance of one foot in one second. 

One cfs is equal to 7.48 gallons of water flowing each second.

cubic feet per second per square mile (CSM): The rate of streamflow per unit land area.

culmination of mean annual increment (CMAI) (see also mean annual increment): The 

culmination of mean annual increment of growth is the age in the growth cycle of an even-aged 

stand at which the average annual rate of increase of volume is at a maximum. In land 
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management plans, mean annual increment is expressed in cubic measure and is based on the 

expected growth of stands, according to intensities and utilization guidelines in the plan.

culture: The ideals, values, and beliefs that members of a society share to interpret experience 

and generate behavior that is reflected by their work and thought (Haviland 2002).

cultural resources: An object or definite location of human activity, occupation, or use 

identifiable through field survey, historical documentation, or oral evidence. Cultural resources 

are prehistoric, historic, archaeological, or architectural sites, structures, places, or objects and 

traditional cultural properties. Cultural resources include the entire spectrum of resources for 

which the Heritage Program is responsible, from artifacts to cultural landscapes, without regard to 

eligibility for listing on the National Register of Historic Places

cumulative effects or impacts: Cumulative effects or impacts are the impacts on the 

environment that results from the incremental impact of the action when added to other past, 

present, and reasonably foreseeable future actions, regardless of what agency (federal or 

nonfederal) or person undertakes such actions. Cumulative impacts can result from individually 

minor but collectively significant actions taking place over a period of time. Effects and impact 

are synonymous (40 CFR 1508.7).

current direction: The existing direction in approved management plans; continuation of 

existing policies, standards and guidelines; current budget updated for changing costs over time; 

and, to the extent possible, production of current levels and mixes of resource outputs.

D

decommission (building): Demolition, dismantling, removal, obliteration and/or disposal of a 

deteriorated or otherwise unneeded asset or component, including necessary cleanup work. This 

action eliminates the deferred maintenance needs for the fixed asset. Portions of an asset or 

component may remain if they do not cause problems nor require maintenance. 

decommission (road): Permanently closing a road to vehicular use and left in a hydrological 

maintenance free condition. Decommissioning will include activities such as water barring, out 

sloping, recontouring, decompaction of road surface, removal of drainage structures, and road 

barricades as needed. 

defensible space: An area surrounding a home or structure that has vegetation characteristics that 

minimize the spread of wildland fire and allows for safely defending the home against fire.

deferred maintenance: Maintenance that was not performed when it should have been or when 

it was scheduled and which, therefore, was put off or delayed for a future period. When allowed 

to accumulate without limits or consideration of useful life, deferred maintenance leads to 

deterioration of performance, increased costs to repair, and decrease in asset value. Deferred 

maintenance needs may be categorized as critical or noncritical at any point in time. Continued 

deferral of noncritical maintenance will normally result in an increase in critical deferred 

maintenance. Code compliance (such as safety, Americans with Disabilities Act, Occupational 

Safety and Health Administration, or environmental), plan direction, best management practices, 

biological evaluations other regulatory or executive order compliance requirements, or applicable 

standards not met on schedule are considered deferred maintenance.

demography: The statistical study of populations, especially with reference to size and density, 

distributions, and vital statistics such as births, and deaths.
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density (stand): An absolute measure of the degree to which an area is occupied by trees and, 

hence the intensity by which trees are competing for site resources, usually expressed in terms of 

trees per acre or basal area per acre (Tappeiner 2007).

departure (ecological): The degree of difference between existing ecological conditions and the 

desired range of conditions. 

departure (sale schedule): A sale schedule that deviates from the principle of nondeclining flow 

by exhibiting a planned decrease in the sale schedule at any time during the planning horizon. A 

departure is characterized by a temporary increase, usually in the beginning decade(s) of the 

planning horizon, over the base sale schedule originally established. This increase does not impair 

the future attainment of desired conditions or the long-term sustained yield capacity.

design criteria: Part Three of the land management plan that provides the parameters, including 

guidelines, for how future site-specific activities can occur within the context of the plan.

designated critical habitat: Specific areas within the geographical area occupied by a species at 

the time of listing under Endangered Species Act that contain physical or biological features 

essential to the conservation of the species.

desired condition:

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

the plan area, or a portion of the plan area, toward which management of the land and resources 

should be directed. Desired conditions must be described in terms that are specific enough to 

allow progress toward their achievement to be determined, but do not include completion dates.

detrimental soil disturbance: A term used by soil scientists to indicate how much adverse soilmovement has occurred in an area following an event or a managed activity. The level of 

disturbance (considered to be a negative impact) is referred to in four erosion hazard classes: low, 

medium, high, and very high. The differences between the levels depends upon many subjective 

visual observations soil scientists have been trained to make during site surveys. These include: 

1) the amount of topsoils buried beneath subsoils, 

2) the redistribution of soil orders and whether or not nutrients needed for plant growth are 

lost, 

3) the amount of vegetation left remaining on and in the soil, 

4) how slope, aspect, and hydrology are altered, and 

5) whether the disturbance is further impacted by compaction, or other landform changes 

(i.e., bank failure, landslides, etc.).

developed recreation: Recreation that requires facilities that in turn result in concentrated use of 

an area; for example, a campground. Examples of developed recreation areas are campgrounds 

and ski areas; facilities in these areas might include roads, parking lots, picnic tables, toilets, 

drinking water, ski lifts, and buildings.

developed site: Facility provided for developed recreation use. Refer to facilities.

diameter at breast height (d.b.h.): A standard method of expressing the diameter of the bole of 

a standing tree, measured at 4.5 feet from the ground.

direct effects: Impacts on the environment caused by the action and occur at the same time and 

place.
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disease: A harmful deviation from normal functioning of physiological processes, usually 

pathogenic or abiotic in origin.

disjunct: Populations that are separated geographically from the main distribution of a species. 

Many plants with disjunct populations are biologically unique because they are not found again 

for dozens to over one hundred miles. Disjunct populations are thus rare in this portion of their 

distribution.

dispersed (recreation): Recreation that does not occur in a developed recreation site; for 

example, hunting or backpacking.

dispersed campsites: Primitive sites typically used for overnight, dispersed recreation. Usually 

includes a hardened area around a fire pit, a barren area, and/or user-constructed facility. 

displacement: Recreation visits are considered “displaced” or no longer consumed at a site or 

area when practical maximum capacity thresholds of the site or area are exceeded. Visitors are 

assumed to completely leave the national forest rather than seek an alternative location for their 

activity.

disturbance: Any relatively discrete event in time that disrupts ecosystem, watershed, 

community, or species population structure and/or function and changes resources, substrate 

availability, or the physical environment. Natural disturbances include, among others, drought, 

floods, wind, fires, volcanic eruptions, and insects and diseases. Human caused disturbances 

include, among others, timber harvesting, livestock grazing, and prescribed burning.

disturbance regime: A description of the characteristic types of disturbance on a given 

landscape; the frequency, severity, and size distribution of these characteristic disturbance types; 

and their interactions. Disturbance regime refers to the spatial and temporal dynamics of 

disturbances over a longer time period.

diversity: The distribution and abundance of different plant and animal communities and species 

within the area covered by a land and resource management plan.

down woody material: A tree or part of a tree that is dead and laying on the ground.

dry upland forest: Forests generally occurring at low to moderate elevations in the montane 

vegetation zone, characterized by warm, dry summers, with warm to hot daytime temperatures 

and cool nighttime temperatures, and cold, wet winters. Late-seral stands are dominated by 

ponderosa pine, Douglas-fir or grand fir. Ponderosa pine or Douglas-fir will also be found as 

cover types in early and mid-seral successional stages. Dry forests generally begin where the 

lower elevation woodlands and shrublands begin to transition into higher sites capable of carrying 

more substantial forest cover. The moist upland forests form their upper elevation transition 

boundary.

E

early seral: see succession.

early spring: Early spring is defined as that period when the perennial cool–season forage plants 

initiate growth and begin shoot elongation. It extends through the period of maximum 

carbohydrate use and the beginning of carbohydrate storage. The end of this period is determined 

by soil moisture. It ends prior to the time that soil moisture is expected to become limiting to the 

extent that essentially full regrowth cannot be ensured.
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Eastside Screens: Regional Forester’s Amendment #2, Interim management direction 

establishing riparian, ecosystem, and wildlife standards for timber sales on National Forest 

System lands in eastern Oregon and Washington (USDA Forest Service 1995).

ecological function: Refer to ecological processes.

ecological integrity: The quality or condition of an ecosystem when its dominant ecological 

characteristics (for example, composition, structure, function, connectivity, and species 

composition and diversity) occur within the natural range of variation and can withstand and 

recover from most perturbations imposed by natural environmental dynamics or human influence. 

(36 CFR 219.19).

ecological processes: The flow and cycling of energy, materials, and organisms in an ecosystem. 

Examples of ecosystem processes include the carbon and hydrologic cycles, terrestrial and 

aquatic food webs, and plant succession, among others.

ecological status: The degree of departure of current vegetation from the potential natural 

vegetation, or potential natural community often synonymous with seral stage.

economics: A social science concerned primarily with description, distribution, and consumption 

of goods and services.

economic well-being: A condition that enables people to work, provide income for their families, 

and generate economic wealth to local communities, the region, and the nation.

economic efficiency: Producing goods and services in areas best suited for that production based 

on natural biophysical advantage or an area’s ability to best serve regional demands of people.

economic impacts:

direct economic impact: Effects caused directly by forest product harvest or processing or 

by forest uses.

indirect economic impact: Effects that occur when supporting industries sell goods or 

services to directly affected industries.

induced economic impact: Effects that occur when employees or owners of directly or 

indirectly affected industries spend their income within the economy.

economy: System of production, distribution, and consumption of economic goods.

ecosystem: A complete, interacting system of living organisms and the land and water that make 

up their environment; the home places of all living things, including humans.

ecosystem diversity: The variety and relative extent of ecosystem types, including their 

composition, structure, and processes within all or a part of an area of analysis. 

ecosystem management: The use of an ecological approach to achieve multiple-use management 

of public lands by blending the needs of people and environmental values in such a way that 

lands represent diverse, healthy, productive, and sustainable ecosystems.

ecosystem function (processes): The major process of ecosystems that regulate or influence the 

structure, composition, and pattern. These include nutrient cycles, energy flows, trophic levels 

(food chains), diversity patterns in time/space development and evolution, cybernetics (control), 

hydrologic cycles and weathering processes.

ecosystem health: A condition where the parts and functions of an ecosystem are sustained over 

time and where the system’s capacity for self-repair is maintained, such that goals for uses, 

values, and services of the ecosystem are met.
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ecosystem services: The combined resources and processes of natural ecosystems that provide 

benefit to humans, including, but not limited to, the production of food and water, the control of 

climate and disease, cycling of nutrients and crop pollination, spiritual and recreational benefits, 

and the preservation or maintenance of biodiversity.

ecosystem sustainability: The ability to sustain diversity, productivity, resilience to stress, health, 

renewability and/or yield of desired values, resource uses, products, or services from an 

ecosystem, while maintaining the integrity of the ecosystem over time. 

edge: An area where plant communities meet or where successional stages or vegetation 

conditions within the plant communities come together.

effects: Environmental changes resulting from an action. Included are direct effects, which are 

caused by the action and occur at the same time and place, and indirect effects, which are caused 

by the action and are later in time or further removed in distance, but which are still reasonably 

foreseeable. Indirect effects may include growth–inducing effects and other effects related to 

induced changes in the pattern of land use, population density, or growth rate, and related effects 

on air and water and other natural systems, including ecosystems.

Effects include ecological (such as the effects on natural resources and on the components, 

structures, and functioning of affected ecosystems), aesthetic quality, historic, cultural, economic, 

social, or healthy effects, whether direct, indirect, or cumulative. Effects may also include those 

resulting from actions that may have both beneficial and detrimental effects even if on balance the 

agency believes that the effects will be beneficial (40 CFR 1508.8, 2).

eligible wild and scenic rivers: River segments that have been identified as eligible for inclusion 

in the national Wild and Scenic Rivers System under the authority of the Wild and Scenic Rivers 

Act. The river segment must be free-flowing and it must possess one or more outstandingly 

remarkable scenic, recreational, geological, fish and wildlife, historical, cultural, ecological or 

other value.

elk security: Effective security for elk includes non-linear areas that are greater than one-half mile 

from open motorized routes and at least 250 acres in size (Hillis et al. 1991).

embeddedness: The degree that larger streambed particles (boulders, rubble, or gravel) are 

surrounded or covered by finer particle sizes such as fine sediment (Rhodes et al. 1994).

emission: A release of air contaminants into the outdoor atmosphere.

endangered species: Species listed under the Endangered Species Act by either the U.S. Fish and 

Wildlife Service or the National Marine Fisheries Service. Any species of animal or plant that is 

in danger of extinction throughout all or a significant portion of its range. 

endemic: Occurring naturally in a certain region and distribution. Populations nearly always 

present, often remaining at low levels, and causing little management concern. Endemism is the 

occurrence of endemic species in an area.

environmental assessment (EA): A comprehensive evaluation of actions and their predictable 

short– and long–term environmental effects, which include physical, biological, economic, social, 

and environmental design factors and their interactions. It is a formal document that must follow 

the requirements of National Environmental Policy Act, the Council on Environmental Quality, 

and guidelines and directives of the agency responsible for the project proposal.

environmental impact statement (EIS): A statement of the environmental effects of a proposed 

action and alternatives to it. It is required for major federal actions under Section 102 of the 

National Environmental Policy Act, and released to the public and other agencies for comment 
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and review. A draft environmental impact statement is released to the public and other agencies 

for review and comment. A final environmental impact statement is issued after consideration of 

public comments. A record of decision is based on the information and analysis in the final 

environmental impact statement.

ephemeral: A channel in which streamflow occurs inconsistently, infrequently, or seasonally and, 

except during periods of streamflow, does not intersect the local groundwater table.

erosion: The wearing away of the land surface by running water, wind, ice, gravity, or other 

geological activities; can be accelerated or intensified by human activities that reduce the stability 

of slopes or soils.

essential fish habitat: Identification by the National Marine Fisheries Service of habitat essential 

to conserve and enhance federal fishery resources that are fished commercially under the 

Magnuson-Stevens Fishery Conservation and Management Act.

evaluation: An essential companion activity to monitoring; the tool for translating data gathered 

by monitoring into useful information that could result in change or adaptive management.

even-aged management: The application of a combination of actions that results in the creation 

of stands in which trees of essentially the same age grow together. Managed even-aged forests are 

characterized by a distribution of stands of varying ages (and, therefore, tree sizes) throughout the 

forest area. The difference in age between trees forming the main canopy level of a stand usually 

does not exceed 20 percent of the age of the stand at harvest rotation age. Regeneration in a 

particular stand is obtained during a short period at or near the time that a stand has reached the 

desired age or size for regeneration and is harvested. Clearcut, shelterwood, seed tree, or coppice 

regeneration cutting methods produce even-aged stands.

evolutionarily significant units (ESU): The minimal unit of conservation management, the 

smallest population unit that can receive federal protection under the Endangered Species Act. An 

ESU is a set of populations that is morphologically and genetically distinct from other similar 

populations or a set of populations with a distinct evolutionary history.34

exotic species: A plant or animal species introduced from a distant place; not native to the area.

extinction: Complete disappearance of a species from the earth.

extirpation: Loss of populations from all or part of a species’ range within a specified area.

F

facility: A single or contiguous group of improvements that exists to shelter or to support Forest 

Service programs. The term may be used in either a broad or narrow context; for example, a 

facility may be a ranger station compound, lookout tower, leased office, work center, separate 

housing area, visitor center, research laboratory, recreation complex, utility system, or 

telecommunications site.

upgrade: Total redesign and construction of a camping facility. Location may change 

considerably depending on ecological, environmental, or social concerns. The overall goal 

would be to maintain a rustic appearance but promote designs and materials that would result 

in lower operation and maintenance costs. Some campground classifications may change to 

the next higher level but none would exceed a Level 4 site development for this planning 

period. Accessibility standards would be appropriate to the designated Recreation 

 34 http://darwin.eeb.uconn.edu/eeb310/lecture-notes/systematics/systematicsli3.html
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Opportunity Spectrum. A change in design standards has the potential to move the ROS to a 

higher development setting although that is not the intent of upgrading a facility.

facilities maintenance (annual): Work performed to maintain serviceability, or repair failures 

during the year in which they occur. Includes preventive and/or cyclic maintenance performed in 

the year in which it is scheduled to occur. Unscheduled or catastrophic failures of components or 

assets may need repaired as a part of annual maintenance. 

preventive maintenance: Scheduled servicing, repairs, inspections, adjustments, and 

replacement of parts that result in fewer breakdowns and fewer premature replacements, and 

help achieve the expected life of the fixed asset. Inspections are a critical part of preventive 

maintenance as they provide the information for scheduling maintenance and evaluating its 

effectiveness.

facilities maintenance (deferred): Work that was not performed when it should have been or 

when it was scheduled and has been delayed to a future period. Deferred maintenance includes 

actions not taken to comply with codes for health and safety, accessibility, environmental factors 

and other compliance requirements or applicable standards. To reduce or eliminate deferred 

maintenance, rehabilitation or replacement may be necessary.

rehabilitation: Renovation or restoration of an existing fixed asset or any of its components 

in order to restore the functionality or life of the asset. Because there is no significant 

expansion or change of purpose for the fixed asset, the work primarily addresses deferred 

maintenance.

replacement: Substitution or exchange of an existing fixed asset or component with one 

having essentially the same capacity and purpose.

custodial: Replacement of nonfunctional site elements or facilities with in–kind materials or 

structures. Location, design, and configuration remain constant. Accessibility standards, 

where possible, are compatible with designated ROS settings.

decommission: Demolition, dismantling, removal, obliteration, and/or disposal of a 

deteriorated or otherwise unneeded asset or component, including necessary cleanup work. 

This action eliminates the deferred maintenance needs for the fixed asset. Portions of an asset 

or component may remain if they do not cause problems nor require maintenance.

fauna: The vertebrate and invertebrate animals of an area or region.

fall/winter season: This period basically begins when all key perennial forage plants have 

achieved dormancy. It runs through the dormant period and ends just before the initiation of new 

growth on the key cool season perennial forage species in the spring. In very general terms, this 

often begins in mid to late October and runs through February, March, or April depending on the 

elevation, aspect and the weather patterns for a given year.

farm/forest/grazing use: Any traditional agricultural, silvicultural, or livestock management use 

or combination thereof on farm/forest/grazing lands. This includes, but is not limited to, true 

farming, growing and harvesting timber, grazing of livestock, horticultural use, animal husbandry 

use, horse, cattle, and sheep ranching, and preparation and storage of the products raised on 

farm/forest/grazing land for on-site use of for disposal by marketing or otherwise. 

Farm/forest/grazing uses may also consist of uses related, to, and in furtherance of, the protection 

of fish and wildlife habitat, and the pursuit of recreational activities.

federally listed species: Species that are listed under the Endangered Species Act.

fine organic matter: Plant litter, duff, and woody material less than 3 inches in diameter.
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fine-scale: A generally high level of landscape resolution involving greater levels of detail and 

relatively small areas. 

fire cycle, fire frequency: Refer to fire return interval.

fire-dependent systems: Forests, grasslands, and other ecosystems historically composed of 

species of plants that evolved with and are maintained by fire regimes.

fire intensity: The energy output from a fire or the amount of energy or heat released per unit of 

time; can be expressed as reaction intensity, fireline intensity, temperature, heating duration, or 

radiant energy

fire intolerant: Species of plants with characteristics that render them relatively more prone to 

significant damage or mortality from the effects of a given frequency and intensity of fire.

fire management plan: A plan that identifies and integrates all wildland fire management and 

related activities within the context of approved land/resource management plans. It defines a 

program to manage wildland fires (wildfire, prescribed fire, and wildland fire use). The plan is 

supplemented by operational plans, including but limited to preparedness plans, preplanned 

dispatch plans, and prevention plans. Fire management plans assure that wildland fire 

management goals and components are coordinated. 

fire regime: The characteristics of fire in a given ecosystem, such as the frequency, predictability, 

intensity, and seasonality of fire. A natural fire regime is a general classification of the role fire 

would play across a landscape in the absence of modern human mechanical intervention but 

including the influence of aboriginal burning (Agee 1993; Brown 1995). Coarse-scale definitions 

for natural fire regimes were developed by Hardy and others (2001) and Schmidt and others 

(2002) and interpreted for fire and fuels management by Hann and Bunnell (2001). The five 

natural fire regimes are classified based on the average number of years between fires (fire 

frequency or Mean Fire Interval [MFI]) combined with the severity of the fire (the amount of 

vegetation replacement) and its effect on the dominant overstory vegetation. These five natural 

fire regimes are as follows: 

fire regime 1: 0- to 35-year frequency and of low severity (most commonly associated with 

surface fires) to mixed severity (in which less than 75 percent of the dominant overstory 

vegetation is replaced).

fire regime 2: 0- to 35-year frequency and of high severity (stand replacement: greater than 

75 percent of the dominant overstory vegetation is replaced).

fire regime 3: 35- to 200-year frequency and of mixed severity.

fire regime 4: 35- to 200-year frequency and of high severity.

fire regime 5: 200-year-plus frequency and of high severity.

fire regime condition class (FRCC): A classification of the degree of departure from the natural 

fire regime. The fire regime condition class classification is based on a relative measure 

describing the degree of departure from the historical natural fire regime. This departure can 

result in changes (or risks) to one, or more, of the following ecological components: vegetation 

(species composition, structural stages, stand age, canopy cover, and mosaic pattern across the 

landscape); fuel composition; fire frequency, severity, and pattern; and other associated 

disturbances. 
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condition class 1: Fire regimes are within the natural (historical) range, and the risk of losing 

key ecosystem components is low. Vegetation attributes (species composition, structure, and 

pattern) are intact and functioning within the natural (historical) range.

condition class 2: Fire regimes have been moderately altered from their natural (historical) 

range. Risk of losing key ecosystem components is moderate. Fire frequencies have departed 

from natural frequencies by one or more return intervals (either increased or decreased). This 

result in moderate changes to one or more of the following: fire size, intensity and severity, 

and landscape patterns. Vegetation and fuel attributes have been moderately altered from their 

natural (historical) range.

condition class 3: Fire regimes have been substantially altered from their natural (historical) 

range. The risk of losing key ecosystem components is high. Fire frequencies have departed 

from natural frequencies by multiple return intervals. Dramatic changes occur to one or more 

of the following: fire size, intensity, severity, and landscape patterns. Vegetation attributes 

have been substantially altered from their natural (historical) range. 

fire return interval: The average time between fires in a given area.

fire severity: Degree to which a site has been altered or disrupted by fire; loosely, a product of 

fire intensity and residence time.

• Low-severity fire, meaning less than 25 percent average vegetation top-kill

• Mixed-severity fire, meaning greater than 25 and less than 75 percent average vegetation 

top-kill 

• High-severity fire, meaning greater than 75 percent average vegetation top-kill

fire suppression: All work and activities connected with fire-extinguishing operation, beginning 

with discovery and continuing until the fire is completely extinguished.

fire-tolerant: Species of plants that have various characteristics which render them relatively less 

prone to significant damage or mortality from a given frequency and intensity of fire. 

fish-producing: Streams, rivers, wetlands, ponds, lakes, and reservoirs that serve as spawning or 

rearing habitat for fish.

fledgling: A young bird that has acquired the feathers necessary for flight.

floodplain: The lowland and relatively flat areas joining inland and coastal waters including 

debris cones and flood-prone areas of off-shore islands, including at a minimum, that area subject 

to a one percent (100-year recurrence) or greater chance of flooding in any given year (Executive 

Order 11988, Section 6c); or the area of relatively flat land adjacent to streams that is inundated 

during times of high flow; or an area formed by the deposition of stream-transported sediment.

floodplain function: Collectively, the normal physical and biological processes that are 

responsible for the formation and maintenance of river floodplains and the biotic communities 

that inhabit them.

flow regime: The range of magnitude, duration, timing and frequency of stream flow 

characteristics of a given stream.

focal species: A small subset of species whose status permits inference to the integrity of the 

larger ecological system to which it belongs and provides meaningful information regarding the 

effectiveness of the Plan in maintaining or restoring the ecological conditions to maintain the 
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diversity of plant and animal communities in the Plan Area. Focal species would be commonly 

selected on the basis of their functional role in ecosystems.

food web: Networks of food chains or feeding relationships by which energy and nutrients are 

passed from one group of living organisms to another.

forb: Broad-leafed, herbaceous, nongrass-like plant species other than true grasses, sedges, and 

non–woody plants; fleshy leafed plants; having little or no woody material.

forage: All browse and herbaceous foods that are available to grazing animals. It may be grazed 

or harvested for feeding. Refer to rangeland vegetation.

forest vegetation treatment: (synonym for silvicultural treatment) A forest management activity 

such as thinning, harvesting, planting, pruning, prescribed burning, mastication, or site 

preparation that is designed to alter the establishment, growth, composition, health, and/or quality 

of forests and woodlands to meet the diverse needs and values of landowners and society on a 

sustainable basis.

forest fragmentation: Refer to fragmentation.

forest health: The perceived condition of a forest derived from concerns about such factors as its 

age, structure, composition, function, vigor, presence of unusual levels of insects and disease and 

resilience to disturbance. Perception and interpretation of forest health are influenced by 

individual and cultural viewpoints, land management objectives, spatial and temporal scales, the 

relative health in stands that comprise the forest, and the appearance of the forest at a point in 

time.

forest land: Land at least 10 percent occupied by forest trees of any size or formerly having had 

such tree cover and not currently developed for non-forest use. Lands developed for non-forest 

use include areas for crops, improved pasture, residential, or administrative areas, improved roads 

of any width, and adjoining road clearing and powerline clearing of any width.

forest roads: Any road wholly or partly within, or adjacent to, and serving the national forest and 

which is necessary for the protection, administration, and utilization of the national forests and 

the use and development of its resources (23 USC 101).

Forest Service Handbook (FSH): Directives that provide detailed instructions on how to 

proceed with a specialized phase of a program or activity.

Forest Service Manual (FSM): A system of manuals that provides direction for Forest Service 

activities.

forest transportation facility: A classified road, designated trail, or designated airfield, 

including bridges, culverts, parking lots, log transfer facilities, safety devices and other 

transportation network appurtenances under Forest Service jurisdiction that is wholly or partially 

within or adjacent to National Forest System lands (36 CFR 212.1).

forest transportation system management: The planning, inventory, analysis, classification, 

record keeping, scheduling, construction, reconstruction, maintenance, decommissioning, and 

other operations undertaken to achieve environmentally sound, safe, cost-effective access for use, 

protection, administration, and management of national forest lands.

fragmentation (habitat): The break-up of a large continuous land area by reducing and dividing 

into smaller patches isolated by areas converted to a different land type. Habitat can be 

fragmented by natural events or development activities.
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fragmentation (forest): The breakup of a large land forest area into smaller patches isolated by 

areas converted to a different land type. Opposite of connectivity.

free-flowing: A river or stream that exists or flows in natural condition without impoundment, 

diversion, straightening, rip-rapping, or other modification of the waterway (16 U.S.C. §1286).

fuel: Plants or plant parts, both living and dead, capable of burning.

fuel load: The dry weight of combustible forest fuels per unit area; usually expressed as tons per 

acre.

fuel treatment: Any forest vegetation treatment which alters the continuity, rearranges, or 

removes forest fuels primarily for the purpose of modifying potential fire behavior and/or 

lessening resistance to control tactics.

functioning-at-risk: Riparian-wetland areas that are in functional condition but an existing soil, 

water, or vegetation attribute makes them susceptible to degradation.

G

geographic information system (GIS): An information processing technology to input, store, 

manipulate, analyze, and display data; a system of computer maps with corresponding sitespecific information that can be combined electronically to provide reports and maps.

geologic: Based on geology which is the study of the structure, processes, and chronology of the 

earth.

geological/geomorphic process: The actions or events that shape and control the distribution of 

materials, their states, and their morphology, within the interior and on the surface of the earth. 

Examples of geologic processes include: volcanism, glaciation, streamflow, metamorphism 

(partial melting of rocks), and landsliding.

goal: Goals are broad statements of intent, other than desired conditions, usually related to 

process or interaction with the public. Goals are expressed in broad, general terms, but do not 

include completion dates.

goods and services: The various outputs, including on-site uses, produced from forest and 

rangeland resources. 

government-to-government consultation: The active and continuous process of contacting 

tribal leadership, soliciting their participation, involvement, comments, concerns, contributions, 

and traditional knowledge that will assist the agency in making informed decisions in planning, 

managing and decision-making actions.

graminoid: Grasses and grass-like plants such as sedges and rushes.

grassland: Land on which the vegetation is dominated by grasses, grass-like plants, or forbs.

grazable forestland: Forestland that produces, at least periodically, understory vegetation that 

can be grazed. In this document, that condition is defined as any forested site with an existing 

overstory canopy cover less than 60 percent with greater than about 200 pounds of forage 

production per year per acre.

grazing: The consumption of standing forage by livestock or wildlife.

grazing allotment: Area designated for the use of a certain number and kind of livestock for a 

prescribed period.
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grazing lands: Any vegetated land that is grazed or has the potential to be grazed by animals 

(domestic or wild). This includes rangeland and grazable forestland.

grazing permit: Document authorizing livestock to use national forest lands or other lands under 

Forest Service control for livestock production.

ground fire: A fire that burns the organic material in the soil layer and the decayed material or 

peat below the ground surface.

groundwater: All of the water that has percolated through the surface soil into the bedrock.

groundwater-dependent ecosystems: Communities of plants, animals, and other organisms 

whose extent and life processes are dependent on access to or discharge of groundwater. (USDA 

Forest Service 2012)

group selection regeneration method: A method of regenerating uneven-aged stands in which 

trees are harvested in small groups, and new age classes are established. The width of groups is 

commonly approximately twice the height of the mature trees, with smaller openings providing 

microenvironments suitable for tolerant regeneration, and the larger openings providing 

conditions suitable for more intolerant regeneration. In the group selection regeneration method, 

the management unit or stand in which regeneration growth and yield are regulated consists of a 

landscape containing an aggregation of groups.

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

departure from its terms, so long as the intent of the guideline is met. (36 CFR 219.15(d)(3)). 

Guidelines are established to help achieve a desired condition or conditions, to avoid or mitigate 

undesirable effects, or to meet applicable legal requirements.

H

habitat: A place that provides seasonal or year-round food, water, shelter, and other 

environmental conditions for an organism, community, or population of plants or animals.

harvest (timber): The removal of trees for wood fiber use and other multiple-use purposes.

harvest (wildlife): removal of game animals or fish from a population, typically by hunting or 

fishing.

harvestable/harvestability: With regard to American Indian Tribes, refers to a population of 

plants or animals that is self-sustaining and capable of producing a dependable harvest annually 

to meet spiritual, cultural, subsistence, and commercial needs.

head month: One month’s use and occupancy of the range by one animal. For grazing fee 

purpose, it is a month’s use and occupancy of range by one weaned or adult cow with or without 

calf, bull, steer, heifer, horse, burro, or mule, or five sheep or goats. Refer to animal unit month.

headwaters: Beginning of a watershed; the uppermost, unbranched tributaries of a stream.

healthy ecosystem: An ecosystem in which structure and functions allow the maintenance of the 

desired conditions of biological diversity, biotic integrity and ecological processes over time.

Hells Canyon National Recreation Area Act: The Act of December 31, 1975, as amended (PL 

94-199, 89 Statute 117), which established the Hells Canyon National Recreation Area.

herbaceous: Green and leaf-like in appearance or texture; includes grasses, grass-like plants, and 

forbs, with little, or no woody component.

herbicide: A pesticide used for killing or controlling the growth of plants.
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herbivore: An animal that subsists on plants or plant materials, either primarily or entirely.

heterogeneous: quality of consisting of dissimilar or diverse elements, as with mixed habitats or 

cover types occurring on a landscape; opposite of homogeneous, in which elements are the same.

hibernacula: Habitat niches where certain animals (such as bats) overwinter, such as caves, 

mines, tree hollows, or loose bark.

hiding cover: Vegetation, primarily trees, capable of hiding 90 percent of a standing adult game 

animal from the view of a human at a distance equal to or less than 200 feet during all seasons of 

the year that elk or deer use the area. Generally, any vegetation used for security or to escape 

from danger.

high-severity fire: see fire severity.

historical conditions: see historical range of variability

historic property: Any prehistoric or historic district, site, building, structure, or object included 

in, or eligible for inclusion in, the National Register of Historic Places. This term includes 

artifacts, records, and remains that are related to and located within such properties. The term 

includes properties of traditional religious and cultural importance to an Indian Tribe or Native 

Hawaiian organization and that meet the National Register of Historic Places criteria.

historical range of variability (HRV): The variation of ecological characteristics and processes 

over scales of time and space that are appropriate for a given management application. The 

historical range of variability concept focuses on a distilled subset of past ecological knowledge 

developed for use by resource managers; it represents an explicit effort to incorporate a past 

perspective into management and conservation decisions. The pre-European influenced reference 

period considered is sufficiently long, often several centuries, to include the full range of 

variation produced by dominant natural disturbance regimes such as fire and flooding and also 

includes short-term variation and cycles in climate. The historical range of variability can help 

identify key structural, functional, compositional, and connectivity characteristics, for which plan 

components may be important for either maintenance or restoration of such ecological conditions.

homogeneous: quality of consisting of similar or standardized elements, as with uniform habitats 

or cover types occurring on a landscape; opposite of heterogeneous, in which elements are 

diverse and mixed.

human capital: An individual’s education, skills, culture, and knowledge that enhance their 

contributions to society (Castle 1998).

human-caused disturbance: Refer to disturbance.

hydroelectric: Of or relating to the production of electricity by waterpower.

hydrologic: Refers to the properties, distribution, and effects of water. Hydrology refers to the 

broad science of the waters of the earth, their occurrence, circulation, distribution, chemical and 

physical properties, and their reaction with the environment.

hydrologic function: The behavioral characteristics of a watershed described in terms of ability 

to sustain favorable conditions of water flow. Favorable conditions of water flow are defined in 

terms of water quality, quantity, and timing.

hydrological regimes: The spatiotemporal dynamics of water flow and associated fluvial process 

in an ecosystem. Refer to flow regime.
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hydrologic unit: A hydrologic unit is a drainage area delineated to nest in a multi-level, 

hierarchical drainage system. Its boundaries are defined by hydrographic and topographic criteria 

that delineate an area of land upstream from a specific point on a river, stream or similar surface 

waters. A hydrologic unit can accept surface water directly from upstream drainage areas, and 

indirectly from associated surface areas such as remnant, noncontributing, and diversions to form 

a drainage area with single or multiple outlet points.

hydrologic unit code (HUC): A hierarchical coding system developed by the U.S. Geological 

Survey to identify geographic boundaries of watersheds of various sizes (12). 

4th-code HUC refers a subbasin generally about 450,000 acres in size. 

5th-code HUC refers to a watershed. These areas generally range from 40,000 to 250,000 

acres in size. 

6th-code HUC refers to a subwatershed hydrologic unit that generally ranges from 10,000 to 

40,000 acres in size.

I

impacts: Refer to effects.

Impact Analysis for Planning (IMPLAN) Model: A computer–based system used by the Forest 

Service for constructing input-output models to measure economic input. The system includes a 

database for all counties in the United States and a set of computer programs to retrieve data and 

perform the computational tasks for input-output analysis.

implement: To carry out.

improvement cutting: An intermediate treatment made in a stand, pole-sized or larger, primarily 

to improve composition and quality by removing less desirable trees of any species.

indirect effects: Impacts on the environments that are caused by the action and are later in time 

or farther removed in distance but are still reasonably foreseeable.

inert ingredient: An ingredient deficient in active properties, lacking the usual or anticipated 

chemical or biological action.

infestation: The attack or invasion by parasites or pests.

infiltration: The process by which water seeps into the soil, influenced by soil texture, aspect, 

and vegetation cover.

infrastructure: The basic facilities, equipment, and installation needed for the functioning of a 

system; commonly refers to items such as roads, bridges, power facilities, and the like.

INFISH: Regional Forester’s Amendment 4, Inland Native Fish Strategy (USDA Forest Service 

1995). Interim strategies for managing fish–producing watersheds in Eastern Oregon and 

Washington, Idaho, Western Montana and portions of Nevada.

insecticide: A pesticide employed against insects.

instream flow: Flow of water in its natural setting (as opposed to waters diverted for off-stream 

uses such as industry or agriculture). Instream flow levels provided for environmental reasons 

enhance or maintain the habitat for riparian and aquatic life, with timing and quantities of flow 

characteristic of the natural setting.
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integrated pest management: A process for selecting strategies to regulate forest pests in which 

all aspects of a pest-host system are studied and weighed. The information considered in selecting 

appropriate strategies includes the impact of the unregulated pest population on various resources 

values, alternative regulatory tactics and strategies, and benefit/cost estimates for these alternative 

strategies. Regulatory strategies are based on sound silvicultural practices and ecology of the 

pest-host system and consist of a combination of tactics such as timber stand improvement plus 

selective use of pesticides. A basic principle in the choice of strategy is that it be ecologically 

compatible or acceptable.

integration: Bringing the values and systems of different disciplines together to address 

questions with a common framework using consistent techniques and measurement units.

interagency: Involving the Forest Service, Bureau of Land Management, Fish and Wildlife 

Service, National Marine Fisheries Service, Environmental Protection Agency, and/or other 

Federal agencies.

interdisciplinary team: A group of specialists assembled as a cohesive team with frequent 

interactions to solve a problem or perform a task.

intermediate harvest treatment: A collective term for any harvest treatment or tending 

designed to enhance growth, quality, vigor, and composition of the stand after establishment or 

regeneration and prior to final regeneration harvest.

intermittent stream: A stream in which the flow of water on the surface is discontinuous, or that 

alternates between zones of surface and sub-surface flow.

invasion (plant): The movement of a plant species into a new area outside its former range.

invasive nonnative species: Are those animal and plant species with an extraordinary capacity 

for multiplication and spread at the expense of other native species. Plants in this category may or 

may not be designated as noxious weeds.

invasive plant species: Nonnative plant species that invade or are introduced into an 

environment or ecosystem in which they did not evolve where they have the ability to compete 

with, and at times overshadow, the existing native plant species. Invasive species are also likely to 

cause economic or environmental harm or harm to human health. Invasive species include seeds, 

eggs, spores, or other biological material capable of propagating that species, that is not native to 

that ecosystem (with respect to a particular ecosystem). Noxious weeds are a specific type of 

invasive plants that carry a legal designation due to their potential for detrimental impacts to the 

environment.

inventoried roadless areas: Those areas identified in the Land Management Plan and listed on a 

set of inventoried roadless area maps, contained in Forest Service Roadless Area Conservation, 

Final Environmental Impact Statement, Volume 2, (USDA Forest Service 2000), which are held 

at the Washington Office of the Forest Service, or any update, correction, or revision of those 

maps through the land management planning process.

invertebrate: Small animals that lack a backbone or spinal column. Spiders, insects, and worms 

are examples of invertebrates.

irretrievable commitment: Applies to losses of production or commitment of renewable natural 

resources. For example, while an area is used as a ski area, some or all of the timber production 

there is “irretrievably” lost. If the ski area closes, timber production could resume; therefore, the 

loss of timber production during the time the area is devoted to skiing is irretrievable but not 
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irreversible, because it is possible for timber production to resume if the area is no longer used as 

a ski area.

irreversible commitment: Applies to nonrenewable resources, such as minerals and 

archaeological sites. Losses of these resources cannot be reversed. Irreversible effects can also 

refer to effects of actions on resources that can be renewed only after a very long period, such as 

the loss of soil productivity.

issue: A point, matter of controversy, dispute, question of public discussion, or general concern 

over resource management activities or land uses to be addressed or decided through the planning 

process. To be considered a significant environmental impact statement issue, it must be well 

defined, relevant to the proposed action, and within the ability of the agency to address through 

alternative management strategies.

K

key habitat: Specific areas within the geographic area occupied by the species on which are 

found those physical and biological features 1) essential to the conservation of the species, and 2) 

which may require special management considerations or protection.

key species/key forage species: (1) Forage species whose use serves as an indicator to the 

degree of use of associated species. (2) Those species which must, because of their importance, 

be considered in the management program.

keystone species: A species whose presence and role within an ecosystem has a disproportionate 

on other organisms within the system.

L

landform: One of the attributes or features that make up the Earth’s surface such as a plain, 

mountain, or valley, as defined by its particular combination of bedrock and soils, erosion 

processes, and climatic influences.

land management plan: A document or set of documents that provide management direction for 

an administrative unit of the National Forest System developed under the requirements of the land 

management planning regulation at 36 CFR part 219 or a prior planning rule.

landscape: A defined area irrespective of ownership or other artificial boundaries, such as a 

spatial mosaic of terrestrial and aquatic ecosystems, landforms, and plant communities, repeated 

in similar form throughout such a defined area.

landscape character: Identifiable image made by particular attributes, qualities, and traits of a 

landscape.

landscape ecology: The study of the interaction between spatial pattern and ecological processes, 

that is, the causes and consequences of spatial heterogeneity across a range of scales (Turner et al. 

2001).

landscape-level/landscape-scale: Refer to broad-scale.

landscape pattern: Number, frequency, size and juxtaposition of landscape elements (stands and 

patches) that are important to the determination or interpretation of ecological processes.
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landscape structure: The mix and distribution of stand or patch sizes across a given area of land. 

Patch sizes, shapes, and distributions are a reflection of the major disturbance regimes operating 

on the landscape.

land-use allocation: The commitment of a given area of land or a resource to one or more 

specific uses--for example, to campgrounds or wilderness.

late/old structure (LOS): Term used by the interim wildlife standard or the Regional Forester’s 

Eastside Plan Amendment No. 2 (Eastside Screens) generally referring to forest structural stages 

where large trees are common. Under the Eastside Screens, late and old structural stages can be 

either “multi-strata with large trees” or “single-stratum with large trees.” In the multi-strata with 

large trees stage, large trees are common, and several to many cohorts and strata of trees are 

present. In the single-stratum with large trees stage, large trees are common and a single stratum 

of large trees is present and young trees are absent or few in the understory. Late old structural 

stages are roughly analogous to the “old forest” structural stages characterized by this FEIS. 

These structural stages may or may not contain the various characteristics sometimes identified 

with old growth structure.

late seral: see succession.

late successional: The stage of ecological succession and type of vegetation that develops after a 

long period of time following a stand-replacing disturbance.

legacy tree: Old trees that have been spared during past harvest, or have survived stand replacing 

natural disturbances, and are thus significantly older than the average trees in the general area. 

This distinguishes them from other ‘residual’ trees, which may also have been spared from 

harvest but are not always significantly older than the average trees in the area (Mazurek and 

Zielinski 2004; Franklin 1990). 

lethal (stand-replacing) fires: Fires that result in stand replacement of the existing forested 

vegetation. Mortality levels are very high at all canopy levels within the stand. In forests, fires in 

which less than 20 percent of the basal area or less than 10 percent of the canopy cover remains; 

in rangelands, fires in which most of the shrub overstory or encroaching trees are killed.

lichens: Organisms made up of specific algae and fungi, forming identifiable crusts on soil, 

rocks, tree bark, and other surfaces. Lichens are primary producers in ecosystems; they contribute 

living material and nutrients, enrich the soil and increase soil moisture-holding capacity, and 

serve as food sources for certain animals. Lichens are slow growing and sensitive to chemical and 

physical disturbances.

litter: The uppermost layer of organic debris on the soil surface, which is essentially the freshly 

fallen or slightly decomposed vegetation material such as stems, leaves, twigs, and fruits.

limits of acceptable change (LAC): Process for establishing acceptable resource and social 

conditions while defining desired future conditions for wilderness or recreation settings that can 

be measured and managed (USDA Forest Service 1992).

local population: A group of individuals that spawn or breed in a particular area; the smallest 

group of individuals that is known to represent an interacting reproductive unit.

loess: Fine grained wind-deposited material predominantly of silt-size particles.

long term: Generally refers to a period longer than 10 years up to 100 years.
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long-term sustained yield timber capacity: The highest uniform wood yield from lands being 

managed for timber production that may be sustained under a specified management intensity 

consistent with multiple-use objectives.

lower montane: A terrestrial community that generally is found in drier and warmer 

environments than the montane terrestrial community. The lower montane community supports a 

unique clustering of wildlife species.

M

mainstem: The main channel of the river in a river basin, as opposed to the streams and smaller 

rivers that feed into it.

maintain: To continue; or keep ecosystem functions, processes, and/or components (such as soil, 

air, water, vegetation) in such a condition that the ecosystem’s ability to accomplish current and 

future management objectives is not weakened. Management activities may be compatible with 

ecosystem maintenance if actions are designed to maintain or improve current ecosystem 

condition.

major population group: A group of either salmon populations or group of steelhead 

populations that are geographically and genetically cohesive. The major population group is a 

level of organization between demographically independent populations and evolutionarily 

significant units or distinct population segments.

management area: A land area identified within the Planning Area that has the same set of 

applicable plan components. A management area does not have to be spatially contiguous.

management concern: An issue, problem, or a condition which constrains the range of 

management practices identified by the Forest Service in the planning process.

management intensity: A management practice or combination of management practices and 

associated costs designed to obtain different levels of goods and services.

management practice: A specific activity, measure, course of action, or treatment.

mean annual increment: Mean annual increment of growth is the total increment of increase of 

volume of a stand (standing crop plus thinnings) up to a given age divided by that age. In land 

management plans, mean annual increment is expressed in cubic measure and is based on the 

expected growth of stands, according to intensities and utilization guidelines in the plan.

mechanical equipment: Any contrivance which travels over ground, snow, or water on wheels, 

tracks, skids, or by flotation that is powered by a living source. This term does not include 

nonmotorized river craft, wheelchairs, or other similar devices used solely to assist persons with 

disabilities.

mechanical fuel treatment: A fuel treatment using mechanical means, such as thinning by 

chainsaw or machines, mastication, crushing down wood, or piling down wood with machines.

mechanized: Wheeled forms of transportation (including nonmotorized carts, wheelbarrows, 

bicycles and any other nonmotorized, wheeled vehicle).

mesic: Pertaining to conditions of moderate moisture or water supply; used of organisms 

occupying moist habitats.

metapopulations: Multiple populations of the same species coexisting in time but not space.
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microclimate: The climatic conditions within a small habitat such as: a tree stump, under a 

boulder, in the space between grasses, or on the side of a slope.

migration corridor: The habitat pathway an animal uses to move from one place to another.

minerals-locatable: Those hardrock minerals that are mined and processed for the recovery of 

metals. They also may include certain nonmetallic minerals and uncommon varieties of mineral 

materials, such as valuable and distinctive deposits of limestone or silica. 

minerals-leasable: Coal, oil, gas, phosphate, sodium, potassium, oil shale, sulphur, and 

geothermal resources.

minerals-materials (salable): A collective term to describe common varieties of sand, gravel, 

stone, pumice, pumicite, cinders, clay, and other similar materials. Common varieties do not 

include deposits of those materials that may be locatable.

minimum impact suppression tactics (MIST): A set of guidelines prescribing safety, fire line 

procedures, tools, and equipment that has the least impact on the environment during suppression 

and mop-up phases of fire (NWCG 2014).

mining: Any activity related to the discovery, extraction, and exploration of minerals under the 

Mining Act of 1872 and the Mineral Leasing Act of 1920 through the use of, among other things, 

hydraulic equipment, pans, ground sluicing, sluice boxes, rockers, or suction dredges.

mining claim: A particular parcel of public land, valuable for a specific mineral deposit or 

deposits, for which an individual has asserted a right of possession. The right is for developing 

and extracting a discovered mineral deposit.

mining lands: Lands primarily used for mining purposes as of June 13, 1994 and which are 

assigned to the mining land category in 36 CFR 292.22 of the private land use regulations.

mitigation: Measures designed and implemented to counteract environmental impacts or to make 

impacts less severe.

mixed-severity fire: These fire regimes will have the greatest toll on thinner barked and/or young 

age classes within the stand. Low intensity fires within the stand will favor overstory fire-resistant 

species (ponderosa pine, western larch, and Douglas fir). Crown fire potential does exist 

depending on stand structures and age classes of different stand cohorts of any available ladder 

fuels. If it occurs, the result will favor the return to grass and forbs.

moist upland forest: forests generally occurring at moderate elevations in the montane 

vegetation zone, or at the lower end of the subalpine zone. They are adjoined by cold forests at 

their upper edge and by dry forests at their lower edge. They are characterized by slightly longer 

growing seasons compared to the cold upland forest, and generally have cooler temperatures and 

higher precipitation than the lower elevation dry upland forests. Late successional stands are 

generally dominated by subalpine fir, grand fir or Douglas-fir. Lodgepole pine or western larch 

often occur as dominant species in early successional moist upland forests. Douglas-fir and 

western white pine are common mid-seral species.

monitoring: A systematic process of collecting information to evaluate effects of actions or 

changes in conditions or relationships.

montane: A terrestrial community that generally is found in moderate (ponderosa pine) and 

subalpine terrestrial communities. Montane communities are generally moister than lower 

montane and warmer than subalpine communities, and support a unique clustering of wildlife 

species.
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mosaic: A pattern of vegetation in which two or more kinds of communities are interspersed in 

patches, such as clumps of shrubs with grassland between.

motorized equipment: Any machine powered by a nonliving source. This term does not include 

motorized river craft or small hand-held devices such as flashlights, shavers, wristwatches, and 

Geiger counters.

multi-story: Structural arrangement of trees within a stand generally characterized by having 

more than one distinct horizontal layer of tree crowns. Each layer may also be referred to as a 

stratum.

multiple-use management: The management of all the various renewable surface resources of 

the National Forest System so that they are utilized in the combination that will best meet the 

needs of the American people; making the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use to conform to changing needs and conditions; that some lands will be used for 

less than all of the resources; and harmonious and coordinated management of the various 

resources, each with the other, without impairment of the productivity of the land, with 

consideration being given to the relative values of the various resources, and not necessarily the 

combination of uses that will give the greatest dollar return or the greatest unit output ([1982] 36 

CFR § 219.3).

municipal watersheds (public supply watersheds): A watershed that serves a public water 

system as defined in Public Law 93-523 (Safe Drinking Water Act) or as defined in state safe 

drinking water regulations. The definition does not include communities served by a well or 

confined groundwater unaffected by Forest Service activities.

mycorrhiza: a fungus that often grows in association with the roots of a plant in a symbiotic 

relationship. The symbiotic relationship between the fungus and the roots of certain plants, 

especially trees enhances their ability to take nutrients from soil.

N

National Ambient Air Quality Standards (NAAQSs): Standards set by the Federal 

Environmental Protection Agency for the maximum levels of air pollutants that can exist in the 

outdoor air without unacceptable effects on human health or the public welfare.

National Environmental Policy Act (NEPA): An act to declare a national policy which will 

encourage productive and enjoyable harmony between humankind and the environment, to 

promote efforts which will prevent or eliminate damage to the environment and biosphere and 

stimulate the health and welfare of humanity, to enrich the understanding of the ecological 

systems and natural resources important to the nation, and to establish a Council on 

Environmental Quality.

National Forest Management Act (NFMA): A law passed in 1976 as an amendment to the 

Forest and Rangeland Renewable Resources Planning Act, requiring the preparation of forest 

plans and the preparation of regulations to guide that development.

National Forest System (NFS): All national forest lands reserved or withdrawn from the public 

domain of the United States; all national forest lands acquired through purchase, exchange, 

donation, or other means; the National Grasslands and land utilization projects administered 

under Title III of the Bankhead-Jones Farm Tenant Act (50 Stat. 525, 7 U.S.C. 1010-1012); and 

other lands, waters, or interests therein which are administered by the Forest Service or are 

designated for administration through the Forest Service as a part of the system.
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National Forest System road: A classified forest road under the jurisdiction of the Forest 

Service. The term National Forest System roads is synonymous with the term forest development 

roads as used in 23 USC 205. Generally referred to as a Forest Road.

National Recreation Trail: Trails designated by the Secretary of the Interior or the Secretary of 

Agriculture as part of the national system of trails authorized by the National Trails System Act. 

National recreation trails provide a variety of outdoor recreation uses.

National Register of Historic Places: A listing (maintained by the U.S. National Park Service) 

of areas that have been designated as being of historical significance. The Register includes 

places of local and state significance as well as those of value to the Nation.

National Wild and Scenic River System: Includes rivers with outstanding scenic, recreational, 

geological, fish and wildlife, historic, cultural or other similar values designated by Congress 

under the Wild and Scenic Rivers Act for preservation of their free-flowing condition. Refer to 

Wild and Scenic River.

native species: Species that normally live and thrive in a particular ecosystem. Animals or plants 

that have historically occupied a given aquatic or terrestrial area.

natural disturbance: (see disturbance).

near natural rates of recovery: Rates not exceeding condition thresholds and meeting standards 

for forage and browse utilization.

neotropical: Those species of birds that nest in the United States or Canada and winter regularly 

in the Neotropics (south of the Tropic of Cancer and Capricorn) in Mexico, the Caribbean Islands, 

or Central or South America. 2).

net public benefits: An expression used to signify the overall long- term value to the nation of all 

outputs and positive effects (benefits) less all associated inputs and negative effects (costs) 

whether they can be quantitatively valued or not. Net public benefits are measured by both 

quantitative and qualitative criteria rather than a single measure or index. The maximization of 

net public benefits to be derived from management of units of the National Forest System is 

consistent with the principles of multiple use and sustained yield.

niche: A place or activity for which a thing is best fitted.

no-action alternative: The most likely condition expected to exist in the future if current 

management direction were to continue unchanged.

nonfunctional: Riparian-wetland areas that clearly are not providing adequate vegetation, 

landform, or large woody debris to dissipate stream energy associated with high flows and not 

reducing erosion or improving water quality. The absence of certain physical attributes, such as a 

floodplain where one should be, is an indicator of nonfunctioning conditions (Process for 

Assessing Proper Functioning Condition, USDI BLM 1993).

nongame species: Those species of animals that are not managed as a sport hunting resource.

nonlethal fire: Fires that consist of low intensity under burns with limited single tree or group 

torching. Fire related mortality to the dominant-fire resistant species is slow, but occurs because 

of this type of localized fire behavior. In forests, fires in which more than 70 percent of the basal 

area or more than 90 percent of the canopy cover survives; in rangelands, fires in which more 

than 90 percent of the vegetative cover survives (implies that fire is occurring in an herbaceousdominated community).
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nonnative invasive species (NNIS): Plant species that are introduced into an area in which they 

did not evolve and in which they usually have few or no natural enemies to limit their 

reproduction and spread. These species can cause environmental harm by significantly changing 

ecosystem composition, structure, or processes and can cause economic harm or harm to human 

health.

nonpoint source pollution: Pollution whose source is general rather than specific in location; the 

sources of the pollutant discharge are dispersed, not well defined or constant. Examples include 

sediments from logging activities and runoff from agricultural chemicals. It is widely used in 

reference to agricultural and related pollutants, such as production of sediments by logging 

operations, agricultural pesticide applications, or automobile exhaust pollution.

nontreaty bands: The five bands of Nez Perce whose traditional homes lay outside the reduced 

reservation boundaries described in the Treaty of 1863.

noxious weeds: Plants designated as noxious weeds by the Secretary of Agriculture or by the 

responsible state official. Noxious weeds generally possess one or more of the following 

characteristics: aggressive and difficult to manage, poisonous, toxic, parasitic, a carrier or host of 

serious insects or disease, and being native or new to or not common to the united states or parts 

thereof. A noxious weed is one that causes disease or has other adverse effects on the human 

environment and therefore is detrimental to the agriculture and commerce of the United States 

and to the public health.

nutrient cycling: Ecological processes in which nutrients and elements such as carbon, 

phosphorous, nitrogen, calcium, and others, circulate among animals, plants, soils, and air.

O

objective: A concise, time-specific statement that describes the incremental progress expected to 

take place to meet goals (desired conditions) over the planning period with respect to estimated 

quantities of services and accomplishments. Objectives are projections of outcomes based on 

certain social, economic, and ecological indicators that measure the plans performance and 

identify specific opportunities and possible future proposals in terms of ongoing programs and 

future projects to support the goals for the Planning Area. 

off-channel: Aquatic habitats separated from the main stream or river, such as side-channels, 

oxbows, ponds, or sloughs, which may or may not be directly connected to a river or stream.

off-highway vehicle (OHV): Any motor vehicle designed for or capable of cross-country travel 

on or immediately over land, water, sand, snow, ice, marsh, swampland, or other natural terrain.

old forest stage: Old forests are ecosystems distinguished by a relative abundance of old trees 

and related structural attributes. Old forest encompasses the later stages of stand development that 

typically differ from earlier stages in a variety of characteristics which may include tree size, 

accumulation of large dead woody material, number of canopy layers, species composition, and 

ecosystem function. The age at which stands reach the old forest stage and the specific structural 

attributes that characterize the old forest stage varies by forest type, site conditions, and 

disturbance regime. Measurable criteria for these attributes have been established for the major 

forest cover types by the Pacific Northwest Region of the Forest Service (USDA Forest Service 

1993). These structure based definitions incorporate minimum numbers of trees per acre of 

minimum qualifying ages ranging from 150 to 200 years as well as minimum sizes of 21 to 31 

inches for several forest types common to this area. Depending largely on the natural disturbance 
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regime, old forest may occur in a single-story stage, called “old forest single-story (OFSS),” or as 

a multi-storied stage, called “old forest multi-storied (OFMS).”

• old forest multi-story (OFMS): This stage of old forest includes multiple age classes 

and canopy layers, along with large, old trees. Decaying fallen trees may also be present 

that leave a discontinuous overstory canopy. Overstory diameters are generally greater 

than 20 inches.

• old forest single-story (OFSS): This stage of old forest typically results from lowintensity surface fire. This structure class can include multiple age classes, but generally 

only includes one main overstory strata. Large, old trees are common. Decaying fallen 

trees may also be present that leave a discontinuous overstory canopy. Overstory 

diameters are generally greater than 20 inches.

ongoing actions: Those actions that have been implemented, or have contracts awarded or 

permits issued. Refer to new actions.

openings: Natural or artificially created areas characterized by a lack of significant tree or shrub 

cover. Examples include meadows, clearcuts, and other areas of vegetation that do not provide 

hiding or thermal cover. When openings are created in the forest by the application of even-aged 

silviculture, as a minimum, openings in forest stands are no longer considered openings once a 

new forest is established.

operational plan: A document approved by the forest supervisor which specifies at the project 

level, implementation of the management direction established in the forest plan.

outcome: The long-term results of a program activity compared to its intended purpose 

(Government Performance and Results Act of 1993 (5 U.S.C. 306)). Outcome is a state of being 

similar to long-term ecological, social, or economic condition or goal (such as the maintenance of 

an ecosystem’s biodiversity, jobs and income, or the quality of a regions’ surface water as 

measured by indicators).

outdoor recreation activities: Activities such as camping, picnicking, rafting, boating, hiking, 

rock climbing, fishing, hunting, horseback riding, and the viewing of wildlife or scenery.

outfitting: Providing through rental or livery any saddle or pack animal, vehicle or boat, tents or 

camping gear, or similar supplies or equipment, for pecuniary remuneration or other gain. The 

term guide includes the holder’s employees, agents, and instructors. Pecuniary remuneration 

means monetary reward (Washington Office Amendment 2709.11-95-11, 41-53C).

outputs: A broad term for describing any result, product, service or concern that a system 

produces by its activities. They are measurable and capable of being used to determine the 

effectiveness of programs and activities in meeting objectives. The unit of measure should 

indicate or serve as a proxy for what the recipients get rather than what the agency does in the 

process of producing the given output. Example: timber sold, recreation use, livestock grazing 

use, etc. Any good, service, or on-site use that is produced from rural resources.

outslope: Roads that are sloped towards the downhill side of the roadway to better match the 

natural drainage patterns and minimize the potential for diversion.

outstandingly remarkable values: Term used in the Wild and Scenic Rivers Act of 1968; to 

qualify as outstandingly remarkable, a resource value must be a unique, rare, or exemplary 

feature that is significant at a regional or national level.

overgrazing: Consumption of rangeland grass by grazing animals to the point that it cannot be 

renewed, or can be only slowly renewed, because of damage to the root system.
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over-snow vehicle: A self-propelled vehicle intended for travel primarily on snow driven by a 

track or tracks in contact with the snow, and steered by a ski, ski’s or tracks in contact with the 

snow.

overstory: Trees whose crowns constitute the highest horizontal layer of vegetation in a forest

stand.

overwinter: To keep livestock or plants alive through the winter by sheltering them, or to be kept 

alive in this way.

P

PACFISH: Regional Forester’s Amendment 3, Interim strategies for managing anadromous fish–

producing watersheds in Eastern Oregon and Washington, Idaho, and portions of California 

(USDA and USDI 1995).

paleontological sites: Areas that contain any remains, trace, or imprint of a plant or animal that 

has been preserved in the earth’s crust before the Holocene epoch.

parcel: Contiguous tax lots under one ownership. For the purposes of the Private LURs, rightsof-way do not divide parcels into smaller units.

particulate emissions: Solid particles or liquid droplets that can be suspended or carried in the 

air, or released as air contaminants into the outdoor atmosphere. 

PM10 – Particulate matter that measures 10 micrometers in diameter or less, a size considered 

small enough to invade the alveolar regions of the lung. PM10 is one of the six pollutants for 

which there are National Ambient Air Quality Standards. 

PM2.5 – Particulate matter that measures 2.5 micrometers in diameter or less.

passive restoration: The achievement of restoration through the use of natural processes, 

sequences, and timing which occurs after the removal or reduction of adverse stresses without 

other specific positive remedial action.

patch: An area of vegetation that is relatively homogeneous internally and differs from 

surrounding elements.

pathogen: An agent such as a fungus, virus, or bacterium that causes disease.

pattern: The spatial arrangement of landscape elements (patches, corridors, matrix) that 

determines the function of a landscape as an ecological system.

pesticide: A chemical preparation used to control individuals or populations of injurious 

organisms.

permittee (livestock): Any entity that has been issued a grazing permit.

phases: Plant communities or seral stages within a steady state connected to each other by 

community pathways.

plan component: Parts of a national forest land and resource management plan that cannot be 

changed without a plan amendment analysis as required by the National Environmental Policy 

Act and the Planning Rule. Plan components include goals, desired conditions, standards, 

guidelines, objectives, special areas, management areas, and suitable uses and activities.

Planning Area: The area of the National Forest System covered by a regional guide or forest 

plan.
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planning horizon: The overall time period considered in the planning process that spans all 

activities covered in the analysis or plan and all future conditions and effects of proposed actions 

which would influence the planning decisions.

plant associations: A plant community type based on the land management potential, 

successional patterns and species composition.

plant communities: Any grouping of plants that have some structural similarity (Johnson and 

Simon 1987).

plateau: Any comparatively flat area of great extent and elevation; specifically an extensive land 

region considerably more elevated above the adjacent country; it is commonly limited on at least 

one side by an abrupt descent.

point source pollution: Pollution that comes from a single identifiable source such as a 

smokestack, a sewer, or a pipe.

pool: Portion of a stream where the current is slow, often with deeper water than surrounding 

areas and with a smooth surface texture. Often occur above and below riffles and generally are 

formed around stream bends or obstructions such as logs, root, wads, or boulders. Pools provide 

important feeding and resting areas for fish.

potential natural community: The biotic community that would become established if all 

successional sequences were completed without interference by humans under present 

environmental conditions. Natural disturbances are inherent in development.

potential vegetation group (PVG): A group of potential vegetation types grouped on the basis of 

similar general moisture or temperature environment and similar types of life forms.

potential vegetation types (PVT): A kind of physical and biological environment that produces a 

kind of vegetation; the species that might grow on a specific site I the absence of disturbance; can 

also refer to vegetation that would grow on a site in the presence of frequent disturbance that is an 

integral part of the ecosystem and its evolution.

precommercial thinning: Thinning generally within stands or size classes considered too small 

to be harvested commercially, where the removal of trees is not for immediate financial return but 

to improve the stand by reducing stocking and concentrating growth on the more desirable trees.

prehistoric site: An area that contains important evidence and remains of the life and activities of 

early societies that did not record their history.

prescribed fire: Any fire ignited by management actions to meet specific objectives. Prescribed 

fire is intended to mimic natural fire regimes to: 1) reduce the risk of fires burning outside of 

historic intensities and severities that could substantially reduce long–term productivity; 2) 

maintain tree species compositions that occur under the natural disturbance regime; 3) reduce 

competition; 4) increase nutrients; 5) prepare sites for natural regeneration; 6) improve forage 

resources; (7) enhance/create wildlife habitat; and (8) protect private and public property values. 

A written, approved prescribed fire plan must exist, and National Environmental Policy Act 

(NEPA) requirements (where applicable) must be met, prior to ignition.

prescription: A management pathway to achieve a desired objective(s).

present net value (PNV): The difference between the discounted value (benefits) of all outputs 

to which monetary values or established market prices are assigned and the total discounted costs 

of managing the Planning Area.
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primitive recreation: Those types of recreation activities associated with unroaded land, for 

example: hiking, backpacking, and cross–country travel.

private land: Land not in federal, state, or local government ownership.

productive capacity: The growth and accumulation of plant biomass (primary productivity) as 

well as the growth of animal species that use the products (secondary productivity). Key elements 

of productivity include the physical, chemical, and biological properties of soils which provide 

for vegetative growth and the accumulation and cycling of nutrients.

productivity: Productivity is based on using natural resources no faster than they are produced or 

can be replaced and using natural resources without impairment of the long-term productive 

capacity of the ecosystem from which they are derived.

programmatic agreement (PA): This is a historic preservation document that records the terms 

and conditions agreed upon to resolve the potential adverse effects of a Federal agency program, 

complex undertaking or other situations in accordance with the Section 106 review under 

National Historic Preservation Act (NHPA) [36CFR800.14(b)].

proper functioning condition (PFC): Riparian and wetland areas achieve proper functioning 

condition when adequate vegetation, landform, or large woody debris is present to dissipate 

stream energy associated with high water flows. This thereby reduces erosion and improves water 

quality; filters sediment, captures bedload, and aids floodplain development; improve flood–water 

retention and ground water recharge; develops root masses that stabilize stream banks against 

cutting action; develops diverse ponding and channel characteristics to provide the habitat and 

water depths, duration, and temperature necessary for aquatic vertebrate and invertebrate 

production, waterfowl breeding, and other issues; and supports greater biodiversity. The 

functioning condition of riparian and wetland areas is a result of the interaction among geology, 

soil, water and vegetation.

project: An organized effort to achieve an objective identified by location, timing, activities, 

outputs, effects, and time period and responsibilities for executions.

project-level: Site-specific analysis and planning processes for a specific project or set of 

projects usually on an individual ranger district.

proposed action: A proposal by a federal agency to authorize, recommend, or implement a 

management action.

preliminary administratively recommended wilderness area (PARWA): An area that has been 

determined to meet the criteria to be designated as wilderness and is proposed in this land 

management plan by the forest supervisor(s) to be recommended to Congress for inclusion into 

the National Wilderness Preservation System.

public issue: A subject or question of widespread public interest relating to management of the 

National Forest System.

Q

qualitative: Traits or characteristics that relate to quality and cannot be measured with numbers.

quality of life: Refers to the satisfaction people feel for the places where they live (or may visit) 

and for the places they occupy as part of that experience.

quantitative: Traits or characteristics that can be measured with numbers.
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R

range forage condition: The current composition or productivity of rangeland relative to what 

that rangeland is capable of producing as a potential natural community, and often synonymous 

with forage condition.

range analysis: The systematic interpretation, analysis, and evaluation of data for rangeland 

resource management planning. It provides ecological and other information for overall 

forestland and resource management planning and allotment management planning.

rangeland (range): Lands where the vegetation is predominately grasses, grass-like plants, forbs, 

or shrubs. Rangelands include natural grasslands, shrublands, savannahs, tundra, most deserts, 

and riparian and wetland plant communities, including marshes and wet meadows, with greater 

than about 200 pounds of forage production per year per acre.

rangeland resources: The physical and biotic resources of rangeland ecosystems.

rangeland resource inventory: The systematic acquisition of inventory data that characterizes 

the vegetation, soil, and other rangeland resources.

rangeland vegetation: Vegetation on all land with rangeland resource objectives or rangeland 

resource values, including riparian areas. Generally, the focus is on land supporting grass or 

grass-like plants, forbs, or shrubs during one or more ecological stages. Forested and nonforested 

sites providing forage and habitat for wild and domestic animal species are included.

rare combinations of aquatic, terrestrial and atmospheric habitats: Principally reflect 

physical environmental features of the landscape that are produced from a unique combination of 

soils, climate, precipitation, and aspect. Refer to the analysis files for a complete description.

rare plants (as applicable to the Hells Canyon National Recreation Area): Plants that are 

federally listed as threatened, endangered, or proposed for federal listing; Forest Service Sensitive 

for Regions 1, 4, and 6, or disjunct species. This includes plants considered rare both globally 

(G1, G2, G3) or within states (S1, S2 or S3). 

real dollar value: A monetary value which compensates for the effects of inflation.

rearing habitat: Area in rivers or streams where juvenile salmon and trout find food and shelter 

to live and grow.

reasonable assurance: A judgment made by the Responsible Official based on best available 

scientific information and local professional experience that practices based on existing 

technology and knowledge are likely to deliver the intended results. Reasonable assurance applies 

to average and foreseeable conditions for the area and does not constitute a guarantee to achieve 

the intended results.

receipt shares: The portion of receipts derived from Forest Service resource management that is 

distributed to State and county governments, such as the Forest Service 25 percent fund 

payments.

recontour: To move soil back (usually with mechanical or hand tools) to a previous condition 

thus making an area blend with the natural landscape.

record of decision (ROD): An official document separate from, but associated, with a final 

environmental impact statement in which a deciding official identifies all alternatives, and 

specifies which were environmentally preferable, states the decision, and states whether all 

practicable means to avoid environmental harm from the alternative have been adopted, and if 

not, why not (40 CFR 1505.2).
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recovery plans: A plan for the survival and conservation of species listed under the Endangered 

Species Act. The Act [Section 4(f)] requires that recovery plans contain: 1) objectives, 

measurable goals for delisting; 2) a comprehensive list of the actions necessary to achieve the 

delisting goals; and 3) an estimate of the cost and time required to carry out those actions. In 

addition, NOAA Recovery Planning Guidelines suggest that recovery plans include an assessment 

of the factors that led to population declines and/or which are impeding recovery. Finally, it is 

important that the plans include a comprehensive monitoring and evaluation program for gauging 

the effectiveness of recovery measures and overall progress toward recovery.

recreation: Leisure time activity such as swimming, picnicking, boating, hunting, and fishing.

developed recreation: Recreation that requires facilities that, in turn, result in concentrated 

use of an area. Examples of developed recreation areas are campgrounds and ski areas; 

facilities in these areas might include roads, parking lots, picnic tables, toilets, drinking water, 

ski lifts, and buildings. 

dispersed recreation: A general term referring to recreation use outside developed recreation 

sites; this includes activities such as scenic driving, hiking, backpacking, hunting, fishing, 

snowmobiling, horseback riding, cross–country skiing, and recreation in primitive 

environments.

recreation opportunity: The availability of choices for users to participate in the recreational 

activities they prefer within the settings they prefer.

recreation opportunity spectrum: A recreation opportunity setting is the combination of 

physical, biological, social, and managerial conditions that give value to a place. Thus, an 

opportunity includes qualities provided by-nature (vegetation; landscape, topography, scenery), 

qualities associated with recreational use (levels and types of use), and conditions provided by 

management (developments, roads, regulations). By combining variations of these qualities and 

conditions, management can provide a variety of opportunities for recreationists. The settings, 

activities, and opportunities for obtaining experiences have been arranged along a continuum or 

spectrum divided into six classes: primitive, semi-primitive nonmotorized, semi-primitive 

motorized, roaded natural, rural, and urban (40 CFR 1505.2).

primitive – Area is characterized by an essentially unmodified natural environment of fairly 

large size Interaction between users is very low and evidence of other users is minimal. The 

area is managed to be essentially free from evidence of human-induced restrictions and 

controls. Motorized use within the area is not permitted.

semi-primitive nonmotorized – Area is characterized by a predominantly natural or natural 

appearing environment of moderate to large size. Interaction between users is low, but there is 

often evidence of other users. The area is managed in such a way that minimum on-site 

controls and restrictions may be present, but would be subtle. Motorized recreation use is not 

permitted, but local roads used for other resource management activities may be present on a 

limited basis. Use of such roads is restricted to minimize impacts on recreational experience 

opportunities.

semi-primitive motorized – Area is characterized by a predominantly natural or natural 

appearing environment of moderate to large size. Concentration of users is low, but there is 

often evidence of other users. The area is managed in such a way that minimum on-site 

controls and restrictions use of local primitive or collector roads with predominantly natural 

surfaces and trails suitable for motor bikes is permitted.
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roaded natural – Area is characterized by predominantly natural-appearing environments 

with moderate evidence of the sights and sounds of man. Such evidence usually harmonizes 

with the natural environment. Interaction between users may be moderate to high, with 

evidence of other users prevalent. Resource modification and utilization practices are evident, 

but harmonize with the natural environment. Conventional motorized use is allowed and 

incorporated into construction standards and design of facilities 

rural – Area is characterized by substantially modified natural environment. Resource 

modification and utilization practices are to enhance specific recreation activities and to 

maintain vegetative cover and soil. Sights and sounds of humans are readily evident, and the 

interaction between users is often moderate to high. A considerable number of facilities is 

designed for use by a large number of people Facilities are often provided for special 

activities. Moderate densities are provided far away from developed sites Facilities for 

intensified motorized use and parking are available. 

urban – Area is characterized by a substantially urbanized environment, although the 

background may have natural appearing elements. Renewable resource modification and 

utilization practices are to enhance specific recreation activities. Vegetative cover is often 

exotic and manicured. Sights and sounds of humans, on-site, are predominant. Large numbers 

of users can be expected, both on site and in nearby areas. Facilities for highly intensified 

motor use and parking are available with forms of mass transit often available to carry people 

throughout the site.

recreation residences: Privately owned recreation cabins authorized by special use permit on 

National Forest System land that occupy planned, approved tracts or those groups of tracts 

established for recreation residence use.

recreation site: Specific places in the national forest other than roads and trails that are used for 

recreational activities. These sites include a wide range of recreational activities and associated 

development. These sites include highly developed facilities like ski areas, resorts, and 

campgrounds. It also includes dispersed recreation sites that have few or no improvements but 

show the effects of repeated recreation use. 

recreation visit: An entry of one person to a recreation site or area of land or water for the 

purpose of participating in one or more recreation activities for an unspecified period.

recreational facilities: Refers to facilities associated with or required for outdoor recreational 

activities and includes, but are not limited to, parks, campgrounds, hunting and fishing lodges, 

and interpretive displays.

recreational river: Refer to Wild And Scenic River.

redd: Nest in gravel of stream bottom where a fish deposits eggs.

reforestation: A reference to a specific reforestation activity used to establish reproduction in a 

stand. Treatments include tree planting, direct seeding, coppice or root suckers, site preparation 

for natural reproduction (regeneration), or natural regeneration without site preparation. 

refugia: Areas that have not been exposed to great environmental changes and disturbances 

undergone by the region as a whole; refugia provide conditions suitable for survival of species 

that may be declining elsewhere.

regeneration: The process of establishing new plant seedlings, whether by natural means or 

artificial measures (e.g., planting, seeding).
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regeneration harvest method: A timber harvest procedure by which a new age class is created. 

The major methods are clearcutting, seed-tree, shelterwood, single tree selection, group selection 

and coppice. Regeneration methods are grouped into four categories: coppice, even-aged, twoaged, and uneven-aged.

regulations: Generally refers to the Code of Federal Regulations, Title 36, chapter II, which 

covers management of the Forest Service.

rehabilitate: To repair and protect certain aspects of a system so that essential structures and 

functions are recovered, even though the overall system may not be exactly as it was before.

relative stand density (see also stand density): The absolute stand density compared relative to 

the biological maximum carrying capacity for a given site and given species or group of species.

relic: Persistent remnants of formerly widespread fauna or flora species existing in certain 

isolated areas or habitats. The existence of an organism or species in an otherwise extinct taxon 

(phylum, order, family, genus, or species) from an earlier time that has survived in an 

environment that has undergone considerable change.

renewable energy: Energy derived from natural sources, such as sunlight, wind, water, tides, or 

geothermal resources, that does not consume the resource when used.

research natural area (RNA): An area set aside by a public or private agency specifically to 

preserve a representative sample of an ecological community, primarily for scientific and 

educational purposes. In Forest Service usage, Research Natural Areas are areas designated to 

ensure representative samples of as many of the major naturally–occurring plant communities as 

possible.

resident fish: Fish that spend their entire life in freshwater; examples include bull trout and 

westslope cutthroat trout.

resilience: The ability of a social or ecological system to absorb disturbances while retaining the 

same basic structure and ways of functioning, the capacity for self-organization, and the capacity 

to adapt to stress and change.

resource: Anything which is beneficial or useful, be it animal, vegetable, mineral, a location, a 

labor force, a view, an experience, etc. Resources, in the context of land use planning, thus vary 

from such commodities as timber and minerals to such amenities as scenery, scenic viewpoints, or 

recreation opportunities.

Resource Advisory Council (RAC): RACs were established by the BLM, under the Federal 

Advisory Committee Act to provide a forum for nonfederal partners to engage in discussion with 

agency managers regarding management of federal lands.

responsible official: The Forest Service employee who has the authority to select and/or carry 

out a specific planning action.

restoration: The process of assisting the recovery of an ecosystem that has been degraded, 

damaged, or destroyed. Ecological restoration focuses on reestablishing the composition, 

structure, pattern, and ecological processes necessary to facilitate terrestrial and aquatic 

ecosystems sustainability, resilience, and health under current and future conditions. 

resource allocation: The action of apportioning the supply of a resource to specific uses or to 

particular persons or organizations.
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riparian area: An area with distinctive soils and vegetation between a stream, or other body of 

water, and the adjacent upland area consisting of vegetation that requires free, or unbound, water 

for survival.

riparian-dependent species: Plant species that rely on free or unbound water for establishment 

and survival, and animal species that would normally occupy, or rely on, riparian habitats.

riparian management areas (RMAs): Portions of watershed where riparian–dependent 

resources receive primary emphasis and management activities are subject to specific standards 

and guidelines. Riparian management areas include traditional riparian corridors, wetlands, 

intermittent headwater streams, and other areas where proper ecological functioning is crucial to 

maintenance of the streams’ water, sediment, woody debris, and nutrient delivery system.

fish-bearing streams: Riparian management areas consist of the stream and the area on each 

side of the stream extending from the edges of the active stream channel to the top of the 

inner gorge, or to the outer edges of the 100-year floodplain, or to the outer edges of riparian 

vegetation, or to a distance equal to the height of two site-potential trees, or 300 feet slope 

distance (600 feet total, including both sides of the stream channel), whichever is greatest. In 

degraded or incised streams, the riparian management area should extend from the edge of

the active channel to the outer extent of the former floodplain. It is expected that riparian 

management area widths along fish-bearing streams will not be less than described here.

permanently flowing non-fish-bearing streams: Riparian management areas consist of the 

stream and the area on each side of the stream extending from the edges of the active stream 

channel to the top of the inner gorge, or to the outer edges of the 100-year floodplain, or to 

the outer edges of riparian vegetation, or to a distance equal to the height of one site-potential 

tree, or 150 feet slope distance (300 feet total, including both sides of the stream channel), 

whichever is greatest. In degraded or incised streams, the riparian management area should 

extend from the water’s edge to the outer extent of the former floodplain.

constructed ponds and reservoirs, and wetlands greater than 1 acre: Riparian 

management areas consist of the body of water or wetland and: the area to the outer edges of 

the riparian vegetation, or to the extent of seasonally saturated soil, or the extent of unstable 

and potentially unstable areas, or to a distance equal to the height of one site-potential tree, or 

150 feet slope distance from the edge of the wetland greater than 1 acre or the maximum pool 

elevation of constructed ponds and reservoirs, whichever is greatest.

lakes and natural ponds: Riparian management areas consist of the body of water and the 

area to the outer edges of the riparian vegetation, or to the extent of seasonally saturated soil,

or to the extent of unstable and potentially unstable areas, or to a distance equal to the height 

of two site-potential trees, or 300 feet slope distance, whichever is greatest.

seasonally flowing or intermittent streams, wetlands, seeps and springs less than 1 acre, 

and unstable and potentially unstable areas: This category applies to features with high 

variability in size and site-specific characteristics. At a minimum, the riparian management 

areas should include:

♦ The extent of unstable and potentially unstable areas (including earthflows).

♦ The stream channel and extend to the top of the inner gorge, or in incised streams, to 

the edge of the former floodplain.

♦ The stream channel or wetland and the area from the edges of the stream channel or 

wetland to the outer edges of the riparian vegetation, extending from the edges of the 

stream channel to a distance equal to the height of one site-potential tree, or 100 feet 
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slope distance, whichever is greatest. A site-potential tree height is the average 

maximum height of the tallest dominant trees for a given site class.

♦ Intermittent streams are defined as any nonpermanent flowing drainage feature 

having a definable channel and evidence of annual scour or deposition. This includes 

what are sometimes referred to as ephemeral streams if they meet these two physical 

criteria. Including intermittent streams, springs, and wetlands within riparian 

management areas is important for full implementation of the Blue Mountains ARCS. 

Accurate identification of these features is critical to the correct implementation of 

the strategy and protection of the intermittent stream and wetland functions and 

processes. Identification of these features is difficult at times due to the lack of 

surface water or wet soils during dry periods. Fish-bearing intermittent streams are 

distinguished from non-fish-bearing intermittent streams by the presence of any 

species of fish for any duration. Many intermittent streams may be used as spawning 

and rearing streams, refuge areas during flood events in larger rivers and streams or 

travel routes for fish emigrating from lakes. In these instances, the guidelines for fishbearing streams would apply to those sections of the intermittent stream used by the 

fish.

riverine: On or near the banks of a river; riparian.

road: A motor vehicle route over 50 inches wide, unless designated and managed as a trail. A 

road may be classified, unclassified, or temporary (36 CFR 212.1).

classified roads: Roads wholly or partially within or adjacent to national forest lands that are 

determined to be needed for long-term motor vehicle access, including state roads, county 

roads, privately owned roads, forest roads, and other roads authorized by the Forest Service 

(36 CFR 212.1).

closed road: A road with all use suspended year–long by an active form of facility 

management utilizing regulations and appropriate enforcement to secure and ensure user 

compliance with closure.

open road: A road that has no use restrictions or regulations imposed and is available for use 

by vehicles at any time during the year.

temporary roads: Roads authorized by contract, permit, lease, other written authorization, or 

emergency operation not intended to be a part of the national forest transportation system and 

not necessary for long-term resource management (36 CFR 212.1).

road construction: Activity that results in the addition of forest classified or temporary road 

miles (36 CFR 212.1). New construction activities may include vegetation clearing and grubbing, 

earthwork, drainage installation, instream activities, pit development or expansion, surfacing 

(including paving), and aggregate placement.

road decommissioning: Activities that result in the stabilization and restoration of unneeded 

roads to a more natural state (36 CFR 212.1, FSM 7703). Road decommissioning activities 

include revegetation, recontouring, water barring, roadbed scarification or ripping, culvert 

removal, berm construction, and side cast pullback.

road density: An indicator of the concentration of roads in an area.

road maintenance: The ongoing upkeep of a road necessary to retain or restore the road to the 

approved road management objective.
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road maintenance levels (MLs): Maintenance levels define the level of service provided by, and 

maintenance required for, a specific road. Maintenance levels must be consistent with road 

management objectives and maintenance criteria. Roads assigned to maintenance levels 2 through 

5 are either constant service roads or intermittent service roads during the time they are open to 

traffic. 

Level 1: Assigned to intermittent service roads during the times they are closed to vehicular 

traffic. The closure period must exceed 1 year. Basic custodial maintenance is performed to 

keep damage to adjacent resources to acceptable levels and to perpetuate the road to facilitate 

future management activities. Emphasis is normally given to maintaining drainage facilities 

and runoff patterns. Planned road deterioration may occur at this level. Appropriate traffic 

management strategies are prohibit and eliminate.

Roads receiving Maintenance Level 1 maintenance may be of any type, class, or construction 

standard, and may be managed at any other maintenance level during the time they are open 

for traffic. However, while being maintained at Maintenance Level 1, they are closed to 

vehicular traffic, subject to prohibitions and restrictions, and may be available and suitable 

for nonmotorized users. 

Maintenance Level 1 maintenance activities include road condition surveys, evaluation, and 

monitoring of maintenance needs. Activities include limited equipment operation, opening 

closed roads, manual cleaning of drainage structures, and vegetation management that 

stabilizes or reduces erosion. Repairs are scheduled and completed within funding limitations 

when critical resource damage is reported.

Roadway activities including blading, clearing logs, and noncritical repairs that can be 

delayed are accomplished when the road is placed in an active status.

Level 2: Assigned to roads open for use by high-clearance vehicles. Providing access for 

passenger cars is not a consideration. Traffic is normally minor, usually consisting of 

administrative, permitted, dispersed recreation, and/or other specialized uses. Log hauling 

may occur. Appropriate traffic management strategies are either to discourage or prohibit 

passenger cars or to accept or discourage high-clearance vehicles.

Maintenance Level 2 maintenance activities include roadside brushing, hazard-tree removal, 

surface blading, drainage maintenance, structure maintenance, clearing logs, slide and slip 

cleanup and repair, sign maintenance and surface replacement. Drainage function and soil 

stabilization are of prime importance. Many roads in this category have grass in the travel 

way. User comfort is not a consideration.

Level 3: Assigned to roads open and maintained for travel by prudent drivers in standard 

passenger cars. User comfort and convenience are not considered priorities.

Roads in this maintenance level are typically low-speed, single-lane, with turnouts and spot 

surfacing. Some roads may be fully surfaced with either native or processed material. 

Appropriate traffic management strategies are encourage or accept. Discourage or prohibit 

strategies may be employed for certain classes of vehicles or users.

Maintenance Level 3 maintenance activities include roadside brushing, hazard-tree removal, 

surface blading, drainage maintenance, structure maintenance, clearing logs, slide and slip 

cleanup and repair, sign maintenance and surface replacement. Drainage function and soil 

stabilization are of prime importance. Dust abatement and more frequent blading may be 

needed on segments of multi-purpose roads.
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Level 4: Assigned to roads that provide a moderate degree of user comfort and convenience 

at moderate travel speeds. Most roads are double-lane and aggregate-surfaced. However, 

some roads may be single-lane. Some roads may be paved and/or dust abated. The most 

appropriate traffic-management strategy is encourage. However, the prohibit strategy may 

apply to specific classes of vehicles or users at certain times.

Maintenance Level 4 maintenance activities include roadside brushing, hazard tree removal, 

surface blading, drainage maintenance, structure maintenance, clearing logs, slide and slip 

cleanup and repair, sign maintenance and surface replacement. Drainage function and soil 

stabilization are of prime importance. Dust abatement and more frequent blading may be 

needed on segments of multi-purpose roads.

Level 5: Assigned to roads that provide a high degree of user comfort and convenience. 

These roads are normally double lane, paved. Some may be aggregate-surfaced and dustabated. The appropriate traffic management strategy is encourage.

Maintenance Level 5 maintenance activities include roadside brushing, hazard-tree removal, 

surface blading, drainage maintenance, structure maintenance, logging out, slide and slip 

cleanup and repair, sign maintenance and surfacing replacement. Drainage function and soil 

stabilization are of prime importance. Dust abatement and more frequent blading may be 

needed on segments of multi-purpose roads. All of the Maintenance Level 5 roads within a 

national forest have a permanent (paved) surface.

road management objectives: Road management objectives define the level of service provided 

by a National Forest System road consistent with the surrounding recreation opportunity spectrum 

(ROS) class.

semi–primitive nonmotorized (SPNM): Most semi-primitive nonmotorized areas do not 

have developed roads. All motorized traffic is prohibited. Semi-primitive nonmotorized roads 

provide hiking or equestrian trails on closed or decommissioned roads. 

semi–primitive motorized (SPM): Semi-primitive motorized roads are generally used for 

four-wheel drive, logging, or ranching activities. Passenger-car use is discouraged by 

entrance conditions or signage. Users can expect semi–primitive motorized roads where there 

are no attractions such as viewpoints or trailheads.

♦ low-level SPM: Native surface roads suitable for high-clearance vehicles but not 

passenger cars or vehicles towing trailers. Users may need to back vehicles for long 

distances when meeting oncoming traffic. Maintenance activities occur usually every 

five years or when resource needs are identified. Roads are allowed to “brush in” and 

users are responsible for removing trees blocking the road. Ruts and potholes are 

accepted if they do not contribute to sediment loading. Corresponds to road 

Maintenance Level 2 and Traffic Service Level D (abbreviated: 2-D).

♦ high-level SPM: Single-lane native surface road or road surfaced with spot rock, 

strip rock or pit run material suitable for high-clearance vehicles. The road may have 

infrequent turnouts. Pit run material is applied to the road surface, but is not grid 

rolled, leaving a rough, rocky surface that drains well and discourages passenger car 

use. User maintenance is the same as for the low-level semi–primitive motorized. 

This standard meets resource and safety needs and is the minimum standard for 

accessing attractions such as viewpoints or trailheads. Maintaining current road 

alignment, road surface type, and corridor width are emphasized. Corresponds to 

Maintenance Level 2 and Traffic Service Level C (abbreviated: 2-C). 
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roaded natural (RN): Roaded natural roads provide safe access for passenger cars. 

Maintenance activities generally occur annually or every two years, depending on funding 

and need. Forest Service clears these roads of brush and logs. Surface maintenance increases 

at higher levels. Because of increased speeds, turnouts are needed more frequently. Open

local roads and some collector roads within roaded natural are managed for high-clearance 

vehicles. In such cases, road-maintenance standards defined for semi–primitive motorized

would be used.

♦ low-level RN: Road-surface type of either native or base course. Pit-run material is 

processed to provide a rough but suitable service for passenger cars. Dust increases 

during dry conditions, and the road provides good resource protection when wet. 

Corresponds to road Maintenance Level 3 and Traffic Service Level C (abbreviated: 

3-C).

♦ medium-level RN: Road-surface type of crushed aggregate, maintained for 

passenger cars. Usually maintained annually, surfaces may “washboard” and become 

dusty with increased use. Corresponds to road Maintenance Level 3 and Traffic 

Service Level C or B (abbreviated: 3-C or 3-B).

♦ high-level RN: Road-surface type of an aggregate that has been dust-abated or 

treated with soil or silicone stabilizers, or asphalt emulsions. A dust-free, smooth 

surface for passenger cars is the desired product. This standard is often applied to 

provide double-lane access to attractions such as viewpoints or campgrounds. 

Corresponds to road Maintenance Level 4 and Traffic Service Level B or A 

(abbreviated: 4-B or 4-A). 

rural (R): Rural is generally the highest standard of road. These arterial roads provide the 

main access to the national forest lands but generally lack the speeds and alignment provided 

by state highways. Roads are double–lane with a road-surface treatment and generally 24-feet 

wide. The road has center striping and often stripes marking the shoulders. Corresponds to a 

road Maintenance Level 5 and Traffic Service Level A (abbreviated: 5-A).

road prism: an area consisting of the road surfaces and any cut slope and road fill.

road reconstruction: Activity that results in improvement or realignment of an existing 

classified road as defined below. Reconstruction activities may include vegetation clearing and 

grubbing, earthwork, drainage installation, instream activities, surfacing (including paving), and 

aggregate placement.

road improvement: Activity that results in an increase of an existing road’s traffic service 

level, expands its capacity, or changes its original design function.

road surface types: 

asphalt/concrete: A well-graded aggregate and asphalt cement.

aggregate: Stone, slag, gravel, or any other hard, inert, mineral material meeting certain 

specified quality requirements for use in a road pavement or surfacing structure.

paved: One or more bituminous bound layers of aggregate placed on a prepared road 

foundation.

pit run: Aggregate consisting of native materials from a given source with a maximum size 

and grading suitable for placing directly on a road without crushing or screening.
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native surface: A road surface consisting of soil or aggregate materials naturally existing at 

the road location.

spot rock: Aggregate placed on a road as a pavement or surfacing structure in designated 

areas that are not continuous throughout the entire length of the road.

strip rock: Aggregate placed on a road as a surfacing structure in designated areas or 

portions of a road greater than 200 feet in length but not continuous throughout the entire 

length of the road.

surface treated: One or more applications of asphalt or other processed or natural materials 

to a road surface to provide traction, abate dust, protect, or renew the surface without 

increasing pavement structural capacity. Surface treatment is commensurate with existing 

surface.

rotation: In a timber production program, the number of years (including the regeneration 

period) required to establish and grow timber under an even-aged management system to a 

specified condition or maturity for regeneration harvest.

runoff (surface): Fresh water from precipitation and melting ice that flows on the earth’s surface 

into nearby streams, lakes, wetlands, or reservoirs.

S

sale schedule: The quantity of timber planned for sale by time period from an area of suitable 

land covered by a forest plan. The first period, usually a decade, of the selected sale schedule 

provides the allowable sale quantity. Future periods are shown to establish that long-term 

sustained yield will be achieved and maintained.

salmonids: Fishes of the family Salmonidae, including salmon, trout, chars, whitefish, ciscoes, 

and grayling.

salvage harvest: Harvest of dead trees or trees being damaged or dying due to injurious agents 

other than competition, to recover value that would otherwise be lost. A salvage harvest is an

intermediate harvest. If the salvage cutting is heavy enough to require regeneration, it would be 

correct to use terminology referring to a regeneration harvest method. 

sanitation harvest: The removal of trees to improve stand health by stopping or reducing actual 

or anticipated spread of insects and diseases. A sanitation harvest is an intermediate harvest. If the 

sanitation cutting is heavy enough to require regeneration, it would be correct to use terminology 

referring to a regeneration harvest method.

satisfactory condition: A condition in which the soil is adequately protected and the forage 

species composition and production meets the land management plan objectives or the trend in 

forage species composition and production is acceptable.

savannah: The transitional biome between grassland and desert or desert and rainforest, typically 

having drought resistant vegetation dominated by grasses with scattered tall trees.

scabland: A region characterized by elevated tracts of rocky ground with little or no soil cover.

scale: (1) The level of resolution under consideration (for example, broad-scale or fine-scale); (2) 

the ratio of length on a map to true length.

scenery management system (SMS): The scenery management system is the method that was 

adopted after the Forest Plan was completed in 1990. The scenery management system utilizes 
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two indicators to determine desired landscape character: ecological landscape integrity and scenic 

integrity. Ecological landscape integrity evaluates whether the landscape is managed in a 

sustainable and ecologically sound manner. Scenic integrity evaluates whether the landscape 

character is being managed in a way that conserves constituent values in terms of the level of 

human-caused deviations that are acceptable to the public (USDA Forest Service 1995 SMS 

Handbook).

scenic area: Places of outstanding or matchless beauty that require special management to 

preserve these qualities. They may be established under 36 CFR 294.1 whenever lands possessing 

outstanding or unique natural beauty warrant this classification. 

scenic class: Scenic class indicates the importance or value of a particular landscape determined 

by constituent information. 

scenic identity: The scenic image and identity is the landscape character of an area. The

landscape character identifies the “ideal” or optimal set of valued scenery attributes and describes 

the setting provided by these scenery attributes within each biophysical setting. It is important to 

understanding of the process, structure, and functions that support the valued set of scenery 

attributes. This understanding helps identify conditions and stressors that put scenery resources at 

risk.

scenic integrity level: Measures the degree to which a landscape is free from visible disturbances 

that detract from the natural or socially valued appearance. Scenic integrity objectives establish 

the desired level of scenic integrity for an area. Scenic stability measures the degree to which the 

valued landscape character and its scenery attributes can be sustained through time and ecological 

progression. Scenic stability objectives establish the desired level of scenic stability for a 

particular area. It is used to describe an existing situation, an objective for management, or 

desired conditions. 

very high scenic integrity: Scenery with fully intact landscape features and scenic 

compositions presenting the optimal landscape character in complete harmony, with very 

minute, if any, scenic discordance. Due to the optimal scenic integrity of the physical, 

biological, and cultural features in these scenic compositions, the landscape character and 

sense of place are expressed at the highest possible level. Very high scenic integrity is most 

compatible with wilderness, backcountry, biophysical, or cultural preserves, and other special 

classification areas.

high scenic integrity: Scenery with whole or nearly intact landscape features and scenic 

compositions that present the optimal landscape character completely or nearly in full, and 

contain scenic discordances that are not evident.

moderately high scenic integrity: Scenery with slightly altered landscape features and 

compositions in which the valued landscape character is the dominant scenic impression, yet 

minor discordance is apparent, but visually subordinate. The “moderate” level of scenic 

integrity in the Scenery Management Handbook has been split into two categories to reflect 

more accurately the scenic conditions on the in the Blue Mountains.

moderately low scenic integrity: Scenery with altered landscape features and compositions 

that display a beginning dominance of valued landscape character expression and readily 

noticeable discordance.

low scenic integrity: Scenery with obviously altered landscape features and compositions 

that dominate yet still express some aspects of valued landscape character. The scenic 
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harmony of the valued landscape character is seriously fragmented and barely restorable 

within reasonable periods and resource expenditures.

very low scenic integrity: Scenery with extremely altered landscape features and 

composition that no longer sustains significant aspects of valued landscape character. The 

scenic harmony of the optimal landscape character does not exist and its restoration may be 

impossible if not unrealistic.

scenic integrity objective: An established goal for the management of the scenic resource 

applied to a specific portion of the national forest.

scenic river: Refer to Wild and Scenic River.

science consistency review: Certification that the revised forest plan takes into account the best 

available science as required by the 2005 Planning Rule.

scoping process: A part of the NEPA process; the early stages of preparation of an environmental 

impact statement, early and open activities used to solicit public opinion, receive comments and 

suggestions, and determine the scope and significance of the issues to be considered in the 

development and analysis of a range of actions, alternatives, and impacts to be considered. 

Scoping may involve public meetings, telephone conversations, mailings, letters, or other 

contacts (40 CFR 1501.7).

screening: The reduction or elimination of the visual impact of any structure or land modification 

as seen from any public travel route within the national forests.

secondary productivity: The growth of animal species that use the products derived from The 

growth and accumulation of plant biomass (primary productivity).

sediment: Solid materials, both mineral and organic, in suspension or transported by water, 

gravity, ice, or air; may be moved and deposited away from their original position and eventually 

will settle to the bottom.

sediment regime: The rate, frequency, magnitude, and duration of sediment movement. Refer to 

flow regime.

seed tree regeneration method: An even-aged regeneration harvest method in which a new age 

class develops from seeds that germinate in fully-exposed micro-environments after removal of 

the previous stand, except for a small number of trees left to provide seed. Any retained trees, 

referred to as leave trees, should generally comprise less than 10% of the growing space of the 

stand. When the seed tree method is employed, the sequence of treatments can include three 

distinct types of cuttings:

1. seed tree preparatory cut - An optional cut that enhances conditions for seed production 

and/or develop wind firmness for a future seed cut.

2. seed cut - A cut to prepare the seed bed and create a new age class under full sun while 

retaining trees needed to provide seed needed for regeneration. 

3. seed tree removal cut - An optional final removal cut that releases established 

regeneration from competition with seed trees after they are no longer needed for seed or 

as leave trees.

selection harvest methods: Silvicultural regeneration harvest methods used to create or maintain 

uneven-aged stands. Harvest methods that develop and maintain uneven-aged stands are singletree selection and group selection.
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self-reliance: Reliance on one’s own capabilities, judgment, or resources through application of 

outdoor skills in an environment that offers a high degree of risk and challenge.

self-sustaining populations: Populations that are sufficiently abundant, interacting, and welldistributed in the Plan Area, within the bounds of their life history and distribution of the species 

and the capability of the landscape, to provide for their long-term persistence, resilience and 

adaptability over multiple generations.

sense of place: A reference for the physical, emotional, cultural, symbolic, and spiritual aspects 

of people’s tangible and intangible relationships with the land and the meanings associated with 

them.

sensitive soils: Forest land areas that have a moderate to very high hazard for soil compaction. 

Erosion, displacement, mass wasting, or forest floor displacement.

sensitive species: Plant or animal species identified by a regional forester for which population 

viability is a concern either: 1) because of significant current or predicted downward trends in 

population numbers or density; or 2) because of significant current or predicted downward trends 

in habitat capability that would reduce a species’ existing distribution. Those species that have 

appeared in the Federal Register as proposed for classification or are under consideration for 

official listing as endangered or threatened species, that are on an official state list, or that are 

recognized by the regional forester as needing special management to prevent placement on 

federal or state lists.

seral: Refers to the stages that plant communities go through during the progression in structure 

and composition over time. Development stages have characteristic structure and plant species 

composition. See succession for definitions of different seral stages.

seral stage (see also succession): The developmental phase of a forest stand or rangeland with 

characteristic structure and plant species composition.

serotinous: characteristic of some lodgepole pine, in which the cones are covered with a resin 

that must be melted by heat for the cones to open and release seeds.

shade intolerant: Species of plants that are less tolerant of shaded conditions than other species, 

and often cannot survive in shaded conditions. 

shade tolerant: Species of plants that can tolerate and survive in more shaded conditions than 

other species can.

shelterwood regeneration method: A method of regenerating an even-aged stand in which a 

new age class develops beneath the moderated micro-environment provided by the residual trees. 

Any retained trees, referred to as leave trees, should generally comprise less than 10% of the 

growing space of the stand. When the shelterwood regeneration method is employed, the 

sequence of treatments can include three distinct types of cuttings: 

1. shelterwood preparatory cut - An optional cut that enhances conditions for seed 

production and/or develop wind firmness for a future shelterwood establishment cut.

2. shelterwood establishment cut - A cut to establish a moderated micro-environment, 

prepare the seed bed, and create a new age class.

3. shelterwood removal cut - A final removal cut that releases established regeneration from 

competition with shelter trees after they are no longer needed for shelter under the 

shelterwood regeneration method

shrubland: Area of land where the potential vegetation is dominated by shrubs.
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short term: Generally refers to a period of 10 years or less.

silviculture: The art and science of controlling the establishment, growth, composition, health, 

and quality of forests and woodlands to meet the diverse needs and values of landowners and 

society on a sustainable basis. 

silvicultural system: A management process whereby forests are tended, harvested, and replaced, 

resulting in a forest of distinctive form. Systems are classified according to the method of 

carrying out the fellings that remove the mature crop and provide for regeneration and according 

to the type of forest thereby produced.

silvicultural treatment: A forest management activity such as thinning, harvesting, planting, 

pruning, prescribed burning, mastication, or site preparation that is designed to alter the 

establishment, growth, composition, health, and quality of forests and woodlands to meet the 

diverse needs and values of landowners and society on a sustainable basis.

single-story: Structural arrangement of trees within a stand generally characterized by having 

only one distinct horizontal layer of tree crowns. This layer may also be referred to as a stratum.

site: (1)A specific location of an activity or project, such as a campground, a lake, or a stand of 

trees to be harvested; (2) The location of a significant event, a prehistoric or historic occupation 

or activity, or a building or structure, whether standing, ruined or vanished, where the location 

itself maintains historical or archeological value regardless of the value of any existing structure 

[36CFR65] (historic or archaeological definition).

site-potential tree: The average maximum height of the tallest trees for a given site class.

snag: A standing dead tree usually greater than five feet in height and six inches in diameter at 

breast height (d.b.h.).

social well-being: A condition that enables citizens, communities, and visitors to contribute to 

their wellness, values and quality of life.

society: A group of people who have a common homeland, are interdependent, and share a 

common culture.

soil: The earth material that has been so modified and acted upon by physical, chemical, and 

biological agents that it will support rooted plants.

soil function: The characteristic physical and biological activity of soils that influences 

productivity, capability, and resiliency.

soil productivity: The inherent capacity of a soil to produce plant growth, due to the soil’s 

chemical, physical, and biological properties (such as depth, temperature, water-holding capacity, 

and mineral, nutrient, and organic matter content). It is often expressed by some measure of 

biomass accumulation.

soil quality: The capacity of a soil to function within ecosystem boundaries to sustain biological 

productivity, maintain environmental quality, and promote plant and animal health.

soil stability: (1) Mass stability of the soil profile or resistance to mass failure; (2) stability of the 

soil surface with respect to accelerated sheet, rill, and gully erosion processes.

soil surveys: All soil surveys are made by examining, describing, and classifying soils in the field 

and delineating their areas on maps. The map scale for field mapping must be large enough to 

allow areas of minimum size to be delineated legibly. Recognition of the different soil survey 

levels is helpful for communicating about soil surveys and maps, even though the levels cannot 
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be sharply separated from each other. The order of a survey is consequence of field procedures, 

the minimum size of delineation, and the kinds of map units that are used.

solid waste: Discarded solid waste materials resulting from mining, industrial, commercial, 

agricultural, silvicultural, and community activities. Does not include domestic sewage or 

pollutants such as silt, or dissolved materials in irrigation return flows.

source habitat: Habitat in such conditions that result in a positive or increasing population 

growth for a particular species. Those characteristics of vegetation that support long-term wildlife 

species persistence, or characteristics of vegetation that contribute to stable or positive population 

growth for a species in a specified area and time. Source habitats are described using dominant 

vegetation cover type and structural stage combinations that can be estimated reliably at the 247-

acre (100-hectare) patch scale. Various combinations of these cover type–structural stages make 

up the source habitats for the terrestrial species discussed in this Final Environmental Impact 

Statement, and provide the range of vegetation conditions required by these species for food, 

reproduction, and other needs (Wisdom et al. 2000).

spatial: Related to or having the nature of space.

special habitat: A habitat which has a special function not provided by plant communities and 

successional stages. Includes riparian zones, snags, dead and downed wood, and edges (Thomas 

1979).

specially designated areas: Also referred to as special areas and is one of the plan components. 

Areas designated because of their unique or special characteristics, such as botanical areas or 

areas designated by stature or administrative processes such as wilderness, wild and scenic rivers, 

or research natural areas.

special use authorization: A permit, term permit lease, or easement which allows occupancy, 

use, rights, or privileges of national forest lands (36 CFR 251.51).

special use permit: A special authorization which provides permission without conveying any 

interest in land, to occupy and use national forest land or facilities for specified purpose, and 

which is revocable, terminable and noncompensable.

species: A population or series of populations of organisms that can interbreed freely with each 

other but not with members of other species.

species composition: The species that occur on a site or in a successional stage of a plant 

community (Thomas 1979).

species diversity: The number of species occurring in a given area.

sprouter: Flora capable of vegetative reproduction from roots or stems.

stand: A contiguous group of trees sufficiently uniform in age class distribution, composition, 

and structure, and growing on a site of sufficiently uniform quality, to be a distinguishable unit, 

such as mixed, pure, even-aged, and uneven-aged stands. 

stand composition: The proportion of each tree species in a stand expressed as a percentage of 

the total number, basal area, or volume of all tree species in the stand.

stand density (see also relative stand density): It is an absolute measure of tree occupancy per 

unit area, like trees per acre or basal area per acre. Stand density indicates the degree to which an 

area is occupied by trees and, hence the intensity by which trees are competing for site resources 

(Tappeiner 2007). 
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stand initiation stage (SI): Structural stage of young stands that develop following a standreplacing disturbance such as wildfire or a regeneration timber harvest. Growing space is 

typically reoccupied rapidly by vegetation that either survives the disturbance or colonizes the 

area. Forest vegetation within these stands literally survive the disturbance above ground, or 

initiate growth from their underground roots or from seeds stored on-site. Colonizers also 

disperse seed into disturbed areas, the seed germinates and then new seedlings establish and 

develop. A single canopy layer of young trees is typically present in this stage. Average dominant 

tree diameters are usually less than five inches.

stand-replacement fire: A fire severity classification where at least 75 percent replacement of 

the upper layer of vegetation is removed.

stand structure: General term referring to the collection and spatial arrangement of species, tree 

sizes, canopy layers, and age-classes in a forest stand. 

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

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

undesirable effects, or to meet applicable legal requirements.

state and transition model: Nonequilibrium ecological model to describe vegetation dynamics 

of rangeland sites as adopted by the Natural Resource Conservation Service. Models recognize 

multiple steady states of vegetation and emphasize disturbance processes.

stem exclusion stage: Structural stage is usually created when vigorous, fast growing trees that 

compete strongly with one another for available light and moisture occupy the growing space. 

Because trees are taller and the growing space is fully occupied, establishment of new trees is 

generally precluded by a lack of sunlight or moisture. Individuals that compete unsuccessfully are 

often stressed or die. These stands typically only have one dominant layer. Average overstory tree 

diameters usually range from 5 to 20 inches.

strategy: Part two of a land management plan that explains the suitable uses and includes the 

special designated areas, and management categories.

stream channel: Refer to channel.

stream class: Classification of streams based on the present and foreseeable uses made of the 

water and the potential effects of on-site changes in downstream uses. Four classes are defined as:

class I: Perennial or intermittent streams that provide a source of water for domestic use; are 

used by large numbers of anadromous fish or significant sports fish for spawning, rearing, or 

migration; and/or are major tributaries to the other Class I streams.

class II: Perennial or intermittent streams that are used by fish for spawning, rearing, or 

migration; and/or may be tributaries to Class I streams or other Class II streams.

class III: Other perennial streams not meeting higher-class criteria.

class IV: Other intermittent streams not meeting higher class criteria.

stringers: Relatively narrow areas suitable to be occupied by forested plant associations within a 

landscape that is otherwise unsuitable due to site or environmental factors.

stronghold: Directly associated with strong populations. For native fish, strong populations have 

stable numbers or are increasing, and all major life history forms that historically occurred within 

the watershed are present.
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stocking level: A measure of stand density relative to a specific optimum that is set in accordance 

with management objectives.

structure (see also stand structure): (1) Any permanent building or facility, or part thereof such 

as barns, outhouses, residences, and storage sheds including transmission line systems, 

substations, commercial radio transmitters, relays or repeater stations, antennas, and other 

electronic sites and associated structures.

structural stage: One of five distinct classifications of stand structure used in the Final 

Environmental Impact Statement analysis process including; stand initiation (SI), stem exclusion 

(SE), understory reinitiation (UR), old forest single-story (OFSS) and old forest multi-story 

(OFMS). 

subalpine: A terrestrial community that generally is found in harsher environments than the 

montane terrestrial community. Subalpine communities are generally colder than montane and 

support a unique clustering of wildlife species.

subbasin: In the National Hydrography Dataset, a subdivision of basins, also called HU8 

(formerly HUC4) and denoted by an 8-digit numeric code. Subbasins in the Pacific Northwest 

have drainage areas averaging between 800,000 and 1,000,000 acres. The Upper John Day 

subbasin, for example, is denoted by the numeric descriptor 17070201; the North Fork John Day 

subbasin is 17070202, the Middle Fork John Day subbasin is 17070203, and the Lower John Day 

subbasin is 17070204. See also: basin, watershed, and subwatershed.

subsistence: Customary and traditional uses of wild renewable resources (plants and animals) for 

food, shelter, fuel, clothing, tools, etc.

subwatershed: In the National Hydrography Dataset, a subdivision of watersheds with drainage 

areas of approximately 20,000 acres, equivalent to a 6th-field (12-digit) HUC, or HU12 (formerly 

HUC6). Subwatersheds are the smallest hydrologic units described in the forest plans and FEIS 

although it is possible to delineate smaller subdivisions, for example HU14 (HUC7) and HU16 

(HUC8). See also: basin, subbasin, and watershed.

succession: The sequential replacement over time of one plant community by another, in the 

absence of major disturbance. Conditions of the prior plant community or successional stage 

create conditions that are favorable for the establishment of the next stage. The different stages of 

succession are often referred to as seral stages. Developmental stages are as follows: 

early seral: Communities that occur early in the successional path and generally have less 

complex structural developmental than other successional communities. Seedling and sapling 

size classes are an example of early seral forests. 

mid-seral: Communities that occur in the middle of the successional path. For forests, this 

usually corresponds to the pole or medium sawtimber growth stages. 

late-seral: Communities that occur in the later stage of the successional path with mature, 

generally larger individuals, such as mature forests.

suitability: The appropriateness of applying certain resource management practices to a 

particular area of land, as determined by an analysis of the economic and environmental 

consequences and the alternative uses foregone. A unit of land may be suitable for a variety of 

individual or combined management practices.

suitable habitat: Habitat that currently has both the fixed and variable stand attributes for a given 

species habitat requirements. Variable attributes change over time and may include seral stage, 

cover type and overstory canopy cover.
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suitable uses: Uses that are compatible with the desired conditions and objectives for a given 

area which are identified as guidance for project and activity decisionmaking and do not represent 

a commitment or final decision approving projects or activities.

surface fire: A fire that burns surface litter, dead woody fuels, other loose debris on the forest 

floor, and some small vegetation without significant movement into the overstory, usually with a 

flame less than a few feet high.

surface water development: The practice of diverting or impounding surface water sources by 

the construction of dams, diversions, canals, or ditches for use, such as irrigation, livestock 

watering, and human consumption.

surrogate species: A species that represents other species that share similar habitat and risk 

factors and include Region 6 sensitive species, State-listed species, or other species for which the 

published literature has identified a concern for their viability. The key characteristic of a 

surrogate species is that its status and trend provide insights to the integrity of the larger 

ecological system to which it belongs. Surrogate species serve an umbrella function in terms of 

encompassing habitats needed for other species, are sensitive to the changes likely to occur in the 

area, or otherwise serve as an indicator of ecological sustainability.

sustainability: Meeting needs of the present generation without compromising the ability of 

future generations to meet their needs. Sustainability is composed of desirable social, economic, 

and ecological conditions or trends interacting at varying spatial and temporal scales, embodying 

the principles of multiple-use and sustained-yield (FSM 1905).

sustained-yield of products and services: The achievement and maintenance in perpetuity of a 

high-level annual or regular periodic output of the various renewable resources of the National 

Forest System without impairment of the productivity of the land.

T

talus: A slope formed by the accumulation of rock debris at the base of a cliff.

temporal: Related to time.

tentatively suitable forest land: Forest land that is producing or is capable of producing crops of 

industrial wood and: (a) has not been withdrawn by Congress, the Secretary, or the Chief; (b) 

existing technology and knowledge is available to ensure timber production without irreversible 

damage to soils productivity, or watershed conditions; (c) existing technology or knowledge, as 

reflected in current research and experience, provides reasonable assurance that it is possible to 

restock adequately within 5 years after final harvest; and (d) adequate information is available to 

project responses to timber management activities.

terrestrial: Pertaining to the land.

terrestrial wildlife: Wildlife species that dwell primarily on land (Thomas 1979).

thermal cover: Cover used by animals to ameliorate effects of weather; for elk, a stand of 

coniferous trees 40 feet or more tall with an average crown closure of 70 percent or more, for 

deer, cover may include saplings, shrubs, or trees at least five feet tall with 75 percent crown 

closure.

thermal regulation: The processes by which many animals actively maintain the temperature of 

all or parts of their body; the protection against local climatic extremes provided by, for example, 

shade produced by vegetation, protection from wind or sun, or protection from extreme cold.
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thinning: An intermediate treatment made to reduce stand density of trees primarily to improve 

growth, enhance forest health, or to recover potential mortality. Variations include crown thinning 

(thinning from above, high thinning), free thinning, low thinning (thinning from below), 

mechanical thinning (geometric thinning), and selection thinning (dominant thinning).

threatened species: Species listed under the Endangered Species Act by either the U.S. Fish and 

Wildlife Service or the National Marine Fisheries Service. These species are likely to become 

endangered within the foreseeable future throughout all or a significant portion of their range.

tiering: Refers to the coverage of general matters in broader environmental impact statements 

(such as the land management plan) with subsequent narrower statements or environmental 

analyses (such as an environmental impact statement or site–specific environmental assessment) 

incorporating, by reference, the general discussions and concentrating solely on the issues 

specific to the statement subsequently prepared.

timber harvest: The removal of trees for wood fiber utilization and other multiple-use purposes.

timber production: The purposeful growing, tending, harvesting, and regeneration of regulated 

crops of trees to be cut into logs, bolts, or other round sections for industrial or consumer use. For 

purposes of this subpart, the term timber production does not include production of fuelwood.

timber sale program quantity (TSPQ): The volume of timber planned for sale during the first 

decade of the planning horizon. It includes the allowable sale quantity (chargeable volume) and 

any additional volume planned for sale from lands generally suitable for timber harvest. The 

timber sale program quantity usually is expressed as an annual average for the first decade. 

total maximum daily load (TMDL): A calculation of the maximum amount of a pollutant that a 

waterbody can receive and still meet water quality standards, and an allocation of that amount to 

the pollutant’s sources. The Clean Water Act, Section 303, establishes the water quality standards 

and TMDL programs.

traditional cultural areas: Those areas of the forest used by Native American Indian Tribes for 

traditional activities and often referred to as “religious use areas” or “sacred areas.” They may 

include areas traditionally used for gathering of special forest products.

transportation facility jurisdiction: The legal right to control or regulate use of a transportation 

facility derived from fee title, an easement, an agreement, or other similar method. While 

jurisdiction requires authority, it does not necessarily reflect ownership.

travel corridors: An area of vegetation that provides completely or partially suitable habitat for 

animals to travel from one location to another.

travel route: A route, such as a county or national forest road or river or trail, that is open for use 

by members of the public.

treaty-reserved right: Tribal rights or interests reserved in treaties, by Native American Indian 

Tribes for the use and benefit of their members. The uses include such activities as described in 

the respective treaty document. Only Congress may abolish or modify treaties or treaty rights.

treaty resource: A resource associated with the language in a specific treaty, usually interpreted 

to include collections or association of species; not limited to a single species. For example: fish 

may include all fish species (some treaties included rights to erect temporary houses for curing 

fish); roots and berries may include a wide variety of plants that will encompass the nature of the 

plants as they were used historically; grasses are necessarily included for the treaty reserved right 

to graze cattle or livestock. Hunting rights may include all species of animals hunted in historic 

and prehistoric times. As these apply to the Forest Service, they are public natural resources on 
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national forest lands, to which American Indian Tribes have reserved certain rights for taking or 

gathering.

tree decadence: Trees per acre with spiked or deformed tops, bole, or root decay.

trend: As used to describe range conditions, the direction of change in range or forage condition 

or in ecological status toward or away from the desired condition.

Tribe: Term used to designate any native American Indian Tribe, band, nation, or other organized 

group or community which is recognized as eligible for the special programs and services 

provided by the United States to Indians because of their status as Indians.

trust resource: A resource or property that constitutes a corpus or object of trust that is held in 

trust status by another (trustee) on behalf of a beneficiary. A trustee is usually a governmental 

entity (Secretary of the Interior) who is assigned a trust duty to care for resources that are for the 

exclusive use and benefit of Indian Tribes and/or their members. A beneficiary may be an Indian 

Tribe or individual tribal member, who has property being held in trust status, for example: land, 

money, timber, or any Indian-owned asset.

two-aged regeneration method: A planned sequence of silvicultural treatments designed to 

regenerate or maintain a stand with two age classes. The resulting stand may be two-aged or tend 

towards an uneven-aged condition as a consequence of both an extended period of regeneration 

establishment and the retention of reserve trees that may represent one or more age classes. (Twoaged regeneration harvests must comply with National Forest Management Act (NFMA)

limitations for even-aged harvest methods).

U

underburn: A type of prescribed fire that burns ground vegetation and ladder fuels on the surface 

under a live tree overstory to meet specific management and/or resource objectives.

understory: The small trees and other woody species/shrubs whose crowns constitute the lowest 

horizontal layer of vegetation in a forest stand, growing under the canopy formed by taller trees.

understory reinitiation stage (UR): Structural stage forming as the forest continues to develop

and new age classes of trees establish as individual overstory trees die or are removed. The 

original trees no longer occupy all of the growing space. Regrowth of understory vegetation then 

occurs, and trees begin to develop in vertical layers. This stage typically contains multiple layers 

and multiple tree sizes. Average tree overstory diameters range from 5 to 20 inches.

uneven-aged management: The application of a combination of actions needed to 

simultaneously maintain continuous high-forest cover, recurring regeneration of desirable species, 

and the orderly growth and development of trees through a range of diameter or age classes to 

provide a sustained yield of forest products. Cutting is usually regulated by specifying the number 

or proportion of trees of particular sizes to retain within each area, thereby maintaining a planned 

distribution of size classes. Cutting methods that develop and maintain uneven-aged stands are 

single-tree selection and group selection.

ungulates: Hoofed, plant-eating mammals such as elk, deer, and cattle.

upland: The portion of the landscape above the valley floor or stream.

unroaded area: Portion of the national forest that does not contain classified roads. Refer to 

road.
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unsuitable forest land (not suited): Forest land not managed for timber production because: (a) 

Congress, the Secretary, or the Chief has withdrawn it; (b) it is not producing or capable of 

producing crops of industrial wood; (c) technology is not available to prevent irreversible damage 

to soils productivity, or watershed conditions; (d) there is no reasonable assurance based on 

existing technology and knowledge, that it is possible to restock lands within 5 years after final 

harvest, as reflected in current research and experience; (e) there is, at present, a lack of adequate 

information about responses to timber management activities; or (f) timber management is 

inconsistent with or not cost efficient in meeting the management requirements and multiple-use 

objectives specified in the forest plan.

unsuitable range: Areas of land that should not be used by livestock because of unstable soils.

utility corridor: A parcel of land, without fixed limits or boundaries that is being used as the 

location for one or more transportation or utility rights-of-way.

V

vascular plants: Plants that have specialized tissues which conduct nutrients, water, and sugars, 

along with other specialized parts such as roots, stems, and reproductive structures. Vascular 

plants include flowering plants, ferns, shrubs, grasses, trees, and many others.

vector: An organism that carries or transmits a pathogenic agent from one host to another.

vegetation management: Management activities such as thinning, harvesting, planting, pruning, 

prescribed burning, mastication, or site preparation that is designed to alter the establishment, 

growth, composition, health, and/or quality of forests, woodlands, grasslands, and shrublands to 

meet the diverse needs and values of landowners and society on a sustainable basis. 

vegetation utilization: Indicates the degree to which vegetation is consumed by animals.

vertebrate: An animal with a backbone; mammals, fishes, birds, reptiles, and amphibians are 

vertebrates.

viability: In general, viability means the ability of a population of a plant or animal species to 

persist for some specified time into the future.

viable population: A population that is regarded as having the estimated numbers and 

distribution of reproductive individuals to ensure that its continued existence is well distributed in 

the Planning Area.

vision: Part one of a land management plan that describes the roles, contribution, and desired 

conditions of the national forest. This section also contains monitoring measures to assess 

progress toward the desired conditions.

W

water right: A right to use surface water or ground water evidenced by a court decree or by a 

permit or certificate approved by the state water resources department. Statutory exempt uses of 

surface water and ground water are not water rights, nor are time-limited licenses. A perfected 

water right is defined by applicant name, source, purpose, amount (quantity, rate and duty), 

season of use, priority date, point of diversion, place of use, and certificate number.

water quality: A term used to describe the chemical, physical, and biological characteristics of 

water, usually in respect to its suitability for a particular purpose.
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watershed: (1) The region draining into a river, river system, or body of water; (2) also the 

divide, or ridgeline that separates two adjacent drainages; (3) In the terminology of the National 

Hydrography Dataset, subdivisions of a subbasin, ranging in size from 40,000 to 250,000 acres; 

the fifth level (10-digit) in the hydrologic hierarchy, and also called HU10 (formerly HUC5). See 

also: basin, subbasin, and subwatershed.

watershed condition classes: Watersheds are rated as Class 1, 2, or 3.

Class 1 Condition: Watersheds exhibit high geomorphic, hydrologic, and biotic integrity 

relative to their natural potential condition. Drainage network is generally stable. Physical, 

chemical, and biological] conditions suggest that soil, aquatic, and riparian systems are 

predominantly functional in terms of supporting beneficial uses.

Class 2 Condition: Watersheds exhibit moderate geomorphic, hydrologic, and biotic 

integrity relative to their natural potential condition. Portions of the watershed may exhibit an 

unstable drainage network. Physical, chemical, and biological conditions suggest that soil, 

aquatic, and riparian systems are at risk in being able to support beneficial uses.

Class 3 Condition: Watersheds exhibit low geomorphic, hydrologic, and biotic integrity 

relative to their natural potential condition. A majority of the drainage network may be 

unstable. Physical, chemical, and biological conditions suggest that soil, aquatic, and riparian 

systems do not support beneficial uses.

watershed function: The processes acting on hillslopes and stream channel within a drainage 

basin that control the movement of water, wood, sediment, and nutrients.

watershed integrity: The degree to which the physical and biological processes affecting the 

movement of water, sediment, wood, and nutrients are operating within normally expected 

ranges.

watershed runoff: Refer to runoff.

water yield: The amount of water that flows from a watershed within a specific period of time. 

wetlands: Those areas that are inundated by surface or ground water with a frequency sufficient 

to support and under normal circumstances do or would support a prevalence of vegetative or 

aquatic life that requires saturated or seasonally saturated soil conditions for growth and 

reproduction. Wetlands generally include swamps, marshes, bogs, and similar areas such as 

sloughs, potholes, wet meadows, river overflows, mud flats, and natural ponds (Executive Order 

11990, Section 7c).

wild and scenic river (WSR): Those rivers or sections of rivers designated as such by 

congressional action under the Wild and Scenic Rivers Act of 1968, as supplemented and 

amended. Wild and scenic rivers include all national forest lands within the designated wild and 

scenic river corridor (15). The following classifications are used:

wild river areas: Those rivers or sections of rivers that are free of impoundments and 

generally inaccessible except by trail, with watersheds or shorelines essentially primitive and 

waters unpolluted.

scenic river areas: Those rivers or sections of rivers that are free of impoundments, with 

watersheds still largely primitive and shorelines largely undeveloped, but accessible in places 

by roads.
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recreational river areas: Those rivers or sections of rivers that are readily accessible by road 

or railroad, that may have some development along their shorelines, and that may have 

undergone some impoundment or diversion in the past.

study river areas: Those rivers formally designated by Congress to be studied under 

Sections 5(a) and 5(b) of the Wild and Scenic Rivers Act.

wilderness area: An area designated by congressional action under the Wilderness Act of 1964. 

Wilderness is defined as undeveloped federal land retaining its primeval character and influence 

without permanent improvements or human habitation. Wildernesses are protected and managed 

to preserve their natural conditions, which generally appear to have been affected primarily by the 

forces of nature with the imprint of human activity substantially unnoticeable; have outstanding 

opportunities for solitude or a primitive and unconfined type of recreation; are of sufficient size to 

make practical their preservation, enjoyment, and use in an unimpaired condition; and may 

contain features of scientific, educational, scenic, or historical value as well as ecologic and 

geologic interest.

Wilderness Recreation Opportunity Spectrum (WROS): The Wilderness Recreation 

Opportunity Spectrum system was developed in conjunction with the Recreation Opportunity 

Spectrum (ROS). The terminology is similar, although settings are described in terms of pristine, 

primitive, and semi-primitive settings for wilderness. The descriptions of the primitive and semiprimitive settings for Wilderness Recreation Opportunity Spectrum differ slightly from the 

Recreation Opportunity Spectrum descriptions and, to avoid confusion with Recreation 

Opportunity Spectrum settings, are not abbreviated as acronyms. 

Pristine: Visitation is very limited. Maintaining a natural and unmodified environment is 

emphasized. Visitors seldom and only temporarily displace wildlife throughout the year. This 

is the best opportunity for isolation and solitude, requiring a maximum degree of primitive 

skills, challenge, and risk. Access is difficult, requiring travel without trails or the use of 

routes created by animals or previous human visitation.

Primitive: Visitation is limited. The environment is essentially unmodified and natural with 

no long-term changes to the landscape except for facilities or structures that are deemed 

historically important to the area or experience. Signs of human use are minimal. Visitation 

does not displace wildlife during critical periods. High opportunity exists for exploring and 

experiencing considerable isolation and solitude. Primitive recreation skills are required with 

a high degree of challenge and risk. Access is via trails maintained to a “most difficult” 

standard.

Semi-primitive: Visitation is low to moderate. The environment is essentially unmodified 

and natural, with no long-term changes to the landscape, except for facilities or structures that 

are historically important to the area or experience. Visitation does not displace wildlife 

during critical periods. Moderate opportunity exists for exploring and experiencing isolation, 

independence, and closeness to nature. No-trace camping and primitive skills are required, 

with a moderate to high degree of challenge and risk. Access is via constructed and 

maintained trails managed to “more difficult” or “most difficult” standards.

wildfire: An unplanned, unwanted wildland fire, including unauthorized human-caused fires, 

escaped wildland fire use events, escaped prescribed fire projects, and all other wildland fire 

where the objective is to put the fire out.

wildland: A nonurban, natural area that contains uncultivated land, timber, range, watershed, 

brush or grassland.
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wildland fire: Any nonstructure fire, other than prescribed fire, that occurs in the wildland. This 

term encompasses fires previously called both wildfires and prescribed natural fires (USDA and 

USDI 1998).

wildland fire situation analysis (WFSA): A decision-making process that evaluates alternative 

management strategies against selected safety, environmental, social, economic, political, and 

resource management objectives (USDA Forest Service 1998).

wildland fire suppression: An appropriate management response to wildland fire that results in 

curtailment of fire spread and eliminates all identified threats from the particular fire. All 

wildland fire suppression activities provide for firefighter and public safety as the highest 

consideration, but minimize loss of resource values, economic expenditures, and/or the use of 

critical firefighting resources (USDA Forest Service 1998).

wildland fire use (WFU): Formerly referred to as “prescribed natural fire.” The application of 

the appropriate management response to naturally ignited wildland fires to accomplish specific 

resource management objectives within a set of predefined conditions of fuels, weather, and 

topography.

wildland-urban interface (WUI): The area directly adjacent to home and communities.

windthrown: Refers to trees blown over by the wind.

winter range: The area available to and used by wildlife (big game) during the winter season. 

Generally, lands below 4,000 feet in elevation, on south and west aspects, that provides forage 

and thermal/snow intercept.

woodland: Dry, low elevation areas with a potential vegetation type of juniper.

X

xeric: Very dry region or climate; tolerating or adapted to dry conditions. Dry soil moisture 

regime. Some moisture is present but does not occur at optimum levels for plant growth. 

Irrigation or summer fallow is often necessary for crop production.

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