United States Department of Agriculture

Final Environmental Impact Statement

for the Malheur, Umatilla, and Wallowa-Whitman

National Forests Land Management Plans

Volume 4: Appendix

Forest Service Pacific Northwest Region 2018 
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contact the Wallowa-Whitman National Forest at (541) 523-1264.
Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

i 

Contents of Volume 4 

Appendix A: Forest Plan Revision Alternatives in Detail ...................................................................... 1

Part 1: No-action Alternative Description (1990 Plans) ............................................................. 2

Part 2: Description of the Plan Revision Alternatives............................................................... 25

Alternative Elements (Plan Revision Alternatives) ............................................................... 26

Suitability of Areas ................................................................................................................ 35

Objectives (Plan Revision Alternatives)................................................................................ 41

Standards and Guidelines (Plan Revision Alternatives) ........................................................ 67

Management Area Standards and Guidelines ...................................................................... 111

Monitoring and Evaluation Plan for the Plan Revision Alternatives .................................. 151

Appendix B: Laws and Regulations Relevant to Forest Planning ...................................................... 153

Appendix C: Responses to Comments on the Draft Environmental Impact Statement ...................... 157

Access ..................................................................................................................................... 163

Aquatics .................................................................................................................................. 179

Climate Change ....................................................................................................................... 189

Cultural.................................................................................................................................... 197

Energy ..................................................................................................................................... 204

Forest Management ................................................................................................................. 205

Grazing .................................................................................................................................... 236

Lands and Special Uses ........................................................................................................... 254

Management Areas ................................................................................................................. 256

Mining ..................................................................................................................................... 259

Planning .................................................................................................................................. 263

Plants ....................................................................................................................................... 280

Public Involvement ................................................................................................................. 283

Recreation and Scenery ........................................................................................................... 286

Social and Economic ............................................................................................................... 290

Soil .......................................................................................................................................... 309

Water Quality .......................................................................................................................... 312

Watershed................................................................................................................................ 314

Wilderness, Backcountry, and Wild and Scenic Rivers .......................................................... 327

Wildfire ................................................................................................................................... 351

Wildlife ................................................................................................................................... 355

Appendix D: Wild and Scenic Rivers ................................................................................................. 373

Introduction ............................................................................................................................. 373

Past Planning Efforts: Malheur National Forest .................................................................. 374

Past Planning Efforts: Umatilla National Forest ................................................................. 374

Past Planning Efforts: Wallowa-Whitman National Forest ................................................. 374

Process to Identify and Classify Potentially Eligible Wild and Scenic Rivers ....................... 374

Wild and Scenic Rivers ........................................................................................................... 382

Designated Rivers ................................................................................................................ 382

Eligibility Summary ............................................................................................................ 384

Suitability Summary ............................................................................................................ 404

Appendix E: Wilderness Evaluation ................................................................................................... 409

Introduction ............................................................................................................................. 409

Potential Wilderness Areas ..................................................................................................... 409

Suitability Analysis ................................................................................................................. 410

Capability and Availability Evaluation ................................................................................... 410

Evaluation Findings ................................................................................................................ 412

Appendix F: Suitable Acres within Range Allotments for Each Alternative ...................................... 453

Appendix G: Maps .............................................................................................................................. 463
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

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Appendix Tables and Figures

Appendix A

Table A-1. Management area designation, name, and acreage by national forest for Alternative A 

(note: 2F and 2G units are miles) based on 1990 forest plan .................................................... 4

Table A-2. PACFISH and INFISH interim riparian management objectives ....................................... 13

Table A-3. Open road density by management area, 1990 forest plans ................................................ 20

Table A-4. 1990 Forest Plans management indicator species identified by national forest and 

criteria for selection ................................................................................................................. 21

Table A-5. Comparison of Habitat Effectiveness Index*/cover standards for management areas 

(the management area identifiers are those used in the 1990 forest plans) ............................. 22

Table A-6. Lands suitable for timber production (acres) as shown in the 1990 forest plans and 

adjustments based on 2011 suitable acres, per alternative A (no action) ................................ 23

Table A-7. Allowable sale quantity (MMBF) as shown in the 1990 forest plans and 2011 actual 

outputs, per alternative A (no action) ...................................................................................... 23

Table A-8. Management direction for the maximum percent utilization of livestock grazing in 

uplands .................................................................................................................................... 24

Table A-9. Management direction for maximum percent utilization of livestock grazing in 

riparian areas ........................................................................................................................... 24

Table A-10. Primary goals and corresponding desired conditions identified to meet the goals – 

Alternatives B, C, D, E, E-Modified, E-Modified Departure, and F ....................................... 26

Table A-11. Riparian management area widths for alternatives B, E, and F ........................................ 28

Table A-12. Riparian management area widths for alternative C ......................................................... 28

Table A-13. Riparian management area widths for alternative D ......................................................... 28

Table A-14. Management area designation, name, and acreage for each national forest (2F and 

2G show miles) in alternative B .............................................................................................. 30

Table A-15. Management area designation, name, and acreage for each national forest (2F and 

2G show miles) in alternative C .............................................................................................. 31

Table A-16. Management area designation, name, and acreage for each national forest (2F and 

2G show miles) in alternative D .............................................................................................. 32

Table A-17. Management area designation, name, and acreage for each national forest (2F and 

2G show miles) in alternatives E and F ................................................................................... 33

Table A-18. Management area designation, name, and acreage for each national forest (2F and 

2G show miles) in alternatives E-Modified and E-Modified Departure ................................. 34

Table A-19. General suitability matrix for management areas for alternative B .................................. 36

Table A-20. General suitability matrix for management areas for alternative C .................................. 37

Table A-21. General suitability matrix for management areas for alternative D .................................. 38

Table A-22. General suitability matrix for management areas for alternatives E and F ....................... 39

Table A- 23. General suitability matrix for management areas for Alternatives E-Modified and EModified Departure ................................................................................................................. 40

Table A-24. Comparison of objectives for the plan revision alternatives for the Malheur National 

Forest. ...................................................................................................................................... 42

Table A-25. Comparison of objectives for the plan revision alternatives for the Umatilla National 

Forest.. ..................................................................................................................................... 50

Table A-26. Comparison of objectives for the plan revision alternatives for the WallowaWhitman National Forest. ....................................................................................................... 57

Table A-27. Malheur National Forest anticipated annual accomplishments for the plan revision 

alternatives (as related to objectives) ...................................................................................... 65

Table A-28. Umatilla National Forest anticipated annual accomplishments for the plan revision 

alternatives (as related to objectives) ...................................................................................... 65

Table A-29. Wallowa-Whitman National Forest anticipated annual accomplishments for the plan 

revision alternatives (as related to objectives) ......................................................................... 66
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

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Table A-30. Comparison of forestwide standards and guidelines for the plan revision alternatives 

for each national forest ............................................................................................................ 67

Table A-31. Comparison of management area specific standards and guidelines for the plan 

revision alternatives for each national forest ......................................................................... 111

Table A-32. Maximum utilization* within riparian management areas – Alternatives B, C, D, E 

and F ...................................................................................................................................... 140

Appendix D

Table D-1. Classification attributes for wild, scenic and recreational river status .............................. 378

Table D-2. Designated wild and scenic rivers1 for each national forest2 ........................................... 383

Table D-3. Eligible wild and scenic river list with classification recommendation ............................ 384

Table D-4. Eligible wild and scenic river list with classification recommendation ............................ 404

Table D-5. Eligible wild and scenic river summary with classification recommendation for the 

Malheur National Forest ........................................................................................................ 385

Table D-6. Eligible wild and scenic river summary with classification recommendation for the 

Umatilla National Forest ....................................................................................................... 386

Table D-7. Eligible wild and scenic river summary with classification recommendation for the 

Wallowa-Whitman National Forest ....................................................................................... 399

Figure D-1. Lake Creek eligible wild and scenic river, Malheur National Forest .............................. 386

Figure D-2. Bear Creek eligible wild and scenic river, Umatilla National Forest .............................. 390

Figure D-3. Butte Creek and West Fork Butte Creek eligible wild and scenic river, Umatilla 

National Forest ...................................................................................................................... 391

Figure D-4. Desolation Creek eligible wild and scenic river, Umatilla National Forest .................... 392

Figure D-5. Lookingglass Creek eligible wild and scenic river, Umatilla National Forest ................ 393

Figure D-6. North Fork Desolation Creek eligible wild and scenic river, Umatilla National Forest .. 394

Figure D-7. North and South Fork Wenaha River eligible wild and scenic river, Umatilla 

National Forest ...................................................................................................................... 395

Figure D-8. Sheep Creek eligible wild and scenic river, Umatilla National Forest (in Washington) . 396

Figure D-9. South Fork Desolation Creek eligible wild and scenic river, Umatilla National Forest .. 397

Figure D-10. Tucannon River eligible wild and scenic river, Umatilla National Forest .................... 398

Figure D-11. Dutch Flat Creek suitable wild and scenic river, Wallowa-Whitman National Forest .. 405

Figure D-12. East Eagle Creek suitable wild and scenic river, Wallowa-Whitman National Forest .. 406

Figure D-13. Five Points Creek suitable wild and scenic river, Wallowa-Whitman National 

Forest ..................................................................................................................................... 407

Appendix E

Table E-1. Area capability assessment criteria ................................................................................... 413

Table E-2. Area capability assessment criteria for the Malheur National Forest (Aldrich 

Mountain, Baldy Mountain, Cedar Grove, Dixie Butte, Dry Cabin, Glacier Mountain) ...... 417

Table E-3. Area capability assessment criteria for the Malheur National Forest (Greenhorn 

Mountain, Jumpoff Joe, Malheur River, McClellan Mountain, Myrtle Silvies, Nipple 

Butte) ..................................................................................................................................... 418

Table E-4. Area capability assessment criteria for the Malheur National Forest (Pine Creek, 

Shake Table, Strawberry Mtn. Additions, Utley Butte) ........................................................ 419

Table E-5. Area capability assessment criteria for the Umatilla National Forest (Asotin Creek, 

Grande Ronde, Greenhorn Mountain, Hellhole, Horseshoe Ridge, Jumpoff Joe) ................ 420

Table E-6. Area capability assessment criteria for the Umatilla National Forest (Lookingglass, 

Meadow Creek, Mill Creek, North Fork John Day Additions, North Fork Umatilla 

Additions, North Mt. Emily) ................................................................................................. 421

Table E-7. Area capability assessment criteria for the Umatilla National Forest (Owsley, 

Potamus, Skookum, South Fork/Tower, Spangler, Squaw/Little Fly) .................................. 422
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

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Table E-8. Area capability assessment criteria for the Umatilla National Forest (Texas Butte, 

Tiger Creek, Upper Tucannon, W-T Three) .......................................................................... 423

Table E-9. Area capability assessment criteria for the Umatilla National Forest (Walla Walla 

River, Wenatchee Creek, Willow Springs) ........................................................................... 424

Table E-10. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Beaver Creek, Big Canyon, Boulder Park/Little Eagle Meadows, Buckhorn, Castle 

Ridge, Cook Ridge) ............................................................................................................... 425

Table E-11. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Deadhorse, Dunns Bluff, Grande Ronde, Greenhorn Mountain, Hellhole, Homestead) ..... 426

Table E-12. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Huckleberry, Hurricane Creek, Imnaha Face, Joseph Canyon, Klopton-Corral Creek, 

Lake Fork) ............................................................................................................................. 427

Table E-13. Area capability assessment criteria for the Wallowa-Whitman National Forest (Lick 

Creek, Little Creek, Little Eagle Meadows, Little Sheep, Lord-Flat-Sommers Point, 

Marble Point) ......................................................................................................................... 428

Table E-14. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Monument Rock, Mountain Sheep, Mount Emily, North Mound Emily, Reservoir, 

Sheep Divide) ........................................................................................................................ 429

Table E-15. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Snake River, Squaw/Little Fly, Tope Creek, South Fork/Tower, Upper Catherine 

Creek) .................................................................................................................................... 430

Table E-16. Area capability assessment criteria for the Wallowa-Whitman National Forest 

(Upper Grande Ronde, Wildhorse) ........................................................................................ 431

Table E-17. Area availability assessment criteria for the Malheur National Forest (Aldrich 

Mountain, Baldy Mountain, Cedar Gove, Dixie Butte, Dry Cabin, Glacier Mountain) ........ 433

Table E-18. Area availability assessment criteria for the Malheur National Forest (Greenhorn 

Mtn, Jumpoff Joe, Malheur River, McClellan Mtn, Myrtle Silvies, Nipple Butte) ............... 434

Table E-19. Area availability assessment criteria for the Malheur National Forest (Pine Creek, 

Shaketable, Strawberry Mtn Additions, Utley Butte) ............................................................ 435

Table E-20. Area availability assessment criteria for the Umatilla National Forest (Asotin Creek, 

Grande Ronde, Greenhorn Mtn, Hellhole, Horseshoe Ridge, Jumpoff Joe) ......................... 436

Table E-21. Area availability assessment criteria for the Umatilla National Forest (Lookingglass, 

Meadow Creek, Mill Creek, North Fork John Day Additions, North Fork Umatilla 

Additions, North Mt. Emily) ................................................................................................. 437

Table E-22. Area availability assessment criteria for the Umatilla National Forest (Owsley, 

Potamus, Skookum, South Fork/Tower, Spangler, Squaw/Little Fly) .................................. 438

Table E-23. Area availability assessment criteria for the Umatilla National Forest (Texas Butte, 

Tiger Creek, Upper Tucannon, W-T Three) .......................................................................... 439

Table E-24. Area availability assessment criteria for the Umatilla National Forest (Walla Walla 

River, Wenatchee Creek, Willow Springs ............................................................................. 440

Table E-25. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Beaver Creek, Big Canyon, Boulder Park/Little Eagle Meadows, Buckhorn, Castle 

Ridge, Cook Ridge) ............................................................................................................... 441

Table E-26. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Deadhorse, Dunns Bluff, Grande Ronde, Greenhorn Mountain, Hellhole, Homestead) ..... 442

Table E-27. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Huckleberry, Hurricane Creek, Imnaha Face, Joseph Canyon, Klopton-Corral Creek, 

Lake Fork) ............................................................................................................................. 443

Table E-28. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Lick Creek, Little Creek, Little Eagle Meadows, Little Sheep, Lord Flat-Sommers 

Point, Marble Point) .............................................................................................................. 444
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

iv

Table E-29. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Monument Rock, Mountain Sheep, Mount Emily, North Mount Emily, Reservoir, 

Sheep Divide) ........................................................................................................................ 445

Table E-30. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Snake River, Squaw/Little Fly, Tope Creek, South Fork/Tower, Twin Mountain, Upper 

Catherine Creek).................................................................................................................... 446

Table E-31. Area availability assessment criteria for the Wallowa-Whitman National Forest 

(Upper Grande Ronde, Wildhorse) ........................................................................................ 447

Table E-32. Area capability and availability summary for the Malheur National Forest ................... 448

Table E-33. Area capability and availability summary for the Umatilla National Forest ................... 449

Table E-34. Area capability and availability summary for the Wallowa-Whitman National Forest .. 450

Appendix F

Table F-1. Suitable acres for cattle grazing in active and vacant cattle allotments for each 

alternative on the Malheur National Forest ........................................................................... 453

Table F-2. Suitable acres for sheep grazing within active sheep allotments for each alternative on 

the Malheur National Forest .................................................................................................. 457

Table F-3. Suitable acres for cattle grazing in active cattle allotments for each alternative on the 

Umatilla National Forest ....................................................................................................... 457

Table F-4. Suitable acres for sheep grazing within active sheep allotments for each alternative on 

the Umatilla National Forest ................................................................................................. 458

Table F-5. Suitable acres for cattle grazing in active and vacant cattle allotments for each 

alternative on the Wallowa-Whitman National Forest .......................................................... 458

Table F-6. Suitable acres for sheep grazing within active and vacant sheep allotments for each 

alternative on the Wallowa-Whitman National Forest .......................................................... 462

Appendix G

Management area maps for each National Forest by alternative ........................................................ 463 
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

v 

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

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 
Final Environmental Impact Statement, Volume 4 

Contents

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

vi

Contents of Volume 2:

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

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 3: 

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

of the Environmental Impact Statement 

Public Involvement 

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

Governments 

Preparers and Contributors 

Distribution of the Final Environmental Impact Statement

Glossary and Acronyms

References

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

1 

Appendix A: Forest Plan

Revision Alternatives in Detail

The alternatives were developed based on public involvement during and prior to the scoping 

period for the proposed action, after the release of the Draft Environmental Impact Statement, and 

based on the purpose and need and issues. The alternatives present a range of analysis options, as 

required by National Environmental Policy Act (NEPA) regulations (40 CFR 1502.14). 

The plan revision alternatives (all alternatives except the no-action alternative) provide a 

framework for analyzing different ways of meeting the purpose and need to revise the forest plans 

by responding to one or more of the issues identified during the scoping period (Chapter 1). Each 

plan revision alternative displays a range of options for guiding land and resource management 

activities on the Blue Mountains national forests during the life of the revised plans. According to 

the National Forest Management Act of 1976, forest plans shall be revised at least every 15 years 

(P.L. 94-588). 

Eight alternatives are analyzed in detail in the Final Environmental Impact Statement. Alternative 

A (retaining the 1990 Forest Plans) is described below in “Part 1—No-action Alternative 

Description.” “Part 2-Description of the Plan Revision Alternatives” describes Alternatives B 

through F, focusing on what differs between them. 

The proposed revised plan includes “plan components” and “other content.” Forest plan 

components consist of goals and desired conditions, standards, guidelines, objectives, special 

areas, management areas, suitable uses and activities, and monitoring and evaluation. The goals 

create the framework for the plan. Under each goal, there is a set of desired conditions, standards, 

guidelines and objectives. The goals and desired conditions are a set of interrelated ecological, 

social, and economic conditions. The Forest Service would manage the land and resources within

the plan area to achieve or maintain the goals and desired conditions, allowing the national forests 

to contribute to a range of outcomes now and in the future. This emphasis on integration of the 

goals and desired conditions promotes an adaptive and active management philosophy, including 

working with partners, to accomplish this vision for the national forests of the Blue Mountains. 

Once approved, any substantive changes to plan components would require amending the forest

plan. Certain changes to plan components may be made using an administrative correction 

process. Nonsubstantive errors, such as misspellings or typographical mistakes may be corrected 

via an errata and information; for example, data and maps may be updated without pursuing a 

forest plan amendment. The public would be notified of all plan amendments and administrative 

corrections before they become effective. 

This appendix does not repeat the background and existing condition information provided in the 

Forest Plans. Components are further described in the plans, as appended to the draft Record(s) of 

Decision. 
Final Environmental Impact Statement, Volume 3

Appendix A: Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

2 

Part 1: No-action Alternative Description (1990 Plans) 

How the Alternative was Developed

NEPA requires an analysis of the no-action alternative (40 CFR 1502.14(d)). Alternative A is the 

No-action Alternative. No action means that there would be no change in current management 

(FSH 1909.15(14.2)). This alternative would keep in effect the original 1990s era forest plans as 

amended and as modified by regulation. Management allocations, activities, and management 

direction described in the existing forest plans (as amended and as modified by regulation) would 

continue for the next 15 years. The no-action alternative also provides a baseline for comparison 

of the plan revision alternatives. 

The original Forest Plans initially placed an emphasis on the production of wood products using 

even-aged regeneration harvest. The assumptions made in the Forest Plans were that ecological 

conditions were healthy and would remain so and that disturbances (such as fire, insects, and 

disease) would not substantially affect planned actions, desired outcomes, or outputs. Significant 

changes in forest plan direction occurred in 1995 when the following three amendments were 

incorporated into the Forest Plans.

PACFISH

The decision supporting the environmental assessment for the “Implementation of Interim 

Strategies for Managing Anadromous Fish-producing Watersheds in Eastern Oregon and 

Washington, Idaho, and Portions of California” (USDA and USDI 1995a), commonly referred to 

as PACFISH, amended the Forest Plans to include management direction to slow the degradation 

of and begin the restoration of aquatic and riparian ecosystems for anadromous fish. 

Inland Native Fish Strategy

The decision supporting the Environmental Assessment for the “Inland Native Fish Strategy, 

Interim Strategies for Managing Fish-producing Watersheds in Eastern Oregon and Washington, 

Idaho, Western Montana and Portions of Nevada” (USDA and USDI 1995b, commonly referred 

to as INFISH), amended the Forest Plans to include management direction, as a companion to the 

protection provided for anadromous fish by PACFISH, providing interim direction to protect 

habitat and populations of resident native fish outside of anadromous fish habitat. 

These two amendments require the establishment of riparian habitat conservation areas (RHCAs) 

and riparian management objectives (RMOs), and focus on restoration of aquatic and riparian 

areas as habitat for native fish species. They provide substantial protection to fish species listed as 

threatened or endangered under the Endangered Species Act and their habitats by maintaining 

quality habitat where it exists and reducing risks to habitat and species over the short term.

Eastside Screens

In 1994, the Forest Service Pacific Northwest Region regional forester issued “Interim Direction 

Establishing Riparian, Ecosystem, and Wildlife Standards for Timber Sales on Eastside Forests” 

(USDA Forest Service 1995c), commonly referred to as the Eastside Screens. It amended the 

1990 Forest Plans by establishing riparian, ecosystem, and wildlife standards for timber sales.

The Eastside Screens amendment emphasizes retaining and developing late old forest structures 

and patch sizes within the historic range of variability; maintaining or developing linkages 

between old forests; meeting requirements for snags, downed logs, and green tree replacements; 

and retaining most trees greater than 21 inches in diameter.
Final Environmental Impact Statement, Volume 3

Appendix A: Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

3 

Although these three amendments resulted in substantial changes to the direction in existing 

plans, objectives for timber harvest and allowable sale quantity (ASQ) were not adjusted. This 

summary of the no-action alternative updates the ASQ and some objectives for all Forest Plans 

using the amended direction. 

Lands administered implementing the 1990 Forest Plans are intended to provide a mix of natural 

resource-based goods and services. Management direction focuses on providing sustained levels 

of resource output, including timber and wood products, livestock forage, big game, and minerals 

in an environmentally sound manner, while also providing other uses and values such as scenery, 

recreation opportunities, viewable wildlife, and clean air and water. Portions of the landscape are 

used for commodity production, while some portions are allocated to wilderness areas, scenic 

areas, and research natural areas, among others.

Management Area Acres

Management areas are not consistently described or identified in the three Forest Plans. While not 

all national forests have the same types of special areas, in general they have similar management 

expectations across large areas. 

For purposes of comparing acres, the current management areas have been put into the same 

categories as Alternatives B through F. The crosswalk showing how the current management 

areas were assigned to this scheme is in the analysis file and is available upon request. The tables 

showing the acres by management area for Alternatives B through F are in Part 2—Comparison 

of the Plan Revision Alternatives.

Table A-1 does not include the Hells Canyon National Recreation Area (HCNRA). The HCNRA 

Comprehensive Management Plan is part of the Wallowa-Whitman National Forest Land and 

Resource Management Plan and guides management of the HCNRA. This plan carries forward in 

its entirety the HCNRA Comprehensive Management Plan, which was updated in 2003. Table A1 includes acre values of the portion of the Ochoco National Forest administered by the Malheur 

National Forest. 

The management area acres displayed in Table A-1 are from the 1990 forest plans and have not 

been recalculated using the most current GIS technology. Adding the acreages in Table A-1 will 

not produce a sum equal to the total acreage for each national forest because of overlapping 

management areas. The overlapping management areas result in the total acreage of all 

management areas being greater than the official national forest acreages. For example, several 

research natural areas (MA 2B) and wild and scenic rivers (MA 2A) overlap into congressionally 

designated wilderness areas (MA 1A).
Final Environmental Impact Statement, Volume 3

Appendix A: Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

4 

Table A-1. Management area designation, name, and acreage by national forest for Alternative A

(note: 2F and 2G units are miles) based on 1990 forest plan

Management Area Designation and Name Malheur Umatilla

WallowaWhitman**

1A – Congressionally Designated Wilderness Areas 82,557 304,173 373,676*

1B – Preliminary Administratively Recommended

Wilderness Areas 0 0 0 

1C – Wilderness Study Area 0 0 2,350

2A – Wild and Scenic River (Includes Designated, 

Eligible, and Suitable Rivers 10,807 6,926 21,936

2B – Research Natural Areas 3,426 8,396 2,635

2C – Botanical Areas 30 817 0 

2D – Geological Areas 40 416 0 

2E – Historical Areas 0 1,178 0 

2F – Scenic Byways and All-American Roads (miles) 0 0 0 

2G – Nationally Designated Trails (miles) 0 0 0 

2H – Scenic Areas 14,399 31,109 0 

2I – Starkey Experimental Forest and Range 0 0 27,251

2J – Municipal Watersheds 519 12,581 0 

3A – Backcountry (nonmotorized use) 47,535 29,760 0 

3B – Backcountry (motorized use) 14,652 11,909 119,938

3C – Wildlife Corridor 0 0 0 

4A – General Forest/Timber/Range 851,877 296,180 734,500

4A – General Forest/Timber/Range

(excludes 4B RHCA) 798,021 255,898 612,820

4B – Riparian Management Areas (no RHCAs) 34,893 25,076 0 

4B – RHCA (within 4A) 53,700 44,700 121,683

4B – RHCA (All) 168,545 237,514 360,123

4C – Old Forest 84,232 44,277 60,285

4D – Big Game Winter/Summer Range 293,453 130,215 396,703

4E – General Wildlife/Fish 50,741 430,166 60,326

4F – Visuals 217,328 65,775 4,287

5 – Developed Sites and Administrative Areas 647 4,922 7,111

*Wallowa-Whitman National Forest private inclusions are included in the acre totals for congressionally designated 

wilderness areas. 

**In addition, this table does not include acreage for the Hells Canyon National Recreation Area (HCNRA). This plan

carries forward in its entirety the HCNRA Comprehensive Management Plan (CMP), which was updated in 2003. The 

HCNRA CMP is the portion of the Wallowa-Whitman National Forest Land and Resource Management Plan that guides 

management of the HCNRA.

RHCA = riparian habitat conservation area
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5 

1990 Forest Plans

Management Direction for Specific Resources

The 1990 forest plans for the Malheur, Ochoco, Umatilla, and Wallowa-Whitman National 

Forests are currently available in their entirety on the Blue Mountains Forest Plan Revision 

portion of the Wallowa-Whitman National Forest website.1

 The portions of the Forest Plans 

described here are highlights of Plan direction for riparian and aquatic resources, old forest, 

invasive species, wildlife habitat (and more specifically elk habitat), timber, and rangeland 

management.

Management Direction for Riparian and Aquatic Resources

The current direction for the management of riparian and aquatic resources is found in the 

following strategies, which were amended to all three forest plans in 1995: 

• Interim Strategies for Managing Anadromous Fish-producing Watersheds in Eastern 

Oregon and Washington, Idaho, and Portions of California (PACFISH) 

• Interim Strategies for Managing Inland Fish-producing Watersheds in Eastern Oregon 

and Washington, Idaho, and Portions of California (INFISH) 

The following section displays PACFISH and INFISH direction. 

Many of the PACFISH and INFISH standards and guidelines are procedural, requiring 

coordination with other agencies, conducting inventories or assessments, or requirements to 

modify or establish specific permits or operating plans. Standards and guidelines are generally 

limitations on activities or uses for reasons of environmental protection, public safety and risk 

reduction, or to achieve goals and desired conditions. 

PACFISH and INFISH Management Direction (General)

Objective. Restore watersheds to reverse or arrest adverse impacts to water quality and fish 

habitat. Areas where fish habitat(s) or water quality has been adversely affected shall be given 

high priority for corrective treatments that mitigate impacts or rehabilitate these areas.

Objective. Provide and maintain a diverse, well-distributed pattern of fish habitat to increase 

anadromous and inland native fish runs. For example: 

• Meet state water quality standards for stream temperature and streamside vegetation;

• Maintain sufficient large woody debris to provide for continuous long-term supply in all 

channels; 

• Promote bank, floodplain, and channel stability to provide resilience to disturbance and 

foster aquatic diversity; and

• Provide pools that are large, well distributed and persistent during low flows, and 

conserve or restore channel morphology appropriate to the climate and landform. 

Guideline. Practices that maintain or promote sufficient residual vegetation and appropriate 

channel morphology and functions can be used to maintain, improve, or restore riparian and 

wetland functions. 

 

1 http://www.fs.usda.gov/goto/BlueMtnsPlanRevision
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6 

Objective. Achieve riparian and wetland area improvement and maintenance through 

management of existing uses, wherever feasible.

Objective. Limit or mitigate surface disturbance in floodplains, riparian areas, and aquatic 

habitats to prevent soil movement, loss, and sedimentation. 

PACFISH and INFISH Aquatic Habitat and Watershed Direction

Objective. Manage and provide aquatic habitat to contribute to the maintenance of stocks of 

anadromous and inland native fish and to ensure consistent, effective, and efficient Endangered 

Species Act consultation.

Objective. Provide protection for all watersheds containing designated critical habitat for listed 

anadromous fish (Key Watersheds).

Objective. Provide a pattern of protection across the landscape with an emphasis on federally 

listed fish. Include watersheds that have strong assemblages, degraded watersheds with a high 

restoration potential, and watersheds that provide for meta-population objectives (Priority 

Watersheds).

Objective. Improve current conditions of watersheds by restoring degraded habitat and providing 

long-term protection to riparian and aquatic resources.

PACFISH and INFISH Livestock Grazing in RHCAs2

Standard GM-1. Modify grazing practices (for example, accessibility of riparian areas to 

livestock, length of grazing season, stocking levels, timing of grazing) that retard or prevent 

attainment of RMOs (riparian management objectives) or are likely to adversely affect aquatic 

resources. Suspend grazing if adjusting practices is not effective in meeting RMOs.

Standard GM-2. New livestock handling and/or management facilities shall be located outside 

of RHCAs. For existing livestock handling facilities inside RHCAs, assure that facilities do not 

prevent attainment of RMOs. Relocate or close facilities where these objectives cannot be met.

Standard GM-3. Limit livestock trailing, bedding, watering, loading, salting, and other handling 

efforts to those areas and times that would not retard attainment of RMOs or adversely affect 

aquatic resources.

Standard GM-4. Adjust wild horse and burro management to avoid impacts that prevent 

attainment of RMOs or adversely affect aquatic resources.

PACFISH and INFISH Timber Management in RHCAs

Standard TM-1. Prohibit timber harvest, including fuelwood cutting, in Riparian Habitat 

Conservation Areas (RHCAs), except as described below. Do not include RHCAs in the land base 

used to determine the Allowable Sale Quantity; however, any volume harvested can contribute to 

the timber sale program.

a) Where catastrophic events such as fire, flooding, volcano, wind, or insects cause damage that 

results in degraded riparian conditions, allow salvage and fuel cutting in RHCAs only where 

present and future woody debris needs are met, where cutting would not retard or prevent 

attainment of other riparian management objectives (RMOs), and where adverse effects can 

 

2 RHCA = riparian habitat conservation area
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7 

be avoided to aquatic resources. Ecosystem Analysis at the Watershed Scale shall be 

completed prior to harvest, including salvage and fuel wood cutting, in RHCAs. 

b) Apply silvicultural practices for RHCAs to acquire desired vegetation characteristics where 

needed to attain RMOs. Apply silvicultural practices in a manner that does not retard 

attainment of RMOs and that avoids adverse effects on aquatic resources.

PACFISH and INFISH Fire Management in RHCAs

Standard FM-1. Design 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. Strategies should recognize the role of fire in ecosystem function and identify those 

instances where fire suppression or fuel management actions could perpetuate or be damaging to 

long-term ecosystem function or aquatic resources.

Standard FM-2. Locate incident bases, camps, helibases, staging areas, helispots, and other 

centers for incident activities outside of RHCAs. If the only suitable location for such activities is 

within the RHCAs, an exemption may be granted following a review and recommendation by a 

resource advisor. The advisor would prescribe the location, use conditions, and rehabilitation 

requirements, with avoidance of adverse effects to aquatic resources a primary goal. Use an 

interdisciplinary team, including a fishery biologist, to predetermine incident base and helibase 

locations during pre-suppression planning. 

Standard FM-3. Prohibit delivery of chemical retardant, foam, or additives to surface waters. 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.

Standard FM-4. Prescribed burn projects and prescriptions should be designed to contribute to 

the attainment of the RMOs.

Standard FM-5. Immediately establish an emergency team to develop a rehabilitation treatment 

plan to attain RMOs and avoid adverse effects on aquatic resources whenever RHCAs are 

significantly damaged by a wildfire or a prescribed fire is burning out of prescription. 

PACFISH and INFISH Road Management in RHCAs

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. 
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8 

♦ 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) Avoid 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) Avoid disruption of natural hydrologic flow paths. 

f) Avoid 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-4. Construct new and improve existing culverts, bridges, and other stream 

crossings to accommodate a 100-year flood, including associated bedload and debris, where those 

existing structures would or do pose a substantial risk to riparian conditions. Such improvements 

should include those structures that do not meet design and operation maintenance criteria that 

have been shown to be less effective than designed for controlling erosion, or that retard 

attainment of RMOs. Priority for upgrading shall be based on risks and the ecological value of the 

riparian resources affected. Construct and maintain crossings to prevent diversion of stream flow 

out of the channel and down the road in the event of crossing failures. 

Standard RF-5. Provide and maintain fish passage at all crossings of existing and potential fishbearing streams.

Standard RF-6. Develop and implement a road management plan or a transportation 

management plan that will meet the RMOs.

PACFISH and INFISH Minerals Management in RHCAs

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 
Final Environmental Impact Statement, Volume 3

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9 

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 re-vegetation. 

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 exists, 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 re-vegetate 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, then: 

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 re-vegetation 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.
Final Environmental Impact Statement, Volume 3

Appendix A: Forest Plan Revision Alternatives in Detail

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10

PACFISH and INFISH Hydro and Surface Water Projects in RHCAs (Lands)

Standard LH-1. For hydroelectric and other surface water development proposals, require 

instream flows and habitat conditions that maintain or restore riparian resources, favorable 

channel conditions, and fish passage, reproduction, and growth. Coordinate this process with the 

appropriate state agencies. During relicensing of hydroelectric projects, provide to the Federal 

Energy Regulatory Commission (FERC) written and timely license conditions that require fish 

passage and flows and habitat conditions that maintain/restore riparian resources and channel 

integrity. Coordinate relicensing projects with the appropriate state agencies.

Standard LH-2. Locate new hydroelectric ancillary facilities outside RHCAs. For existing 

ancillary facilities inside the RHCA that are essential to proper management, provide 

recommendations to FERC to assure that the facilities would not prevent attainment of the RMOs 

and that adverse effects on aquatic resources are avoided. Where these objectives cannot be met, 

proved recommendations to FERC that such ancillary facilities should be relocated. Locate, 

operate, and maintain hydroelectric facilities that must be located in RHCAs to avoid adverse 

effects on aquatic resources.

Standard LH-4. Use land acquisition, exchange, and conservation easements to meet RMOs and 

facilitate restoration of fish stocks and other species at risk of extinction.

PACFISH and INFISH Leases and Permits in RHCAs

Standard LH-3. Issue leases, permits, rights-of-way, and easements to avoid adverse effects on 

aquatic resources and to avoid effects that would be inconsistent with or prevent attainment of 

RMOs. Where the authority to do so was retained, adjust existing leases, permits, rights-of-way, 

and easements to eliminate effects that would retard or prevent attainment of the RMOs or 

adversely affect aquatic resources. If adjustments are not effective, eliminate the activity. Where 

the authority to adjust was not retained, negotiate to make changes in existing leases, permits, 

rights-of-way, and easements to eliminate effects that would prevent attainment of the RMOs or 

adversely affect aquatic resources. Priority for modifying easements would be based on the 

current and potential adverse effects on aquatic resources and the ecological value of the riparian 

resources affected.

PACFISH and INFISH Fuel, Pesticides, and Herbicides in RHCAs

Standard RA-3. Apply herbicides, pesticides, and other toxicants and chemicals in a manner that 

does not retard or prevent attainment of RMOs and that avoids adverse effects on aquatic 

resources.

Standard RA-4. Prohibit storage of fuels and other toxicants within RHCAs. Prohibit refueling 

within RHCAs unless there are no other alternatives. Refueling sites within RHCAs shall be 

approved by the Forest Service or Bureau of Land management and have an approved spill 

containment plan. 

Standard RA-5. Locate water-drafting sites to avoid adverse effects on aquatic resources and 

instream flow and in a manner that does not retard or prevent attainment of RMOs.

PACFISH and INFISH Recreation in RHCAs

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.
Final Environmental Impact Statement, Volume 3

Appendix A: Forest Plan Revision Alternatives in Detail

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11

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/or specific sites closures are not effective in meeting RMOs and avoiding adverse effects on 

aquatic resources, eliminate the practice or occupancy.

PACFISH and INFISH Watershed and Habitat Restoration in RHCAs

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 userenhancement 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 userenhanced 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. 
Final Environmental Impact Statement, Volume 3

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12

PACFISH and INFISH Riparian Habitat Conservation Area Widths Descriptions

Riparian Area Minimum Widths

Fish-bearing Streams

Interim RHCAs 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.

Permanently Flowing Non-fish-bearing Streams

Interim RHCAs 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.

Constructed Ponds, Reservoirs, and Wetlands Greater than 1 Acre

Interim RHCAs 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 moderately and 

highly 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 maximum pool elevation of constructed ponds and reservoirs, 

or from the edge of the wetland, pond or lake, whichever is greatest.

Lakes and Natural Ponds

Same as constructed ponds, reservoirs, and wetlands greater than 1 acre. 

RHCAs: Seasonally flowing or intermittent streams, wetlands smaller than 1 acre, 

landslides, and landslide-prone areas. 

RMAs: Seasonally flowing, intermittent and ephemeral streams, wetlands smaller than 1 

acre, and unstable areas

This category applies to features with high variability in size and site-specific characteristics. At a 

minimum, the RHCAs should include: 

a) The extent of landslides and landslide-prone areas 

b) The intermittent stream channel and the area to the top of the inner gorge. 

c) The intermittent stream channel or wetland and the area to the outer edges of the riparian 

vegetation.

d) For priority watersheds, the area from the edges of the stream channel, wetland, landslide, or 

landslide-prone area to a distance equal to the height of one site-potential tree, or 100 feet 

slope distance, whichever is greatest. 

e) For watersheds not identified as Priority Watersheds, the area from the edges of the stream 

channel, wetland, landslide, or landslide-prone area to a distance equal to the height of onehalf site-potential tree, or 50 feet slope distance, whichever is greatest.

Non-forested Rangeland Ecosystems

The Interim riparian habitat conservation area (RHCA) width for permanently flowing streams in 

categories 1 and 2 is the extent of the 100-year flood plain. 
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13

Table A-2. 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 

Management Direction for Old Forest

All three forest plans designate management areas for old growth. None of the 1990 forest plans 

allows scheduled timber harvest in designated old growth management areas. 

For areas outside of designated old growth management areas, the following direction applies. 

Current direction for timber sales includes “Interim Management Direction Establishing Riparian, 

Ecosystem and Wildlife Standards for Timber Sales” (Eastside Screens), which was amended into 

the three forest plans in 1995 (USDA and USDI 1995b). The Eastside Screens requirements are 

shown on the following page.

The following activities are not subject to Eastside Screens direction:

• Personal use firewood sales

• Post and pole sales 

• Sales to protect health and safety

• Sales to modify vegetation within recreation special use areas

The following sales are not subject to the historic range of variability analysis, but must apply 

wildlife standards:

• Pre-commercial thinning sales

• Sales of material sold as fiber

• Sales of dead material less than 7 inches diameter, with incidental green volume 

• Salvage sales, with incidental green volume, located outside currently mapped oldgrowth 

• Commercial thinning and understory removal sales located outside currently mapped oldgrowth
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14

All other sales are subject to the historic range of variability analysis. The historic range of 

variability is a way of characterizing the landscape for patterns of stand structure by biophysical 

environment and comparing them to pre-settlement conditions.

Eastside Screens Requirements

1. DETERMINE the historic range of variability:

♦ describe the dominant historical disturbance regime

♦ characterize the landscape pattern and abundance of structural stages maintained by 

the disturbance regime

♦ describe spatial pattern and distribution of structural stages under the Historic Range 

of Variability disturbance regime

♦ map the current pattern of structural stages AND calculate their abundance by 

biophysical environmental setting

2. CHARACTERIZE the proposed timber sale and its associated watershed for patterns of stand 

structure by biophysical environment within a watershed and compare to the historic range of 

variability.

Scenario A: WHERE either late/old structure (LOS), single story, or multi-story falls BELOW 

HRV, NO NET LOSS of LOS from that biophysical environment. DO NOT ALLOW timber sale 

harvest activities to occur within LOS stages that are BELOW HRV.

1. Some timber sale activities can occur WITHIN the LOS multi-story stages that are AT or 

ABOVE the historic range of variability in a manner to MAINTAIN or ENHANCE LOS 

within that biophysical environment. It is ALLOWABLE to manipulate one type of LOS to 

move stands into the LOS stage that is DEFICIT (LOS multi to LOS single), if this meets 

historical conditions.

2. OUTSIDE LOS, many types of timber sale activities are ALLOWED. The intent is still to 

maintain and/or enhance LOS components in stands subject to timber harvest as much as 

possible, by adhering to the following standards: 

a. MAINTAIN ALL remnant late and old seral (LOS) and/or structural live trees ≥ 21" 

d.b.h. that currently exist within stands proposed for harvest activities; 

b. MANIPULATE vegetative structure that does not meet LOS conditions, in a manner 

that moves it towards these conditions as appropriate to meet the Historic Range of 

Variability.

c. MAINTAIN open, park-like stand conditions where this condition occurred 

historically. Manipulate vegetation in a manner to encourage the development and 

maintenance of large diameter, open canopy structure.

3. Maintain or enhance the current level of connectivity between LOS stands and between all 

Forest Plan designated old-growth habitats by maintaining stands between them.

i. CONNECT these LOS and old-growth habitats with each other in a contiguous 

network pattern by at least two different directions; 

ii. Connectivity corridors should be as SHORT as possible 

iii. A connectivity corridor stand is one in which MEDIUM diameter or larger trees are 

COMMON, canopy covers are within the TOP 1/3 of SITE POTENTIAL, and stand 

WIDTH is at least 400 feet wide at the narrowest point;
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iv. Harvesting within connectivity corridors IS PERMITTED IF, all criteria in the above 

element can be met (maintained during harvest). 

v. Reduce fragmentation of LOS stands, or at least, DO NOT INCREASE it from 

current levels. Stands that do not currently meet LOS that are located within, or 

surrounded by, blocks of LOS stands SHOULD NOT be considered for even-aged 

regeneration harvest, or group selection at this time.

4. All sale activities WILL MAINTAIN snags and GTR trees of > 21" d.b.h., at 100% potential 

population levels of primary cavity excavators;

Pre-activity down logs may be removed only when they exceed the quantities listed below: 

Species Pieces/acre Diameter Piece size and total feet

Ponderosa pine 3-6 12” > 6' and 20-40 ft. 

Mixed conifer 15-20 12" > 6' and 100-140 ft. 

Lodgepole pine 15-20 8" > 8' and 120-160 ft. 

i. These down log criteria are NOT INTENDED TO PRECLUDE the use of 

prescribed fire. Consumption WILL NOT EXCEED 3 inches total of diameter 

reduction in the featured large logs. 

ii. Leave logs in current lengths, DO NOT CUT them into pieces. Longer logs may 

be counted for multiple "pieces" without cutting them. 

iii. For all stands, snags >20 inches d.b.h. are preferred and should be left whenever 

possible, with snags down to the 15 inch category being left when larger snags 

are not available.

iv. Leave pre-activity (currently existing) levels of down logs, unless they exceed 

the quantities listed below. Harvest activities should supplement pre-activity 

levels of down logs up to the maximum level. Exceptions can be made where fire 

protection needs for life and property cannot be accomplished with this quantity 

of debris left on site. 

5. Follow the following goshawk requirements. Protect known active and historically used 

goshawk nest sites. Harvest is prohibited in the 30 acres surrounding active and historical 

goshawk nest sites. Establish a 400-acre post fledging area around every active nest site.

Scenario B: If the single story LOS stage is within or exceeds the historic range of variability 

within a watershed, or if both LOS single and multi-story are within or exceed the historic range 

of variability, then harvest can occur within these stages as long as LOS conditions do not fall 

below the Historic Range of Variability. Enhance LOS structure and attributes as possible.

1. Harvest activities can occur in order of the following three priorities:

(a) within stands OTHER THAN LOS

(b) within smaller, isolated LOS stands less than 100 acres in size, and/or at the edges of large 

blocks of LOS stands (> 100 acres)

(c) Within the interior of large LOS stands (> 100 acres)

2. MAINTAIN connectivity as directed in SCENARIO A.

3. Non-fragmentation Standards - within the interior of large LOS stands > 100 acres, harvest 

activities ARE LIMITED TO non-fragmenting prescriptions (i.e., thinning, single-tree 

selection, salvage, understory removal, and other non-regeneration activities). GROUP 
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SELECTION IS ONLY ALLOWED when openings created either mimic the natural forest 

pattern, and/or DO NOT EXCEED one-half acre in size.

4. ADHERE to the specific wildlife prescriptions for SNAGS, GREEN TREE 

REPLACEMENTS, and DOWN LOGS, as described in SCENARIO A.

5. Follow SCENARIO A, with the following EXCEPTION for goshawk post fledging areas 

outlined above in 5): 

• A 400-acre "post fledging area" will be established around every active nest site. While 

harvesting activities can occur within this area, up to 60% of the area should be retained 

in LOS conditions, (i.e., if 35% of the area is now in LOS stands, then it all needs to be 

retained; if 75% of the area is now in LOS stands, then some can be harvested, as long as 

this late and old stand structure does not drop below 60% of the area). 

Management Direction for Invasive Species

In 2005, the regional forester amended the 1990 Forest Plans with the direction displayed below. 

Many standards and guidelines in the 1990 Forest Plans were superseded by this new amendment. 

The numbering is not sequential because the 2005 Invasive Plants Final Environmental Impact 

Statement selected alternative adopted no standard for standards 5, 9, 10, and 17. 

2005 Preventing and Managing Invasive Plants Record of Decision Element

Standards and Guidelines

Standard 1. Prevention of invasive plant introduction, establishment and spread will be 

addressed in watershed analysis; roads analysis; fire and fuels management plans, Burned Area 

Emergency Recovery Plans; emergency wildland fire situation analysis; wildland fire 

implementation plans; grazing allotment management plans, recreation management plans, 

vegetation management plans, and other land management assessments.

Standard 2. Actions conducted or authorized by written permit by the Forest Service that will 

operate outside the limits of the road prism (including public works and service contracts), 

require the cleaning of all heavy equipment (bulldozers, skidders, graders, backhoes, dump 

trucks, etc.) prior to entering National Forest System Lands.

This standard does not apply to initial attack of wildland fires, and other emergency situations 

where cleaning would delay response time. 

Standard 3. Use weed-free straw and mulch for all projects, conducted or authorized by the 

Forest Service, on National Forest System Lands. If State certified straw and/or mulch is not 

available, individual Forests should require sources certified to be weed free using the North 

American Weed Free Forage Program standards (see Appendix O of the Pacific Northwest 

Region’s 2005 Invasive Plants Final Environmental Impact Statement) or a similar certification 

process. 

Standard 4. Use only pelletized or certified weed free feed on all National Forest System lands. 

If state certified weed free feed is not available, individual Forests should require feed certified to 

be weed free using North American Weed Free Forage Program standards or a similar 

certification process. This standard may need to be phased in as a certification processes are 

established. 

Standard 6. Use available administrative mechanisms to incorporate invasive plant prevention 

practices into rangeland management. Examples of administrative mechanisms include, but are 
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not limited to, revising permits and grazing allotment management plans, providing annual 

operating instructions, and adaptive management. Plan and implement practices in cooperation 

with the grazing permit holder. 

Standard 7. Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow material for 

invasive plants before use and transport. Treat or require treatment of infested sources before any 

use of pit material. Use only gravel, fill, sand, and rock that is judged to be weed free by District 

or Forest weed specialists.

Standard 8. Conduct road blading, brushing and ditch cleaning in areas with high concentrations 

of invasive plants in consultation with District or Forest-level invasive plant specialists, 

incorporate invasive plant prevention practices as appropriate.

Standard 11. Prioritize infestations of invasive plants for treatment at the landscape, watershed 

or larger multiple forest/multiple owner scale.

Standard 12. Develop a long-term site strategy for restoring/re-vegetating invasive plant sites 

prior to treatment. 

Standard 13. Native plant materials are the first choice in re-vegetation for restoration and 

rehabilitation where timely natural regeneration of the native plant community is not likely to 

occur. Non-native, noninvasive plant species may be used in any of the following situations: 1) 

when needed in emergency conditions to protect basic resource values (e.g., soil stability, water 

quality and to help prevent the establishment of invasive species), 2) as an interim, non-persistent 

measure designed to aid in the reestablishment of native plants, 3) if native plant materials are not 

available, or 4) in permanently altered plant communities. Under no circumstances will nonnative 

invasive plant species be used for re-vegetation.

Standard 14. Use only APHIS and State-approved biological control agents. Agents 

demonstrated to have direct negative impacts on non-target organisms would not be released.

Standard 15. Application of any herbicides to treat invasive plants will be performed or directly 

supervised by a State or Federally licensed applicator. All treatment projects that involve the use 

of herbicides will develop and implement herbicide transportation and handling safety plan. 

Standard 16. Select from herbicide formulations containing one or more of the following 10 

active ingredients: chlorsulfuron, clopyralid, glyphosate, imazapic, imazapyr, metsulfuron 

methyl, picloram, sethoxydim, sulfometuron methyl, and triclopyr. 

Mixtures of herbicide formulations containing 3 or less of these active ingredients may be applied 

where the sum of all individual Hazard Quotients for the relevant application scenarios is less 

than 1.0. 

All herbicide application methods are allowed including wicking, wiping, injection, spot, 

broadcast and aerial, as permitted by the product label. Chlorsulfuron, metsulfuron methyl, and 

sulfometuron methyl will not be applied aerially. The use of triclopyr is limited to selective 

application techniques only (e.g., spot spraying, wiping, basal bark, cut stump, injection). 

Additional herbicides and herbicide mixtures may be added in the future at either the Forest Plan 

or project level through appropriate risk analysis and NEPA/ESA procedures. This standard will 

be applied to invasive plant projects with NEPA decisions signed after March 1, 2006. 

Standard 18. Use only adjuvants (e.g. surfactants, dyes) and inert ingredients reviewed in Forest 

Service hazard and risk assessment documents such as SERA, 1997a, 1997b; Bakke, 2003. 
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Standard 19. To minimize or eliminate direct or indirect negative effects to non-target plants, 

terrestrial animals, water quality and aquatic biota (including amphibians) from the application of 

herbicide, use site-specific soil characteristics, proximity to surface water and local water table 

depth to determine herbicide formulation, size of buffers needed, if any, and application method 

and timing. Consider herbicides registered for aquatic use where herbicide is likely to be 

delivered to surface waters.

Standard 20. Design invasive plant treatments to minimize or eliminate adverse effects to 

species and critical habitats proposed and/or listed under the Endangered Species Act. This may 

involve surveying for listed or proposed plants prior to implementing actions within unsurveyed 

habitat if the action has a reasonable potential to adversely affect the plant species. Use sitespecific project design (e.g. application rate and method, timing, wind speed and direction, nozzle 

type and size, buffers, etc.) to mitigate the potential for adverse disturbance and/or contaminant 

exposure. 

Standard 21. Provide a minimum buffer of 300 feet for aerial application of herbicides near 

developed campgrounds, recreation residences and private land (unless otherwise authorized by 

adjacent private landowners).

Standard 22. Prohibit aerial application of herbicides within legally designated municipal 

watersheds.

Standard 23. Prior to implementation of herbicide treatment projects, National Forest system 

staff will ensure timely public notification. Treatment areas will be posted to inform the public 

and forest workers of herbicide application dates and herbicides used. If requested, individuals 

may be notified in advance of spray dates.

Desired Conditions

In National Forest lands across Region Six, healthy native plant communities remain diverse and 

resilient, and damaged ecosystems are being restored. High quality habitat is provided for native 

organisms throughout the region. Invasive plants do not jeopardize the ability of the National 

Forests to provide goods and services communities expect. The need for invasive plant treatment 

is reduced due to the effectiveness and habitual nature of preventative actions, and the success of 

restoration efforts. 

Goals and Objectives

Goal 1 Protect ecosystems from the impacts of invasive plants through an integrated approach 

that emphasizes prevention, early detection, and early treatment. All employees and users of the 

National Forest recognize that they play an important role in preventing and detecting invasive 

plants.

Objective 1.1 Implement appropriate invasive plant prevention practices to help reduce the 

introduction, establishment and spread of invasive plants associated with management actions 

and land use activities.

Objective 1.2 Educate the workforce and the public to help identify, report, and prevent 

invasive plants

Objective 1.3 Detect new infestations of invasive plants promptly by creating and maintaining 

complete, up-to-date inventories of infested areas, and proactively identifying and inspecting 

susceptible areas not infested with invasive plants.
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Objective 1.4 Use an integrated approach to treating areas infested with invasive plants. Utilize 

a combination of available tools including manual, cultural, mechanical, herbicides, biological 

control. 

Objective 1.5 Control new invasive plant infestations promptly, suppress or contain expansion 

of infestations where control is not practical, conduct follow up inspection of treated sites to 

prevent reestablishment.

Goal 2 Minimize the creation of conditions that favor invasive plant introduction, establishment 

and spread during land management actions and land use activities. Continually review and adjust 

land management practices to help reduce the creation of conditions that favor invasive plant 

communities. 

Objective 2.1 Reduce soil disturbance while achieving project objectives through timber 

harvest, fuel treatments, and other activities that potentially produce large amounts of bare 

ground 

Objective 2.2 Retain native vegetation consistent with site capability and integrated resource 

management objectives to suppress invasive plants and prevent their establishment and growth. 

Objective 2.3 Reduce the introduction, establishment and spread of invasive plants during fire 

suppression and fire rehabilitation activities by minimizing the conditions that promote invasive 

plant germination and establishment.

Objective 2.4 Incorporate invasive plant prevention as an important consideration in all 

recreational land use and access decisions. Use Forest-level Access and Travel Management 

planning to manage both on-highway and off-highway travel and travel routes to reduce the 

introduction, establishment and spread of invasive plants.

Objective 2.5 Place greater emphasis on managing previously “unmanaged recreation” (OHVs, 

dispersed recreation, etc.) to help reduce creation of soil conditions that favor invasive plants, 

and reduce transport of invasive plant seeds and propagules.

Goal 3 Protect the health of people who work, visit, or live in or near National Forests, while 

effectively treating invasive plants. Identify, avoid, or mitigate potential human health effects 

from invasive plants and treatments. 

Objective 3.1 Avoid or minimize public exposure to herbicides, fertilizer, and smoke. 

Objective 3.2 Reduce reliance on herbicide use over time in Region Six

Goal 4 Implement invasive plant treatment strategies that protect sensitive ecosystem 

components, and maintain biological diversity and function within ecosystems. Reduce loss or 

degradation of native habitat from invasive plants while minimizing adverse effects from 

treatment projects.

Objective 4.1 Maintain water quality while implementing invasive plant treatments.

Objective 4.2 Protect non-target plants and animals from negative effects of both invasive 

plants and applied herbicides. Where herbicide treatment of invasive plants is necessary within 

the riparian zone, select treatment methods and chemicals so that herbicide application is 

consistent with riparian management direction contained in PACFISH, INFISH, and the 

Aquatic Conservation Strategies of the Northwest Forest Plan. 
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Objective 4.3 Protect threatened, endangered, and sensitive species habitat threatened by 

invasive plants. Design treatment projects to protect threatened, endangered, and sensitive 

species and maintain species viability.

Goal 5 Expand collaborative efforts between the Forest Service, our partners, and the public to 

share learning experiences regarding the prevention and control of invasive plants, and the 

protection and restoration of native plant communities.

Objective 5.1 Use an adaptive management approach to invasive plant management that 

emphasizes monitoring, learning, and adjusting management techniques. Evaluate treatment 

effectiveness and adjust future treatment actions based on the results of these evaluations.

Objective 5.2 Collaborate with tribal, other federal, state, local and private land managers to 

increase availability and use of appropriate native plants for all land ownerships. 

Objective 5.3 Work effectively with neighbors in all aspects of invasive plant management: 

share information and resources, support cooperative weed management, and work together to 

reduce the inappropriate use of invasive plants (landscaping, erosion control, etc.).

Management Direction for Wildlife

Open Road Density

Open road density and corresponding human disturbance play a key role in determining whether 

wildlife remains in an area. Human disturbance associated with open roads can displace 

individual animals and make them vulnerable to harassment, reduce the amount of suitable 

habitat, and disturb nests and roosting activities. 

Table A-3. Open road density by management area, 1990 forest plans

National Forest Road Density Management Area(s)* Plan Component

Malheur

1.5 miles/square mile MA 4D Wildlife Emphasis

2.2 miles/square mile MA 4D Winter Range Standard

3.2 miles/square mile Summer Range**

Umatilla 2 miles/square mile Forestwide Desired condition

Wallowa-Whitman

1.5 miles/square mile MA 4E Winter Range 

MA 4D General Wildlife/Fish Standard

2.5 miles/square mile MA 4A General Forest

* See crosswalk in project record for more information.

** Includes all areas outside wildlife emphasis, winter range, and designated wilderness areas.

Management Indicator Species

In the 1990 Plans, management indicator species (MIS) were selected because their population 

changes were believed to indicate the effects of management activities. The MIS identified for the 

1990 forest plans are displayed in Table A-4. 
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Table A-4. 1990 Forest Plans management indicator species identified by national forest and criteria 

for selection

Management 

Indicator Species MAL UMA WAW OCH Criteria for Selection

Rocky Mountain elk X X X Commonly hunted; general habitat needs; 

cover/forage/roads

American marten X X X Old growth; dead and down tree habitat; 

mature habitat with large trees

Pileated 

woodpecker

X X X X Old growth; mature and old growth stands 

at high elevations

Northern goshawk X Mature to old conifer stands

Northern three-toed 

woodpecker

X X Old growth; dead and down in mature and 

old lodgepole pine

Lewis’ woodpecker X Dead and defective habitat

Yellow-bellied 

sapsucker

X Dead and defective habitat

Red-breasted 

sapsucker

X Dead and defective habitat

Williamson’s 

sapsucker

X Dead and defective habitat

Downy woodpecker X Dead and defective habitat

Hairy woodpecker X Dead and defective habitat

White-headed 

woodpecker

X Dead and defective habitat

Black-backed 

woodpecker

X Dead and defective habitat

Northern flicker X Dead and defective habitat; Old growth 

juniper habitat

Primary cavity 

excavators1

X X X Snag habitat; dead and down tree habitats; 

standing dead trees

Resident trout2 X X High quality water and fishery habitat

Rainbow trout 

(resident)

X Streams/riparian habitats

Rainbow/redband 

trout

X Non-anadromous riparian

Steelhead trout X X X Anadromous riparian; streams/riparian 

habitats; high quality water and fishery 

habitat

Bull trout X Non-anadromous riparian

Cutthroat trout X Non-anadromous riparian

1. Primary cavity excavator definition or list:

• Ochoco National Forest: wildlife species that excavate cavities in snags

• Umatilla National Forest: wildlife species that excavate cavities in snags

• Wallowa-Whitman National Forest: common flicker, Lewis’ woodpecker, yellow-bellied sapsucker, Williamson’s 

sapsucker, hairy woodpecker, downy woodpecker, white-headed woodpecker, black-backed woodpecker threetoed woodpecker, northern three-toed woodpecker, mountain chickadee, white-breasted nuthatch, red-breasted 

nuthatch and pygmy nuthatch 

• Malheur National Forest: did not use a primary cavity excavators group

2. Resident trout definition:

• Wallowa-Whitman National Forest: did not define resident trout

• Other national forests: did not use a resident trout group
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Appendix A: Forest Plan Revision Alternatives in Detail

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Habitat Effectiveness Index for Rocky Mountain elk

The Habitat Effectiveness Index (HEI) model is used to predict the influence of forest 

management on elk. It predicts how effectively an area supports elk. It is intended to be only a 

relative measure of habitat effectiveness and does not consider many factors that influence the 

actual number of elk found in an area. Those factors include hunting, predation, disease, changes 

in weather and forage production, and competition with other species for forage. Model 

parameters include open road density, cover-to-forage ratio, and cover quality. Further discussion 

of the model can be found in the 1990 forest plans. 

Table A-5. Comparison of Habitat Effectiveness Index*/cover standards for management areas (the 

management area identifiers are those used in the 1990 forest plans)

Umatilla National Forest Malheur National Forest Wallowa-Whitman National 

Forest** 

A10, C4,F4 – Elk habitat will be 

managed to achieve an HEI of 

no less than 60

A10, C4 – 30% of area is cover 

with minimum of 15% (20% 

desired) of satisfactory cover.

F4 – 30% of summer and winter 

area as cover with minimum of 

10% (15-20% desired) of 

satisfactory cover

C7, E2 – Elk habitat will be 

managed to achieve an HEI of 

no less than 45; 30% of area is 

cover with minimum of 10% (15-

20% desired) of satisfactory 

cover.

E1 – Elk habitat will be managed 

to achieve an HEI of at least 30; 

cover not mentioned

C8 – (grass-tree mosaic) 

minimum HEI of 70% and 30% 

of summer and winter area as 

cover with minimum of 10% (15-

20% desired) of satisfactory 

cover

C3 – (winter range) minimum 

HEI of 70% with 30% of area as 

cover with minimum of 10% (15-

20% desired) of satisfactory 

cover

C3a – (sensitive winter range) 

minimum HEI of 70% with 30% 

of area as cover with minimum of 

10% (15-20% desired) of 

satisfactory cover

1-Manage elk summer range to 

provide 20% cover and an HEI 

of 0.4. The mix of sat/mar cover 

can vary by summer range.

4A-Manage winter range to 

provide 25% cover and an HEI 

of 0.5.

20A, 20B, 21- Manage wildlife 

emphasis areas to provide and 

HEI of 0.7 and 40% cover

Ochoco National Forest-No HEI 

standards and guidelines for 

management areas

1 – General forest will be 

managed to obtain an 0.5 HEI

3, 3a, 18 – Manage winter range 

and selected summer ranges to 

achieve an HEI of 74%

Attempt to achieve an HEI of 0.5 

in timber sale planning. *** 

1 – Retain at least 30% of the 

forested area within a project in 

satisfactory or marginal cover.*** 

* HEI including discounts for roads open to motor vehicle traffic, as described in Wildlife Habitats in Managed Forests 

(Thomas et al. 1979). Marginal cover, satisfactory cover, and forage areas will be managed to meet size and spacing 

criteria as described in Habitat Effectiveness for Elk on Blue Mountains Winter Ranges (Thomas et al. 1988).

** The Wallowa-Whitman National Forest does not have forestwide elk standards. Those listed are from MA 3 

Timber/Wildlife Emphasis. 

*** From the record of decision.
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Management Direction for Timber Harvest

Direction pertaining to timber sales is included in the Eastside Screens as well as in other portions 

of the 1990 forest plans. Tables A-6 and A-7 are specific to the lands suitable for timber 

production and the allowable sale quantity. 

Table A-6. Lands suitable for timber production (acres) as shown in the 1990 forest plans and 

adjustments based on 2011 suitable acres, per alternative A (no action)

Year MAL* UMA WAW** Total

1990 985,000 619,000 837,000 2,441,000

2011 update*** 780,000 380,000 590,000 1,750,000

* Includes Ochoco National Forest acres administered by the Malheur National Forest.

** The HCNRA was removed from Wallowa-Whitman National Forest lands suitable for timber production by regulation in 

1994.

*** 2011 figures are based on recalculated timber suitability acres accounting for amendments and updated 

vegetation/soil mapping.

Table A-7. Allowable sale quantity (MMBF) as shown in the 1990 forest plans and 2011 actual 

outputs, per alternative A (no action)

Year MAL* UMA WAW Total

1990 234 124 141 499

2011 55 51 46 152

* Includes 34 MMBF from the portion of the Ochoco National Forest administered by the Emigrant 

Creek Ranger District of the Malheur National Forest.

Management Direction

for Livestock Grazing and Grazing Land Vegetation

Table A-8 displays the current upland grazing standards contained in each plan. See Table A-9 for 

livestock grazing direction in RHCAs. The maximum utilization figures apply regardless of what 

is consuming the forage. One level of utilization applies when rangeland is satisfactory condition 

and another when rangeland is in unsatisfactory condition (see glossary for definitions). Different 

utilization levels are also allowed depending on the level of management within an allotment. 

Management level is defined as:

Level B Stewardship (minimum level): Livestock use managed within current grazing capacity. 

Cost-effective improvements used only to maintain stewardship of range. 

Level C Extensive: Livestock managed to achieve full utilization of allocated forage.

Level D Intensive: Livestock managed to optimize forage production and utilization. May 

involve fencing and water development to implement complex grazing systems.

Sat: Satisfactory range condition–Forage condition is at least fair, with stable trend, and allotment 

is not classified PC (basic resource damage) or PD (other resource damage). 

Unsat: Unsatisfactory range condition. 
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Table A-8. Management direction for the maximum percent utilization of livestock grazing in uplands

National 

Forest

Management 

Level

Forested Grasslands Shrubland

Sat Unsat Sat Unsat Sat Unsat

MAL* Stewardship B 40% 0-30% 50% 0-30% 40% 0-25%

Extensive C 45% 0-35% 55% 0-35% 50% 0-30%

UMA Stewardship B 40% 0-30% 50% 0-30% 40% 0-25%

Extensive C 45% 0-35% 55% 0-35% 45% 0-30%

Intensive D 50% 0-40% 60% 0-40% 50% 0-35%

WAW Stewardship B 40% 0-30% 50% 0-30% 40% 0-25%

Extensive C 45% 0-35% 55% 0-35% 45% 0-30%

Intensive D 50% 0-40% 60% 0-40% 50% 0-35%

OCH Stewardship B 40% 0-30% 50% 0-30% 40% 0-25%

Extensive C 45% 0-35% 55% 0-35% 45% 0-30%

Intensive D 50% 0-40% 55% 0-40% 50% 0-35%

* Does not mention level D.

Sat=satisfactory, Unsat = unsatisfactory

For the Umatilla National Forest, utilization of transitory range (where timber harvest has 

occurred during the last 30 years) shall not exceed 60 percent for domestic livestock. 

Domestic Sheep Grazing

Wallowa-Whitman and Umatilla National Forests

Standard: Manage the conflict between bighorn sheep and domestic sheep in coordination with 

state wildlife agencies.

Malheur National Forest

Standard: Do not stock livestock allotments in bighorn sheep range with domestic sheep.

Table A-9. Management direction for maximum percent utilization of livestock grazing in riparian 

areas

National 

Forest

Management 

Level

Grass and grass-like Shrubs

Sat Unsat Sat Unsat

MAL* Stewardship B 40% 0-30% 30% 0-25%

Extensive C 45% 0-35% 40% 0-30%

UMA Stewardship B 40% 0-30% 30% 0-25%

Extensive C 45% 0-35% 40% 0-30%

Intensive D 50% 0-40% 50% 0-35%

WAW Stewardship B 40% 0-30% 30% 0-25%

Extensive C 45% 0-35% 40% 0-30%

Intensive D 50% 0-40% 50% 0-35%

OCH Stewardship B 40% 0-30% 30% 0-25%

Extensive C 45% 0-35% 40% 0-30%

Intensive D 50% 0-40% 50% 0-35%

* Does not mention level D.

Sat=satisfactory, Unsat = unsatisfactory
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Part 2: Description of the Plan Revision Alternatives 

Introduction 

The Forest Plans (appended to the draft Record(s) of Decision) describe plan components for the 

agency preferred alternative, E-Modified. This section describes how the plan revision 

alternatives (Alternatives B, C, D, E, E-Modified Departure, and F) differ from Alternative EModified. 

The components of a forest plan include:

• Goals and desired conditions

• Management areas

• Special areas

• Suitable uses and activities

• Objectives

• Standards 

• Guidelines 

• Monitoring and evaluation 

Laws and Regulations

All plan revision alternatives are designed to comply with applicable laws, regulations, and 

policies that govern the Forest Service and the management of National Forest System lands. This 

plan revision is guided by the 2012 Planning Rule that includes provisions allowing the Forest 

Service to use the 1982 planning rule to amend or revise plans. Generally, laws and regulations 

are not repeated in the text of the revised Forest Plans or in this appendix. A list of laws and 

regulations applicable to national forest planning is in Appendix B of this document. 

Special Designations

All of the existing areas protected by special designations during the life of the 1990 forest plans 

maintain those special designations across the plan revision alternatives. Discussions of any 

additional special areas or proposed additional special areas are included in the individual action 

alternative descriptions. 

Goals and Desired Conditions

The goals and desired conditions are common to each of the plan revision alternatives except for 

desired condition 2.7, Roads and Trail Access. The rate of achieving desired conditions may vary 

by alternative due to differences in the suitability of lands for different activities and to 

differences in management intensity as reflected by differences in objectives. The goals and 

desired condition statements for Alternatives E-Modified and E-Modified Departure were edited 

to improve clarity but are intended to achieve the same intent as described for the Alternatives B, 

C, D, E, and F in the Draft Environmental Impact Statement. 

The three goals for the Malheur, Umatilla and Wallowa-Whitman National Forests Forest Plans 

are to: (1) promote ecological integrity, (2) promote social well-being, and (3) promote economic 

well-being. The plans are organized under these three goals with unique desired conditions, 

objectives, standards and guidelines for each goal (Table A-10). For the full text of the goals and 

desired conditions, refer to the forest plans in the Appendix to the draft Record of Decision.
Final Environmental Impact Statement, Volume 3

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Table A-10. Primary goals and corresponding desired conditions identified to meet the goals – 

Alternatives B, C, D, E, E-Modified, E-Modified Departure, and F

Goal 1: Promote Ecological Integrity

1.1 Watershed Function

1.1.1 Hydrologic Function

1.1.2 Riparian Function

1.1.3 Wetland Function and Groundwaterdependent Ecosystem Function

1.1.4 Stream Channel Function

1.1.5 Aquatic Habitat Function

1.2 Species Diversity

1.3 Federally Listed and Sensitive Species

1.4 Disturbance Processes

1.4.1 Wildland Fire 

1.4.2 Insects and Diseases 

1.5 Invasive Species

1.6 Structural Stages

1.7 Plant Species Composition

1.8 Stand Density

1.9 Air Quality

1.10 Soil Quality

1.11 Water Quality

1.12 Landscape Patterns

1.13 Special Plant Habitats

1.13.1 Whitebark Pine

1.13.2 Aspen

1.13.3 Sagebrush Steppe

1.14 Old Forest and Individual Old/Large Trees

1.15 Snags and Down Wood

Goal 2: Promote Social Well-Being

2.1 Scenery

2.1.1 Scenic Integrity and Scenic Stability

2.2 Recreation

2.2.1 Developed Recreation

2.2.2 Dispersed Recreation

2.2.3 Backcountry Recreation

2.3 Hunting and Fishing

2.3.1 Rocky Mountain Elk

2.3.2 Bighorn Sheep

2.4 Cultural Resources

2.5 Roads and Trails Access

2.6 Wildland Urban Interface

2.7 Tribal Rights and Interest

2.8 Culturally Significant Foods

2.9 Community Resilience

2.10 Wild Horses

Goal 3: Promote Economic Well-Being

3.1 Facilities and Infrastructure

3.2 Land Ownership

3.3 Goods and Services

3.3.1 Forest Products

3.3.2 Livestock Grazing

3.3.3 Special Uses

3.3.4 Mineral, Energy, and Geological 

Resources 

3.3.5 Water Use

Alternative Elements (Plan Revision Alternatives)

As discussed in the introduction to Part 2—Comparison of the Plan Revision Alternatives, the 

alternative elements include discussion and comparison of some of the forest plan components, 

including management areas, suitability determinations, objectives, standards, and guidelines. 

Most forest plan management direction will be common to each of the three National Forests. 

Only where specifically noted will management direction be specific to only one of the National 

Forests.

Management Areas

Management areas broadly describe areas where general management intent is similar. The 

purpose of management areas is to provide consistent guidance for similar portions of the national 

forest landscape when implementing or continuing management activities. The management areas 

generally range along a continuum from little development by humans in MA 1A to extensive 

human development in MA 5. 

Management area descriptions and intent do not vary by alternative except for MA 4B. Not all 

management areas occur in all alternatives. Table A-14 to Table A-17 list the management areas 

by national forest for each of the alternatives. These tables do not include the management area 

acre totals within the Hells Canyon National Recreation Area, but they do display the portion of 

the Ochoco National Forest administered by the Malheur National Forest. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

27

Please refer to the Revised Forest Plans, appended to the Record of Decision, that describe the 

desired conditions for each management area, except for MA 3C – Wildlife Corridor, MA 4B – 

Riparian Management Areas, and MA 4C – Old Forest, which are described below.

MA 3C Wildlife Corridor (Alternatives C, E, and F)

Description: Wildlife corridors are areas designed to maintain habitat linkages between 

wilderness areas. Although disagreement exists regarding the utility of corridors, this 

management area emphasizes management for landscape connectivity, which is “the degree to 

which the landscape facilitates or impedes movement among resource patches,” (Taylor et al. 

1993) or “the functional relationship among habitat patches, owing to the spatial contagion of 

habitat and the movement responses of organisms to landscape structure,” (With et al. 1997). A 

wide variety of vegetation structure and composition is present, with some showing evidence of 

past human disturbance and others showing affects primarily from natural disturbances, such as 

wildfires. Both summer and winter motor vehicle travel is restricted to designated routes. 

Recreation users can expect to find evidence of human activity in the form of vegetation 

management, mining, and road building. However, many of the roads that are closed to motor 

vehicle travel occur in these areas.

Desired Condition: Wildlife species using these areas experience minimal human disturbance. 

Thinning forested vegetation results in variable densities, with greater than 40 percent canopy 

cover, over greater than 75 percent of the area, during the life of the plan.

The social setting is one of little challenge and risk. The area’s many routes may not be available 

for motor vehicle travel. Within HUC5 watersheds in this management area, year round open 

motor vehicle route density is less than 1 mile per square mile, including over-the-snow motor 

vehicle routes. Over-the-snow motor vehicle travel is restricted to designated routes. Major 

travelways (i.e., state, county, and paved roads) remain open year round, and may be groomed for 

over-the-snow motor vehicle use in winter. The recreation opportunity spectrum in MA3C is 

semi-primitive motorized.

MA 4B Riparian Management Areas 

Description: Riparian management areas (RMAs) are areas that include portions of watersheds 

where aquatic and riparian-dependent resources receive primary emphasis and where special 

management direction applies. Riparian management areas encompass lands adjacent to 

permanently flowing streams, ponds, lakes, wetlands, seeps, springs, and intermittent streams, 

including geologically unstable sites that may influence these lands. Riparian management areas 

will generally have minimum widths (displayed in Table A-11, Table A-12, and Table A-13) but 

are designed to extend to the outer edge of riparian vegetation or to the outer extent of the 100-

year floodplain, whichever is greater. Riparian management areas are managed to maintain and 

restore the riparian structure and function of intermittent and perennial streams, confer benefits to 

riparian-dependent plant and animal species, enhance habitat conservation for organisms that are 

dependent on the transition zone between upslope and riparian areas, and provide for greater 

connectivity within and between watersheds for both riparian and upland species. 

Riparian vegetation performs numerous key functions for stream ecosystems, including the 

provision of shade, bank stability, nutrient transfer, retention of organic material, and the supply 

of woody material. 

Because riparian plant species vary in their establishment mechanisms, water requirements, and 

tolerance to flooding, differences in channel and floodplain morphology result in high spatial and 

temporal variability in species composition and age class structure within and along riparian 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

28

zones. This makes riparian areas among the most biologically diverse and productive habitats on 

the landscape. 

Table A-11. Riparian management area widths for alternatives B, E, and F

Category Minimum Riparian Management Area Width*

Fish-bearing streams 300 feet slope distance on either side of stream or to outer 

edge of 100-year floodplain, whichever is greatest

Permanently-flowing non-fish-bearing 

streams

150 feet slope distance on either side of stream or to outer 

edge of 100-year floodplain, whichever is greatest

Constructed ponds, reservoirs and 

wetlands greater than 1 acre

150 feet slope distance from the outer edge of wetland or from 

the maximum pool elevation, whichever is greatest

Lakes and natural ponds 300 feet slope distance

Seasonally-flowing, intermittent and 

ephemeral streams, wetlands smaller 

than 1 acre, and unstable areas

100 feet slope distance

* Additional delineation criteria apply, as described in the glossary.

Table A-12. Riparian management area widths for alternative C

Category Minimum Riparian Management Area Width*

Fish-bearing streams 300 feet slope distance on either side of stream 

Permanently-flowing non-fish-bearing 

streams

300 feet slope distance on either side of stream

Constructed ponds, reservoirs and 

wetlands greater than 1 acre

300 feet slope distance 

Lakes and natural ponds 300 feet slope distance

Seasonally-flowing, intermittent and 

ephemeral streams, wetlands smaller 

than 1 acre, and unstable areas

300 feet slope distance

* Additional delineation criteria apply, as described in the glossary.

Table A-13. Riparian management area widths for alternative D

Category Minimum Riparian Management Area Width*

Fish-bearing streams 100 feet slope distance on either side of stream or to outer 

edge of 100-year floodplain, whichever is greatest

Permanently-flowing non-fish-bearing 

streams

70 feet slope distance on either side of stream or to outer 

edge of 100-year floodplain, whichever is greatest

Constructed ponds, reservoirs and 

wetlands greater than 1 acre

50 feet slope distance from the outer edge of wetland or from 

the maximum pool elevation, whichever is greatest

Lakes and natural ponds 50 feet slope distance

Seasonally-flowing, intermittent and 

ephemeral streams, wetlands smaller 

than 1 acre, and unstable areas

50 feet slope distance

* Additional delineation criteria apply, as described in the glossary.

Healthy riparian areas are important for the protection of the water quality upon which aquatic 

species depend and are also used by approximately 75 percent of terrestrial vertebrate species in 

the Blue Mountains (Raedeke 1989, Thomas 1979). In addition, riparian areas provide critical 

habitat for numerous sensitive, rare, or uncommon plant and lichen species. Management 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

29

activities within riparian management areas are designed to maintain, enhance, or restore the 

ecological processes responsible for the diversity, productivity, and sustainability of riparian 

habitats. 

Management of riparian management areas focuses on the ecological processes and conditions 

within the riparian management areas and contributes to the value of the aquatic and riparian 

habitats they contain. The glossary describes the full definition and criteria for delineating 

riparian management areas.

Desired Condition: Riparian management areas within any given watershed reflect a natural 

composition of native and desired nonnative plant and animal species and a distribution of 

physical and vegetative conditions appropriate to natural disturbance regimes affecting the area.

Key riparian processes and conditions, including slope stability and associated vegetative root 

strength; wood delivery to streams; input of leafy and organic matter to aquatic and terrestrial 

systems; solar shading; microclimate; and water quality, are within ranges typical of the 

biophysical setting and the corresponding disturbance regime. The recreation opportunity 

spectrum in MA 4B is semi-primitive to primitive. 

Acres associated with MA 4B are only those acres within MA 4A General Forest. However, the 

desired conditions and standards and guidelines that apply to MA 4B apply to all riparian 

management areas.

MA 4C Old Forest (Alternative C)

Description: Old forest is a late stage of stand development that develops over a relatively long 

period of time. Old forest has an abundance of physiologically old trees (for the species and site 

conditions) that are dominant in the overstory and are usually larger in diameter (see glossary for 

definition by potential vegetation group). Old forest is valued as wildlife habitat, contributions to 

riparian habitat, for recreation, and for aesthetic and cultural values. 

Desired Condition: Old forest is maintained and restored to meet a wide variety of ecological 

and social values. Old forest provides habitat for wildlife, preserves aesthetic values, and 

contributes to landscape diversity. The amount of old forest is consistent with the HRV. See the 

ecological desired conditions for specific ranges for the percent of each upland forest or 

woodland potential vegetation group in old forest structural stages. The management of old forest 

is also guided by other ecological desired conditions, such as stand density, species composition, 

fire regime condition class, snags, and downed wood. The recreation opportunity spectrum in 

MA4C is semi-primitive motorized or nonmotorized. 

Management Area Acreages (Plan Revision Alternatives)

The following tables display the management area designations and allocations for the plan 

revision alternatives. All management areas are displayed in full. Overlap occurs between most 

management areas but is not accounted for in these tables. The overlapping management areas 

result in the total acreage of all management areas being greater than the official national forest 

acreages. For example, several research natural areas (MA 2B) and wild and scenic rivers (MA 

2A) overlap into congressionally designated wilderness areas (MA 1A). 

Wilderness area acres have been recalculated using the most current GIS technology. No 

additions or subtractions to any wilderness areas have been made since the 1990 forest plans were 

signed. Acres of private land inclusions are not included in any wilderness area acre calculations.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

30

Scenic byways and national designated trails within the HCNRA are not included in these tables. 

The figures in the tables are rounded to the nearest hundred acres and to the nearest whole mile. 

In addition, these tables do not include acreage for the HCNRA. The HCNRA CMP, which was 

updated and approved in 2003, will be carried forward in its entirety. The HCNRA CMP is the 

portion of the Wallowa-Whitman National Forest Land and Resource Management Plan that 

guides management of the HCNRA. The tables display the portion of the Ochoco administered by 

the Malheur as part of the Malheur.

Alternative B, Modified Proposed Action

Table A-14. Management area designation, name, and acreage for each national forest (2F and 2G 

show miles) in alternative B

Management Area Designation and Name Malheur Umatilla WallowaWhitman

1A – Congressionally Designated Wilderness Areas 82,600 304,200 372,900

1B – Recommended Wilderness Areas 1,200 1,400 10,800 

1C – Wilderness Study Area 0 0 2,400 

2A – Wild and Scenic River (Includes Designated, 

Eligible, and Suitable Rivers)

12,100 44,600 84,400

2B – Research Natural Areas 11,100 11,000 8,000

2C – Botanical Areas 100 2,400 0 

2D – Geological Areas 200 400 0 

2E – Historical Areas 34,000 1,200 24,700

2F – Scenic Byways and All-American Roads 13 miles 51 miles 85 miles

2G – Nationally Designated Trails 9.3 miles 29.9 miles 25.4 miles

2H – Scenic Areas 14,400 31,100 0 

2I – Starkey Experimental Forest and Range 0 0 30,453

2J – Municipal Watersheds 500 20,200 24,500

3A – Backcountry (nonmotorized use) 59,300 19,300 0 

3B – Backcountry (motorized use) 129,100 240,900 248,900

3C – Wildlife Corridor 0 0 0 

4A – General Forest 1,252,000 640,300 848,000

4B – Riparian Management Areas (300/150/100 foot 

buffer) 

192,900 237,500 362,500

4B – Riparian Management Areas (within 4A) 149,900 118,700 184,600

4C – Old Forest 0 0 0 

5 – Developed Sites and Administrative Areas 2,200 3,700 7,700
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

31

Alternative C

Table A-15. Management area designation, name, and acreage for each national forest (2F and 2G 

show miles) in alternative C

Management Area Designation and Name Malheur Umatilla WallowaWhitman

1A – Congressionally Designated Wilderness Areas 82,600 304,200 372,900

1B – Recommended Wilderness Areas 83,800 248,500 172,700

1C – Wilderness Study Area 0 0 2,400

2A – Wild and Scenic River (Includes Designated, 

Eligible, and Suitable Rivers)

12,100 44,600 84,400

2B – Research Natural Areas 11,100 11,000 8,000

2C – Botanical Areas 100 2,400 0 

2D – Geological Areas 200 400 0 

2E – Historical Areas 34,000 1,200 0 

2F – Scenic Byways and All-American Roads 13 miles 51 miles 85 miles

2G – Nationally Designated Trails 9 miles 30 miles 25 miles

2H – Scenic Areas 14,400 31,100 0 

2I – Starkey Experimental Forest and Range 0 0 30,500

2J – Municipal Watersheds 500 20,200 24,500

3A – Backcountry (nonmotorized use) 270,400 105,800 210,100

3B – Backcountry (motorized use) 0 0 0 

3C – Wildlife Corridor 167,700 91,900 242,600

4A – General Forest/Timber/Range 702,500 329,000 397,200

4B – Riparian Management Areas

(300-foot buffers)

369,000 499,800 727,500

4B – Riparian Management Areas (within 4A) 172,400 178,100 200,900

4C – Old Forest 205,100 94,800 91,000

5 – Developed Sites and Administrative Areas 2,200 3,700 7,700
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

32

Alternative D

Table A-16. Management area designation, name, and acreage for each national forest (2F and 2G 

show miles) in alternative D

Management Area Designation and Name Malheur Umatilla WallowaWhitman

1A – Congressionally Designated Wilderness Areas 82,600 304,200 372,900

1B – Recommended Wilderness Areas 0 0 0 

1C – Wilderness Study Area 0 0 2,400

2A – Wild and Scenic River (Includes Designated, 

Eligible, and Suitable Rivers)

12,100 44,600 52,900

2B – Research Natural Areas 11,100 11,000 8,000

2C – Botanical Areas 100 2,400 0 

2D – Geological Areas 200 400 0 

2E – Historical Areas 34,000 1,200 24,700

2F – Scenic Byways and All-American Roads 13 miles 51 miles 85 miles

2G – Nationally Designated Trails 9 miles 30 miles 25 miles

2H – Scenic Areas 14,400 31,100 0 

2I – Starkey Experimental Forest and Range 0 0 30,500

2J – Municipal Watersheds 500 20,200 24,500

3A – Backcountry (nonmotorized use) 0 0 0 

3B – Backcountry (motorized use) 165,800 218,700 219,500

3C – Wildlife Corridor 0 0 0 

4A – General Forest 1,359,800 742,300 998,700

4B – Riparian Management Areas

(100/70/50 foot buffers)

83,100 106,900 162,900

4B – Riparian Management Areas (within 4A) 66,000 58,100 87,100

4C – Old Forest 0 0 0 

5 – Developed Sites and Administrative Areas 2,200 3,700 7,700
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

33

Alternatives E and F

Table A-17. Management area designation, name, and acreage for each national forest (2F and 2G 

show miles) in alternatives E and F

Management Area Designation and Name Malheur Umatilla WallowaWhitman

1A – Congressionally Designated Wilderness Areas 82,600 304,200 372,900

1B – Recommended Wilderness Areas 30,400 40,100 20,300

1C – Wilderness Study Area 0 0 2,400

2A – Wild and Scenic River (Includes Designated, 

Eligible, and Suitable Rivers)

12,100 44,600 52,900

2B – Research Natural Areas 11,100 11,000 8,000

2C – Botanical Areas 100 2,400 0 

2D – Geological Areas 200 400 0 

2E – Historical Areas 34,000 1,200 24,700

2F – Scenic Byways and All-American Roads 13 miles 51 miles 85 miles

2G – Nationally Designated Trails 9 miles 30 miles 25 miles

2H – Scenic Areas 14,400 31,100 0 

2I – Starkey Experimental Forest and Range 0 0 30,500

2J – Municipal Watersheds 500 20,200 24,500

3A – Backcountry (nonmotorized use) 53,600 70,100 104,500

3B – Backcountry (motorized use) 119,100 160,600 145,500

3C – Wildlife Corridor 0 21,600 6,500

4A – General Forest 1,245,600 625,200 844,300

4B – Riparian Management Areas 

(300/150/100 foot buffer)

192,900 237,500 362,500

4C – Old Forest 0 0 0 

5 – Developed Sites and Administrative Areas 2,200 3,700 7,700
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

34

Alternatives E-Modified and E-Modified Departure

Table A-18. Management area designation, name, and acreage for each national forest (2F and 2G 

show miles) in alternatives E-Modified and E-Modified Departure

Management Area Designation and Name Malheur Umatilla WallowaWhitman

1A – Congressionally Designated Wilderness Areas 82,600 304,200 372,900

1B – Recommended Wilderness Areas 26,600 31,900 12,000

1C – Wilderness Study Area 0 0 2,400

2A – Wild and Scenic River (Includes Designated, Eligible, and 

Suitable Rivers) 12,100 44,400 52,900

2B – Research Natural Areas 11,100 11,000 8,000

2C – Botanical Areas 100 900 1,000

2D – Geological Areas 200 400 0 

2E – Historical Areas 34,000 1,200 2,300

2F – Scenic Byways and All-American Roads 13 miles 51 miles 85 miles

2G – Nationally Designated Trails 9 miles 30 miles 25 miles

2H – Scenic Areas 14,400 31,100 0 

2I – Starkey Experimental Forest and Range 0 0 30,500

2J – Municipal Watersheds 500 20,200 24,500

3A – Backcountry (non-motorized use) 47,200 49,700 31,700

3B – Backcountry (motorized use) 118,000 169,200 209,400

3C – Wildlife Corridor 0 0 0 

4A – General Forest 1,250,200 648,000 861,400

4B – Riparian Management Areas (300/150/100-foot buffer) 192,900 237,500 362,500

4B – Riparian Management Areas (within 4A) 149,500 119,900 190,100

4C – Old Forest 0 0 0 

5 – Developed Sites and Administrative Areas 2,200 7,500 7,700
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

35

Suitability of Areas 

An area may be identified as generally suitable for uses that are compatible with desired 

conditions and objectives for that area. An area may be identified as generally not suitable for 

uses that are not compatible with desired conditions and objectives for that area. Identification of 

an area as generally suitable or generally not suitable for a use is guidance for project and activity 

decision making and not a commitment nor a final decision approving projects and activities. 

Uses of specific areas are approved through project and activity decisionmaking.

Management areas are used in this forest plan to help further refine suitable uses and guide 

management. 

The management area designations and names follow:

1A Congressionally Designated Wilderness Areas 

1B Preliminary Administratively Recommended Wilderness Areas

1C Wilderness Study Area

2A Wild and Scenic River (Includes Designated, Eligible, and Suitable Rivers)

2B Research Natural Areas

2C Botanical Areas

2D Geological Areas

2E Historical Areas

2F Scenic Byways and All American Roads

2G Nationally Designated Trails

2H Scenic Areas

2I Starkey Experimental Forest and Range 

2J Municipal Watersheds

3A Backcountry (nonmotorized use) 

3B Backcountry (motorized use) 

3C Wildlife Corridors

4A General Forest

4B Riparian Management Areas

4C Old Forest 

5 Developed Sites and Administrative Areas

For ease of comparison, general suitability determinations for management areas for each of the 

plan revision alternatives are displayed in the following tables. Some management areas are not 

proposed for each national forest or for each alternative. Suitability designations that differ from 

the agency preferred alternative (E-Modified), as displayed in the revised forest plans appended 

to the draft Record(s) of Decision, are noted with an asterisk. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

36

Alternative B

Omits Management Area 4C - Old Forest and 3C - Wildlife Corridors.

Table A-19. General suitability matrix for management areas for alternative B

Use or 

Activity 1A 1B 1C 2A 2B 2C 2D 2E 2F 2G 2H 2I 2J3 3A 3B 4A 4B 5 

Timber 

production U U U U U U U U U U U U U U U S U U 

Timber harvest U U U S U S S S S S S S S S S S S S 

Grazing (cattle 

and sheep) S S S S U U S S S S S S U S S S S U 

Motor 

vehicle use 

(summer)

1

U U U U2 U S S S S S* S U* U U S S S S 

Motor vehicle 

use (winter) U S* U U2 U S S S S S S U* U U S S1 S S 

Road 

construction U U U U2 U U S S S U S U* U U U S U S 

Trail 

construction 

(for motor 

vehicle use)

U U U U2 U U S S S U S U* U U S S U S 

Mechanical 

fuel treatment U U U U2 U U S S S S S S S S S S S S 

Energy 

development 

(wind farms, 

utility corridors, 

pipelines, etc.)

U U U U U U U U U U U U U U U S U S 

S designates use or activity as generally suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

U designates use or activity as generally not suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

* Suitability designation differs from agency preferred alternative, E-Modified.

1. indicates generally suitable applies only to use or activity on designated roads and trails and within designated areas.

2. indicates generally not suitable for wild and scenic rivers, generally suitable for recreational rivers.

3. All activities in municipal watersheds are dependent on the agreement for management of the watershed between the 

Forest Service and the municipality.

 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

37

Alternative C

Omits Management Area 3B - Backcountry (motorized use) and includes Management Areas 3C - 

Wildlife Corridors and 4C - Old Forest. 

Table A-20. General suitability matrix for management areas for alternative C

Use or 

Activity 1A 1B 1C 2A 2B 2C 2D 2E 2F 2G 2H 2I 2J3 3A 3C 4A 4B 4C 5 

Timber 

production U U U U U U U U U U U U U U U S U U U 

Timber harvest U U U S U S S S S S S S S U* S S U* U* U*

Grazing (cattle 

and sheep) S S S S U U S S S S S S U S S S U* S S* 

Motor 

vehicle use 

(summer)1 U U U U2 U S S S S S* S U* U U U S U* U U*

Motor vehicle 

use (winter) U U U U2 U S S S S S S U* U U S1 S U* U U*

Road 

construction U U U U2 U U S S S U S U* U U U S U U U*

Trail 

construction 

(for motor 

vehicle use) U U U U2 U U S S S U S U* U U U S U U U*

Mechanical 

fuel treatment U U U U2 U U S S S S S S S U* S S U* S S 

Energy 

development 

(wind farms, 

utility corridors, 

pipelines, etc.) U U U U U U S* S* S* S* S* S* S* U S S U U S 

S designates use or activity as generally suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

U designates use or activity as generally not suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

* Suitability designation differs from agency preferred alternative, E-Modified.

1. indicates generally suitable applies only to use or activity on designated roads and trails and within designated areas.

2. indicates generally not suitable for wild and scenic rivers, generally suitable for recreational rivers.

3. All activities in municipal watersheds are dependent on the agreement for management of the watershed between the 

Forest Service and the municipality.

 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

38

Alternative D

Omits Management Areas 3A – Backcountry (nonmotorized use), 3C - Wildlife Corridors, and 4C 

– Old Forest. 

Table A-21. General suitability matrix for management areas for alternative D

Use or 

Activity 1A 1C 2A 2B 2C 2D 2E 2F 2G 2H 2I 2J3 3B 4A 4B 5 

Timber 

production U U U U U U U U U U U U U S U U 

Timber 

harvest U U S U S S S S S S S S S S S S* 

Grazing 

(cattle and 

sheep)

S S S U U S S S S S S U S S S U 

Motor 

vehicle use 

(summer)1

U U U2 U S S S S S* S* U* U* S S S S 

Motor vehicle 

use (winter) U U U2 U S S S S S S U* U S S1 S S 

Road 

construction U U U2 U U S S S U S U* U U S U S 

Trail 

construction 

(for motor 

vehicle use)

U U U2 U U S S S U S U U S S U S 

Mechanical 

fuel treatment U U U2 U U S S S S S S S S S S S 

Energy 

development 

(wind farms, 

utility 

corridors, 

pipelines, etc.)

U U U U U U U U U U U U U S U S 

S designates use or activity as generally suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

U designates use or activity as generally not suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

* Suitability designation differs from agency preferred alternative, E-Modified.

1. indicates generally suitable applies only to use or activity on designated roads and trails and within designated areas.

2. indicates generally not suitable for wild and scenic rivers, generally suitable for recreational rivers.

3. All activities in municipal watersheds are dependent on the agreement for management of the watershed between the 

Forest Service and the municipality.

 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

39

Alternatives E and F

Omits Management Area 4C – Old Forest. 

Table A-22. General suitability matrix for management areas for alternatives E and F

Use or 

Activity 1A 1B 1C 2A 2B 2C 2D 2E 2F 2G 2H 2I 2J3 3A 3B 3C 4A 4B 5

Timber 

production U U U U U U U U U U U U U U U U S U U 

Timber 

harvest U U U S U S S S S S S S S S S S S S S 

Grazing 

(cattle and 

sheep)

S S S S U U S S S S S S U S S S S S U 

Motor 

vehicle use 

(summer)1

U U U U2 U S S S S S* S U* U U S S S S S 

Motor vehicle 

use (winter) U S* U U2 U S S S S S S U* U U S S1 S S S 

Road 

construction U U U U2 U U S S S U S U* U U U S S U S 

Trail 

construction 

(for motor 

vehicle use)

U U U U2 U U S S S U S U* U U S S S U S 

Mechanical 

fuel treatment U U U U2 U U S S S S S S S S S S S S S 

Energy 

development 

(wind farms, 

utility 

corridors, 

pipelines, etc.)

U U U U U U U U U U U U U U U U S U S 

S designates use or activity as generally suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

U designates use or activity as generally not suitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

* Suitability designation differs from agency preferred alternative, E-Modified.

1. indicates generally suitable applies only to use or activity on designated roads and trails and within designated areas.

2. indicates generally not suitable for wild and scenic rivers, generally suitable for recreational rivers.

3. All activities in municipal watersheds are dependent on the agreement for management of the watershed between the 

Forest Service and the municipality.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

40

Alternatives E-modified and E-Modified Departure

Table A- 23. General suitability matrix for management areas for Alternatives E-Modified and E-Modified 

Departure

Use or Activity 1A 1B 1C 2A2 2B 2C 2D 2E 2F 2G4 2H 2I 2J5 3A 3B 4A 4B 5 

Timber production U U U U U U U U U U U U U U U S U U 

Timber harvest3 U U U S U S S S S S S S S S S S S S 

Grazing (cattle and 

sheep) S S S S U U S S S S S S U S S S S U 

Motor vehicle use1

(summer) U U U U U S S S S U S S U U S S S S 

Motor vehicle use 

(winter) U U U U U S S S S S S S U U S S S S 

New Road 

construction U U U U U U S S S U S S U U U S U S 

New Trail 

construction (for 

motor vehicle use)

U U U U U U S S S U S S U U S S U S 

Mechanical fuel

treatment U U U U U U S S S S S S S S S S S S 

Energy development 

(wind farms, utility 

corridors, pipelines, 

etc.)

U U U U U U U U U U U U U U U S U S6

S designates use or activity as suitable. Refer to desired conditions and standards and guidelines for each management 

area and/or use for specific guidance.

U designates use or activity as unsuitable. Refer to desired conditions and standards and guidelines for each 

management area and/or use for specific guidance.

1. Indicates suitable applies only to use or activity on roads, trails, and areas open to motor vehicle use that are in 

compliance with the Travel Management Rule (36 CFR 212).

2. Indicates not suitable for river segments classified as wild rivers, suitable for river segments classified as scenic and 

recreational rivers.

3. Vegetation in areas suitable for timber harvest shall not be subject to regularly scheduled timber production (regularly 

schedule timber harvest on suitable lands); since they are not part of our timber suitability landbase.

4. Establishing legislation may influence whether motorized use is allowed.

5. All activities in municipal watersheds are dependent on the agreement for management of the watershed between the 

Forest Service and the municipality.

6. Energy development is only suitable in designated utility corridors.

 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

41

Objectives (Plan Revision Alternatives) 

Objectives are projections of Forest Service activities and program outcomes that are measurable 

and time specific. Like goals and desired conditions, objectives are not commitments or final 

decisions approving projects or activities. They are a way to measure progress towards meeting or 

maintaining the desired conditions over the life of the plan. The objectives reflect activities and 

program outcomes necessary to maintain or achieve desired conditions. 

Objectives are based on ecological needs, community capacity, and expected funding, including 

budgets, partnerships, and cooperative agreements. The actual accomplishments will be 

dependent on actual funding, staffing levels, and local infrastructure. The objectives are not 

intended to limit or guarantee the amount of work that will be accomplished. More work may be 

accomplished if additional infrastructure or funding, such as increased budget allocations, 

partnerships, or other external sources, becomes available. Less work could occur if funding is 

less than expected, additional infrastructure is not constructed, or existing infrastructure declines 

and becomes unusable. 

The identified objectives are just a partial list of the management activities expected to be 

accomplished to contribute to maintaining or achieving desired conditions during the first decade 

of the plan period, unless otherwise indicated within the objective statement. Objectives are 

displayed separately for each the Blue Mountains national forests (Table A-24 to Table A-26).

The tables display the portion of the Ochoco administered by the Malheur as part of the Malheur. 

More detail regarding the anticipated annual silvicultural, invasive and grazing accomplishments 

are provided in Table A-24 to Table A-26. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

42

Malheur National Forest Objectives

Table A-24. Comparison of objectives for the plan revision alternatives for the Malheur National Forest. The objectives are just a partial list of the 

management activities expected to be accomplished to contribute to maintaining or achieving desired conditions during the first decade of the plan 

period, unless otherwise indicated within the objective statement.

1.1 Watershed Function3

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

(W1) Increase the number of watersheds in 

condition class 1 (from CC2) and 2 (from CC3)

through active restoration. Measure: number of 

subwatersheds (HUC6) with improved condition 

class.

16 watersheds 20 watersheds 16 watersheds 16 watersheds 16 watersheds

Improve hydrologic function by:

• Improving forest vegetative conditions (acres) 

(WH1)

4,400 acres

(annually)

2,000 acres

(annually)

20,700 acres

(annually)

Alt. E: 7,800 acres

Alts. E-Mod. and E-Mod. Dep: 

5,500 acres

(annually)

5,600 acres

(annually)

• Improving soil hydrologic function in areas of 

detrimental soil disturbance (acres) (WH2)

450 acres 800 acres 400 acres 600 acres 540 acres

• Reducing road-related sedimentation by 

reducing road density and reducing 

hydrologic connectivity of the road system 

(road miles) (WH3)

25-30 miles 

road surface 

treated

(annually)

45-75 miles road 

surface treated

(annually)

50-80 miles road 

surface treated

(annually)

30-35 miles road surface 

treated (annually)

30-35 miles 

road surface 

treated

(annually)

Improve riparian and wetland function by:

• Restoring floodplain connections, channel 

morphology, channel structure, and flow 

regime (flood flows and low flows) (stream 

miles) (WR1)

55 miles 60 miles 50 miles 80 miles 75 miles

• Restoring riparian/wetland species 

composition (riparian acres) by increasing 

natural seedling establishment, planting, 

fencing, or modifying riparian management 

(riparian acres) (WR2)

200 acres 300 acres 200 acres 300 acres 275 acres

 

3 All measures are proposed in priority watersheds.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

43

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

• Increasing effective stream shade (WQ 

objective 1) by increasing amount and extent 

of woody riparian species and increasing ageclass structure of terrestrial vegetation in MA 

4B 

(stream miles) (WR3)

300 miles 600 miles 300 miles 450 miles 400 miles

Improve riparian and wetland function by 

(continued):

• Increasing extent and vegetative species 

diversity of off-channel and isolated wetlands 

by restoring hydrologic pathways, modifying 

existing water diversions, or fencing (number 

of sites) (WR4)

20 sites 30 sites 30 sites 30 sites 30 sites

• Increasing the number and extent of beavercreated wetlands (sites)

10 sites 15 sites 10 sites 12 sites 10 sites

Improve stream channel and aquatic habitat 

function by:

• Improving riparian habitat conditions (riparian 

acres, WR1-3)

400 acres

(annually)

900 acres

(annually)

900 acres

(annually)

600 acres

(annually)

570 acres

(annually)

• Restoring channel morphology to reflect 

natural conditions (miles)

25 miles 40 miles 25 miles 38 miles 35 miles

• Increasing habitat complexity through channel 

reconstruction, placement of large wood or 

other structures, habitat enhancement (miles)

50 miles 170 miles 50 miles 75 miles 70 miles

• Increasing aquatic habitat connectivity 

through culvert replacement (number of 

culverts)

60 culverts

90 stream miles

100 culverts

125 stream miles

60 culverts

95 stream miles

90 culverts

143 stream miles

80 culverts

140 stream 

miles
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

44

1.2 Species Diversity

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

In cooperation with state wildlife agencies, 

expand bull trout occurrence within 10 years 

into unoccupied suitable stream segments 

within its historic range. 

1 segment 2 segments 0 segments 1 segment 1 segment

Increase the amount and quality of source 

habitat (open, OFSS in the dry upland forest 

potential vegetation group) for white-headed

woodpecker (per decade).

31,000 acres 26,000 acres 58,000 acres 64,000 acres 32,000 acres

Increase the amount and quality of source 

habitat (open canopy dry/moist upland forest 

potential vegetation group) for western 

bluebird and Cassin’s finch.

43,000 acres 

(finch)

27,000 acres 

(finch)

69,000 acres (finch)

11,000 acres 

(bluebird)

49,000 acres (finch) 37,000 acres 

(finch)

Maintain mule deer security cover on a 

percentage of the landscape within MA 4A.

26% of landscape 28% of landscape 24% of landscape 24% of landscape 26% of 

landscape

Restore stronghold watersheds connectivity 

for aquatic species.

6-10 

subwatersheds

or 120-200 

stream miles

8-12 

subwatersheds or 

160-240 stream 

miles

3-5 subwatersheds or 

60-100 stream miles

4-6 subwatersheds or 

80-120 stream miles

4-6 

subwatersheds 

or 80-120 

stream miles

Reduce juniper canopy cover to less than 10 

percent in sagebrush steppe habitat.

NA NA NA 800 acres 800 acres

Reduce sagebrush density to less than 10 

percent canopy cover in sagebrush steppe 

habitats where sagebrush canopy cover is 

greater than 25 percent.

NA NA NA 700 acres 700 acres

In nesting habitat, retrofit existing tall 

structures (e.g., power poles, communication 

tower sites) with perch deterrents or other 

anti-perching devices within 2 years of 

signing the record of decision (ROD). 

NA NA NA Alt E: NA

Alts. E-Mod & E-Mod. 

Dep:

All tall structures

NA
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

45

1.4 Disturbance Processes

1.4.1 Wildland Fire (planned and unplanned ignitions)

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Treat stands using silvicultural treatments and/or 

prescribed burning (planned ignition) to move 

towards Fire Regime Condition Class 1 and 2 in 

the dry and moist upland forest potential 

vegetation groups (per decade). 

166,000 acres 129,000 acres 205,000 acres Alt. E: 220,000 acres

Alts. E-Mod & E-Mod. 

Dep:

240,000 acres

178,000 acres

Treat stands using silvicultural treatments and/or 

prescribed burning (planned ignition) to decrease 

the potential for high severity wildfire in the dry 

upland forest potential vegetation group (per 

decade).

150,000 acres 115,000 acres 180,000 acres 185,000 acres 155,000 acres

Manage wildfire (unplanned ignition) for resource 

benefits: modify species composition, stand 

density, structural stages, fire frequency, and fire 

severity to move Fire Regime Condition Class 2 

and 3 to Fire Regime Condition Class 1 and 2 

(per decade). 

NA 86,000 acres NA Alt. E: 39,000 acres 

Alts. E-Mod & E-Mod. 

Dep:

64,000 acres

39,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

46

1.4.2 Insects and Diseases

Objective Statements for the Malheur National 

Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Within the dry upland forest potential vegetation 

group, treat stands with moderate to high 

susceptibility ratings using silvicultural treatments 

and/or wildland fire to decrease insect and 

disease susceptibility to low or moderate (per 

decade).

170,000 acres 130,000 acres 230,000 acres Alt. E: 225,000 acres

Alts. E-Mod & E-Mod. 

Dep:

243,000 acres

180,000 acres

Within the moist upland forest potential vegetation 

group, treat stands with moderate to high 

susceptibility ratings using silvicultural treatments

and/or wildland fire to decrease insect and 

disease susceptibility to low or moderate (per 

decade).

20,000 acres 15,000 acres 25,000 acres Alt. E: 25,000 acres

Alts. E-Mod & E-Mod. 

Dep:

7,000 acres

20,000 acres

1.5 Invasive Species

Objective Statements for the Malheur National 

Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Reduce current infestations of invasive plant 

species. 

1,500 acres 1,500 acres 3,000 acres 1,500 acres 1,500 acres

1.6 Structural Stages

Objective Statements for the Malheur National 

Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Decrease mid-age multi-story forest (UR stage) in 

the dry and moist upland forest potential 

vegetation groups by continuing to manage 

towards a large diameter (old forest) condition 

(per decade).

130,000 acres 100,000 acres 160,000 acres Alt. E: 180,000 acres

Alts E-Mod & E-Mod. 

Dep:

223,000 acres

140,000 acres

Increase OFSS (open canopy) in the dry upland 

forest potential vegetation group by converting 

OFMS to OFSS (per decade).

8,000 acres 1,500 acres 48,000 acres Alt. E: 16,000 acres

Alts. E-Mod & E-Mod. 

Dep:

16,000 acres

10,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

47

1.7 Plant Species Composition

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Increase shade intolerant stands in the dry 

upland forest potential vegetation group (per 

decade).

170,000 acres 130,000 acres 230,000 acres Alt. E: 225,000 acres

Alts. E-Mod & E-Mod. 

Dep:

237,000 acres

180,000 acres

Manage rangeland vegetation to improve 

phases C and D to phase A or B. 

NA NA NA Alt. E: 7,000 acres

Alts. E-Mod & E-Mod. 

Dep:

20,560 acres

7,000 acres

1.8 Stand Density

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Reduce the dry and moist upland forest 

potential vegetation groups that are in the 

closed stand density class (per decade).

166,000 acres 129,000 acres 205,000 acres Alt. E: 220,000 acres

Alts. E-Mod & E-Mod. 

Dep: 

77,000 acres

178,000 acres

1.10 Soil Quality

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Implement erosion control and stabilization 

measures on unstable hillslopes. Possible 

activities include road realignment and 

improving forest vegetation conditions. 

200-400 acres 300-500 acres 150-250 acres 200-400 acres 180-350 acres

Restore soil function (also see objectives for 

1.1 Watershed Function).

150-300 acres 200-400 acres 75-150 acres 175-350 acres 150-300 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

48

1.11 Water Quality

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E, 

E-Modified & 

E-Modified Departure Alternative F

Improve water quality through 

implementation of water quality restoration 

plans. 

4-8 watersheds

160-320 stream 

miles

6-10 watersheds

240-400 stream 

miles

3-6 watersheds

120-240 stream 

miles

4-6 watersheds

160-240 stream miles

4-6 watersheds

120-220 stream 

miles

2.3.1 Rocky Mountain Elk

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Increase instances of elk occupancy and use 

of NFS lands by:

• moving towards vegetative desired 

conditions and objectives to promote a 

mosaic patchwork of hiding cover and 

forage; and 

• providing a continuum of effective elk 

security in strategic locations.

See objectives for vegetation (1.1, 1.4-1.8, 

and 1.12).

See objectives for 2.7.

NA NA NA Alt. E: NA 

Alts E-Mod & E-Mod. 

Departure: 

Within 7 years of plan 

approval, improve elk 

security to within 

Desired Condition range 

(30-100%) throughout 

50% of the priority 

subwatershed. 

Within 15 years of plan 

approval, improve elk 

security to within 

Desired Condition range 

(30-100%) throughout 

100% of the priority 

subwatershed.

Within the life of the 

plan, improve elk 

security to within 

Desired Condition range 

(30-100%) throughout 

50% of General Forest 

MA – 4A

NA
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

49

2.7 Roads and Trails Access

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Maintain the road system for safe and 

efficient travel and for the protection, 

management, and use of NFS lands. Where 

open motor vehicle route density exceeds 

desired conditions, implement route closures 

and/or decommissioning or consider 

designating routes for other uses 

(refer to 1.1 Watershed Function for road 

decommissioning/obliteration objectives).

Miles of road

maintenance: 

225 miles MLs 4/5

27 miles ML 3

900 miles ML 2

(annually)

Miles of road

maintenance: 

160 miles ML 4/5

11 miles ML 3

64 miles ML 2

(annually)

Miles of road

maintenance: 

280 miles MLs 4/5

44 miles ML 3

1,280 miles ML 2

(annually)

ALT E: Miles of road

maintenance: 

250 miles MLs 4/5

38 miles ML 3

1,025 miles ML 2

(annually)

Alts E-Mod & E-Mod. 

Dep: There are no 

objectives for road 

maintenance

Miles of road

maintenance: 

240 miles MLs 4/5

35 miles ML 3

1,000 miles ML 2

(annually)

3.3 Goods and Services

Objective Statements for the Malheur 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Contribute to local economies by harvesting 

sawlogs and timber volume other than 

sawlogs (TSPQ annually). 

45 MMBF 16 MMBF 141 MMBF Alt E: 83 MMBF

Alt. E-Modified:

84 MMBF

Alt. E-Mod. Dep.: 

134 MMBF

58 MMBF

Contribute to local economies by providing 

forage for cattle and sheep.

126,500 AUMs 

(annually)

62,200 AUMs 

(annually)

125,500 AUMs 

(annually)

Alt. E: 123,500 AUMs 

(annually)

Alts. E-Mod & E-Mod 

Dep.: 

133,500 AUMs

123,500 AUMs 

(annually)
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

50

Umatilla National Forest Objectives

Table A-25. Comparison of objectives for the plan revision alternatives for the Umatilla National Forest. The objectives are just a partial list of the 

management activities expected to be accomplished to contribute to maintaining or achieving desired conditions during the first decade of the plan 

period, unless otherwise indicated within the objective statement. 

1.1 Watershed Function4

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

(W1) Increase the number of watersheds in 

condition class 1 (from CC2) and 2 (from 

CC3). Measure: number of subwatersheds 

(HUC6) with improved condition class.

15 watersheds 20 watersheds 12 watersheds 14 watersheds 14 watersheds

Improve hydrologic function by:

• Improving forest vegetative conditions 

(acres) (WH1)

2,500 acres

(annually)

1,500 acres

(annually)

12,600 acres

(annually)

Alt. E: 6,600 acres

(annually)

Alts. E-Mod & E-Mod. 

Dep:

3,200 acres

3,700 acres

(annually)

• Improving soil hydrologic function in areas 

of detrimental soil disturbance (acres) 

(WH2)

500 acres 900 acres 450 acres 750 acres 700 acres

• Reducing road-related sedimentation by 

reducing road density and reducing 

hydrologic connectivity of the road system 

(road miles) (WH3)

25-30 miles road 

surface treated

(annually)

45-75 miles road 

surface treated

(annually)

50-80 miles road 

surface treated

(annually)

30-35 miles road 

surface treated

(annually)

30-35 miles road 

surface treated

(annually)

Improve riparian and wetland function by:

• Restoring floodplain connections, channel 

morphology, channel structure, and flow 

regime (flood flows and low flows) 

(stream miles) (WR1)

60 miles 70 miles 55 miles 90 miles 85 miles

• Restoring riparian/wetland species 

composition (riparian acres) by increasing 

natural seedling establishment, planting, 

fencing, or modifying riparian 

management (riparian acres) (WR2)

110 acres 200 acres 110 acres 165 acres 150 acres

 

4 All measures are proposed in priority watersheds.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

51

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

• Increasing effective stream shade (WQ 

objective 1) by increasing amount and 

extent of woody riparian species and 

increasing age-class structure of 

terrestrial vegetation in MA 4B 

(stream miles) (WR3)

150 miles 300 miles 150 225 miles 210 miles

• Increasing extent and vegetative species 

diversity of off-channel and isolated 

wetlands by restoring hydrologic 

pathways, modifying existing water 

diversions, or fencing (number of sites) 

(WR4)

25 sites 35 sites 35 sites 40 sites 35 sites

• Increasing the number and extent of 

beaver-created wetlands (sites)

8 sites 15 sites 8 sites 10 sites 9 sites

Improve stream channel and aquatic habitat 

function by:

• Improving riparian habitat conditions 

(riparian acres, WR1-3)

350 acres

(annually)

800 acres

(annually)

600 acres

(annually)

525 acres

(annually)

500 acres

(annually)

• Restoring channel morphology to reflect 

natural conditions (miles)

30 miles 55 miles 30 miles 45 miles 40 miles

• Increasing habitat complexity through 

channel reconstruction, placement of 

large wood or other structures, habitat 

enhancement (miles)

60 miles 200 miles 60 miles 90 miles 85 miles

• Increasing aquatic habitat connectivity 

through culvert replacement (number of 

culverts)

50 culverts

45 stream miles

75 culverts

60 stream miles

50 culverts

45 stream miles

75 culverts

68 stream miles

70 culverts

60 stream miles

1.2 Species Diversity

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

In cooperation with state wildlife agencies, 

expand bull trout occurrence within 10 years 

into unoccupied suitable stream segments 

within its historic range. 

1 segment 2 segments 0 segments 1 segment 1 segment
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

52

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Increase the amount and quality of source 

habitat (open, OFSS single story LOS in the 

dry upland forest potential vegetation group) 

for white-headed woodpecker (per decade).

9,000 acres 8,000 acres 16,000 acres 12,000 acres 10,000 acres

Increase the amount and quality of source 

habitat (open canopy dry/moist upland forest 

potential vegetation group) for western 

bluebird and Cassin’s finch.

44,000 acres 

(bluebird)

28,000 acres 

(bluebird)

91,000 acres 

(bluebird)

78,000 acres 

(bluebird)

53,000 acres 

(bluebird)

Maintain mule deer security cover on a 

percentage of the landscape within MA 4A. 

33% 33% 28% Alt. E: 29%

Alts. E-Mod. and EMod. Dep.:

N/A

32%

Restore stronghold watersheds connectivity 

for aquatic species.

5-9 subwatersheds 

or 100-180 stream 

miles

8-10 

subwatersheds or 

160-200 stream 

miles

4-6 subwatersheds 

or 80-120 stream 

miles

3-5 subwatersheds or 

60-100 stream miles

3-5 subwatersheds 

or 60-100 stream 

miles

Develop and Implement habitat management 

plans for Spalding’s catchfly key 

conservation areas. 

NA NA NA Alt E: N/A

Alts. E-Mod. and EMod. Dep.:

Lick Creek key 

conservation area 

(aka Blue Mountain 

Foothills KCA)

NA

1.4 Disturbance Processes

1.4.1 Wildland Fire (planned and unplanned ignitions)

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Treat stands using silvicultural treatments 

and prescribed burning (planned ignition) to 

move towards Fire Regime Condition Class 

1 and 2 in the dry and moist upland forest 

potential vegetation groups (per decade).

170,000 acres 140,000 acres 200,000 acres Alt. E: 220,000 acres

Alts. E-Mod. and EMod. Dep.:

135,000 acres

180,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

53

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Treat stands using silvicultural treatments 

and prescribed burning (planned ignition) to 

decrease the potential for high severity 

wildfire in the dry upland forest potential 

vegetation group (per decade). 

95,000 acres 80,000 acres 110,000 acres Alt. E: 125,000 acres

Alts. E-Mod. and EMod. Dep.:

N/A

100,000 acres

Manage wildfire (unplanned ignition) for 

resource benefits: modify species 

composition, stand density, structural stages, 

fire frequency, and fire severity to move Fire 

Regime Condition Classes 2 and 3 to Fire 

Regime Condition Classes 1 and 2 (per 

decade). 

NA 52,000 acres NA Alt. E: 37,000 acres

Alts. E-Mod. and EMod. Dep.:

45,000 acres

35,000 acres

1.4.2 Insects and Diseases 

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Within the dry upland forest potential 

vegetation group, treat stands with moderate 

to high susceptibility ratings using 

silvicultural treatments and/or wildland fire to 

decrease insect and disease susceptibility to 

low or moderate (per decade).

120,000 acres 100,000 acres 140,000 acres Alt. E:155,000 acres

Alts. E-Mod. and EMod. Dep.:

124,000 acres

125,000 acres

Within the moist upland forest potential 

vegetation group, treat stands with moderate 

to high susceptibility ratings using 

silvicultural treatments and/or wildland fire to 

decrease insect and disease susceptibility to 

low or moderate (per decade).

40,000 acres 35,000 acres 50,000 acres Alt. E:55,000 acres

Alts. E-Mod. and EMod. Dep.:

23,000 acres

45,000 acres

1.5 Invasive Species

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Reduce current infestations of invasive plant 

species. 

7,000 acres 7,000 acres 15,000 acres 7,000 acres 7,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

54

1.6 Structural Stages

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Decrease mid-age multi-story forest (UR 

stage) in the dry and moist upland forest 

potential vegetation groups by continuing to 

manage towards a large diameter (old forest) 

condition (per decade).

140,000 acres 110,000 acres 160,000 acres Alt E: 175,000 acres

Alts. E-Mod. and EMod. Dep.:

118,000 acres

145,000 acres

Increase the OFSS (open canopy) stage in 

the dry upland forest potential vegetation 

group by converting OFMS to OFSS (per 

decade). 

2,500 acres 0 acres 17,000 acres Alt E: 6,000 acres

Alts. E-Mod. and EMod. Dep.:

5,000 acres

3,000 acres

1.7 Plant Species Composition

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Increase shade intolerant stands in the dry 

upland forest potential vegetation group (per 

decade).

120,000 acres 100,000 acres 140,000 acres Alt E: 155,000 acres

Alts. E-Mod. and EMod. Dep.:

123,000 acres

125,000 acres

Manage rangeland vegetation to improve 

phases C and D to phase A or B. 

NA NA NA Alt E: 6,000 acres

Alts. E-Mod. and EMod. Dep.:

8,790 acres

6,000 acres

1.8 Stand Density

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Reduce the dry and moist upland forest 

potential vegetation groups that are in the 

closed stand density class (per decade).

170,000 acres 140,000 acres 200,000 acres Alt E: 220,000 acres

Alts. E-Mod. and EMod. Dep.:

56,000 acres

180,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

55

1.10 Soil Quality

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Implement erosion control and stabilization 

measures on unstable hillslopes. Possible 

activities include road realignment and 

improving forest vegetation conditions. 

200-400 acres 300-500 acres 150-250 acres 200-400 acres 200-360 acres

Restore soil function (also see objectives for 

1.1 Watershed Function).

150-300 acres 200-400 acres 75-150 acres 175-350 acres 160-320 acres

1.11 Water Quality

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Improve water quality through 

implementation of water quality restoration 

plans. 

5-7 watersheds

200-280 stream 

miles

6-10 watersheds 

240-400 stream 

miles

4-6 watersheds

160-240 stream 

miles

5-7 watersheds

200-280 stream miles

5-7 watersheds

200-280 stream 

miles

2.3.1 Rocky Mountain Elk

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified & 

E-Modified Departure Alternative F

Increase instances of elk occupancy and use 

of NFS lands by:

• moving towards vegetative desired 

conditions and objectives to promote a 

mosaic patchwork of hiding cover and 

forage; and 

• providing a continuum of effective elk 

security in strategic locations.

See objectives for vegetation (1.1, 1.4-1.8, 

and 1.12).

See objectives for 2.7.

N/A N/A N/A Alt E: N/A

Alts. E-Modified and E-Modified 

Departure: Within 7 years of plan 

approval, improve elk security to within 

Desired Condition range (30-100%) 

throughout 50% of the priority 

subwatershed. 

Within 15 years of plan approval, 

improve elk security to within Desired 

Condition range (30-100%) throughout 

100% of the priority subwatershed.

Within the life of the plan, improve elk 

security to within Desired Condition 

range (30-100%) throughout 50% of 

General Forest MA 4A

N/A
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

56

2.7 Roads and Trails Access

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Maintain the road system for safe and 

efficient travel and for the protection, 

management, and use of NFS lands. Where 

open motor vehicle route density exceeds 

desired conditions, implement route closures 

and/or decommissioning or consider 

designating routes for other uses 

(refer to 1.1 Watershed Function for road 

decommissioning/obliteration objectives).

Miles of road 

maintenance:

158 miles MLs 4/5

159 miles ML 3

110 miles ML 2

(annually)

Miles of road 

maintenance:

100 miles MLs 4/5

79 miles ML 3

30 miles ML 2

(annually)

Miles of road 

maintenance:

210 miles ML 4/5

300 miles ML 3

400 miles ML 2

(annually)

Miles of road 

maintenance:

200 miles ML 4/5

200 miles ML 3

140 miles ML 2

(annually)

Miles of road 

maintenance:

158 miles MLs 4/5

159 miles ML 3

110 miles ML 2

(annually)

3.3 Goods and Services

Objective Statements for the Umatilla 

National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Contribute to local economies by harvesting 

sawlogs and timber volume other than 

sawlogs (TSPQ annually). 

29 MMBF 16 MMBF 76 MMBF Alt E: 57 MMBF

Alt E-Mod.: 

56 MMBF

Alt E-Mod. Dep.: 94 

MMBF

36 MMBF

Contribute to local economies by providing 

forage for cattle and sheep.

35,600 AUMs 

annually

4200 AUMs 

annually

35,800 AUMs 

annually

Alt E: 35,800 AUMs 

annually

Alts. E-Mod. and E-Mod. 

Dep.: 49,200 AUMs 

annually

35,800 AUMs 

annually
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

57

Wallowa-Whitman National Forest Objectives

Table A-26. Comparison of objectives for the plan revision alternatives for the Wallowa-Whitman National Forest. The objectives are just a partial list of 

the management activities expected to be accomplished to contribute to maintaining or achieving desired conditions during the first decade of the plan 

period, unless otherwise indicated within the objective statement.

1.1 Watershed Function5

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F 

(W1) Increase the number of watersheds in 

condition class 1 (from CC2) and 2 (from 

CC3) through active restoration. Measure: 

number of subwatersheds (HUC6) with 

improved condition class.

24 watersheds 30 watersheds 24 watersheds 24 watersheds 24 watersheds

Improve hydrologic function by:

• Improving forest vegetative conditions 

(acres) (WH1)

3,500 acres

(annually)

2,100 acres

(annually)

17,700 acres

(annually)

Alt E: 7,300 acres

(annually)

Alts. E-Mod. and EMod. Dep.: 5,000 

acres

4,600 acres

(annually)

• Improving soil hydrologic function in areas 

of detrimental soil disturbance (acres) 

(WH2)

650 acres 1,200 acres 600 acres 950 acres 850 acres

• Reducing road-related sedimentation by 

reducing road density and reducing 

hydrologic connectivity of the road system 

(road miles) (WH3)

25-30 miles road 

surface treated

(annually)

45-75 miles road 

surface treated

(annually)

50-80 miles road 

surface treated

(annually)

30-35 miles road 

surface treated

(annually)

30-35 miles road 

surface treated

(annually)

Improve riparian and wetland function by:

• Restoring floodplain connections, channel 

morphology, channel structure, and flow 

regime (flood flows and low flows) 

(stream miles) (WR1)

60 miles 70 miles 55 miles 90 miles 80 miles

• Restoring riparian/wetland species 

composition (riparian acres) by increasing 

natural seedling establishment, planting, 

fencing, or modifying riparian 

management (riparian acres) (WR2)

150 acres 250 acres 150 acres 225 acres 210 acres

 

5 All measures are proposed in priority watersheds.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

58

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

• Increasing effective stream shade (WQ 

objective 1) by increasing amount and 

extent of woody riparian species and 

increasing age-class structure of 

terrestrial vegetation in MA 4B 

(stream miles) (WR3)

250 miles 500 miles 250 miles 375 miles 350 miles

• Increasing extent and vegetative species 

diversity of off-channel and isolated 

wetlands by restoring hydrologic 

pathways, modifying existing water 

diversions, or fencing (number of sites) 

(WR4)

25 sites 35 sites 35 sites 40 sites 35 sites

• Increasing the number and extent of 

beaver-created wetlands (sites)

10 sites 20 sites 10 sites 12 sites 12 sites

Improve stream channel and aquatic habitat 

function by:

• Improving riparian habitat conditions 

(riparian acres, WR1-3)

450 acres

(annually)

1,000 acres

(annually)

800 acres

(annually)

675 acres

(annually)

600 acres

(annually)

• Restoring channel morphology to reflect 

natural conditions (miles)

40 miles 60 miles 40 miles 60 miles 50 miles

• Increasing habitat complexity through 

channel reconstruction, placement of 

large wood or other structures, habitat 

enhancement (miles)

75 miles 230 miles 75 miles 113 miles 100 miles

• Increasing aquatic habitat connectivity 

through culvert replacement (number of 

culverts)

60 culverts

90 stream miles

90 culverts

120 stream miles

60 culverts

90 stream miles

90 culverts

135 stream miles

80 culverts

120 stream miles
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

59

1.2 Species Diversity

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

In cooperation with state wildlife agencies, 

expand bull trout occurrence within 10 years 

into unoccupied suitable stream segments 

within its historic range. 

1 segment 2 segments 0 segments 1 segment 1 segment

Increase the amount and quality of source 

habitat (open, OFSS in the dry upland forest 

potential vegetation group) for white-headed

woodpecker (per decade).

8,000 acres 7,000 acres 19,000 acres 11,000 acres 9,000 acres

Increase the amount and quality of source 

habitat (open canopy dry/moist upland forest 

potential vegetation group) for western 

bluebird and Cassin’s finch.

41,000 acres 

(bluebird)

22,000 acres 

(bluebird)

85,000 acres 

(bluebird)

25,000 acres 

(finch)

66,000 acres 

(bluebird)

12,000 acres (finch)

44,000 acres 

(bluebird)

3,000 acres (finch)

Maintain Rocky Mountain elk security cover 

on a percentage of the landscape within MA 

4A. 

36% 36% 32% 33% 35%

Restore stronghold watersheds connectivity 

for aquatic species.

6-10 

subwatersheds or 

120-200 stream 

miles

8-12 

subwatersheds or 

160-240 stream 

miles

5-8 subwatersheds 

or 100-160 stream 

miles

6-9 subwatersheds or 

120-180 stream miles

6-9 subwatersheds 

or 120-180 stream 

miles

Develop and implement habitat management 

plans for Spalding’s catchfly key 

conservation areas.

N/A N/A N/A Alt. E: N/A 

Alts. E-Mod. and 

E-Mod. Dep.: Lower 

Imnaha, Crow Creek, 

and Clear Lake Ridge 

Key conservation 

areas

N/A 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

60

1.4 Disturbance Processes

1.4.1 Wildland Fire (planned and unplanned ignitions)

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Treat stands using silvicultural treatments 

and prescribed burning (planned ignition) to 

move towards Fire Regime Condition Class 

1 and 2 in the dry and moist upland forest 

potential vegetation groups.

170,000 acres 155,000 acres 215,000 acres Alt. E: 220,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 180,000 

acres

190,000 acres

Treat stands using silvicultural treatments 

and prescribed burning (planned ignition) to 

decrease the potential for high severity 

wildfire in the dry upland forest potential 

vegetation group. 

110,000 acres 100,000 acres 140,000 acres Alt. E: 140,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: N/A

120,000 acres

Manage wildfire (unplanned ignition) for 

resource benefits: modify species 

composition, stand density, structural stages, 

fire frequency, and fire severity to move Fire 

Regime Condition Class 2 and 3 to Fire 

Regime Condition Class 1 and 2.

N/A 78,000 acres N/A Alt. E: 64,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 50,000 

acres

76,000 acres

1.4.2 Insects and Disease

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Within the dry upland forest potential 

vegetation group, treat stands with moderate 

to high susceptibility ratings using 

silvicultural treatments and/or wildland fire to 

decrease insect and disease susceptibility to 

low or moderate.

135,000 acres 125,000 acres 170,000 acres Alt. E: 170,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 155,000 

acres

150,000 acres

Within the moist upland forest potential 

vegetation group, treat stands with moderate 

to high susceptibility ratings using 

silvicultural treatments and/or wildland fire to 

decrease insect and disease susceptibility to 

low or moderate.

25,000 acres 23,000 acres 30,000 acres 35,000 acres 30,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

61

1.5 Invasive Species

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Reduce current infestations of invasive plant 

species. 

7,000 acres 7,000 acres 15,000 acres 7,000 acres 7,000 acres

1.6 Structural Stages

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Decrease mid-age multi-story forest (UR 

stage) in the dry and moist upland forest 

potential vegetation groups by continuing to 

manage towards a large diameter (old forest) 

condition.

135,000 acres 125,000 acres 170,000 acres Alt. E: 170,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 158,000 

acres

150,000 acres

Increase OFSS (open canopy) in the dry 

upland forest potential vegetation group by 

converting OFMS to OFSS.

2,000 acres 0 acres 20,000 acres Alt. E: 5,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 10,000 

acres

3,500 acres

1.7 Plant Species Composition

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Increase shade intolerant stands in the dry 

upland forest potential vegetation group. 

135,000 acres 125,000 acres 170,000 acres Alt. E: 170,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 154,000 

acres

150,000 acres

Manage rangeland vegetation to improve 

phases C and D to phase A or B. 

NA NA NA Alt. E: 10,000 acres

Alts. E-Mod. and 

E-Mod. Dep.: 12,405 

acres

10,000 acres
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

62

1.8 Stand Density

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Reduce the dry and moist upland forest 

potential vegetation groups that are in the 

closed stand density class. 

170,000 acres 155,000 acres 215,000 acres Alt. E: 220,000 acres

Alts. E-Mod. and 

E-Mod. Dep.:74,000 

acres

190,000 acres

1.10 Soil Quality

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Implement erosion control and stabilization 

measures on unstable hillslopes. Possible 

activities include road realignment and 

improving forest vegetation conditions. 

200-400 acres 200-400 acres 300-500 acres 150-250 acres 200-400 acres

Restore soil function (also see objectives for 

1.1 Watershed Function).

150-300 acres 150-300 acres 200-400 acres 75-150 acres 175-350 acres

1.11 Water Quality

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Improve water quality through 

implementation of water quality restoration 

plans. 

8-10 watersheds 

320-400 stream 

miles

12-14 watersheds 

480-560 stream 

miles

4-6 watersheds 

160-240 stream 

miles

5-7 watersheds 

200-280 stream miles

5-7 watersheds 

200-280 stream 

miles
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

63

2.3.1 Rocky Mountain Elk

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Increase instances of elk occupancy and use 

of NFS lands by:

• moving towards vegetative desired 

conditions and objectives to promote a 

mosaic patchwork of hiding cover and 

forage; and 

• providing a continuum of effective elk 

security in strategic locations.

See objectives for vegetation (1.1, 1.4-1.8, 

and 1.12).

See objectives for 2.7.

N/A N/A N/A Alt E: N/A

Alts. E-Modified and EModified Departure

Within 7 years of plan 

approval, improve elk 

security to within Desired 

Condition range (30-

100%) throughout 50% 

of the priority 

subwatershed. 

Within 15 years of plan 

approval, improve elk 

security to within Desired 

Condition range (30-

100%) throughout 100% 

of the priority 

subwatershed.

Within the life of the plan, 

improve elk security to 

within Desired Condition 

range (30-100%) 

throughout 50% of 

General Forest MA – 4A

N/A

2.7 Roads and Trails Access

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Maintain the road system for safe and 

efficient travel and for the protection, 

management, and use of NFS lands. Where 

open motor vehicle route density exceeds 

desired conditions, implement route closures 

and/or decommissioning or consider 

designating routes for other uses 

(refer to 1.1 Watershed Function for road 

decommissioning/obliteration objectives).

Miles of road 

maintenance:

79 miles MLs 4/5

147 miles ML 3

218 miles ML 2

(annually)

Miles of road 

maintenance:

75 miles MLs 4/5

79 miles ML 3

50 miles ML 2

(annually)

Miles of road 

maintenance:

100 miles MLs 4/5

200 miles ML 3

400 miles ML 2

(annually)

Miles of road 

maintenance:

90 miles MLs 4/5

170 miles ML 3

150 miles ML 2

(annually)

Miles of road 

maintenance:

95 miles MLs 4/5

160 miles ML 3

218 miles ML 2

(annually)
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

64

3.3 Goods and Services

Objective Statements for the WallowaWhitman National Forest Alternative B Alternative C Alternative D

Alternatives E,

E-Modified &

E-Modified Departure Alternative F

Contribute to local economies by harvesting 

sawlogs and timber volume other than 

sawlogs (TSPQ annually). 

57 MMBF 30 MMBF 104 MMBF Alt E: 63 MMBF

Alt. E-Mod.: 

65 MMBF

E-Mod. Dep.: 

98 MMBF

41 MMBF

Contribute to local economies by providing 

forage for cattle and sheep.

77,500 AUMs 

(annually) 

29,500 AUMs 

(annually) 

84,500 AUMs 

(annually) 

Alt. E: 80,500 AUMs 

(annually)

Alt. E-Mod. & E-Mod. 

Dep.: 

112,000 AUMs 

(annually) 

80,500 AUMs 

(annually) 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

65

Table A-27. Malheur National Forest anticipated annual accomplishments for the plan revision alternatives (as related to objectives)

Activity Unit of 

Measure Alternative B Alternative C Alternative D Alternative E Alternative F

Acres Suitable for Timber Production acres 770,000 530,000 1,080,000 770,000 770,000

Predicted Harvest Level (TSPQ) MMBF 31 16 87 56 37

ASQ MMBF 55 34 88 55 55

Timber Harvest (includes the following two rows)

Even-aged regeneration harvest acres 1,500 800 3,300 2,900 1,800

Uneven-aged and intermediate harvest acres 5,600 2,600 17,200 9,600 6,500

Total Timber Harvest acres 7,100 3,400 20,500 12,500 8,300

Planting acres 700 400 1,600 1,400 900

Precommercial thinning acres 1,400 1,000 3,000 1,400 1,400

Prescribed burning (planned ignition) and mechanical 

treatment of fuels (within and outside harvest units)

acres 16,600 12,900 20,500 22,000 17,800

Suppress invasive plants acres 1,500 1,500 3,000 1,500 1,500

Cattle and sheep grazing AUMs 126,500 62,200 125,500 123,500 123,500

Table A-28. Umatilla National Forest anticipated annual accomplishments for the plan revision alternatives (as related to objectives)

Activity Unit of 

Measure Alternative B Alternative C Alternative D Alternative E Alternative F

Acres Suitable for Timber Production acres 420,000 260,000 610,000 420,000 420,000

Predicted Harvest Level (TSPQ) MMBF 29 16 76 56 36

ASQ MMBF 51 31 73 51 51

Timber Harvest (includes the following two rows)

Even-aged regeneration harvest acres 1,200 500 2,600 2,400 1,500

Uneven-aged and intermediate harvest acres 4,000 1,800 13,000 8,200 4,900

Total Timber Harvest acres 5,200 2,300 15,600 10,600 6,400

Planting acres 600 200 1,300 1,200 700

Precommercial thinning acres 1,600 1,500 3,200 1,600 1,600

Prescribed burning (planned ignition) and mechanical 

treatment of fuels (within and outside harvest units)

acres 19,100 12,300 16,000 20,600 16,400

Suppress invasive plants acres 1,500 1,500 3,000 1,500 1,500

Cattle and sheep grazing AUMs 35,600 4,200 35,800 35,800 35,800
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

66

Table A-29. Wallowa-Whitman National Forest anticipated annual accomplishments for the plan revision alternatives (as related to objectives)

Activity Unit of 

Measure

Alternative B Alternative C Alternative D Alternative E Alternative F

Acres Suitable for Timber Production acres 530,000 310,000 770,000 530,000 530,000

Predicted Harvest Level (TSPQ) MMBF 27 15 80 50 34

ASQ MMBF 46 22 75 46 46

Timber Harvest (includes the following two rows)

Even-aged regeneration harvest acres 1,000 500 2,500 2,000 1,400

Uneven-aged and intermediate harvest acres 3,550 1,550 13,750 7,350 4,650

Total Timber Harvest acres 4,550 2,050 16,250 9,350 6,050

Planting acres 500 200 1,200 1,000 700

Precommercial thinning acres 2,600 1,700 5,200 2,600 2,600

Prescribed burning (planned ignition) and mechanical 

treatment of fuels (within and outside harvest units)

acres 15,050 12,550 17,000 19,850 16,550

Suppress invasive plants acres 3,500 3,500 3,500 3,500 3,500

Cattle and sheep grazing AUMs 109,000 29,500 84,500 80,500 80,500
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

67

Standards and Guidelines (Plan Revision Alternatives) 

The vast majority of the standards and guidelines included in the 

proposed action published for the scoping period remain as part of 

alternative B, the modified proposed action. Changes and additions 

are noted in the following tables and are proposed to help emphasize 

the different ways that the plan revision alternatives respond to the 

purpose and need and to the significant issues. 

Forestwide Standards and Guidelines

Standards and guidelines are organized by resource or management 

action and apply to all three National Forests, except where 

specifically noted in the table. 

Table A-30. Comparison of forestwide standards and guidelines for the plan revision alternatives for each national forest

1.1 Watershed Functions

Standard or 

Guideline 

Designator Alternative B Alternatives C, D, E, and F Alternatives E-Modified and E-Modified Departure 

KW-1S 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 road-related risk 

to watershed condition. 

Priority should be given to 

roads that pose the greatest 

relative ecological risks to

riparian and aquatic 

ecosystems. 

This alternative retains the 

Alternative B management

direction.

Standard6

In Key Watersheds or subwatersheds with the Endangered Species Act

critical habitat for aquatic species or subwatersheds containing listed 

aquatic species that are functioning properly there shall be no net increase 

(1 mile of road-related risk reduction for every new mile of road 

construction), where they are functioning-at-risk, there shall be a net 

decrease (1.5 miles of road-related risk reduction for every new mile of road 

construction), and where they are impaired function, there shall be a net 

decrease (2.0 miles of road-related risk reduction for every new mile of road 

construction) in system roads that affect hydrologic function. Priority for 

road-related risk reduction shall be given to roads that pose the greatest 

relative ecological risks to riparian and aquatic ecosystems. Road-related 

risk reduction will occur prior to new road construction unless logistical 

restrictions require post-construction risk reduction. This standard shall 

apply to the affected subwatershed when new system road construction is 

proposed in that subwatershed, and shall not be offset by reductions in 

open-road densities in other subwatersheds.

 

6 “Functioning properly”, “functioning-at-risk”, and “impaired function” for the roads and trails indicator of Watershed Condition Framework are defined in Watershed Condition 

Framework Technical Guide, USDA Forest Service, 2011b. Local inventory, assessment and monitoring data and information can be used to refine initial classifications made 

per the Framework. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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68

Standard or 

Guideline 

Designator Alternative B Alternatives C, D, E, and F Alternatives E-Modified and E-Modified Departure

KW-2S 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. 

This alternative retains the 

alternative B management

direction.

Standard 

In Key Watersheds and subwatersheds with the Endangered Species Act

critical habitat for aquatic species or subwatersheds containing listed 

aquatic species, 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.

KW-3S 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. 

This alternative retains the 

alternative B management 

direction.

Standard

In Key Watersheds and in subwatersheds with the Endangered Species Act

critical habitat for aquatic species or subwatersheds containing listed 

aquatic species, 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.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

69

Standard or 

Guideline 

Designator Alternative B Alternative C and D Alternatives E and F Alternatives E-Modified and E-Modified Departure

WM-1S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding 

standard or guideline.

This alternative has no 

corresponding standard 

or guideline.

Standard

When watershed function7 desired conditions are being 

achieved and watersheds are functioning properly8, projects 

shall maintain9 those conditions. When watershed function 

desired conditions are not yet achieved or watersheds have 

impaired function or are functioning-at-risk and to the 

degree that project activities would contribute to those 

conditions, projects shall restore10 or not retard11 attainment 

of desired conditions. Short-term adverse effects12 from 

project activities may occur when they support or do not 

diminish long-term recovery13 of watershed function desired 

conditions and federally listed species. Exceptions to this 

standard include situations where Forest Service authorities 

are limited (Alaska National Interest Lands Conservation Act 

[ANILCA], 1872 Mining law, valid state water right, etc.). In 

those cases, project effects shall be minimized and not 

retard attainment of desired conditions to the extent possible 

within Forest Service authorities. Use ARCS Attachment 2 

to assist in determining compliance with this standard.

WM-2S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding 

standard or guideline.

This alternative has no 

corresponding standard 

or guideline.

Standard

All projects shall be implemented in accordance with Best 

Management Practices, as described in National and 

Regional Technical Guides.

 

7 Per Revised Forest Plan Watershed Function desired conditions (watershed function, hydrologic, riparian, wetland, stream channel, groundwater dependent ecosystem, and 

aquatic habitat).

8 The Watershed Condition Framework categories of terminology for “functioning properly”, “functioning-at-risk”, and impaired function are equivalent to the “functioning 

appropriately” “functioning-at-risk” and “functioning at unacceptable risk” categories within the matrix of pathways and indicators (USFWS 1998), and to the respectively 

equivalent to “properly functioning” or “at risk” or “not properly functioning” categories within the matrix of pathways and indicators used by NMFS (1996).

9 See glossary in the ARCS (Appendix A) for definitions of “maintain” and “degrade.”

10 See glossary in the ARCS (Appendix A) for definitions of “restore.” 11 See glossary in the ARCS (Appendix A) for definitions of “retard attainment.” 12 See glossary in the ARCS (Appendix A) for definition of “short-term adverse effects.” 13 See glossary in the ARCS (Appendix A) for definition of “long-term recovery.”
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

70

Standard or 

Guideline 

Designator Alternative B Alternative C and D Alternatives E and F Alternatives E-Modified and E-Modified Departure

RE-1G Guideline

Watershed restoration 

projects should be 

designed to maximize the 

use of natural ecological 

processes as a tool in 

meeting and maintaining 

restoration objectives. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Watershed restoration projects should be designed to utilize 

or emulate natural ecological processes to the extent 

practicable, for meeting and maintaining restoration 

objectives.

RE-2G Guideline

Watershed restoration 

projects should be 

designed to minimize the 

need for long-term 

maintenance. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

This alternative retains the alternative B management 

direction.

RE-3S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding 

standard or guideline.

This alternative has no 

corresponding standard 

or guideline.

Standard 

Except where Forest Service authorities are limited, 

mitigation or planned restoration shall not be used as a 

substitute for preventing long-term watershed or habitat 

degradation.

RE-4S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding 

standard or guideline.

Guideline

Hydrologic connectivity 

and sediment delivery 

from roads and trails 

should be minimized. 

This includes roads 

inside and outside of 

riparian management 

areas.

Standard

Hydrologic connectivity and sediment delivery from roads 

and trails shall be minimized. This includes roads, or road 

segments, whether inside and outside of riparian 

management areas, that deliver sediment to streams.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

71

1.2 Species Diversity

Late Old Structure Habitat

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

WLD-HAB-1 Guideline

Management activities that limit 

the ability of wildlife to disperse 

between patches of source 

habitat should be avoided; area 

and patch size of late old 

structure should be maintained or 

improved and road density within 

and between old forest patches 

should be maintained or reduced.

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 should be 

maintained or reduced.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

WLD-HAB-2 Guideline

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. 

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. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

WLD-HAB-3 Guideline

Riparian corridors connecting 

moist and cold old forest types 

should not be reduced. 

Standard

Riparian corridors connecting 

moist and cold old forest types 

shall be improved. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

WLD-HAB-4 This alternative has no 

corresponding standard or 

guideline.

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.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

72

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

WLD-HAB-5 This alternative has no 

corresponding standard or 

guideline.

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 and species composition 

across the landscape. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

SD-1G Guideline

To the extent practical, known 

cavity or nest trees should be 

preserved when conducting 

prescribed burning (planned 

ignition) activities, mechanical 

fuel treatments, and silvicultural 

treatments.

Standard

Known cavity or nest trees shall

be preserved when conducting 

prescribed burning (planned 

ignition) activities, mechanical 

fuel treatments, and silvicultural 

treatments.

This alternative retains the 

alternative B management 

direction.

Guideline

To the extent practical, known 

cavity or nest trees should be 

preserved when conducting 

prescribed (planned ignition) 

burning activities, mechanical fuel 

treatments, and silvicultural 

treatments to protect the integrity 

of the nest site.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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73

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E, and F

Alternative E-Modified and E-Modified 

Departure

SD-3G 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. 

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B .management 

direction

Guideline

With the exception of the removal of 

danger/hazard trees or fuel treatments within 

the WUI, when a need to harvest or destroy 

snags is identified as part of a silvicultural 

treatment, current conditions should be 

evaluated relative to the desired conditions 

tables for each snag size class (see Sec. 

1.15, Tables 15 & 16) and: 

•Treatments should be limited to the extent 

that they will not result in a desired sizedensity category becoming 

underrepresented relative to desired 

conditions.

• If an area is determined to be currently 

underrepresented in one or more of the 

desired size-density categories, snags 

should be retained within treatment units in 

quantities that will contribute to the highest 

density levels that are currently 

underrepresented.

•Areas containing very low levels (<1 per 

acre) of snags as a result of the treatment 

should not exceed 10 contiguous acres in 

the Dry Upland Forest potential vegetation 

group, or 5 contiguous acres within all other 

PVGs to assure a sufficient supply of 

habitat for snag-dependent wildlife species.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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74

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E, and F

Alternative E-Modified and E-Modified 

Departure

SD4G(WLDHAB-20) 

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. 

Guideline

Salvage logging shall not 

occur within burned source 

habitat areas less than 100 

acres, except for the removal 

of danger/hazard trees.

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

In addition to the requirements of guideline 

SD-3G, if a need for post-fire salvage 

harvesting is identified, current conditions 

should also be evaluated relative to the 

desired conditions table pertaining to post-fire 

habitat, (see Sec. 1.15, Table 17) and (see 

next items):

• Post-fire salvage treatments should be 

limited to the extent that the desired 

potential vegetation group proportions for 

post-fire habitat are currently being 

exceeded.

• Post-fire salvage should generally not occur 

following individual fire events of less than 

100 acres, except within the WUI or where 

necessary for the removal of danger/hazard 

trees.

SD-6G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Management activities within one mile of a 

known active (during same calendar year that 

use is documented) wolf den and rendezvous 

sites should implement appropriate seasonal 

restrictions based on site specific 

consideration and potential activity effects, to 

reduce disturbance to denning wolves.

SD-7G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Do not authorize turnout of sick or injured 

livestock to reduce risk of attracting wolves.

SD-8G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Remove or otherwise dispose of livestock 

carcasses such that the carcass will not 

attract wolves. If, due to location of the 

carcass, this is not possible, develop other 

remedies.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

75

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E, and F

Alternative E-Modified and E-Modified 

Departure

SD—9G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Do not authorize salt or other livestock 

attractants near known active (during same 

calendar year that use is documented) wolf 

dens or rendezvous sites to minimize 

livestock use of these sites.

Special Habitats

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

WLD-HAB-6 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.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management direction.

WLD-HAB-7 This alternative has no 

corresponding standard or 

guideline.

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.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

WLD-HAB-8 This alternative has no 

corresponding standard or 

guideline.

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. 

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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76

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

WLD-HAB-9 Guideline

Northern goshawk home range 

establishment:

• Post-fledgling family areas will 

be approximately 600 acres in 

size. Post-fledgling family 

areas will include the nest sites 

and consist of the habitat most 

likely to be used by the 

fledglings during their early 

development.

• Establish a minimum of three 

nest areas and three 

replacement nest areas per 

post-fledgling family area. The 

nest areas and replacement 

nest areas should be 

approximately 30 acres in size. 

A minimum total of 150 acres 

of nest areas should be 

identified within each postfledgling family area.

• Nest site selection will be 

based first on using active nest 

sites followed by the most 

recently used historical nest 

areas. When possible, all 

historical nest areas should be 

maintained.

• Manage for nest replacement 

sites to attain sufficient quality 

and size to replace the three 

suitable nest sites.

This alternative retains the 

alternative B management 

direction.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

WLD-HAB-11 This alternative has no 

corresponding standard or 

guideline.

Standard 

Manage for breeding areas that 

will support a minimum of 3 

reproductive pairs of pileated 

woodpeckers per watershed.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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77

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

WLD-HAB-12 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.

This alternative retains the 

alternative B management 

direction.

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management direction.

RME-1S This alternative has no 

corresponding standard or 

guideline

This alternative has no 

corresponding standard or 

guideline

This alternative has no 

corresponding standard or 

guideline

Standard

There shall be no net loss of elk 

security measured within watersheds 

(5th field HUC) through building of new 

motorized routes or re-opening of 

closed motorized routes for public 

travel.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

RME-2G Guideline

Motor vehicle use within elk winter 

range should not be authorized or 

allowed between December 1 and 

April 30.

Standard

Motor vehicle use within elk 

winter range shall not be 

authorized or allowed between 

December 1 and April 30.

This alternative retains the 

alternative B management 

direction.

Guideline

Motorized travel on system roads, 

trails and areas open to motorized 

vehicle use should not be authorized 

within elk winter range between 

December 1 and April 14. These dates 

may be modified by as much as, but 

not exceed two weeks (e.g., March 

31st, April 30th) as appropriate in 

consultation with State wildlife 

agencies. Federal and state highways 

and major forest system roads (such 

as arterials) may be exempted from 

this guideline to provide reasonable 

public access. Authorized 

administrative use of forest system 

roads also may be exempted from this 

guideline. 

The intent is to minimize disturbance 

to elk while occupying winter range 

and encourage elk use of public land. 

Elk winter range maps in the Project 

Record should be used as the basis 

for identifying winter range for future 

projects.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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79

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternative E-Modified and EModified Departure

RME-3G This alternative have no 

corresponding standard or 

guideline.

This alternative have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Encourage elk use of Forest Service 

lands. Management activities that fall 

within identified elk priority areas 

should increase security by a minimum 

of 15 percent, to reach 30 percent or 

greater at the subwatershed (6th Field 

HUC) scale. This guideline applies to 

projects that affect security and/or treat 

greater than 500 acres of forested 

vegetation (prescribed fire is exempt). 

The intent is to improve distribution of 

elk across all seasonal ranges on 

Forest Service lands by moving toward 

and/or within the desired condition 

range of 30-100 percent elk security. 

Project effect analyses should identify 

and consider elk security, elk forage/

nutrition, elk hiding cover, and elk 

habitat selection and distribution.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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80

Sage-grouse

Standard or 

Guideline 

Designator Alternatives B, C, and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

SD-5S This alternative has no corresponding 

standard or guideline.

This alternative has no corresponding 

standard or guideline.

Standard

Any management activities that take place 

within greater sage-grouse habitat shall follow 

the specific plan direction (desired conditions, 

objectives, standards, and guidelines) 

identified in Appendix B- Sage Grouse 

Guidance for Malheur and Wallowa-Whitman 

National Forests. Appendix B contains 

general, special use authorization (nonrecreation), land ownership adjustment, land 

withdrawal, wind and solar, habitat, livestock 

grazing, fire management, Wild horse and 

burro, roads/transportation, fluid mineral, 

coal, locatable mineral, non-energy leasable 

mineral, and mineral material direction for the 

Greater Sage-grouse. Appendix B contains 

considerations for compensatory mitigation 

for the greater sage-grouse.

WLD-HAB-14 This alternative has no corresponding 

standard or guideline.

Guideline

In greater sage-grouse 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.

See standard SD-5S above

WLD-HAB-15 This alternative has no corresponding 

standard or guideline.

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). 

See standard SD-5S above

WLD-HAB-16 This alternative has no corresponding 

standard or guideline.

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). 

See standard SD-5S above
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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81

Standard or 

Guideline 

Designator Alternatives B, C, and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

WLD-HAB-17 This alternative has no corresponding 

standard or guideline.

Guideline

Construction of wind turbines should not be 

authorized or allowed within 3 miles of known 

greater sage-grouse leks (protected activity 

centers). 

See standard SD-5S above

RNG-7 This alternative has no corresponding 

standard or guideline.

Guideline

Grazing utilization within occupied greater 

sage-grouse 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.

See standard SD-5S above

RNG-8 This alternative has no corresponding 

standard or guideline.

Guideline

During greater sage-grouse breeding season, 

livestock turnout and trailing should avoid 

concentration on known greater sage-grouse 

leks (protected activity centers). 

See standard SD-5S above

Bat Maternity and Roost Sites

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternatives E-Modified and E-Modified 

Departure

SD-2G Guideline

Bat maternity and roost sites 

should not be disturbed.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Known bat maternity and roost sites should 

not be disturbed to minimize disturbance to 

bats during critical times and to protect the 

integrity of the site.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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82

Bighorn Sheep

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternatives E-Modified and EModified Departure

BHSM-1S 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 alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Domestic sheep or goat grazing, 

trailing of domestic sheep or goats, or 

the use of domestic goats or sheep 

for manipulation of vegetation (i.e., 

noxious weed control, fuels 

reduction) shall not be authorized 

where effective separation14 from 

bighorn sheep cannot be reasonably 

maintained. Effective separation 

between bighorn sheep and domestic 

sheep and goats is determined with a 

site-specific analysis.

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.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.

BHSM-2S Standard 

The use of recreational pack 

goats shall not be authorized or 

allowed within or adjacent to 

source habitat for bighorn sheep.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

The use of pack goats shall not be 

authorized in occupied bighorn sheep 

habitat or where effective separation 

from bighorn sheep cannot be 

reasonably maintained.

 

14 Effective separation should be determined on a site specific basis through a quantitative and qualitative analysis that includes the following considerations: 

• bighorn sheep herd size and relevant population parameters; 

• proximity of domestic sheep or goats to bighorn sheep; 

• permeability of the area separating bighorn sheep from permitted domestic sheep or domestic goats; and 

• management practices that contribute to maintaining effective separation between these species.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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83

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternatives E-Modified and EModified Departure

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.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.

RNG-13 Guideline

Trailing of domestic sheep or 

goats should not be authorized or 

allowed within 7 miles of bighorn 

sheep home ranges.

Standard

Trailing of domestic sheep or 

goats shall not be authorized 

or allowed within 15 miles of 

bighorn sheep home ranges.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.

RNG-14 Standard

When effective monitoring has not 

been conducted for bighorn sheep 

presence, domestic sheep or goat 

grazing shall not be authorized. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.

BHSM-3S 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.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

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 domestic 

sheep or goats must be made by the

livestock grazing permittee and 

reported back to the Forest Service 

within 24 hours.

RNG-16 Standard 

When permitted sheep are found 

to be missing, the Forest Service 

shall be notified within 24 hours.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

84

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E, and F

Alternatives E-Modified and EModified Departure

BHSM-4S 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. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Domestic sheep and goats shall be 

individually marked in a manner that 

allows field identification of ownership 

when on National Forest System

lands.

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.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline.

BHSM-5S 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

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

To maintain effective separation, 

when bighorn sheep presence is 

likely to result in association with 

domestic sheep or goats, the Forest 

Service shall:

1) notify the appropriate state 

agency; and

2) implement actions that minimize 

the risk of contact between bighorns 

and domestic sheep or goats. This 

may involve rerouting within the 

permitted allotment, movement to a 

different allotment, or, if the situation 

cannot otherwise be resolved, 

moving the sheep off the National 

Forest until the situation can be 

resolved. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

85

Standard or 

Guideline 

Designator Alternative B Alternative C and D Alternatives E and F

Alternatives E-Modified and EModified Departure

WLD-HAB-22 This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

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.

See Standard SD-5S above

Standard or 

Guideline 

Designator Alternative B Alternative C Alternatives D, E and F

Alternatives E-Modified and EModified Departure

WLD-HAB-23 This alternative has no 

corresponding standard or 

guideline.

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.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

WLD-HAB-24 This alternative has no 

corresponding standard or 

guideline.

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. 

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

86

Standard or 

Guideline 

Designator Alternative B Alternative C Alternative D Alternatives E and F

Alternatives E-Modified, 

and E-Modified 

Departure

WLD-HAB-25 Guideline

Where management 

activities occur within 

riparian habitat, the quantity, 

stature, and health of shrubs 

should not be reduced or 

degraded. 

This alternative retains 

the alternative B 

management direction.

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain 

the alternative B 

management direction.

See management 

direction for MA 4B

WLD-HAB-26 Guideline

Roads and trails should not 

be constructed within high 

elevation riparian areas.

Standard 

Roads and trails shall 

not be constructed 

within high elevation 

riparian areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

See management 

direction for MA 4B

WLD-HAB-27 Guideline

Residual herbaceous 

vegetation within riparian 

areas should be maintained 

at a level adequate to 

prevent stream bank 

degradation.

Standard 

Residual herbaceous 

vegetation within 

riparian areas shall be 

maintained at a level 

adequate to prevent 

stream bank 

degradation.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

See management 

Direction for MA 4B

WLD-HAB-28 Guideline

Vigor and areal extent of 

seed producing grasses and 

forbs should not be reduced.

This alternative retains 

the alternative B 

management direction.

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain 

the alternative B 

management direction.

These alternatives have

no corresponding 

standard or guideline.

WLD-HAB-29 This alternative has no 

corresponding standard or 

guideline.

Guideline

Where management 

activities occur within 

source habitat, the 

amount of shrubs in 

the early-seral stages 

of forest communities 

should not be reduced.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have 

no corresponding 

standard or guideline.

These alternatives have 

no corresponding 

standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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87

1.3 Federally Listed and Sensitive Species

Spalding’s catch-fly (Silene spaldingii) 

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

RE-5S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

Standard

Minimize adverse effects to federaly listed, 

proposed, and candidate species and their 

designated and proposed critical habitat in 

accordance with Forest Service authorities. 

Management activities shall not “retard 

recovery”

1 of listed, proposed, and candidate 

species and their designated and proposed 

critical habitat in the long-term in accordance 

with Forest Service authorities. Federally 

listed, proposed, and candidate species and 

their designated and proposed critical habitats 

shall be managed in accordance with their 

recovery or other conservation plans, in 

accordance with Forest Service authorities.

1) Retard recovery: management action 

effects that, individually or in combination with 

other management actions or natural 

disturbances, measurably slow the natural 

rate of recovery. 

FLS-1G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

Guideline

Management activities should avoid adverse 

impacts to wolverine and its habitat to maintain 

population viability and avoid a trend towards 

federal listing.

FLS-16S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

Standard 

Domestic sheep grazing shall not be 

authorized (during same calendar year that 

use is documented) in an allotment that 

contains a known active wolf den or 

rendezvous site unless a herder is with the 

sheep at all times and retrieves known strays 

within 24 hours.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

88 

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

FLS-15S 

Umatilla and 

WallowaWhitman 

National 

Forests

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. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Standard 

Livestock grazing of occupied Spalding’s 

catchfly (Silene spaldingii) habitat shall not be 

authorized between July 1 and September 30 

(flowering-fruiting period).

(PL-TES-2)

Umatilla and 

WallowaWhitman 

National 

Forests

Standard

Livestock grazing shall not be 

authorized or allowed in 

pastures occupied by Silene 

Spaldingii that exhibit 

moderate or greater departure 

from desired condition.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

This alternative has no corresponding 

standard or guideline. 

FLS-2G Guideline

Domestic livestock grazing 

should not be authorized or 

allowed in the fens/bogs 

sensitive plant habitat groups. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Livestock grazing should not be authorized in 

the peatlands sensitive plant habitat group to 

protect the fragile habitat from trampling.

FLS-3S 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. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Standard 

Maximum utilization of key forage species 

shall not exceed 30 percent in occupied 

habitat of threatened, endangered, proposed 

or candidate plant species, except where an 

approved conservation strategy, conservation 

agreement, or recovery plan recommends an 

alternate use level.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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89

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

FLS-4G Same as FLS-3S above These alternatives have no 

corresponding standard or 

guideline.

Same as FLS-3S above Guideline

Maximum utilization of key forage species 

should not exceed 30 percent in occupied 

habitat of sensitive plant species, except 

where an approved conservation strategy or 

conservation agreement recommends an 

alternate use level.

FLS-5G 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. 

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

New water developments and salting should 

not be authorized within one-quarter mile of 

occupied habitat of threatened, endangered, 

candidate or sensitive plant species to reduce 

concentrated livestock use and its associated 

impacts (e.g., excessive trampling, soil 

compaction and herbivory). 

FLS-6S 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.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Standard 

Timber harvest and associated vegetation 

management activities shall avoid adverse 

effects to the occupied habitat of threatened, 

endangered, proposed, candidate or sensitive 

plant species unless the silvicultural 

prescription would benefit the species or its 

habitat.

FLS-7G 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).

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

Slash piles and other fuels should be managed 

to avoid the occupied habitat of threatened, 

endangered, proposed or candidate plant 

species unless the burn plan or prescription 

would benefit the species or its habitat.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

90

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

FLS-8G Guideline

Wildland fire (planned and 

unplanned) suppression lines 

should not be constructed 

within occupied habitat of 

threatened, endangered, and

sensitive plant species.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

Construct fire control lines to avoid the 

occupied habitat of threatened, endangered, 

proposed, candidate and sensitive plant 

species to minimize adverse effects and 

impacts to these categories of plant species 

except where needed to provide for the 

protection of human life and public safety.

FLS-9S Guideline

New road construction should 

be designed to avoid the 

occupied habitat of 

threatened, endangered, and

sensitive plant species 

(minimum 25-foot buffer).

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Standard 

Road maintenance and new road construction 

shall be designed to minimize adverse effects 

to the occupied habitat of threatened, 

endangered, proposed or candidate plant 

species.

FLS-10G Same as above Same as above Same as above Guideline

New road construction should be designed to 

minimize adverse impacts to the occupied 

habitat of sensitive plant species, to avoid a 

trend towards federal listing.

FLS-11S Guideline

All new trail construction 

should be designed to avoid 

the occupied habitat of 

threatened, endangered, and

sensitive plant species 

(minimum 25 foot buffer).

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Standard

Trail maintenance and new trail construction 

shall be designed to avoid adverse effects to 

the occupied habitat of threatened, 

endangered, and proposed plant species.

FLS-13G Same as above Same as above Same as above Guideline

Trail maintenance and new trail construction 

should be designed to avoid adverse impacts 

to the occupied habitat of sensitive plant 

species to avoid a trend towards federal listing.

FLS-12S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

Recreation areas (e.g., ski areas) and other 

recreational action shall minimize adverse 

impact to whitebark pine and its habitat.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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91

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and E-Modified 

Departure

FLS-14G Guideline

Mining operations should be 

authorized or allowed only if 

activities are planned to avoid 

threatened and endangered 

plant species. Sensitive plant 

species should be avoided to 

the greatest extent possible.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

Leasable Minerals: Consent to Mineral 

Leases should be given with stipulations to 

minimize adverse effects to threatened and 

endangered species.

Active minerals leases should be mitigated to 

minimize impacts that exploration and 

production operations may have on threatened 

and endangered species. Where exploration or 

mineral production activities cannot avoid or 

minimize the effects of operations, utilize 

compensatory mitigation to enhance off-site 

habitats and to support no net loss or, if 

possible, a net benefit for threatened or 

endangered species.

Locatable Minerals: Locatable mineral 

operations should be mitigated within the 

context of the USFS regulations at 36 CFR 

228 to protect threatened and endangered 

plant species from the effects of exploration 

and mining activities.

LH-4G Guideline

Land exchanges should avoid 

the disposition of occupied 

habitat of threatened, 

endangered, and sensitive 

plant species.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives retain the 

alternative B management 

direction.

Guideline

Land exchanges should avoid the disposition 

of occupied habitat of threatened, endangered, 

candidate, proposed, or sensitive species.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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92

Wildland Fire15

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and 

E-Modified Departure

FIRE-1 Standard 

Safety shall be the top priority when 

conducting wildland fire (planned and 

unplanned) operations.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

FIRE-2 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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

FIRE-3 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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

FIRE-4 This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Greater sage-grouse habitat 

should be identified in fire 

management plans and should 

be given high priority for 

protection.

These alternatives have no 

corresponding standard or 

guideline.

 

15 Standards and guidelines apply to all three National Forests.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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93

Standard or 

Guideline 

Designator Alternative B Alternatives C and D Alternatives E and F

Alternatives E-Modified and 

E-Modified Departure

FIRE-5 This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Prescribed fire should not be 

authorized or allowed within 

greater sage-grouse habitat 

unless the pre-burn 

assessment documents 

minimal risk of invasion by 

cheat grass or other invasive 

weeds.

These alternatives have no 

corresponding standard or 

guideline.

1.5 Invasive Species

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

NOX-1 Standard 

See alternative A 

“Management Direction for 

Invasive Species.”

These alternatives retain 

the alternative B 

management direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no corresponding 

management direction.

IS-1G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline 

Avoid cross contamination between streams, 

reservoirs and lakes from pumps, suction and 

dipping devices or any other equipment. Avoid 

dumping water directly from one stream or lake 

into another. Disinfect water storage and 

conveyance equipment including sampling

equipment, water tenders, pumps, engines and 

aircraft prior to use on Forest.

IS-2S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

An integrated pest management (IPM) 

approach, including Early Detection and Rapid 

Response, shall be used to manage pests, 

such insects, diseases, and invasive or 

unwanted plants and animals.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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94

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

IS-3G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Determine appropriate range of treatments 

necessary to meet objectives for invasive 

species and native pests, while minimizing 

negative effects of treatments. Methods 

including prevention, manual, cultural, 

mechanical, regionally approved chemicals and 

biological agents may be considered within all 

management areas.

IS-4G Standard 

All activities shall be conducted 

to minimize or prevent the 

potential spread or 

establishment of invasive 

species.

These alternatives retain 

the alternative B 

management direction.

These alternatives retain the 

alternative B management 

direction.

Guideline

All activities should be planned and conducted 

to minimize or prevent the potential spread or 

establishment of invasive species.

IS-5S Standard

Materials used for construction 

or restoration projects on 

National Forest System lands 

shall be free of invasive 

species. 

These alternatives retain 

the alternative B 

management direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Materials (e.g., straw, mulch, gravel, rock, fill, or 

soil) used for construction or restoration 

projects on NFS lands shall be weed-free. If 

State certified straw and/or mulch is not 

available, individual Forests should require 

sources certified to be weed-free using the 

North American Weed Free Forage Program 

standards or a similar certification process.

IS-6S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Equipment used for actions conducted or 

authorized by written permit or contract by the 

USFS that will operate outside the limits of the 

road prism shall be weed and pest-free prior to 

entering NFS lands.

IS-7S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Pelletized or certified weed free feed shall be 

used on all NFS lands. If state certified weed 

free feed is not available, individual Forests 

should require feed certified to be weed-free 

using North American Weed Free Forage 

Program standards or a similar certification 

process.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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95

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

IS-8G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Restore or revegetate sites disturbed by 

management activities, including sites 

specifically treated for invasive plants, to 

prevent the introduction or spread of invasive 

species.

IS-9G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline 

To avoid or minimize exposure to pesticides, 

treatment areas should be posted to inform the 

public and forest workers of application dates 

and pesticides used.

1.9 Air Quality

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

AQ-1S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Planned (prescribed) burning 

shall be conducted in 

accordance with State smoke 

management plans in Oregon 

and Washington, as applicable. 

1.10 Soil Quality

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

SQ-1S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Design project activity units to 

result in no more than 20% 

detrimental soil disturbance at 

project conclusion. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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96

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

SQ-2S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

After completion of 

management activities, the 

minimum effective ground cover

within each activity unit shall be 

in place to prevent erosion from 

exceeding background erosion 

rates for each of four 

established erosion hazard 

classes: low, medium, high, or 

very high (see table below).

Effective ground cover can 

include rocks, woody debris, 

vegetation, etc.

SQ-3S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Management actions shall be 

designed to avoid the potential 

for triggering landslides.

SQ-4G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Mechanical fireline should not 

be constructed in areas with 

greater than 35 percent slope or 

on highly erodible soils unless 

potential detrimental effects can 

be mitigated.

Required minimum percent of effective ground cover (EGC) in the first and second years after 

an activity for each erosion hazard class

Erosion Hazard Class

Required Minimum % Effective 

Ground Cover (EGC) 1st year 

following activity

Required Minimum % 

Effective Ground Cover (EGC) 

2nd year following activity

Low (Very Slight) 20%-30% 30%-40%

Medium (Moderate) 31%-45% 41%-60%

High (Severe) 46%-60% 61%-75%

Very High (Very Severe) 61%-75% 76%-90%
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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97

1.14 Old Forest16

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D Alternatives E and F Alternatives E-Modified 

and E-Modified Departure

OF-1G Guideline

Management activities within 

or outside old forest stands 

should retain live old forest 

trees ≥ 21 inches d.b.h.

Exceptions include:

• 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 

Standard

Management activities 

within and outside old 

forest stands shall retain 

live trees ≥ 21 inches 

d.b.h. 

This alternative has no 

corresponding 

standard or guideline.

Guideline

Alternative E:

Management activities 

within and outside old 

forest stands should 

generally emphasize 

retaining live old trees of 

desirable species. For most 

species, old trees are 

generally considered to be 

greater than 150 years 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 projectspecific basis.

Alternative F:

Management activities 

should retain live old trees 

greater than 150 years old, 

except in lodgepole pine 

cover types (retain trees 

greater than 120 years 

old).

See below

 

16 Standards and guidelines apply to all three National Forests
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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98

Standard or 

Guideline 

Designator

Alternatives E-Modified and E-Modified Departure

OF-1G Guideline

Management activities should retain and generally emphasize recruitment of old17 trees, large18 trees and legacy19 trees. Exceptions where 

individual old, large or legacy trees may be removed or destroyed include situations where: 

• Trees need to be removed to meet or maintain desired conditions for species composition on the landscape by removing shade 

tolerant species in favor of shade-intolerant species. (see Desired Conditions Sec. 1.7) 

• Trees need to be removed from high-density forest to meet or maintain desired conditions for low density stand conditions on 

the landscape where removal of smaller trees alone cannot achieve desired conditions. 

• Trees need to be removed to control or limit the spread of insect or disease infestation.

• Trees need to be removed to reduce danger/hazard trees along roads or in developed sites.

• Trees need to be removed where strategically critical to reinforce, facilitate, or improve effectiveness of fuel reduction in 

wildland-urban interfaces.

Additional exception applies only to large trees that do not also meet the definition of old trees: 

• Trees need to be removed to favor aspen, cottonwood, whitebark pine or other special plant habitats. 

• Trees needed to be removed to form key pieces in complex instream large wood structures.

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D Alternatives E and F Alternatives E-Modified 

and E-Modified Departure

OF-2 Guideline

New motor vehicle routes 

should not be constructed 

within old forest stands.

Standard

New motor vehicle 

routes shall not be 

constructed in old forest 

stands.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

These alternatives have no 

corresponding standard or 

guideline.

 

17 For the purpose of this guideline, the definition for the terms are as follows: “Old” trees are live trees with distinct features indicating ages of generally ≥ 150 years (see 

guidelines outlined in Van Pelt 2008). 18 "Large" trees are live grand fir over 30-inch diameter at breast height or live trees of any other species over 21 inches diameter at breast height. 19 “Legacy” trees are 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). Legacy trees of particular value to wildlife include those that are also large, rough-boled with dead horizontal 

limbs, have witch’s broom deformities, are hollow, have heart rot, pockets of decay, dead or broken tops, cavities and/or substantial wounds (Bull et. al. 1997).
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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99

2.1 Scenery20

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

SC-1G Guideline

Short-term reductions to existing 

scenic integrity levels should be 

authorized only when needed to 

achieve the long-term restoration or 

rehabilitation of scenic integrity 

and/or scenic stability. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline

Short-term reductions to 

existing scenic integrity levels 

should be authorized only 

when needed to achieve the 

long-term ecosystem 

restoration or to improve scenic 

integrity and/or scenic stability.

2.2 Recreation

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

REC-1G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

Recreation-related project-level 

decisions and implementation 

activities should be consistent 

with mapped classes and 

setting descriptions in the 

recreation opportunity 

spectrum. 

 

20 Guideline applies to all three National Forests
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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100

2.4 Cultural Resources

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

CR-1S Guideline

Prehistoric, historic, and traditional 

cultural properties should be protected 

unless an exemption is specified in a 

programmatic agreement or a project 

specific mitigation plan is developed in 

consultation with the appropriate State 

Historic Preservation Officer.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Prehistoric, historic, and 

traditional cultural properties 

shall be protected unless an 

exemption is specified in a 

programmatic agreement or a 

project specific mitigation plan 

is developed in consultation 

with the appropriate State 

Historic Preservation Officer 

and affected Indian Tribe(s).

2.5 Roads and Trails Access21

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

RT-1S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

Limit motorized vehicles to 

roads, trails, and areas that are 

designated for use in the 

Umatilla National Forest 

Motorized Access and Travel 

Management Plan. Temporary 

exceptions are authorized for 

those conducting official duties 

including firefighting, organized 

rescues, duties by special use 

permit or contract, and others 

listed in the Forest Motorized 

Access and Management Plan 

or having the district ranger’s 

authorization.

 

21Applies to the Umatilla National Forest
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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101

2.7 Tribal Rights and Interest

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

TR-1S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

The Forests shall use 

consultation processes 

established with American 

Indian tribal governments to 

identify and manage areas and 

resources of tribal importance 

on Forest lands.

TR-2G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

The Forests should take into 

account project effects to 

culturally significant foods prior 

to tribal consultation efforts.

3.2 Land Ownership

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

LO-1G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Use stipulations for permits and 

leases to protect sensitive 

resources, and exclude 

leasable and common mineral 

and energy development from 

areas in which such use is 

incompatible with mineral or 

energy development.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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102

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

LO-2G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Landownership adjustments 

should emphasize the following 

objectives: a) acquisition to 

meet identified resource 

management needs, b) 

acquisition contributing to 

consolidation that reduces 

administrative problems and 

costs and further enhances 

public use, and c) conveyance 

of land better suited for nonFederal ownership.

3.3.1 Forest Products

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

FP-3S Standard

Clearcutting, shelterwood, and other 

even-aged 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. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Standard

As directed by the NFMA, clearcutting and 

other even-aged harvests may be used only 

when developed through interdisciplinary 

review that assesses the projects impacts 

through appropriate environmental 

documentation and a finding that the project 

is consistent with the multiple uses of the 

general area.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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103

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

FP-1S 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. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Standard 

As directed by the National Forest 

Management Act, cut blocks, patches, strips 

or other forest openings created by the 

application of even-aged or two-aged 

regeneration harvest methods shall be 

limited to a maximum size of 40 acres. 

Where units larger than 40 acres are 

considered likely to produce a more 

desirable combination of net public benefits, 

harvest openings larger than 40 acres may 

be permitted on an individual timber sale 

basis after 60 days' public notice and review 

by the Regional Forester. This maximum 

size opening limitation does not apply to 

areas harvested as a result of natural 

catastrophic conditions such as fire, insect 

and disease attack, or windstorm.

FP-2S 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.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Standard

As directed by the NFMA, cut blocks, 

patches, or strips created by the application 

of even-aged or two-aged regeneration 

harvest methods shall be shaped and 

blended with the natural terrain. 

FOR-4 Standard 

Areas that are harvested using evenaged 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. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

This alternative has no corresponding 

standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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104

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

FOR-5 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.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

This alternative has no corresponding 

standard or guideline.

FOR-6 Guideline

Silvicultural treatments should 

include provisions to avoid 

detrimental changes in water 

temperatures, blockages of 

watercourses, and deposits of 

sediment.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

See direction for soils, watershed, and MA 

4B-Riparian Management Areas

FOR-7 Guideline

Timber harvest projects should 

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.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

See direction for soils, watershed, and MA 

4B-Riparian Management Areas
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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105

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and E-Modified 

Departure

FP 4-S Guideline

Silvicultural treatments should 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.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Standard 

As directed by the NFMA, the harvesting 

systems chosen for a project shall not be 

selected primarily because they give the 

greatest dollar return or the greatest output 

of timber.

FOR-9 Guideline

Timber harvest should not cause 

irreversible damage to soil, slope, or 

other watershed conditions.

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

See direction for soils, watershed, and MA 

4B-Riparian Management Areas

FP-6S Guideline

Timber harvest on lands not suitable 

for timber production should occur 

only to meet multiple-use purposes 

other than timber production. 

This alternative retains 

the alternative B 

management direction.

These alternatives retain 

the alternative B 

management direction.

Standard

Timber harvest on lands not suitable for 

timber production shall occur only to meet 

desired conditions other than timber 

production.

FP-5S This alternative has no corresponding 

standard or guideline.

This alternative has no 

corresponding standard 

or guideline.

This alternative has no 

corresponding standard or 

guideline.

Standard

As directed by the NFMA, clearcutting shall 

be used only where it is determined to be 

the optimum method for meeting desired 

conditions.

FP-7G This alternative has no corresponding 

standard or guideline.

This alternative has no 

corresponding standard 

or guideline.

This alternative has no 

corresponding standard or 

guideline.

Guideline

The silvicultural systems utilized to manage 

forest vegetation should be consistent with 

those shown in the table below by forest 

vegetation type. All intermediate silvicultural 

tending treatments including but not limited 

to commercial and pre-commercial thinning, 

improvement cuttings, sanitation/salvage, 

prescribed fire, tree planting, pruning, site 

preparation or mechanical fuel reduction 

may be incorporated into these systems if 

use is consistent with other plan 

components.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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106

Appropriate silvicultural system

Forest Vegetation 

Group or Cover Type Even-Aged Two-Aged 1 Uneven-Aged

Cold upland forest Clearcutting; Overstory 

Removal; ClearcuttingSalvage; Seed Tree; 

Shelterwood

Clearcutting; Overstory 

Removal w/Reserves; 

Seed Tree w/Reserves; 

Shelterwood 

w/Reserves

Single Tree Selection; 

Group Selection

Moist upland forest Clearcutting; Overstory 

Removal; ClearcuttingSalvage; Seed Tree; 

Shelterwood

Clearcutting; Overstory 

Removal w/Reserves; 

Seed Tree w/Reserves; 

Shelterwood 

w/Reserves

Single Tree Selection; 

Group Selection

Dry upland forest Overstory Removal; 

Clearcutting-Salvage; 

Seed Tree; 

Shelterwood

Overstory Removal 

w/Reserves; Seed Tree 

w/Reserves; 

Shelterwood 

w/Reserves

Single Tree Selection; 

Group Selection

1. Cuts in two-aged systems are a form of even-aged management and must comply with NFMA limitations for evenaged regeneration harvests. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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107

3.3.2 Livestock Grazing22

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D Alternatives E and F Alternatives E-Modified 

and E-Modified Departure

LG-1G Guideline

Grazing after wildland 

fire (planned and 

unplanned) should be 

managed so as not to 

cause a trend away 

from the key species 

desired condition. This 

may include growing 

season deferment for

one or more years 

following wildland fire.

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.

This alternative has no 

corresponding standard or 

guideline.

These alternatives retain 

the alternative B

management direction.

Guideline 

Grazing after fire (planned 

and unplanned ignitions) 

should be managed so as 

not to cause a trend away 

from the native or desired 

non-native species desired 

condition. This may include 

deferment for one or more 

growing seasons following 

unplanned fire, which will 

be defined at the project 

level when restoration 

needs are assessed.

RNG-2 Guideline

New fences should be 

designed to 

accommodate wildlife 

movement. 

This alternative retains the 

alternative B management 

direction. 

This alternative retains the 

alternative B management 

direction.

Guideline 

This alternative retains the 

alternative B management 

direction with the following 

addition: 

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.

This alternative has no 

corresponding standard or 

guideline.

 

22 Standards and guidelines apply to all three National Forests
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Appendix A. Forest Plan Revision Alternatives in Detail

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108

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D Alternatives E and F Alternatives E-Modified 

and E-Modified Departure

LG-2S Guideline

All new water 

developments should 

provide for small 

mammal and bird 

escape.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Standard 

All new water 

developments shall provide 

for small mammal and bird 

escape.

LG-3G 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.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

In areas classified as less 

than fully capable or 

suitable for grazing, only 

limited livestock use should 

be authorized after the 

limitations of the site are 

considered in designing the 

site-specific allotment 

management plan.

LG-5G Guideline

Upland shrub utilization 

should not exceed 45 

percent as determined 

by any science-based 

method. 

Standard 

Upland shrub utilization 

shall not exceed 25 percent

as determined by any 

science-based method. 

This alternative has no 

corresponding standard or 

guideline.

Guideline

Upland shrub utilization 

should not exceed 40 

percent as determined by 

any science-based method. 

Guideline

To maintain plant diversity 

and productivity, upland 

shrub utilization of annual 

leader growth should not 

exceed 40 percent as 

determined by a sciencebased method, to maintain 

shrub health and 

reproduction capability.
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Appendix A. Forest Plan Revision Alternatives in Detail

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109

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D Alternatives E and F Alternatives E-Modified 

and E-Modified Departure

LG-4G Maximum percent 

utilization by 

management system. 

See table below. 

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Upland Forage Utilization 

Guideline: Maximum 

percent utilization by 

management system. 

Utilization should be based 

on a point in time 

measurement. Utilization 

accounts for reduction in 

forage by wildfire and all 

use by permitted livestock, 

wildlife, insects, or 

recreational use. Utilization 

will be based on heightweight curves and/or ocular 

estimates or other 

approved measures. 

Utilization is based on key 

species. See table below. 

LG-4G (RNG-5) Maximum percent utilization by management system. See MA 4B standards and guidelines for management direction for grazing within riparian 

management areas. 

Key grass and forbs species maximum percent utilization within upland sites

Management System

Maximum Percent Utilization

Alt. B 

Departure from Desired 

Condition

(guideline)

Alt. C 

Departure from Desired 

Condition

(standard)

Alt. D 

Departure from Desired 

Condition

(guideline)

Alt. E, E-Modified, E-Modified 

Departure and F 

Departure from Desired 

Condition (guideline)

Low Moderate or 

Greater

Low Moderate or 

Greater

Low Moderate or 

Greater

Low Moderate or 

Greater

Season long 50% 30% 30% 30% 45% 40% 35% 30%

Management systems that 

incorporate deferment, rest, rotation

55% 35% 30% 30% 50% 45% 40% 35%

Utilization should be based on a point in time measurement.

Utilization includes all use by permitted livestock, wildlife, insects, wildfire, or recreational use.

Utilization will be based on height-weight curves and/or ocular estimates or other approved measures. 

Utilization is based on key species.

Low-moderate departure: phase A or B 

Moderate or greater departure: phase C or D
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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110

3.3.3. Special Uses

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

SU-1G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Wind towers should be placed 

to avoid areas of High Scenic 

Integrity. 

SU-2G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Wind towers should be placed 

to avoid areas where natural 

topography, such as ridgetops, 

saddles, or mountain passes, 

create preferred travel, 

foraging, or migration routes for 

migratory birds, raptors, or bats.

SU-3G This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Any development of wind 

energy and associated 

infrastructure within the 

planning area will consider and 

mitigate negative impacts to 

wildlife. 

3.3.4 Mineral, Energy, and Geological Resources

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

ME-1S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

Roads for mineral operations 

shall not be constructed prior to 

approval of a plan of operations 

and shall be designed and 

located to provide adequate 

protection to surface resources, 

including but not limited to slope 

stability, surface erosion, and 

water quality. 
Final Environmental Impact Statement, Volume 3 

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111

Standard or 

Guideline 

Designator

Alternative B Alternatives C and D Alternatives E and F Alternatives E-Modified and 

E-Modified Departure

ME-2S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

The collection of vertebrate 

fossils from National Forest 

System lands is prohibited, 

except by permit to authorized 

individuals.

Management Area Standards and Guidelines

The following standards and guidelines are organized by 

management area. Forestwide design criteria displayed in the 

previous tables apply to all management areas. Standards and 

guidelines are organized by resource or management action and 

apply to all three National Forests except as noted in the tables. The 

standard and guideline designator column includes the current 

designator along with the one used for the proposed action (G- or S-) 

where applicable to ease comparison. New or modified standards and 

guidelines are identified as such.

Alternative Comparison Tables

Table A-31. Comparison of management area specific standards and guidelines for the plan revision alternatives for each national forest

MA 1A Congressionally Designated Wilderness Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-1S Standard

With the exception of permitted 

livestock, animals other than pack 

stock and pets (see glossary) 

shall not be authorized or allowed 

in wilderness areas. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Animals and pets, other than 

those that are permitted, shall not 

be authorized in wilderness 

areas.

MA1A-2S Standard 

Wheeled vehicles, such as 

wagons and game carts, shall not 

be authorized or allowed within 

wilderness areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Wheeled vehicles, such as 

wagons and game carts, shall not 

be authorized within wilderness 

areas.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

112

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA 1A

WIL-3 

Guideline

New proposals for outfitter and 

guide special use permits or 

recreation event permits should 

be approved only when the 

special use or event is consistent 

with wilderness area desired 

conditions and a need is 

identified by a Needs 

Assessment and Capacity 

Analysis.

Standard 

New proposals for outfitter and 

guide special use permits or 

recreation event permits shall 

be approved only when the 

special use or event is 

consistent with wilderness area 

desired conditions and a need is 

identified by a Needs 

Assessment and Capacity 

Analysis.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA1A-3G Guideline

Party sizes greater than 12 

people and/or 18 head of stock 

should not be authorized or 

allowed within wilderness areas.

Standard

Party sizes greater than 12 

people and/or 18 head of stock 

shall not be authorized or 

allowed within wilderness areas.

These alternatives retain the 

alternative B management 

direction.

Guideline

Party sizes greater than 12 

people or with more than 18 head 

of stock should not be authorized 

within wilderness areas to 

maintain wilderness 

characteristics. 

MA1A-4G Guideline

The hitching or tethering of a 

horse or other saddle or pack 

animal should not be authorized 

or allowed within 200 feet of lakes 

or within 100 feet of streams and 

posted wetlands within 

wilderness areas.

Standard

The hitching or tethering of a 

horse or other saddle or pack 

animal shall not be authorized 

or allowed within 200 feet of

lakes or within 100 feet of 

streams and posted wetlands 

within wilderness areas.

These alternatives retain the 

alternative B management 

direction.

Guideline

The hitching or tethering of a 

horse or other saddle or pack 

animal should not be authorized 

within 200 feet of lakes or within 

100 feet of streams and posted 

wetlands in wilderness areas to 

maintain wilderness 

characteristics. 

MA1A-5S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Storing or abandoning personal 

property, equipment, and supplies 

for more than 72 hours in 

wilderness areas shall not be 

authorized.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

113

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-16S Standard 

Hitching or tethering of horses or 

other saddle or pack animals to 

trees, except for loading or 

unloading, shall not be authorized 

or allowed at campsites within 

wilderness areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Hitching or tethering of horses or 

other saddle or pack animals to 

trees, except for loading or 

unloading, shall not be authorized 

at campsites within wilderness 

areas. 

(Applies only to the WallowaWhitman National Forest)

MA 1A Congressionally Designated Wilderness Areas within the Malheur National Forest

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA 1A

MAL-WIL-1 

Standard

Storing or abandoning personal 

property, equipment, and 

supplies for more than 72 hours 

shall not be authorized or allowed 

in the Strawberry Mountain 

Wilderness Area.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

See Standard MA1A-5S above.

MA1A-6G Guideline

Camping and campfires should 

not be authorized or allowed 

within 200 feet of lakes, streams, 

or other camps within wilderness 

areas. 

Standard 

Camping and campfires shall

not be authorized or allowed 

within 200 feet of lakes, 

streams, or other camps within 

wilderness areas.

These alternatives retain the 

alternative B management 

direction.

Guideline 

Camping and campfires should 

not be authorized within 200 feet 

of lakes, streams, or other camps 

within wilderness areas in order 

to maintain wilderness 

characteristics.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

114

MA 1A Congressionally Designated Wilderness Areas within the Umatilla National Forest

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-7G Guideline

Camping and campfires should 

not be authorized or allowed 

within 200 feet of lakes, streams, 

or other camps within wilderness 

areas. 

Standard

Camping and campfires shall

not be authorized or allowed 

within 200 feet of lakes, 

streams, or other camps within 

wilderness areas.

These alternatives retain the 

alternative B management 

direction.

Guideline 

Camping and campfires should 

not be authorized within 200 feet 

of lakes, streams, or other camps 

within wilderness areas in order 

to maintain wilderness 

characteristics.

MA 1A Congressionally Designated Wilderness Areas within the Wallowa-Whitman National Forest

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-8S Standard 

Eagle Cap Wilderness Area 

visitors shall not be authorized 

unless they obtain and possess 

an entry permit.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA1A-9S Standard

Campfires shall not be authorized 

or allowed within 100 feet of any 

lake or posted wetland in the 

Eagle Cap Wilderness Area.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Campfires shall not be authorized 

within 100 feet of any lake or 

posted wetland in the Eagle Cap 

Wilderness Area. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

115

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-10S Standard 

Campfires shall not be authorized 

or allowed within one-quarter mile 

of the following lakes in the Eagle 

Cap Wilderness Area: Bear Lake 

(Bear Creek Area), Blue Lake, 

Chimney Lake, Dollar Lake, 

Eagle Lake, Frazier Lake, Little 

Frazier Lake, Glacier Lake, Hobo 

Lake, Ice Lake, Jewett Lake, 

Laverty Lake, Maxwell Lake, 

Mirror Lake, Moccasin Lake, 

Prospect Lake, Steamboat Lake, 

Sunshine Lake, Swamp Lake, 

Tombstone Lake, Traverse Lake, 

and Upper Lake.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Campfires shall not be authorized 

within one-quarter mile of the 

following lakes in the Eagle Cap 

Wilderness Area: Bear Lake 

(Bear Creek Area), Blue Lake, 

Chimney Lake, Dollar Lake, 

Eagle Lake, Frazier Lake, Little 

Frazier Lake, Glacier Lake, Hobo 

Lake, Ice Lake, Jewett Lake, 

Laverty Lake, Maxwell Lake, 

Mirror Lake, Moccasin Lake, 

Prospect Lake, Steamboat Lake, 

Sunshine Lake, Swamp Lake, 

Tombstone Lake, Traverse Lake, 

and Upper Lake.

MA1A-11S Standard 

Grazing of horses and other 

saddle and pack animals shall not 

be authorized or allowed within 

200 feet of any lake in the Eagle 

Cap Wilderness Area.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Grazing of horses and other 

saddle and pack animals shall not 

be authorized within 200 feet of 

any lake in the Eagle Cap 

Wilderness Area. 

MA1A-12S Standard

Eagle Cap Wilderness Area 

visitors shall not be authorized or 

allowed to enter posted 

restoration sites.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Eagle Cap Wilderness Area 

visitors shall not be authorized to 

enter posted restoration sites.

MA1A-13S Standard 

Storing or abandoning personal 

property, equipment, and 

supplies for more than 72 hours 

shall not be authorized or allowed 

in the Eagle Cap Wilderness 

Area. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Storing or abandoning personal 

property, equipment, and supplies 

for more than 72 hours shall not 

be authorized in the Eagle Cap 

Wilderness Area. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

116

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-14S Standard 

Party sizes greater than 12 

people and/or 18 head of stock 

shall not be authorized or allowed 

in the Eagle Cap Wilderness 

Area. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Party sizes greater than 12 

people and more than 18 head of 

stock shall not be authorized in 

the Eagle Cap Wilderness Area. 

MA1A-15S Standard

When camping, party sizes 

greater than 6 people and/or 9 

head of stock shall not be 

authorized or allowed in the 

Lakes Basin Management Area 

of the Eagle Cap Wilderness 

Area. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

When camping, party sizes 

greater than 6 people and greater 

than 9 head of stock shall not be 

authorized in the Lakes Basin 

Management Area of the Eagle 

Cap Wilderness Area. 

Wildland Fire Management Activities within MA 1A

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-17G Guideline

All firelines should be restored by 

actions such as scattering slash piles 

along and onto firelines, knocking down 

or burning all slash piles greater than 

18 inches tall, pulling back and 

covering all sod with slash, and placing 

boulders, logs, and slash on firelines to 

discourage use and camouflage 

entrance points.

Additionally, all firelines that are within 

100 feet of intercepting trails, roads, or 

stream crossings should be restored by 

cutting stumps flush and close to the 

ground (height of 4 to 5 inches), 

covering tops with a layer of soil (1 to 2 

inches), and chopping and roughening 

the ends of logs and stumps.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

To maintain wilderness characteristics, 

all firelines should be restored by actions 

such as scattering slash piles along and 

onto firelines, knocking down or burning 

all slash piles greater than 18 inches tall, 

pulling back and covering all sod with 

slash, and placing boulders, logs, and 

slash on firelines to discourage use and 

camouflage entrance points. Additionally, 

all firelines within 100 feet of intercepting 

trails, roads, or stream crossings should 

be restored by cutting stumps flush and 

close to the ground (height of 4 to 5 

inches), covering tops with a layer of soil 

(1 to 2 inches), and chopping and 

roughening the ends of logs and stumps. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

117

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and EModified Departure

MA1A-18G Guideline

Waterbars should be constructed on 

fireline slopes that exceed 10 percent.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Waterbars should be constructed on 

fireline slopes that exceed 10 percent in 

order to maintain wilderness 

characteristics. 

MA 1A

WIL-FIRE-3 

Guideline

Garbage and trash should be removed.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

These alternatives have no 

corresponding standard or guideline.

MA1A-19G Guideline

Camps should be restored by replacing 

logs and rocks, re-contouring terrain, 

scarifying soil, and scattering twigs, 

rocks, and dead branches to 

discourage use and camouflage 

entrance points.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Camps should be restored by replacing 

logs and rocks, recontouring terrain, 

scarifying soil, and scattering twigs, 

rocks, and dead branches to discourage 

use and camouflage entrance points to 

maintain wilderness characteristics. 

MA1A-20G Guideline

Closed roads that were opened to 

provide access to wilderness areas 

should be closed after the use has 

concluded.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Closed roads that were opened to 

provide access to wilderness areas 

should be closed after the use has 

concluded to maintain wilderness 

characteristics. 

MA1A-21G Guideline

Wilderness trails used as firelines 

should be returned to original condition 

after the use has concluded.

This alternative retains the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

Guideline

Wilderness trails used as firelines should 

be returned to original condition after the 

use has concluded in order to maintain 

wilderness characteristics. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

118

MA 1B Preliminary Administratively Recommended Wilderness Areas and MA 1C Wilderness Study Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and EModified Departure

MA1B-1S Guideline

Existing and proposed uses 

that could compromise 

wilderness area eligibility prior 

to congressional designation 

should not be authorized. 

Standard 

Existing and proposed uses 

that could compromise 

wilderness area eligibility prior 

to congressional designation 

shall not be authorized.

These alternatives retain the 

alternative B management 

direction.

Standard 

Proposed uses that could compromise 

wilderness area eligibility prior to 

congressional designation shall not be 

authorized. 

MA1B-2G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline 

Mechanized (bicycle) use and nonmotorized travel may occur on existing 

trails in recommended wilderness areas. 

MA1B-3G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Motorized equipment including chain 

saws and trail machines may be used for 

trail maintenance and reconstruction on 

existing trails within recommended 

wilderness areas.

MA1C-1G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Management activities should not reduce 

or impair the wilderness characteristics 

and qualities for which the area was 

designated
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

119

MA 2A Wild and Scenic Rivers (includes Designated, Eligible, and Suitable Rivers)

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2A-1G Guideline

New proposals for outfitting and 

guiding special use permits or 

recreation event permits should 

be approved only when the 

special use or event is consistent 

with outstandingly remarkable 

values, wild and scenic rivers 

desired conditions, and when a 

need is identified by a needs 

assessment and capacity 

analysis.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline 

New proposals for outfitting 

and guiding special use 

permits or recreation event 

permits should be approved 

only when the special use or 

event is consistent with 

Outstandingly Remarkable 

Values (ORVs), wild and 

scenic rivers desired 

conditions, and when a need is 

identified and capacity is 

available. 

MA2A-2S Standard 

Hitching or tethering of horses or 

other saddle or pack animals to 

trees, except for loading or 

unloading, shall not be authorized 

or allowed at campsites within 

wild and scenic river corridors.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Hitching or tethering of horses 

or other saddle or pack 

animals to trees, except for 

loading or unloading, shall not 

be authorized at campsites 

within wild and scenic river 

corridors. 

MA 2A

WSR-3 

Guideline

Hitching, tethering, hobbling, and 

confining of saddle and pack 

animals within wild and scenic 

river corridors should be 

authorized or allowed only in 

designated stock facilities or at 

hardened campsites.

Standard

Hitching, tethering, hobbling, and 

confining of saddle and pack 

animals within wild and scenic river 

corridors shall be authorized or 

allowed only in designated stock 

facilities or at hardened campsites.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A

WSR-4 

Guideline

New designated routes and trails 

should not be constructed within 

riparian management areas 

unless no other feasible 

alternative exists.

Standard 

New designated routes and trails 

shall not be constructed within 

riparian management areas.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

120

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA 2A

WSR-5 

Guideline

Recreation livestock should be 

allowed or authorized only in 

designated areas.

Standard 

Recreation livestock shall be 

allowed or authorized only in 

designated areas.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A

WSR-6 

Guideline

Timber harvest roads should not 

be constructed within wild and 

scenic river corridors.

Standard 

Timber harvest roads shall not be 

constructed within wild and scenic 

river corridors

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A

WSR-7 

Guideline

Firewood collection (except for 

use at onsite campfires) should 

be allowed only at designated 

sites within wild and scenic river 

corridors, preferably not within 

riparian management areas. 

Standard 

Firewood collection (except for use 

at onsite campfires) shall be 

allowed only at designated sites 

within wild and scenic river 

corridors, outside riparian 

management areas. 

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA2A-3S Guideline

The construction of roads and 

river crossings that are visible 

from the river corridor of wild and 

scenic sections should not be 

authorized or allowed except 

when necessary to meet 

recreation purposes.

Standard 

The construction of roads and river 

crossings that are visible from the 

river corridor of wild and scenic 

sections shall not be authorized or 

allowed except when necessary to 

meet recreation purposes.

These alternatives retain the 

alternative B management 

direction.

Standard 

New roads and motorized trails 

shall not be authorized within 

wild classifications of Wild and 

Scenic River Management 

allocations. 

MA2A-4S Standard 

Hazard trees shall be felled and 

left where they fall or moved to a 

desirable location within the wild 

and scenic river corridor.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

Hazard trees felled at 

trailheads or watercraft putin/takeout locations within river 

segments classified as wild 

rivers will be left where they 

fall, or moved to an 

ecologically desirable location. 

MA2A-5S Standard

Mining of common minerals shall 

not be authorized.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

121

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA 2A

WSR-11

Standard 

Oil and gas leasing shall not be 

authorized or allowed within 

1,320 feet of the high water mark 

in wild river corridors.

Oil and gas leasing shall not be 

authorized or allowed within wild 

river corridors.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A Wild and Scenic Rivers within the Malheur National Forest (includes Designated, Eligible, and Suitable Rivers)

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA 2A

MAL-WSR-1 

Standard 

Motor vehicle use shall not be 

authorized or allowed on trail 303 

within the Malheur Wild and 

Scenic River corridor and on trail 

381 with in the North Fork 

Malheur Wild and Scenic River 

corridor. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A

MAL-WSR-2 

Standard 

Livestock grazing shall not be 

authorized between Crane Creek 

and the southern boundary of the 

Malheur National Forest between 

July 1 and September 15.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2A Wild and Scenic Rivers within the Wallowa Whitman National Forest (includes Designated, Eligible, and Suitable Rivers)

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2A-6S Standard

Camping shall not be authorized 

or allowed in the Lostine River 

corridor except in campgrounds, 

at trailheads, and in designated 

campsites.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction. 

Standard

Camping shall not be 

authorized in the Lostine River 

corridor except in 

campgrounds, at trailheads, 

and in designated campsites.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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122

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2A-7S Standard 

With the exception of trailheads 

and other designated areas, 

hitching, tethering, hobbling, and 

confining of saddle and pack 

animals shall not be authorized or 

allowed within the Lostine River 

corridor. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard 

With the exception of 

trailheads and other 

designated areas, hitching, 

tethering, hobbling, and 

confining of saddle and pack 

animals shall not be authorized 

within the Lostine River 

corridor. 

MA 2B Research Natural Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2B-1S Standard

Management activities that 

directly or indirectly modify the 

integrity of the ecological 

processes shall not be authorized 

or allowed.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Management activities shall 

not be authorized that inhibit 

the purpose for the research 

natural area establishment

MA2B-2G Standard

Mineral exploration and 

development activities shall be 

managed to minimize impacts to 

research natural areas. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline

Mineral exploration and 

development activities should 

be managed to minimize 

impacts to research natural 

areas, consistent with valid 

existing rights. 

MA2B-3S Standard

Removal of common mineral 

material shall not be authorized 

or allowed within research natural 

areas. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Standard

Removal of common mineral 

material shall not be authorized 

within research natural areas. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

123

MA 2C Botanical Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2C-1G Guideline

Visitor activities should be 

managed to avoid degradation to 

botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2C-2G Guideline

Interpretive facilities should not 

conflict with the overall purpose 

of establishing botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2C-3G Guideline

Silvicultural treatments should be 

allowed only when designed to 

enhance the special features of 

botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline 

Silvicultural treatments should 

not degrade the special 

features of botanical areas. 

MA2C-4G Guideline

Firewood collection should not be 

authorized or allowed within 

botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline 

To prevent damage to special 

features, firewood collection 

should not be authorized within 

botanical areas

MA2C-5G Guideline

Mineral exploration and 

development activities should be 

managed to minimize impacts to 

botanical areas. 

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2C-6G Guideline

Removal of common mineral 

material should not be authorized 

or allowed within botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline 

Removal of common mineral 

material should not be 

authorized within botanical 

areas unless doing so will not 

adversely modify special 

features
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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124

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2C-7G Guideline

Botanical areas should be 

managed as avoidance areas for 

utility corridors.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline 

Utility corridors should not be 

authorized within botanical 

areas, unless doing so will not 

adversely modify special 

botanical features

MA 2C

BOT-8 

Guideline

Planned fire should be used to 

maintain or enhance the 

vegetation condition for which the 

botanical area was established.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA2C-8G

MA 2C

BOT-9 

Guideline

Endemic (normal) levels of 

insects and disease disturbance 

should be allowed within 

botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

Guideline

Artificial control of endemic 

(normal) levels of insects and 

disease should not be 

authorized within botanical 

areas, to retain natural 

processes and influences.

MA 2C

BOT-10

Guideline

Invasive species should be 

reduced or eradicated within 

botanical areas.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

These alternatives have no 

corresponding standard or 

guideline.

MA 2D Geological Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2D-1G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no

corresponding standard or 

guideline.

Guideline

Management activities should 

not reduce or impair the natural 

and ecological values and 

qualities for which the area 

was designated. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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125

MA 2E Historical Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2E-1G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Visitor activities should be 

managed to avoid degradation 

to historical areas, and 

interpretive facilities should not 

conflict with the overall 

purpose of designated 

historical areas. 

MA 2F Scenic Byways and All American Roads

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2F-1G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Visual impacts from vegetation 

treatments, recreation uses, 

rangeland developments, and 

other structures should blend 

with the overall landscape 

character along scenic byways.

MA2F-2G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Signs, kiosks, and other 

exhibits should provide 

interpretive, education, and 

safety information along scenic 

byways and in adjacent 

recreation sites.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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126

MA 2G Nationally Designated Trails

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2G-1S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

The Nez Perce National 

Historic Trail shall be managed 

consistently with the guidance 

in the Nez Perce National 

Historic Trail Comprehensive 

Management Plan (USDA 

Forest Service et al. 1990).

MA2G-2S This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard

The Nez Perce National 

Historic Trail shall be managed 

as a non-motorized route for 

primitive hiking and horseback 

riding for trail segments that 

are not identified as auto tour 

routes.

MA 2H Nationally Designated Trails

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2H-1G This alternative has no 

corresponding standard or 

guideline.

This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Signs, kiosks, and other 

exhibits should provide 

interpretive, education, and 

safety information along scenic 

byways and in adjacent 

recreation sites. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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127

MA 2I Starkey Experimental Forest and Range

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2I-6G Guideline

To protect valuable infrastructure 

and assure compatibility with 

research needs and objectives, 

natural, unplanned ignitions 

should be suppressed with a high 

level of management response. 

Suppression activities are 

coordinated with the Station 

director, research project leader, 

or designee. 

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Guideline

To protect valuable 

infrastructure and assure 

compatibility with research 

needs and objectives, 

unplanned ignitions should be 

suppressed with a high level of 

management response. 

Suppression activities are 

coordinated with the Station 

director, research project 

leader, or designee

MA2I-5G Guideline

Planned ignitions should occur 

when/where compatible with 

research needs or objectives.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Guideline

Planned ignitions should occur 

only when/where compatible 

with research needs or 

objectives. 

MA2I-4S Standard 

Special forest product collection 

and firewood cutting shall only be 

allowed when/where compatible 

with research objectives.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2I-1S Standard

Vehicle access shall only be

allowed on designated routes, 

unless necessary to meet 

research needs or objectives.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2I-2S 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. 

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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128

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2I-3G Guideline

Existing old growth stands 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. 

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

These alternatives retain the 

alternative B management 

direction.

MA2I-7S Standard 

Plans of operation for existing 

locatable mineral claims shall be 

reviewed and modified, to the 

extent practicable, to be 

compatible with existing or 

planned research.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Standard 

Plans of operation for 

locatable, leasable, and 

saleable mineral operations 

shall be reviewed and 

modified, to the extent 

practicable, to be compatible 

with existing or planned 

research. 

MA 2J Municipal Watersheds

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2J-1S Standard 

All management activities shall 

be designed to protect water 

quality at the intake in public 

water supply watersheds.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

All management activities shall 

be designed to protect water 

quality at the intake in public 

water supply watersheds. 

Activities that could influence 

drinking water sources will be 

conducted consistent with 

State and federal water quality

regulations.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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129

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA2J-2S Standard 

Fertilizers and chemicals shall 

only be used in emergency 

situations, subject to the terms of 

existing agreements between 

individual cities and the U.S. 

Department of Agriculture.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Standard 

All fertilizers and chemicals 

shall only be used in 

emergency situations, 

consistent with existing 

agreements between individual 

cities and the U.S. Department 

of Agriculture.

MA 3A Backcountry (nonmotorized use) 

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA3A-1S Standard

New road construction shall be 

limited to that required for 

designated special uses or 

required by law to provide access 

to non-Federal land or valid 

existing rights.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Standard

Backcountry management 

areas within Inventoried 

Roadless Areas shall be 

managed consistent with the 

guidance in the 2001 Roadless 

Area Conservation Rule (36 

CFR 294) (USDA 2001).
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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130

MA 3B Backcountry (motorized use)

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and 

E-Modified Departure

MA3B-1S 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. 

Standard 

Silvicultural treatments shall not be 

allowed.

This alternative retains the 

alternative B management 

direction.

This alternative has no 

corresponding standard or 

guideline.

MA 3A/B

BACK-2 

Standard

New road construction shall be 

limited to that required for 

designated special uses or 

required by law to provide access 

to non-Federal land or valid 

existing rights.

This alternative retains the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Standard

Backcountry management 

areas within Inventoried 

Roadless Areas shall be 

managed consistent with the 

guidance in the 2001 Roadless 

Area Conservation Rule (36 

CFR 294) (USDA 2001).
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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131

MA 4A General Forest

Standard or 

Guideline 

Designator

Alternative B Alternative C Alternative D, E and F Alternatives E-Modified and E-Modified Departure

MA4A-1S This alternative has 

no corresponding 

standard or 

guideline

This alternative has 

no corresponding 

standard or 

guideline

These alternatives have 

no corresponding 

standard or guideline.

Standard 

As directed by the National Forest Management Act, when trees are 

harvested from lands identified as suitable for timber production, the 

harvests shall be made in such a way as to reasonably assure that 

the technology and knowledge exists to adequately restock the lands 

within five years of final regeneration harvest. Research and 

experience shall be the basis for determining whether the harvest and 

regeneration practices planned can be expected to result in adequate 

restocking. The adequate level of restocking shall be prescribed in a 

site-specific silviculture prescription for a project, which will specify 

the minimum number, size, distribution and species composition of 

regeneration needed based on the objectives and desired conditions 

for the Plan Area and project.

MA4A-2G This alternative has 

no corresponding 

standard or 

guideline

This alternative has 

no corresponding 

standard or 

guideline

These alternatives have 

no corresponding 

standard or guideline.

Guideline

As directed by the NFMA, even-aged regeneration harvests of stands 

on lands suitable for timber production should not occur until the 

stands have generally reached or surpassed the culmination of the 

mean annual increment measured in cubic feet. This does not 

preclude the use of thinning or other intermediate stand improvement 

treatments or salvage/sanitation harvesting of timber stands that are 

substantially damaged by fire, windthrow, or other catastrophic event 

or that are in imminent danger of insect or disease outbreaks. 

Exceptions may be made after consideration of overall multiple uses 

other than timber production including: 

• Cutting related to research or experimental purposes, or

• Removing particular species of trees, or

• Improving wildlife habitat, range or recreation resources.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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132

MA 4B Riparian Management Areas

General Management within Riparian Management Areas 

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

RMA-1S 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 riparian management 

areas 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 riparian management areas 

may be acceptable when they support, or 

do not diminish, long-term benefits to 

aquatic and riparian resources. 

These alternatives retain 

the alternative B

management direction.

Standard 

Riparian management areas include portions of watersheds where 

aquatic and riparian-dependent resources receive primary 

management emphasis. When riparian management area desired 

conditions are functioning properly, projects shall protect or 

maintain those conditions. When riparian management area 

desired conditions are not yet achieved or riparian management 

areas have impaired function or are functioning-at-risk and to the 

degree that project activities would contribute to those conditions, 

projects or permitted activities shall restore or not retard attainment 

of desired conditions.23 Short-term adverse effects from project 

activities may occur when they support long-term recovery of 

riparian management area desired conditions.24 Exceptions to this 

standard include situations where Forest Service authorities are 

limited (Alaska National Interest Lands Conservation Act {ANILCA}, 

1872 Mining law, valid state water right, etc.). In those cases, 

project effects shall be minimized and not retard attainment of 

desired conditions to the extent possible within Forest Service 

authorities. Use ARCS Attachment 2 (e.g. diagnostic indicators and 

RMA ecological process and function descriptions) to assist in 

determining compliance with this standard.

RMA-2S 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.

These alternatives retain 

the alternative B

management direction.

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 in a manner that does not harm aquatic or riparian 

resources. 

 

23 Per Watershed Condition Framework Technical Guide, USDA Forest Service (2011b), subsequent versions of this guide and/or other comparable methods. The Watershed 

Condition Class terminology for functioning properly, “functioning-at-risk”, and impaired function are equivalent to “functioning appropriately” or “, “functioning-at-risk” and 

“functioning at unacceptable risk” functioning categories within the matrix of pathways and indicators (USFWS 1998, and respectively equivalent to “Properly Functioning” or 

“At Risk” or “Not Properly Functioning” categories within the matrix of pathways and indicators used by National Marine Fisheries Service (1996). 24 The definitions and rationale for the terms maintain, restore, degrade, retard attainment, short-term, and long-term are included in Forest Plan standard WM-1S.
Final Environmental Impact Statement, Volume 3 

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133

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

RMA-3S Guideline

Generally, trees needed to maintain, 

protect, or enhance aquatic and riparian 

resources that are felled for safety should 

be felled and left on site.

These alternatives retain 

the alternative B

management direction.

Standard 

Trees felled for safety shall be retained onsite unless in excess of 

what is needed to achieve aquatic and riparian desired conditions. 

If the desired quantity and size distribution of large wood has been 

met on site, the wood can be transported to other aquatic and 

riparian restoration projects.

RMA-4G 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. 

These alternatives retain 

the alternative B

management direction.

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. To prevent the spread of invasive 

species, water should not be discharged into other water bodies.

RMA-5S Standard

Pumps shall be screened at drafting sites 

to prevent entrainment of fish and shall 

have one-way valves to prevent back-flow 

into streams. 

These alternatives retain 

the alternative B

management direction.

Standard

Pumps shall be screened at drafting sites to prevent entrainment of 

fish and shall have one-way valves to prevent back-flow into 

streams. 

RMA-6G Guideline

Fish habitat and water quality should be 

protected when withdrawing water for 

administrative purposes.

These alternatives retain 

the alternative B

management direction.

Guideline

Fish habitat and water quality should be protected when 

withdrawing water for administrative purposes. 

RMA-7S This alternative has no corresponding 

standard or guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Refueling shall occur with appropriate containment equipment and 

a spill response plan in place. Wherever possible, storage of 

petroleum products and refueling will occur outside of riparian 

management areas. The use of containment devices, absorbent 

pads, and a developed spill plan will help reduce the risk of fuel 

and petroleum products from getting into streams and other 

waterways if an accident were to occur. If refueling or storage of 

petroleum products is necessary within RMAs, these operations 

will be conducted no closer than 100 feet from waterways
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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134

Fuels Management and Wildland (Unplanned) Fire Activities within MA 4B

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

MA 4B

RMA-FIRE-1 

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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives have no corresponding standard or guideline.

FM-11G Guideline

Chemicals and retardant should 

not be used for suppression and 

mop-up within riparian areas.

These alternatives retain the 

alternative B management 

direction.

Guideline

Chemicals or retardant should not be used for suppression or 

mop-up within riparian areas. 

FM-6G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

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.

FM-7G Guideline

Pumping directly from a stream 

channel should be avoided if 

chemical products are to be 

injected directly into the system. 

When chemicals are used, 

pumping should be conducted 

from a fold-a-tank that is located 

outside the riparian area.

These alternatives retain the 

alternative B management 

direction.

Guideline

Pumping directly from a stream channel should be avoided if 

chemical products are to be injected directly into the system. When 

chemicals are used, pumping should be conducted from a fold-atank that is located outside the riparian area. 

FM-12S Guideline

Pumps and charged hoses 

should not be back flushed into 

live water.

These alternatives retain the 

alternative B management 

direction.

Standard 

Pumps and charged hoses shall not be back flushed into stream 

channels, wetlands, or surface water. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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135

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

FM-1G Guideline

Temporary firefighting facilities 

(e.g., incident bases, camps, 

helibases, staging areas, 

helispots, and other centers) for 

incident activities should be 

located outside riparian 

management areas. When no 

practical alternative exists, all 

appropriate measures to 

maintain, restore, or enhance 

aquatic and riparian dependent 

resources should be used. 

(See guideline MA4B RMA-FIRE1). 

These alternatives retain the 

alternative B management 

direction.

Guideline

Locate temporary firefighting facilities (e.g., incident bases, camps, 

helibases, staging areas, helispots, and other centers) for incident 

activities outside RMAs. When no practical alternative exists, all 

appropriate measures to protect, maintain, restore, or enhance 

aquatic and riparian dependent resources should be used. If the 

only suitable location for such activities is within a RMA, use may 

be granted following review by a resource advisor and discussion 

with the agency administrator. The resource advisor will work with

the incident management team to prescribe the location, use 

conditions, and rehabilitation requirements. Use an 

interdisciplinary team to predetermine suitable incident base and 

helibase locations. 

MA 4B

RMA-FIRE-6 

Guideline

Aerial application of chemical 

retardant, foam, or other 

firefighting chemicals and 

petroleum should be avoided 

within 300 feet of waterways. 

These alternatives retain the 

alternative B management 

direction.

These alternatives have no corresponding standard or guideline.

MA 4B

RMA-FIRE-7 

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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives have no corresponding standard or guideline.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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136

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

FM-3S Standard 

Portable pump set-ups shall 

include containment provisions 

for fuel spills and fuel containers 

shall have appropriate 

containment provisions. Vehicles

shall be parked in locations that 

avoid entry of spilled fuel into 

streams. 

These alternatives retain the 

alternative B management 

direction.

Standard 

Portable pump set-ups shall include containment provisions for 

fuel spills and fuel containers shall have appropriate containment 

provisions. Vehicles shall be parked in locations that avoid entry of 

spilled fuel into streams. When drafting, pumps shall be screened 

at drafting sites to prevent entrainment of aquatic species, screen 

area shall be sized to prevent impingement on the screens, and 

shall have one-way valves to prevent back-flow into streams. Use 

National Marine Fisheries Service approved screening criteria 

where listed fish or critical habitat are present. 

FM-4G Guideline

Generally, firelines should be 

located and configured to 

minimize sediment delivery, 

creation of new stream channels, 

and unauthorized roads and 

trails.

These alternatives retain the 

alternative B management 

direction.

Guideline

Locate and configure firelines to minimize sedimentation to 

waterbodies, capture of overland and stream flows, and 

development of unauthorized roads and trails. Restore firelines 

following suppression or prescribed fire activities. 

FM-5S Standard 

To minimize soil damage when 

chipping fuels within riparian 

management areas, chip bed 

depths on dry soils shall be 

limited to 7.5 cm or less (Busse et 

al. 2005). 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain the alternative B management direction.

FM-8G Standard 

Minimum Impact Suppression 

Tactics (NWCG 2006) techniques

for wildfire suppression activities

shall be used in riparian 

management areas. 

These alternatives retain the 

alternative B management 

direction.

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. 

FM-9G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Guideline

Prescribed burn direct ignition in RMAs should not be used unless 

site/project scale effects analysis demonstrates that it would not 

retard attaining aquatic and riparian desired conditions.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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137

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

FM-10S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Ensure prescribed burn projects contribute to and do not retard the 

attainment of the aquatic and riparian desired conditions.

Silviculture and Timber Management within MA 4B

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

TM-1S Guideline

Silvicultural treatments should 

occur in riparian management 

areas only as necessary to 

maintain, restore or enhance 

conditions that are needed to 

support aquatic and riparian 

dependent resources. 

These alternatives retain the 

alternative B management direction.

Standard 

Silvicultural treatments shall occur in riparian management areas 

only as necessary to maintain, enhance or restore desired 

conditions for aquatic and riparian resources. When conducted, 

these activities shall avoid or minimize adverse effects to aquatic 

and riparian resources. Vegetation in riparian management 

areas shall not be subject to regularly scheduled timber harvest, 

because they are not part of the timber suitability landbase. 

TM-2S 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 (i.e., 

bankfull depth measured at 

thalweg).

These alternatives retain the 

alternative B management direction.

Standard

Fuelwood cutting shall not be authorized in RMAs unless 

specifically designed to attain aquatic and riparian desired 

conditions. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

138

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

TM-3G Guideline

New landings, designated skid 

trails, staging or decking should 

not occur in riparian management 

areas, unless there are no 

reasonable alternatives, in which 

case they should:

Be of minimum size

Be located outside the active 

floodplain

Minimize effects to large wood, 

bank integrity, temperature, and 

sediment levels

These alternatives retain the 

alternative B management direction.

Guideline

Use of existing or construction of new landings, designated skid 

trails, staging, and decking should not occur in riparian 

management areas, unless they are associated with projects 

designed to improve riparian management areas conditions. 

These features should:

• be of minimum size,

• be located outside the active floodplain, and 

• avoid negative effects to large wood, bank integrity, 

temperature, and sediment levels.

TM-4G Guideline

Yarding activities should achieve 

full suspension over the active 

channel.

Active channel is the bankfull width 

of flowing perennial or intermittent 

streams.

These alternatives retain the 

alternative B management direction.

Guideline

Yarding activities should achieve full suspension over the active 

channel25 unless other alternatives will have less damage to 

riparian areas and stream channels.

TM-5S This alternative has no 

corresponding standard or 

guideline

These alternatives have no 

corresponding standard or guideline

Standard 

Silvicultural practices shall include provisions, as appropriate, to 

avoid detrimental changes in water temperatures, blockages of 

water courses; including protection for streams, stream banks, 

shorelines, lakes, wetlands, and other bodies of water, and 

deposits of sediment.

TM-6S This alternative has no 

corresponding standard or 

guideline

These alternatives have no 

corresponding standard or guideline

Standard

Silvicultural practices shall include provisions (e.g., BMPs) for 

the maintenance or restoration of soil resources.

TM-7S This alternative has no 

corresponding standard or 

guideline

These alternatives have no 

corresponding standard or guideline

Standard 

Timber harvest on lands not suitable for timber production shall

occur only to meet desired conditions for each management area 

other than timber production.

 

25 Active channel is the bank full width of flowing perennial or intermittent streams.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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139

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

TM-8G This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

Guideline

In watersheds in which stream channels and aquatic habitats are 

in properly functioning condition, forest vegetation within RMAs 

should be managed to maintain or increase large wood 

recruitment and delivery to streams.

TM-9S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

Standard 

In watersheds in which stream channels and aquatic habitats are 

not in properly functioning condition, and where instream wood 

frequency and volume are below reference conditions and/or site 

potential, manage forest vegetation within RMAs to maintain or 

increase large wood recruitment and delivery to streams.

TM-10S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

Standard 

As directed by the National Forest Management Act, timber 

harvest shall only occur when a site-specific finding has 

determined that it will not cause irreversible damage to soil, 

slope, or other watershed conditions.

Range Management and Domestic Livestock Grazing within MA 4B

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

GM-1S This alternative has no 

corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or 

guideline.

Standard 

Manage livestock grazing to attain aquatic and riparian desired 

conditions. Where livestock grazing is found to prevent or retard 

attaining aquatic and riparian desired conditions, modify grazing 

practices (such as number of livestock, timing, and physical 

structures). If adjusting practices is not effective, remove livestock 

from that area using appropriate administrative authorities and 

procedures.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

140

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified Departure

GM-2S 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. 

These alternatives retain the 

alternative B management 

direction.

Standard 

New livestock handling and/or management facilities shall be 

located outside riparian management areas unless they do not 

prevent or retard attaining aquatic and riparian desired conditions. 

GM-3G Guideline 

Table A-32 displays the 

maximum utilization guidelines for 

riparian management areas.

Guideline 

Table A-32 displays the maximum 

utilization guidelines for riparian 

management areas.

Guideline

See text following Table A-32. 

Table A-32. Maximum utilization1 within riparian management areas – Alternatives B, C, D, E and F

Measure Alt. B Alt. C2 Alt. D Alt. E3 Alt. F 

Maximum percent utilization 

of woody vegetation (percent 

of mean annual vegetative 

production)

40% 25% 40% 25% within bull trout spawning 

and rearing reaches 

40% for all other watercourses 

including anadromous fish 

reaches

25% in bull trout spawning and rearing habitat (all three 

National Forests) 

35% in anadromous fish reaches (UMA and WAW)

40% outside bull trout spawning and rearing habitat (MAL)

40% outside anadromous fish reaches (UMA and WAW)

Maximum percent utilization 

of herbaceous 

vegetation(percent of mean 

annual vegetative 

production)

40% 10% 40% 25% within bull trout spawning 

and rearing reaches 

40% for all other watercourses 

including anadromous fish 

reaches

25% in bull trout spawning and rearing habitat (all three 

National Forests) 

35% in anadromous fish reaches (UMA and WAW)

40% outside bull trout spawning and rearing habitat (MAL)

40% outside anadromous fish reaches (UMA and WAW)

1. In addition, the minimum residual stubble height (applies at the greenline) for all alternatives is 4 to 6 inches. The maximum bank alteration for all alternatives is 20 percent.

2. For alternative C, this is a standard for maximum utilization within riparian management areas.

3. See next page for Alternatives E-Modified and E-Modified Departure

UMA = Umatilla; WAW = Wallowa-Whitman; MAL = Malheur
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

141

Alternatives E-Modified and E-Modified Departure - GM-3G Annual livestock use and 

disturbance indicators

Guideline GM-3G. The purpose of this guideline is to manage livestock grazing to help attain and 

maintain aquatic and riparian desired conditions over time. Specifically, it is intended to maintain or 

improve vegetative and stream conditions, help ensure the viability of aquatic species, provide 

important contributions to the recovery of federally listed species, and facilitate attainment of State 

water quality standards.

The annual livestock use and disturbance indicators described below should be applied to help achieve, 

over longer timeframes, conditions at site and watershed scales that enable attainment and maintenance 

of desired conditions. The values specified below are starting points for management. Only those 

indicators and numeric values that are appropriate to the site and necessary for maintaining or moving 

towards desired conditions should be applied.26 Specific indicators and indicator values should be 

prescribed and adjusted, if needed, in a manner that reflects existing and desired conditions and the 

natural potential of the specific geo-climatic, hydrologic and vegetative setting in which they are being 

applied.27 Indicators and indicator values should be adapted over time based on long-term monitoring 

and evaluation of conditions and trends. Alternative use and disturbance indicators and values, including 

those in current Endangered Species Act consultation documents or non-Endangered Species Act

allotment management plans or allotment analysis decisions, may be used if they are based on best 

available science and monitoring data and meet the purpose of this guideline.

1. Where desired conditions for water quality, aquatic habitat, and riparian vegetation have been 

attained28 and riparian vegetation is in late-seral condition,

29 protect or maintain those conditions by 

managing annual livestock grazing use and disturbance as follows: 30

• maintain a minimum of 4-inch residual stubble height 31 of key herbaceous species on the 

greenline;

 

26 Not all indicators may apply to a particular site. For example, stubble height is a meaningful indicator for lower gradient 

streams where herbaceous vegetation plays an important role in stabilizing streambanks. It is generally less useful for steeper 

channels, where channel morphology is controlled by coarse substrates. Moreover, not all numeric values may apply to a 

particular site (e.g., sites with short graminoids).

27 Indicator values for specific sites should be determined based on consideration of local conditions including, but not limited to, 

the degree of departure between existing and desired conditions, the current and desired rate of improvement, site sensitivity to 

grazing, grazing season, the presence of special status species (e.g., ESA-listed species, Regional Forester’s sensitive species) that 

are sensitive to grazing, whether or not water quality standards and related requirements (e.g., TMDLs for impaired waters) are 

being met, and the site’s importance in maintaining or attaining those standards and requirements. Consideration of these 

conditions is especially important in prescribing specific stubble height values within the 4-inch to 6-inch range and streambank 

alteration values within the 15-20% range. 

28 Assessment of conditions and trends should be based on best available information at a variety of spatial and temporal scales. 

Site-specific information is particularly important.

29 Late seral conditions means the existing riparian vegetation community is similar to the potential natural community 

composition (per Winward 2000).

30 Per PACFISH/INFISH Monitoring, Multiple Indicator Monitoring (BLM Technical Reference 1737-23) protocols or 

comparable methods for stubble height, streambank alteration, and use of woody species. Per Bureau of Land Management 

protocols (BLM/RS/ST-96/004+1730) or comparable methods for herbaceous utilization.

31 Stubble height criteria apply at the end of the grazing period, when that period ends after the growing season. When the 

grazing period ends before the growing season does, stubble height criteria can be applied at the end of the grazing period or 

the end of the growing season.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

142

• utilize no more than 30-45 percent of deep-rooted herbaceous vegetation in the active 

floodplain32 and, as needed, in other critical portions of the riparian management area; 

• limit streambank alteration33 to no more than 20-25 percent; and 

• limit use of woody species to no more than 30-40 percent of current year’s leaders along 

streambanks and, as needed, in other critical portions of the riparian management area.

2. Where desired conditions for water quality, aquatic habitat, and/or riparian vegetation have not yet 

been attained, but conditions are moving towards those desired conditions,28 enable continued 

recovery by managing annual livestock grazing use and disturbance as follows:

• maintain a minimum of 4-inch to 6-inch residual stubble height of key herbaceous species on 

the greenline;31

• follow the criteria for utilization of deep-rooted herbaceous vegetation, streambank alteration, 

and use of woody species described in number 1 above. 

3. Where desired conditions for water quality, aquatic habitat, and/or riparian vegetation have not been 

attained and conditions are not moving towards those desired conditions28, enable recovery by 

managing annual livestock grazing use and disturbance as follows:

• maintain a minimum of 6-inch residual stubble height of key herbaceous species on the 

greenline;

• utilize no more than 30-35 percent of deep-rooted herbaceous vegetation in the active floodplain 

and, as needed, in other critical portions of the riparian management area; 

• limit streambank alteration to no more than 15-20 percent;27 and 

• limit use of woody species to no more than 20-30 percent of current year’s leaders along 

streambanks and, as needed, in other critical portions of the riparian management area.

 

32 Active floodplain is defined as the area bordering a stream inundated by flows at a surface elevation that is two times the 

maximum bankfull depth (measured at the thalweg).

33 Streambank alteration criteria apply within 1-2 weeks of removal of livestock from each pasture.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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143

Range Management and Domestic Livestock Grazing within MA 4B (continued)

Standard or 

Guideline 

Designator

Alternative B Alternatives C, E and F Alternative D Alternatives E-Modified and 

E-Modified Departure

GM-4G Guideline

During allotment management 

planning, removing existing 

livestock handling or 

management facilities from 

riparian management areas 

should be considered. 

These alternatives retain the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Guideline

During allotment management 

planning, existing livestock 

handling or management 

facilities that prevent or retard 

attaining aquatic and riparian 

desired conditions should be 

removed, as appropriate.

GM-5G Guideline

Livestock trailing, bedding, 

watering, loading, and other 

handling in riparian management 

areas should be minimized. 

These alternatives retain the 

alternative B management 

direction.

This alternative retains the 

alternative B management 

direction.

Guideline 

Livestock trailing, watering, 

loading, and other handling in 

riparian management areas 

should be avoided or 

minimized.

GM-6S Standard

Trampling of federally listed 

threatened or endangered fish 

redds by livestock shall be 

avoided. 

These alternatives retain the 

alternative B management 

direction.

Guideline

Trampling of federally listed 

threatened or endangered fish 

redds by livestock should be 

avoided. 

Standard

Livestock grazing shall be 

managed and implemented to 

avoid trampling federally listed 

threatened or endangered fish 

redds. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

144

Roads Management within MA 4B

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified 

Departure

RF-1G This alternative has no corresponding standard 

or guideline.

These alternatives have no 

corresponding standard or guideline.

Guideline

New roads and trails should not be constructed 

within riparian management areas unless no other 

feasible alternative exists. 

RF-2G This alternative has no corresponding standard 

or guideline.

These alternatives have no 

corresponding standard or guideline.

Guideline

Temporary roads, including stream crossings, in 

RMAs should be minimized. Temporary roads, if 

constructed, should be managed to protect and 

restore aquatic and riparian desired conditions.

RF-3S Standard 

Side-casting (placement of unconsolidated 

earthen waste materials resulting from road 

construction or maintenance) in riparian 

management areas shall be avoided. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.

RF-4S Standard 

Fill material shall not be placed on organic 

debris in riparian management areas. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.

RF-5S 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 reconstructing roads or 

landings either inside or outside of riparian 

management areas. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.

RF-6G 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. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

145

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified 

Departure

RF-7S 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. 

These alternatives retain the 

alternative B management direction.

Standard 

New or replaced permanent stream crossings shall 

be designed to allow for the 100-year flood and its 

bedload and debris. 100-year flood estimates will 

reflect the best available science regarding potential 

effects of climate change

RF-8S Standard

Where physically feasible, construction or 

reconstruction of stream crossings shall avoid 

diversion of streamflow out of the channel and 

down the road in the event of crossing failure. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.

RF-9S Standard 

In fish bearing streams, construction or 

reconstruction of stream crossings shall

provide and maintain passage for all fish 

species and all life stages of fish. 

These alternatives retain the 

alternative B management direction.

Standard 

Construction or reconstruction of stream crossings 

shall provide and maintain passage for all life 

stages of all native and desired non-native aquatic 

and riparian-dependent organisms. Crossing 

designs shall reflect the best available science 

regarding potential effects of climate change on 

peak flows and low flows.

MA 4B

RMA-RD-8 

Guideline

Construction or reconstruction of stream 

crossings should allow passage for other 

riparian dependent species where connectivity 

has been identified as an issue. 

These alternatives retain the 

alternative B management direction.

See RF-9S above.

RF-10G Guideline

Fish passage barriers should be retained 

where they serve to restrict access by 

undesirable nonnative species and are 

consistent with restoration of habitat for native 

species. 

These alternatives retain the 

alternative B management direction.

These alternatives retain the alternative B 

management direction.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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146

Standard or 

Guideline 

Designator

Alternative B Alternatives C, D, E and F Alternatives E-Modified and E-Modified 

Departure

RF-11G Guideline

Hydrologic connectivity and sediment delivery 

from roads should be minimized. This includes 

roads inside and outside of riparian 

management areas. 

These alternatives retain the 

alternative B management direction.

Guideline

Design roads to minimize delivery of water and 

sediment from roads to streams. Avoid or minimize 

disruption of hydrologic flow paths, including 

diversion of streamflow and interception of surface 

and subsurface flow when constructing, 

reconstructing, and maintenance of roads or 

landing.

RF-12G Guideline

Road drainage should be routed away from 

potentially unstable channels, fills, and 

hillslopes. This applies both inside and outside 

of riparian management areas. 

These alternatives retain the 

alternative B management direction.

Guideline

Road drainage should be routed away from 

potentially unstable channels, fills, and hillslopes to 

the extent practicable. 

RF-13S This alternative has no corresponding standard 

or guideline.

These alternatives have no 

corresponding standard or guideline.

Standard

Road maintenance and new road construction shall 

be designed to minimize adverse effects to 

threatened, endangered, proposed, or candidate 

aquatic species and their habitat.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

147

Recreation Management within MA 4B34

Standard or

Guideline 

Designator

Alternative B Alternative C Alternatives D, E and F Alternatives E-Modified and 

E-Modified Departure

RM-1G

MA 4B

RMA-REC-1 

G-126

Guideline

Generally, placing new facilities 

or infrastructure within expected 

long-term channel migration 

zones should be avoided. Where 

activities, such as the placement 

or construction of road-stream 

crossings, boat ramps, docks, 

and interpretive trails, inherently 

must occur in riparian 

management areas, locate them 

to minimize impacts on riparian 

dependent resource conditions 

(e.g., within geologically stable 

areas, avoiding major spawning 

sites). 

Standard

Placing new facilities or 

infrastructure within expected longterm 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 riparian 

management areas, they shall be 

located to minimize impacts on 

riparian dependent resource 

conditions (e.g., within geologically 

stable areas, avoiding major 

spawning sites).

This alternative retains the 

alternative B management 

direction.

Guideline

New facilities or infrastructure 

should not be placed within 

expected long-term channel 

migration zones if it has the 

potential to impact channel or 

floodplain function. If some 

facilities must occur in riparian 

management areas (e.g., road 

stream crossings, boat ramps, 

docks, and interpretive trails), 

locate and design them to 

minimize impacts on 

floodplains and other riparian 

dependent resource conditions 

(e.g., within geologically stable 

areas, avoiding major 

spawning sites)

RM-2G

MA 4B

RMA-REC-2 

G-127

Guideline

Removing or relocating existing 

recreation facilities that are 

causing unacceptable impacts in 

riparian management areas 

should be considered. 

Standard

Existing recreation facilities that are 

causing unacceptable impacts in 

riparian management areas shall be 

relocated. 

This alternative retains the 

alternative B management 

direction.

Guideline

Existing recreation facility 

components that are causing 

unacceptable impacts in 

riparian management areas 

should be removed or 

relocated. Site condition should 

be restored to improve riparian 

area function. 

 

34 Standards and guidelines apply to all three National Forests.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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148

Minerals Management within MA 4B35

Standard or 

Guideline 

Designator

Alternative B Alternative C and D Alternatives, E and F Alternatives E-Modified and E-Modified 

Departure

MM-1G Guideline

Adverse effects to aquatic and 

other riparian-dependent 

resources from mineral 

operations should be minimized 

or avoided. For operations in 

riparian management areas, 

ensure operators take all 

practicable measures to maintain, 

protect, and rehabilitate water 

quality and habitat for fish and 

wildlife and other riparian 

dependent resources that may be 

affected by the operations. 

This alternative retains 

the alternative B 

management direction.

This alternative retains the 

alternative B management 

direction.

Guideline 

For operations in RMAs, ensure operators take 

all practicable measures to maintain, protect, 

and rehabilitate water quality and habitat for fish 

and wildlife and other riparian dependent 

resources that may be affected by the 

operations. Ensure operations do not retard or 

prevent attaining aquatic and riparian desired 

conditions. Exceptions to this guideline include 

situations where Forest Service has limited 

discretional authorities. In those cases, project 

effects should be minimized and should not 

prevent or retard attaining aquatic and riparian 

desired conditions to the extent possible within 

those authorities.

MM-2G Guideline

Structures, support facilities, and 

roads should be located outside 

riparian management areas. 

Where no alternative to siting 

facilities in riparian management 

areas exists, locate them in a way 

to minimize adverse effects to 

aquatic and other ripariandependent resources. Existing 

roads should be maintained to 

minimize damage to aquatic and 

riparian dependent resources. 

This alternative retains 

the alternative B 

management direction.

This alternative retains the 

alternative B management 

direction.

Guideline

To the maximum extent possible locate and 

manage structures, support facilities, and roads 

outside riparian management areas. Where 

none exists, locate and manage them to 

minimize effects upon aquatic and ripariandependent desired conditions. Existing roads 

should be maintained to minimize damage to 

aquatic and riparian dependent resources. 

When structures, support facilities, and roads 

are no longer required for mineral activities, 

they should be restored or reclaimed to achieve 

aquatic and riparian desired conditions.

 

35 Standards and guidelines apply to all three National Forests.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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149

Standard or 

Guideline 

Designator

Alternative B Alternative C and D Alternatives, E and F Alternatives E-Modified and E-Modified 

Departure

MM-3S Standard 

Mine waste facilities with the 

potential to generate hazardous 

material (per CERCLA) shall be 

located outside of riparian 

management areas. If no 

reasonable alternative to locating 

these facilities in riparian 

management areas exists, then 

locate and design the waste 

facilities using the best 

conventional techniques to 

ensure mass stability and prevent 

the release of acid or toxic 

materials. 

These alternatives

retains the alternative B 

management direction.

This alternative retains the 

alternative B management 

direction.

Standard 

Mine waste with the potential to generate 

hazardous material (as defined by CERCLA) 

shall not be authorized within RMAs and/or 

areas where groundwater contamination is 

possible. The exception is temporary staging of 

waste during abandoned mine cleanup. 

MM-4G Guideline

Where possible, the operating 

plans for existing activities should 

be adjusted to minimize adverse 

effects to aquatic and riparian 

dependent resources in the 

riparian management areas. 

This alternative retains 

the alternative B 

management direction.

This alternative retains the 

alternative B management 

direction.

Guideline

Mineral operations should minimize adverse 

effects to aquatic and riparian-dependent 

resources in RMAs. Require BMPs and other 

appropriate conservation measures to mitigate 

potential mine operation effects. 
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

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150

Lands Ownership (Hydropower) within MA 4B36

Standard or 

Guideline 

Designator

Alternative B Alternative C, D, E, and F

Alternatives E-Modified 

and E-Modified 

Departure

MA 4B

RMA-HYD-1 

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 re-establishment, 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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain 

the alternative B 

management direction.

MA 4B

RMA-HYD-2 

Standard

New support facilities shall be located outside of riparian management areas. 

Support facilities include any facilities or improvements (e.g., 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. 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain 

the alternative B

management direction.

MA 4B

RMA-HYD-3 

Guideline

If existing support facilities are located within the riparian management areas, 

they should be operated and maintained to restore or enhance aquatic and 

riparian dependent resources. At time of permit re-issuance, consider 

removing support facilities, where practical. 

These alternatives retain the 

alternative B management 

direction.

These alternatives retain 

the alternative B

management direction.

MA 5 Developed Sites and Administrative Areas

Standard or 

Guideline 

Designator

Alternative B Alternative C, D, E, and F Alternatives E-Modified and EModified Departure

MA5-1G This alternative has no corresponding standard or 

guideline.

These alternatives have no 

corresponding standard or guideline.

Facilities should be maintained and 

protected to support management 

operations. 

NOTE: MA 3C Wildlife Corridor does not have specific standards or guidelines. 

 

36 Standards and guidelines apply to all three National Forests.
Final Environmental Impact Statement, Volume 3 

Appendix A. Forest Plan Revision Alternatives in Detail

Revised Land Management Plans for the Blue Mountains national forests

151

Monitoring and Evaluation Plan for the Plan Revision Alternatives

Monitoring includes testing assumptions, tracking changes, and measuring management 

effectiveness and progress toward achieving or maintaining the plan’s desired conditions or 

objectives. Monitoring information should enable the Forest to determine if a change in plan 

components or other plan content applicable to the plan area may be needed, forming the basis for 

continual improvement and adaptive management. Monitoring also serves as a means to inform the 

management of resources on the plan area, through means such as testing relevant assumptions, 

tracking relevant changes, and measuring management effectiveness and progress toward achieving 

or maintaining the plan’s desired conditions or objectives. 

Monitoring and evaluation are separate, sequential activities required by the National Forest 

Management Act. Monitoring is the collection of data by observation or measurement. Evaluation 

is the analysis and interpretation of monitoring data. The results of monitoring and evaluation may 

lead to changes in forest plan management direction. 

There are three types of monitoring: implementation, effectiveness, and validation. Implementation 

monitoring evaluates whether “we did what we said we would do.” Effectiveness monitoring 

evaluates how well a particular practice helps achieve a project objective, such as the effectiveness 

of a standard or guideline. The purpose of validation monitoring is to test key assumptions and 

generally involves designed research. 

Two monitoring approaches, using implementation and effectiveness-type monitoring actions, are 

used for monitoring the Plan area to determine whether the land management plan needs to be 

changed. 

1. The plan monitoring program identifies the monitoring questions and associated indicators for 

monitoring the plan. The Plan monitoring program consists of a set of monitoring questions 

and associated indicators to evaluate whether plan components are effective and appropriate 

and whether management is effective in maintaining or achieving progress toward desired 

conditions and objectives for the plan area. 

2. Broader-scale monitoring information is used to address relevant plan monitoring questions 

that are best answered at a larger geographic scale. The regional forester is responsible for

developing a broader-scale monitoring strategy (FSH 1909.12 sec. 33) to answer and manage 

plan monitoring questions common to two or more plan areas in the Region. Broader-scale 

monitoring strategies may be comprised of questions and indicators or may also include a 

description of protocols, data management, responsibilities, and partnerships for the questions 

and indicators. An example of broad-scale monitoring may include the PACFISH INFISH 

Biological Opinion Effectiveness Monitoring program, which addresses the condition of 

aquatic and riparian communities within the range of steelhead and bull trout. 

The Plan monitoring program will be coordinated and integrated with broader-scale monitoring 

strategies to ensure that monitoring is complementary and efficient, and that information is 

gathered at scales appropriate to the monitoring questions (36 CFR 219.12). Biennial monitoring 

evaluation reports will document whether a change to the plan or monitoring program is warranted 

based on new information, whether a new assessment may be needed, or whether there is no need 

for change at that time (36 CFR 219.12). The monitoring evaluation report will summarize plan 

monitoring results and will incorporate broad-scale monitoring information to answer the relevant 

monitoring and evaluation questions. The report is intended to inform adaptive management for the 

plan area. The monitoring evaluation report will be made available to the public. 

To reduce duplicative text, the monitoring plan is not repeated here. Please refer to the monitoring 

plan in the revised forest plans, as appended to the draft Record of Decision. 

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153

Appendix B: Laws and

Regulations Relevant to Forest Planning

There is a complex legal framework within which planning takes place for management actions

proposed within National Forest System lands. The following list, while not comprehensive, will 

provide some guidance as to the laws, regulations, executive orders and other guiding direction 

applied to planning for multiple uses and a range of resource needs. Forest Service Manuals and 

Handbooks also provide more specific guidance. This list is intended to provide some context for 

the development of desired conditions, standards, guidelines, proposed management activities, 

and the decisionmaking process. A simple internet search of any law or regulation listed here can 

provide more information. 

Laws

American Indian Religious Freedom Act of 1996 

Antiquities Act of 1906

Archaeological and Historic Preservation Act of 1974 

Archaeological Resources Protection Act of 1979 

Architectural Barriers Act of 1968

Bald and Golden Eagle Protection Act of 1940 

Civil Rights Act (Titles VI, VII, and IX)

Clean Air Act of 1970 

Cooperative Forestry Assistance Act of 1978

Economy Act of 1932 

Endangered Species Act of 1973 

Federal Land Assistance, Management and Enhancement Act of 2009

Federal Land Policy and Management Act of 1976 

Federal Lands Recreation Enhancement Act of 2004 

Federal Noxious Weed Act of 1974 

Forest and Rangeland Renewable Resources Planning Act of 1974 

Forest Service Partnership Enhancement Act of 2006 

Granger-Thye Act of 1950 

Healthy Forests Restoration Act of 2003 

Highway Safety Act of 1966

Land and Water Conservation Fund Act of 1965 

Magnuson-Stevens Fishery Conservation and Management Act of 1976 

Migratory Bird Treaty Act of 1918 

Multiple-Use Sustained Yield Act of 1960 

National Environmental Policy Act of 1969 

National Forest Management Act of 1976

National Historic Preservation Act of 1966 

National Trails System Act of 1968 
Final Environmental Impact Statement, Volume 4 

Appendix B: Laws and Regulations Relevant to Forest Planning

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

154

Native American Graves Protection and Repatriation Act of 1990

Omnibus Oregon Wild and Scenic Rivers Act of 1988 

Omnibus Parks and Public Lands Management Act of 1996 

Organic Administration Act of 1897

Public Law 94-199 of 1975: To establish the Hells Canyon National Recreation Area in the States 

of Oregon and Idaho, and for other purposes. 

Public Rangelands Improvement Act of 1978 

Reciprocal Fire Protection Act of 1955 

Rehabilitation Act of 1973

Religious Freedom Restoration Act of 1993 

Rescission Act of 1995

Ski Area Recreational Opportunity Enhancement Act of 2011 

Surface Transportation Assistance Act of 1978 

Sustainable Fisheries Act of 1996 

Sustained Yield Forest Management Act of 1944 

Taylor Grazing Act of 1934 

Term Permit Act of 1915 

The Endangered American Wilderness Act of 1978 

The Forest Resources Conservation and Shortage Relief Act of 1990

The Knutson-Vandenberg Act of 1930

The National Forest Roads and Trails Act of 1964 

The Oregon Wilderness Act of 1984 

The Safe Drinking Water Act of 1974 

The Small Business Act of 1953 

Tribal Forest Protection Act of 2004 

Wild and Scenic Rivers Act of 1968 

Wild Horses and Burros Act of 1971 

Wilderness Act of 1964 

Code of Federal Regulations (CFR) 

36 CFR 60: National Register of Historic Places

36 CFR 217: Requesting Review of National Forest Plans and Project Planning 

36 CFR 219 (1982) National Forest System Land and Resource Management Planning Rule 

36 CFR 219 (2012) National Forest System Land Management Planning Rule 

36 CFR 221 Timber Management Planning 

36 CFR 222: Grazing and Livestock Use on the National Forest System

36 CFR 223: Sale and Disposal of National Forest System Timber, Special Forest Products, and 

Forest Botanical Products 

36 CFR 261: Forest Service Prohibitions 

36 CFR 293: Wilderness–Primitive Areas

36 CFR 294: Special Areas; Roadless Area Conservation 
Final Environmental Impact Statement, Volume 4 

Appendix B: Laws and Regulations Relevant to Forest Planning

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155

36 CFR 296: Protection of Archaeological Resources 

36 CFR 800: Protection of Historic Properties

40 CFR 51: Regional Haze Regulations 

43 CFR 7: Protection of Archaeological Resources 

43 CFR 10: Native American Graves Protection and Repatriation Regulations 

Executive Orders 

Executive Order 11593: Protection and Enhancement of the Cultural Environment 

Executive Order 11988: Floodplain Management 

Executive Order 11990: Protection of Wetlands 

Executive Order 12580: Superfund Implementation 

Executive Order 12862: Setting Customer Service Standards 

Executive Order 12866: Regulatory Planning and Review 

Executive Order 12898: Federal Actions to Address Environmental Justice in Minority 

Populations and Low-Income Populations 

Executive Order 13007: Indian Sacred Sites 

Executive Order 13175: Consultation and Coordination with Indian Tribal Governments 

Executive Order 13186: Responsibilities of Federal Agencies to Protect Migratory Birds 

Executive Order 13287: Preserve America

Executive Order 13443: Facilitation of Hunting Heritage and Wildlife Conservation 

Executive Order 13751: Safeguarding the Nation from Impacts of Invasive Species

Treaties 

Treaty of 1855 between the United States and The Confederated Tribes of the Cayuse, Umatilla 

and Walla Walla

Treaties of 1855 and 1863 between the United States and the Nez Perce Tribe 

Treaty of 1868 between the United States and the Eastern Band of Shoshoni and Bannock 

Other Regulations 

USDA regulation 9500-004: Fish and Wildlife Policy 

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157

Appendix C: Responses to Comments on

the Draft Environmental Impact Statement

The purpose of this appendix is to respond to comments received on the Draft Environmental 

Impact Statement. We received comments from 1,104 entities (individuals, organizations, 

agencies, governments, and Tribes). Using “content analysis” we followed a systematic process 

of reading, coding, and summarizing the comments that were submitted. This process ensured 

that every comment was read, analyzed, and considered. Each commenter was assigned a 

commenter code and each unique comment was numbered sequentially and paraphrased into a 

concern statement to focus on issues. Similar comments were grouped and combined into 

“concern statements.” Therefore, while not every comment is listed in this appendix exactly as 

written by each respondent, each comment was considered individually. Concern statements were 

then sorted by topic and arranged alphabetically according to resource and topic. All comments 

received, and the content analysis used to review, code, and sort comments, are located in the 

planning record. 

The interdisciplinary team prepared responses for each comment based on its merits, regardless of 

the source or whether expressed by many or by one. Responses to comments focus on the 

following as required by regulations 40 CFR 1503.4: 

• modifying one or more of the alternatives as requested. 

• developing and evaluating suggested alternatives. 

• supplementing, improving, or modifying the analysis. 

• making factual corrections. 

• explaining why the comments do not warrant further agency response. 

Letters from State, Federal, and local agencies, as well as those received from local Tribes are 

attached in their entirety in Volume 3 in the section “Involvement with Native American Tribes 

and Federal, State, and Local Agencies and Governments.” 
Final Environmental Impact Statement, Volume 4 

Appendix C: Responses to Comments on the Draft Environmental Impact Statement

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158

Contents of Appendix C 

How the Alternative was Developed ....................................................................................................... 2

PACFISH .................................................................................................................................... 2

Inland Native Fish Strategy ......................................................................................................... 2

Eastside Screens .......................................................................................................................... 2

Management Area Acres ......................................................................................................................... 3

1990 Forest Plans Management Direction for Specific Resources ......................................................... 5

Management Direction for Riparian and Aquatic Resources ...................................................... 5

Management Direction for Old Forest ...................................................................................... 13

Management Direction for Invasive Species ............................................................................ 16

Management Direction for Wildlife .......................................................................................... 20

Management Direction for Timber Harvest .............................................................................. 23

Management Direction for Livestock Grazing and Grazing Land Vegetation ......................... 23

Introduction ........................................................................................................................................... 25

Laws and Regulations ............................................................................................................... 25

Special Designations ................................................................................................................. 25

Goals and Desired Conditions ................................................................................................... 25

Alternative Elements (Alternatives B through F) ..................................................................... 26

Suitability of Areas ................................................................................................................... 35

Objectives (Plan Revision Alternatives) ................................................................................... 41

Standards and Guidelines (Alternatives B through F) .............................................................. 67

Management Area Standards and Guidelines ......................................................................... 111

Monitoring and Evaluation Plan for the Plan Revision Alternatives ...................................... 151

Access ................................................................................................................................................. 163

Access: Airstrips ..................................................................................................................... 163

Access: Designated Routes ..................................................................................................... 163

Access: Emphasize Nonmotorized Access ............................................................................. 164

Access: Forest Management ................................................................................................... 164

Access: Forest Products .......................................................................................................... 165

Access: Increase ATV/OHV/OSV Access .............................................................................. 165

Access: Limit Motorized Use.................................................................................................. 166

Access: Motorized Forest Access ........................................................................................... 167

Access: No Road or Access Restrictions ................................................................................ 168

Access: Private Lands and Other Ownerships ........................................................................ 170

Access: Road Density ............................................................................................................. 171

Access: Road Maintenance and Funding ................................................................................ 175

Access: Roads-Wildlife ........................................................................................................... 176

Access: RS 2477 ..................................................................................................................... 177

Access: Snowmobile Access ................................................................................................... 177

Access: Special-Use Permits ................................................................................................... 178

Access: Trail Maintenance ...................................................................................................... 179

Aquatics .............................................................................................................................................. 179

Aquatics: At-risk and Federally Listed Species ...................................................................... 179

Aquatics: Habitat ..................................................................................................................... 184

Aquatics: PACFISH/INFISH .................................................................................................. 186

Climate Change ................................................................................................................................... 189

Climate Change: Aquatics....................................................................................................... 189

Climate Change: Assumptions ................................................................................................ 190

Climate Change: Carbon Sequestration .................................................................................. 191

Climate Change: Ecological Resilience .................................................................................. 194
Final Environmental Impact Statement, Volume 4 

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159

Climate Change: Monitoring and Adaptive Management ...................................................... 196

Cultural ............................................................................................................................................... 197

Cultural: Analysis ................................................................................................................... 197

Cultural: Managing Cultural Resources .................................................................................. 198

Cultural: Tribal Consultation .................................................................................................. 200

Cultural: Tribal Role-Desired Conditions ............................................................................... 201

Cultural: Tribal Role-Treaty Rights ........................................................................................ 201

Cultural: Wildlife and Plants ................................................................................................... 203

Energy ................................................................................................................................................. 204

Energy: Generation and Transmission .................................................................................... 204

Energy: Suitability .................................................................................................................. 204

Forest Management ............................................................................................................................. 205

Forest Management: Biomass ................................................................................................. 205

Forest Management: Cool and Moist Forest Types ................................................................ 206

Forest Management: Ecological Resilience ............................................................................ 207

Forest Management: Existing and Desired Conditions ........................................................... 211

Forest Management: Forest Products ...................................................................................... 214

Forest Management: Historical Range of Variability (HRV) ................................................. 214

Forest Management: Level, Pace and Scale ............................................................................ 217

Forest Management: Old Forests and 21-Inch Rule ................................................................ 220

Forest Management: Restoration ............................................................................................ 223

Forest Management: Salvage .................................................................................................. 226

Forest Management: Snags ..................................................................................................... 227

Forest Management: VDDT Model ........................................................................................ 228

Timber: Allowable Sale Quantity and Timber Sale Program Quantity .................................. 229

Timber: Standards and Guidelines .......................................................................................... 232

Timber: Suitability .................................................................................................................. 234

Grazing ................................................................................................................................................ 236

Grazing: Allotment Monitoring and Compliance ................................................................... 236

Grazing: Animal Unit Months (AUMs) and Production ......................................................... 237

Grazing: Benefits .................................................................................................................... 237

Grazing: Climate Change ........................................................................................................ 238

Grazing: Current and Desired Condition ................................................................................ 238

Grazing: Fees/Permits ............................................................................................................. 239

Grazing: Fire ........................................................................................................................... 239

Grazing: Listed and Sensitive Plant Species ........................................................................... 241

Grazing: Modeling .................................................................................................................. 242

Grazing: No Reduction or Restrictions ................................................................................... 242

Grazing: Range of Alternatives ............................................................................................... 243

Grazing: Restocking Allotments ............................................................................................. 244

Grazing: Restrict or Eliminate Grazing ................................................................................... 244

Grazing: Scale ......................................................................................................................... 247

Grazing: Soils .......................................................................................................................... 247

Grazing: Spatial Data and Grazing Analysis........................................................................... 247

Grazing: Standards and Guidelines ......................................................................................... 248

Grazing: Utilization ................................................................................................................. 249

Grazing: Water Quality ........................................................................................................... 252

Grazing: Wildlife .................................................................................................................... 253

Range: Feral Horses ................................................................................................................ 253

Lands and Special Uses....................................................................................................................... 254

Land and Special Uses: Land Acquisition .............................................................................. 254
Final Environmental Impact Statement, Volume 4 

Appendix C: Responses to Comments on the Draft Environmental Impact Statement

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160

Land and Special Uses: Land Disposition .............................................................................. 255

Land and Special Uses: Land Ownership ............................................................................... 255

Management Areas ............................................................................................................................. 256

MA 2B: Research Natural Areas............................................................................................. 256

MA 2C: Botanical Areas ......................................................................................................... 256

MA 2E: Historical Areas ......................................................................................................... 257

MA 2F: Scenic Byways and All-American Roads and MA 2G: Nationally Designated Trails

 ................................................................................................................................................. 258

Mining ................................................................................................................................................. 259

Mining: Authorities and Law .................................................................................................. 259

Mining: General ...................................................................................................................... 260

Mining: Impacts ...................................................................................................................... 261

Mining: Motorized Access ...................................................................................................... 262

Mining: Wildlife ..................................................................................................................... 262

Planning .............................................................................................................................................. 263

Planning: 1982 Rule ................................................................................................................ 263

Planning: Alternatives-Range ................................................................................................. 264

Planning: Best Available Science ........................................................................................... 266

Planning: Budget ..................................................................................................................... 267

Planning: Goals and Desired Conditions ................................................................................ 268

Planning: Laws, Regulations, Policy ...................................................................................... 269

Planning: Management Areas ................................................................................................. 275

Planning: Monitoring .............................................................................................................. 275

Planning: Process .................................................................................................................... 276

Planning: Separate Plans ......................................................................................................... 278

Planning: Standards and Guidelines ........................................................................................ 278

Plants ................................................................................................................................................... 280

Plants: Current Inventories ...................................................................................................... 280

Plants: Diversity ...................................................................................................................... 280

Plants: Nonnative .................................................................................................................... 281

Plants: Sensitive ...................................................................................................................... 282

Plants: Standards and Guidelines ............................................................................................ 283

Public Involvement ............................................................................................................................. 283

Public Involvement: Collaboration and General ..................................................................... 283

Public Involvement: Cooperation-NEPA ................................................................................ 284

Public Involvement: Coordination-NFMA ............................................................................. 285

Recreation and Scenery ....................................................................................................................... 286

Recreation: Developed Recreation .......................................................................................... 286

Recreation: Dispersed Recreation ........................................................................................... 286

Recreation: Increase Opportunities ......................................................................................... 287

Recreation: Mountain Bike Support ........................................................................................ 287

Scenery .................................................................................................................................... 288

Social and Economic ........................................................................................................................... 290

Social and Economic: Analysis ............................................................................................... 290

Social and Economic: Balance with Ecological Analysis ....................................................... 294

Social and Economic: Coordination ........................................................................................ 295

Social and Economic: Desired Conditions .............................................................................. 295

Social and Economic: Economic Well-being ......................................................................... 297

Social and Economic: Grazing ................................................................................................ 300

Social and Economic: Manage for Social and Economic Benefits ......................................... 302

Social and Economic: Mining ................................................................................................. 305
Final Environmental Impact Statement, Volume 4 

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161

Social and Economic: Social Well-being ................................................................................ 305

Social and Economic: Timber ................................................................................................. 306

Social and Economic: Tribal Economics ................................................................................ 307

Social and Economic: Vision .................................................................................................. 308

Social and Economic: Wilderness ........................................................................................... 308

Soil ...................................................................................................................................................... 309

Soil: Productivity and Health .................................................................................................. 309

Soil: Wildfire and Prescribed Fire ........................................................................................... 311

Water Quality ...................................................................................................................................... 312

Water Quality: Pollutants ........................................................................................................ 312

Water Quality: Sediment ......................................................................................................... 312

Water Quality: Stream Temperatures ...................................................................................... 313

Watershed ........................................................................................................................................... 314

Watershed: Assessments ......................................................................................................... 314

Watershed: Key and Priority Watersheds ............................................................................... 316

Watershed: Monitoring ........................................................................................................... 318

Watershed: Riparian- Riparian Management Areas (RMAs) ................................................. 319

Watershed: Roads ................................................................................................................... 323

Watershed: Use and Rights ..................................................................................................... 326

Wilderness, Backcountry, and Wild and Scenic Rivers ...................................................................... 327

Wilderness: Against Designation ............................................................................................ 327

Wilderness: For Designation ................................................................................................... 335

MA1A and 1B: Standards and Guidelines .............................................................................. 341

MA3A and 3B: Backcountry and Roadless Areas .................................................................. 342

MA1C: Wilderness Study Area .............................................................................................. 345

MA3C: Wildlife Corridors ...................................................................................................... 345

MA2A: Wild and Scenic Rivers ............................................................................................. 346

Wildfire ............................................................................................................................................... 351

Wildfire: Analysis and Planning ............................................................................................. 351

Wildfire: Fuels and Fire Risk .................................................................................................. 351

Wildfire: Historical Range of Variability................................................................................ 352

Wildfire: Prescribed Fire ......................................................................................................... 352

Wildfire: Prescribed Fire - Air Quality ................................................................................... 353

Wildfire: Standards and Guidelines ........................................................................................ 354

Wildfire: Suppression and Wildland Fire Use ........................................................................ 354

Wildfire: Wildland Urban Interface ........................................................................................ 355

Wildlife ............................................................................................................................................... 355

Wildlife: Bighorn Sheep - Domestic Grazing ......................................................................... 355

Wildlife: Bighorn Sheep - Packgoats ...................................................................................... 358

Wildlife: Bighorn Sheep Analysis and Habitat Management ................................................. 359

Wildlife: Climate Change ....................................................................................................... 360

Wildlife: Coordination with States.......................................................................................... 361

Wildlife: Deer and Elk Habitat ............................................................................................... 361

Wildlife: Habitat Connectivity ................................................................................................ 362

Wildlife: Management Indicator and Focal Species ............................................................... 363

Wildlife: Monitoring ............................................................................................................... 365

Wildlife: Other Species ........................................................................................................... 365

Wildlife: Roads ....................................................................................................................... 366

Wildlife: Sage Grouse Habitat and Management .................................................................... 367

Wildlife: Species Viability ...................................................................................................... 367

Wildlife: Standards and Guidelines ........................................................................................ 369
Final Environmental Impact Statement, Volume 4 

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162

Wildlife: Threatened, Endangered and Sensitive Species ....................................................... 370

Wildlife: Wolf Management ................................................................................................... 371

Introduction ......................................................................................................................................... 373

Past Planning Efforts: Malheur National Forest ..................................................................... 374

Past Planning Efforts: Umatilla National Forest ..................................................................... 374

Past Planning Efforts: Wallowa-Whitman National Forest .................................................... 374

Process to Identify and Classify Potentially Eligible Wild and Scenic Rivers ................................... 374

Scenery .................................................................................................................................... 376

Recreation ............................................................................................................................... 376

Wildlife ................................................................................................................................... 376

Fisheries .................................................................................................................................. 376

Heritage Resources ................................................................................................................. 377

Geologic/Hydrologic ............................................................................................................... 377

Botany/Ecologic ...................................................................................................................... 377

Water Quality .......................................................................................................................... 377

Summary Evaluation Form ..................................................................................................... 381

Wild and Scenic Rivers ....................................................................................................................... 382

Designated Rivers ................................................................................................................... 382

Eligibility Summary ................................................................................................................ 384

Suitability Summary ............................................................................................................... 404

Introduction ......................................................................................................................................... 409

Potential Wilderness Areas ................................................................................................................. 409

Suitability Analysis ............................................................................................................................. 410

Capability and Availability Evaluation ............................................................................................... 410

Capability ................................................................................................................................ 410

Availability.............................................................................................................................. 411

Need ........................................................................................................................................ 412

Evaluation Findings ............................................................................................................................ 412

Capability Process ................................................................................................................... 412

Availability Process ................................................................................................................ 432

Need Evaluation ...................................................................................................................... 451
Final Environmental Impact Statement, Volume 4 

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Concern Statements and Responses

Access

Access: Airstrips

1. Concern Statement: The Forest Service should retain or increase existing airstrips and 

landing areas because aviation is a valid and low-impact means of access for recreation 

activities. Airstrips can provide access for people with disabilities, search and rescue or

safety operations, emergency landing, and firefighting. Many airstrips have historical 

value. 

Response: In response to numerous comments on the draft revised Forest Plan and 

Environmental Impact Statement that expressed concerns regarding aviation use on the 

national forests, additional material was included in the plan recognizing the importance 

of aviation and backcountry airstrips as a recreational use and as administrative 

infrastructure on the Blue Mountains national forests. The Forest Service recognizes the 

importance of maintaining collaboration with recreational aviation users for supporting 

Forest Service airstrip programs including operation, rehabilitation, maintenance, and 

continued public use as outlined in the “Service-Wide Memorandum of Understanding 

Between the Recreational Aviation Foundation and the USDA Forest Service, WO” 

(2015). 

Additional language was added in Goal 2.2 (Recreation) under the background section, 

Goal 2.2.3 (Backcountry Recreation) under the desired condition, and under Management 

Area 5 (Developed Sites and Administrative Areas) under the subheading 

“Administrative Sites). Airstrips are considered as a component of the national forest 

transportation system and are generally assessed and analyzed through travel 

management planning processes. 

Access: Designated Routes

2. Concern Statement: The Forest Service should eliminate the need to travel only on 

designated routes. The Forest Service should allow “cross country travel” to be more 

access friendly. User conflict and safety issues could occur as a larger percentage of 

people are directed into the same areas. The default position should be open roads rather 

than closed. 

Response: With the exception of wilderness areas, the 1990 Forest Plans for the 

Wallowa-Whitman and Malheur National Forests include little management direction to 

distinguish motor vehicle use allocations from nonmotorized use allocations; however, 

the Forest Plan for the Umatilla National Forest included detailed management direction 

related to motor vehicle use. Subsequent to the Umatilla National Forest 1990 Forest Plan 

decision, each ranger district on the Umatilla National Forest made access and travel 

management decisions leading to the production of a forestwide motor vehicle use map in 

compliance with the Travel Management Rule (36 CFR 212 Subpart B). 

In March 2015, direction was given by Jim Peña, the Pacific Northwest Regional 

Forester, that directs the Blue Mountains national forests to defer any additional work 

required under Subpart B of the Travel Management Rule until after the Blue Mountains 

Plan Revision is completed. In line with the Regional direction, the Wallowa-Whitman 

and Malheur National Forests have paused Subpart B analysis until the Forest Plan 
Final Environmental Impact Statement, Volume 4 

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164

Revision is complete. The National Forests completed Subpart A of Travel Management 

Planning in the latter part of 2015. All three National Forests will continue to address 

natural resource concerns and public access needs as part of ongoing project-level 

decisions and forest restoration efforts, and base these analyses on existing regulation and 

the guidance contained in the Forest Plans. 

In response to public comments that expressed a desire to remove phrases such as 

“designated routes” and “no cross country travel” from the draft Forest Plans and 

Environmental Impact Statement, the documents were edited to remove the referenced 

language. Instead, the language was replaced with the acknowledgement that national 

forests are required to comply with existing Forest Service regulation, in this particular 

instance the regulations at 36 CFR 212 that implement the Forest Service’s Travel 

Management Rule (2005). The acknowledgement responds to additional public 

comments that expressed a desire for the Forest Service to enforce compliance with 

regulations for off-highway vehicle use. 

3. Concern Statement: The Forest Service should designate routes to control where and 

how people travel while accommodating the growing demand for public access to public 

lands. For example, designated routes could direct off-highway vehicle traffic around 

sensitive sites. 

Response: The Forest Service is required to follow all federal laws, regulations, and 

policies including those that may be enacted during the life of the revised Forest Plans. 

The revised Forest Plans acknowledge that national forests are required to comply with 

existing Forest Service regulation, in this particular instance the regulations at 36 CFR 

212 that implement the Forest Service’s Travel Management Rule (2005). This 

acknowledgement responds to public comments that expressed a desire for the Forest 

Service to enforce compliance with regulations for off-highway vehicle use.

Access: Emphasize Nonmotorized Access

4. Concern Statement: The Forest Service should increase backcountry nonmotorized 

vehicle areas, close roads to support the protection of habitat, and prohibit additional 

cross-country and over-the-snow vehicle travel. 

Response: Three primary management areas including designated wilderness (MA 1A), 

preliminary administrative recommended wilderness (MA 1B), and backcountry 

(nonmotorized use; MA 3A) comprise large areas that are nonmotorized year-round and 

offer recreation experiences that are primitive with high degrees of self-reliance. The 

Final Environmental Impact Statement allocated varying amounts (acres) to these 

management areas in different alternatives. The Forest Plans do not designate routes, 

trails, or areas open to motor vehicle uses, and similarly do not close routes to vehicle 

use. That will be done through the Travel Management process and subsequent sitespecific analysis processes. 

Access: Forest Management

5. Concern Statement: The Forest Service should maintain its roads to allow access to 

manage forests and fuels, suppress wildfire, manage emergencies, and support grazing, 

mining, and special uses. If necessary, roads should be closed but not decommissioned. 

Response: We agree that motorized access is an important component of forest 

management to meet multiple resource needs. We recognize that a sustainable 
Final Environmental Impact Statement, Volume 4 

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165

transportation system is vital for forest-related management objectives including 

vegetation management, wildfire responses, emergencies, and to support economic 

related objectives including grazing, mining, and special uses. The revised Forest Plans 

provide programmatic direction as to where motorized use may or may not be suitable. 

Additionally, desired conditions for motorized use are integrated to meet other resource 

needs, provide for user safety, and to comply with existing laws, regulation, and policy. 

The desired condition for Goal 2.5 (Roads and Trials Access) states “Roads identified for 

long-term use, but not currently funded for adequate maintenance are put in a stored 

condition, where they remain on the system but are not actively used.” The desired 

condition acknowledges that roads, if necessary, may be placed into “storage” rather than 

be decommissioned. The revised Forest Plans do not designate routes, trails, or areas 

open to motor-vehicle uses, and similarly do not close routes to vehicle use. Forest 

transportation systems are considered through the travel management process and 

subsequent site-specific analysis processes.

Access: Forest Products 

6. Concern Statement: The Forest Service should maintain access routes so local residents 

can gather low-cost firewood, berries, and mushrooms, and hunt and fish. Access to these 

forest products and access to traditionally used locations are important cultural resources 

for nourishment, income, survival, travel and enjoyment. 

Response: Access is analyzed in the Final Environmental Impact Statement and includes 

a range of alternatives that vary the areas (acres) rated suitable for either motorized or 

nonmotorized use, and rated for both summer and winter use. Additional indicators used 

in the analysis include road maintenance (see the Access Section in the Final 

Environmental Impact Statement). Objectives stated for Roads and Trails Access (Goal 

2.5) reflect the activities and program outcomes necessary to achieve or maintain desired 

conditions and includes the miles of road maintenance expected during the first decade of 

plan implementation. 

The “Economic and Social Well-being” section in Volume 1 of the Final Environmental 

Impact Statement was enhanced to include both sense of place and access descriptions to 

recognize the importance of subsistence—and often times intergenerational—uses on the 

national forests. These sections of the Final Environmental Impact Statement further 

detail subsistence uses including access for firewood, hunting, gathering, recreating, and 

general travel. 

Access: Increase ATV/OHV/OSV Access

7. Concern Statement: The Forest Service should consider increasing all-terrain 

vehicle/off-highway vehicle/over-the-snow vehicle opportunities by: 1) designating all 

routes as open for motorized recreational vehicle use; and 2) offering an adequate 

quantity and quality of beginning, intermediate, and advanced routes and trails, including: 

20- to 60-mile loop trails, OHV 4x4 Class 2 trails, single-track trails, beginner loops near 

campsites and in minimal traffic areas, long-distance routes (for example 90-125 miles), 

interpretive mining heritage routes; side destination developments, and dual-use road 

inter-connections. 

Response: The Forest Plans do not designate routes, trails, or areas open to motor-vehicle 

uses. These designations are considered in a separate process that is completed under the 

Travel Management Rule (36 CFR 212). Access is analyzed in the Final Environmental 
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Impact Statement and includes a range of alternatives that vary the areas (acres) rated 

suitable for either motorized or nonmotorized use, and rated for both summer and winter 

use. Subsequent analyses of projects under the Forest Plan will have site-specific data to 

show differences among project alternatives and their effects on motorized travel.

The revised Forest Plans do not make site-specific route decisions and do not intend to 

limit or reduce access. Where appropriate, motorized recreation opportunities may be 

maintained or expanded. 

The specificity outlined in the concern for the quality and quantity of trails types, class of 

vehicle, and trail opportunities are similarly considered under separate travel 

management planning or project specific planning processes. These recreational elements 

are central in the Desired Condition for Roads and Trials Access (2.5) in the revised 

Forest Plans that recognize the need and public desire for diverse motorized recreational 

opportunities.

8. Concern Statement: The Forest Service should differentiate between ATV and 

motorcycle trails in order to recognize the different needs and impacts. Users on singletrack trails should not be separated. 

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. These designations are considered in a separate process that is completed 

under the Travel Management Rule (36 CFR 212). Similarly, these specific designations 

for ATV or motorcycle trails is completed during travel management planning or project 

level planning processes. The Final Environmental Impact Statement does include a 

range of alternatives that vary the amount of area (acres) that are rated suitable for either 

motorized or nonmotorized use, and rated for both summer and winter use. These ratings 

will help inform future travel management planning and project-level analysis. 

Access: Limit Motorized Use

9. Concern Statement: The Forest Service should preserve large areas for nonmotorized 

use to provide quiet natural spaces and limit impacts to the quality of hunting, camping, 

hiking, fishing, backcountry packing, and skiing opportunities. 

Response: Three primary management areas including designated wilderness (MA 1A), 

preliminary administrative recommended wilderness (MA 1B), and backcountry 

(nonmotorized use; MA 3A) comprise large areas that are nonmotorized year-round and 

offer recreation experiences that are primitive with high degrees of self-reliance. The 

Final Environmental Impact Statement allocated varying amounts (acres) to these 

management areas in different alternatives. Additional management areas that contribute 

to primitive recreation opportunities include wild and scenic rivers (MA 2A) and other 

special area designations. Combined, these areas provide quiet natural spaces that 

conserve large, predominately natural appearing landscapes with high scenic quality for 

current and future generations. 

10. Concern Statement: The Forest Service should enforce compliance with regulations for 

OHV use to prevent environmental degradation. 

Response: The revised Forest Plans acknowledge that national forests are required to 

comply with existing Forest Service regulation, in this particular instance, the regulations 

at 36 CFR 212 that implement the Forest Service’s Travel Management Rule (2005). The 

Forest Plans do not designate routes, trails, or areas open to motor-vehicle uses. That will 

be done through the Travel Management process. Criteria for designating road, trails, and 
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areas on National Forest System lands for motor vehicle use are stated in 36 CFR 212.55, 

and direct the responsible official to consider the effects from such designations on 

natural and cultural resources. Likewise, off-highway vehicle enforcement is outlined in 

36 CFR 261.13. 

Access: Motorized Forest Access

11. Concern Statement: The Forest Service should not demonize motorized use and should 

recognize that motorized users also seek solitude. The Forest Service shouldn’t try to 

regulate user conflict or change policy to manage such conflict because it doesn’t exist. 

Motorized access could be maintained by developing new trails and making better use of 

nonmotorized trails. 

Response: The revised Forest Plans and Environmental Impact Statement did not intend 

to bias any specific use or group over another use or group. Rather, the Forest Service 

seeks a balance among many uses and groups as outlined by the Multiple Use Sustained 

Yield Act (Public Law 86-517) and other applicable statutes.

We agree that motorized access is an important recreation use to meet the needs of many 

recreationists. However, a variety of resources is affected by motorized traffic. The 

revised Forest Plans seek a range of recreational opportunities while considering many 

other resource management needs and responsibilities combined with user safety. 

Changes to specific routes are not a forest plan decision but an outcome of a site-specific 

analysis process. 

We agree that technical advancement of snowmobiles, off-highway vehicles, and 

mountain bikes, along with an increase in the popularity of these activities, has resulted in 

more users accessing more areas than they have in the past.

We also agree with research provided that the interest and desire to participate in offhighway vehicle recreation in the outdoors is increasing and that motorized recreation is 

expected to have a beneficial effect on health and fitness. These activities promote mental 

and physical health of the public. 

The revised Forest Plans do not attempt to regulate user conflict. The Forest Plans 

allocate management areas and provide suitability ratings for each management area for a 

range of activities. The mention of “user conflict” in either the revised Forest Plans or the 

Environmental Impact Statement refers to Executive Order 11644 that states: “It is the 

purpose of this order to establish policies and provide for procedures that will ensure that 

the use of off-road vehicles on public lands will be controlled and directed so as to 

protect the resources of those lands, to promote the safety of all users of those lands, and 

to minimize conflicts among the various uses of those lands.” The revised Forest Plans 

recognize this regulatory authority, and acknowledge it as a condition to consider in 

future travel management planning. 

In response to public comments requesting additional recreational opportunities, the 

forestwide Goal 2.6 (Roads and Trails Access) and Desired Condition was modified to 

recognize the opportunity to provide connectivity between Forest Service recreation sites, 

and to connect these sites with adjacent communities through pathways, trails, bike lanes, 

and waterways, and to provide loop-riding opportunities. 

12. Concern Statement: The Forest Service should not perpetuate bias against OHV use, as 

compared to other uses. Analysis of impacts to wildlife, erosion and spread of invasive 

weeds should be from all sources (grazing, logging, wildfire, floods, for example) and not 
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just from OHVs. The Forest Service should provide data or describe how it determined 

that motorized use (especially OHVs) negatively impacts wildlife, vegetation and soils 

and that limiting motorized use would benefit these resources. Likewise, the Forest 

Service should provide sediment-related data to contrast historic sediments loads to 

current sediment loads.

Response: The revised Forest Plans and Environmental Impact Statement did not intend 

to bias any specific use or group over another use or group or resource. Rather, the Forest 

Service seeks a balance among many uses and groups and resources as outlined by the 

Multiple Use Sustained Yield Act (Public Law 86-517) and other applicable statutes. 

We agree that motorized access is an important recreation use to meet the needs of many

recreationists. However, a variety of resources is affected by motorized vehicle use and 

the national forest’s transportation system. We do provide data and descriptions regarding 

off-highway vehicle use and resource considerations and effects in the respective 

resource analysis sections in the Final Environmental Impact Statement including soils, 

watershed function, aquatic species, terrestrial wildlife species, and nonnative invasive 

species. Future site-specific analysis conducted through the travel management process 

will consider resources affected by motorized use on the national forests, and the 

beneficial effects of the national forests’ transportation system, and will include public 

involvement and participation. 

Access: No Road or Access Restrictions

13. Concern Statement: The Forest Service should maintain current levels of access and not 

place any restrictions on access because access is important for a broad range of activities 

including hunting, fishing, cycling, camping, hiking, mining, mushroom picking, berry 

picking, firewood gathering, photography, bird watching, wildlife watching, skiing, 

snowshoeing, motorcycling, riding off-road vehicles, gold panning, and rock hounding. 

Also, old logging roads should be left open to the public for wood gathering. 

Response: We agree that access and dispersed use (including but not limited to camping, 

berry picking, firewood gathering, hunting, and fishing) are important uses on the Blue 

Mountains national forests. The Revised Forest Plans include plan components and 

suitability ratings that identify where motor vehicle use is either suitable or not suitable, 

and where road and trail construction is rated suitable or not suitable for each 

management area. These plan components and suitability ratings, along with the recently 

completed Travel Analysis Reports for Malheur, Umatilla, and Wallowa-Whitman 

National Forests, will help inform future project-level decisionmaking regarding the 

national forests’ transportation system. The revised Forest Plans do not limit or reduce 

levels of access or propose site-specific changes to the forest transportation system. Other 

resource area considerations, including Rocky Mountain elk and watershed function, may 

also influence future forest transportation system use and distribution. 

14. Concern Statement: The Forest Service should not limit access because it would hurt 

local businesses and social stability, impact those who access national forest lands for 

sustenance, and destroy trust in the Forest Service.

Response: We recognize the importance of national forest access for its contribution to 

local economies and for providing access for sustenance-related activities. The 

“Economic and Social Well-being” section in Chapter 3 of the Final Environmental 

Impact Statement describes economic impact zones and the contributions provided by 

recreation-related activity on the Blue Mountains national forests. As stated in the FEIS, 
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“For all alternatives, the quantity of recreation visits to the national forests in not 

expected to vary from current use levels. The current supply of recreational opportunities 

is expected to exceed demand for the foreseeable future.” 

The revised Forest Plans do not make site-specific route decisions and do not intend to 

limit or reduce access. Where appropriate, motorized recreation opportunities may be 

maintained or expanded. The national forest transportation system may be used to access 

areas for hunting, berry picking, camping, pleasure driving, firewood removal, and to 

access the trail system for off-highway vehicle use, bicycle, hiking, and horseback use. 

These trails also provide access to the backcountry for hunting, fishing, camping, 

photography, and many more recreation and subsistence related activities. Changes to 

specific routes are not a forest plan decision but an outcome of a site-specific analysis 

process.

15. Concern Statement: The Forest Service should not limit access because it will 

disproportionately affect children, aging populations, wounded veterans, and people with 

disabilities. 

Response: We agree that motorized access is an important component of national forest 

management to meet the needs of many recreating publics, and the Forest Service strives 

to meet user needs and accessibility guidelines. The Forest Service Trail Accessibility 

Guidelines and the Forest Service Outdoor Recreation Accessibility Guidelines (Forest 

Service Manual 2300) provide administrate oversight in managing access and use. 

Under section 504 of the Rehabilitation Act of 1973, no person with a disability can be 

denied participation in a Federal program that is available to all other people solely 

because of his or her disability. In conformance with section 504, wheelchairs are 

welcome on all National Forest System lands that are open to foot travel and are 

specifically exempted from the definition of motor vehicle in 36 CFR 212.1 of the Travel 

Management Rule, even if they are battery powered. 

The revised Forest Plans do not limit or reduce levels of access or propose site-specific 

changes to the national forest transportation system, and reasonable restrictions on motor 

vehicle use, applied consistently to everyone, are not discriminatory. There is no 

requirement to allow people with disabilities to use off-highway vehicles or other motor 

vehicles on roads, trails, and areas that are closed to motor vehicle use. 

16. Concern Statement: The Forest Service should not limit access because it would 

negatively impact the deep cultural and historic ties communities have to the forests.

Response: The revised Forest Plans do not limit or reduce levels of access or propose 

site-specific changes to the national forest transportation system. The “Economic and 

Social Well-being” section in Volume 1 of the Final Environmental Impact Statement was 

enhanced to include a sense of place description to recognize the cultural and historic ties 

of local communities to the national forests. As stated in the FEIS, “Subsistence uses, or 

the ability to get materials for survival, from national forests contribute to how people 

connect with the land. People value subsistence opportunities on national forests and 

believe it contributes to their well-being. Therefore, they have positive attitudes towards 

open access to the forest land.” 

The revised Forest Plans do not make site-specific route decisions and do not intend to 

limit or reduce access. Where appropriate, motorized recreation opportunities may be 

maintained or expanded. 
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17. Concern Statement: The Forest Service should not close roads. The forest plans should 

only identify issues of concern. Roads should only be closed if there is demonstrated sitespecific impact that is greater than naturally-occurring events. Restrictions should be 

considered instead of closures. If a motorized route is closed, the plan should allow for a 

route of equal opportunity in a different location. In addition, the Forest Service should 

not close any specific forest roads, for example Government Mountain Road or the Mt. 

Howard access road or Forest Service road 5427.

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. These designations are considered in a separate process that is completed 

under the Travel Management Rule (36 CFR 212). Access is analyzed in the Final 

Environmental Impact Statement and includes a range of alternatives that vary the 

amount of area (acres) that are rated suitable for either motorized or nonmotorized use, 

and rated for both summer and winter use. Subsequent analyses of projects under the 

Forest Plans will have site-specific data to show differences among project alternatives 

and their effects on motorized travel. 

Access that is authorized as part of a permitted use will not change under the revised 

Forest Plans. The status of Forest Service routes (collectively roads and trails) will not 

change under the revised Forest Plans, including access to Mt. Howard and any other 

specific location. The management area allocation for the Mt. Howard location is 

Management Area 5 (Developed Sites and Administrative Areas) and Management Area 

3B (Backcountry—motorized use); both of these allocations are rated suitable for motor 

vehicle use. 

Access: Private Lands and Other Ownerships

18. Concern Statement: The Forest Service should maintain access to private lands and 

cabins for continuance of existing and historic and existing uses, including National 

Forest System Road 2036 and property at 3N-Range 36 section 36. 

Response: The Forest Service is required to follow all federal laws, regulations, and 

policies including those that may be enacted during the life of the revised Forest Plans. 

As stated in the desired condition for Goal 2.5 (Roads and Trails Access), “Right-of way 

and easements provide adequate and legal access to National Forest System lands.” Laws 

and regulations that direct access to private lands are outlined in Forest Service Manual, 

Chapter 2700, Special Uses Management. Chapter 2701.1 – Current Statutory Authorities 

states: “The Alaska National Interest Lands Conservation Act (ANILCA) provides 

numerous authorities related to access that are specific to National Forests in Alaska 

(except for sec. 1323(a), which applies to all National Forest System lands....” 

Additionally, this section states: “The provisions of section 1323(a) apply to all National 

Forest System lands. This section provides that, subject to terms and conditions 

established by the Secretary of Agriculture, the owners of non-Federal land within the 

National Forest System shall be provided adequate access to their land. Regulations 

implementing section 1323(a) are set forth at Title 36, Code of Federal Regulations, Part 

251, Subpart D - Access to Non-Federal Lands. See FSM 2701.3, paragraph 3, for the 

summary of the provisions of 36 CFR 251, Subpart D.” 

The summary of provisions states: “Title 36, Code of Federal Regulations, Part 251, 

Subpart D. This Subpart governs procedures by which landowners may apply for access 

across National Forest System lands, the terms and conditions that govern any special-use 

authorization that is issued by the Forest Service to permit such access, and the criteria 
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that authorized officers must consider in evaluating such applications. The rules provide 

that, subject to the terms and conditions set out in the rules, "landowners shall be 

authorized such access as the authorized officer deems to be adequate to secure them the 

reasonable use and enjoyment of their land.” 

Access: Road Density

19. Concern Statement: The Forest Service should clarify the differences in road density 

standards, among the alternatives and among the management areas. The Forest Service 

should use existing road densities, not open road densities, in the forest plan revision’s 

analysis. Existing road densities should capture temporary roads, for example.

Response: The influence of roads varies by resource. The watershed analysis uses 

existing roads, in part because the condition of closed roads is incompletely known. 

Reduced traffic should result in reduced road surface erosion, but the effect of roads on 

watershed runoff varies with the local characteristics of individual road segments as 

recognized by Lee et al. (1997). The approach proposed for the Forest Plans is to first 

identify the roads that are hydrologically connected to streams, and then treat those roads 

or road segments by a variety of means, including but not limited to, out-sloping the road 

surface, surfacing with gravel, improving road drainage, decreasing the spacing between 

road drainage features, and dissipating or dispersing road-related runoff. Pilot studies on 

several national forests, including one study on the Umatilla National Forest, all have 

shown that a high percentage of road-related sediment is delivered to streams by a small 

percentage of forest roads. The result of the study of Wall Creek on the Umatilla National 

Forest by Nelson et al. (2010) was that 90 percent of road-related sediment delivered to 

streams came from roughly 10 percent of the road network. Based on this, a focus on the 

specific roads and road drainage features responsible for the majority of sediment 

delivered to streams appears to be warranted, rather than a strict adherence to road 

density standards that may or may not address the problem. Further, the authors of the 

original study on which current road density standards are based (Lee et al. 1997) 

recognized that local characteristics influence the effects of individual roads on streams 

and watersheds that could not be identified in their study. Temporary roads are not 

included in the analysis and are not part of the national forest road system. These roads 

are intended only for short-term use and measures are taken to restore ground cover and 

infiltration capacity following their use.

Likewise, as described in the wildlife section of the forest plans and Final Environmental 

Impact Statement, the science regarding the effects of roads on elk, for example, has also 

changed. The traditional measure of open road density has been found not to address the 

complexities in patterns of open routes or the frequency of use by motor vehicles 

(Rowland et al. 2000, 2005 as cited in section 2.3.1 of the Forest Plans). Motor vehicle

use on the national forests in all seasons is consistently associated with elk distributions, 

and has increased in recent decades. The approach taken in the Forest Plans and described 

in the Environmental Impact Statement is based on recognition of the importance of 

proximity to security and foraging areas in maintaining acceptable elk distributions 

(Thomas et al. 1979, Wisdom et al. 1986, Rowland et al. 2005). The desired features and 

extent of elk foraging and security areas on each of the National Forests is displayed in 

section 2.3.1 of the Forest Plans. 

20. Concern Statement: The Forest Service should maintain current road densities because 

this is desired by the majority of the residents of Eastern Oregon. Any proposed 

reductions should be fully evaluated to determine what they would do to the human 
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environment and cultural and historic resources. The closing of some roads would 

increase impacts to other roads. The Forest Service should focus instead on maintaining 

and upgrading existing infrastructure. 

Response: Road densities are likely to change over the course of implementing the 

revised Forest Plans. The changes are likely to result from implementing stated desired 

conditions and standards associated with other resource considerations including 

watershed functions (Goal 1.1) and Rocky Mountain elk (Goal 2.3.1). Proposed actions 

that would change existing road densities will be analyzed through a separate, sitespecific process that would include project-level analysis and public involvement and 

participation. The concern that closing some roads would create additional impacts to 

other roads is subject to site-specific analysis, and would likely be considered and 

analyzed as part of the travel management process that is conducted outside of the forest 

plan revision process. Maintenance activities and upgrading existing infrastructure are 

embedded within the revised forest plans and are expressed in desired conditions and 

objectives for roads and trails access (Goal 2.5). 

21. Concern Statement: The Forest Service should make the MA 4A General Forest road 

density 2.4 miles of road per square mile in all of the alternatives. 

Response: Road density is defined as an indicator of the concentration of roads in an 

area. The 1990 Forest Plans each contained road density standards for management areas 

that were partially based on road density standards identified in biological opinions for 

endangered and threatened species. The table below displays road density standards for 

the 1990s forest plans. 

Open road density by management area, 1990 forest plans

National Forest Road Density Management Area(s)* Plan Component

Malheur

1.5 miles/square mile MA 4D Wildlife Emphasis

2.2 miles/square mile MA 4D Winter Range Standard

3.2 miles/square mile Summer Range**

Umatilla 2 miles/square mile Forestwide Desired condition

Wallowa-Whitman 1.5 miles/square mile MA 4E Winter Range 

MA 4D General Wildlife/Fish Standard

2.5 miles/square mile MA 4A General Forest

* See crosswalk in project record for more information.

** Includes all areas outside wildlife emphasis, winter range, and designated wilderness areas

Road density can be further distinguished as open road density. Open road density and 

corresponding human activity play a key role in determining whether wildlife remains in 

an area. Human disturbance associated with open roads can displace individual animals 

and make them vulnerable to harassment, reduce the amount of suitable habitat, and 

disturb nests and roosting activities. The table below displays road density standards for 

the Revised Land Management Plan for each alternative for applicable management 

areas.
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Comparison of open road density by management/resource area by alternative, proposed 

forest plan revision (values stated in table are contained within desired condition plan 

components unless otherwise noted)

Management/ 

Resource Area Alt. B Alt. C Alt. D Alt. E and F

E Modified and E 

Modified Departure,

MA 3B 1.5 miles/ 

square mile

N/A1 None Desired 

Condition2

Desired Condition2

MA 3C N/A1 1.0 miles/ 

square mile

N/A1 1.0 miles/ 

square mile

N/A1

MA 4A 2.4 miles/ 

square mile

2.4 miles/ 

square mile

3.0 miles/ 

square mile

Desired 

Condition2

Desired Condition2

Winter Elk 

Habitat

1.5 miles/ 

square mile

1.5 miles/ 

square mile

1.5 miles/ 

square mile

1.5 miles/ 

square mile

Guideline (see RME2G) 

1. Indicates management area allocation is not contained within alternative. 

2. Desired condition for these management areas is to reduce road-related sedimentation by reducing road 

density and reducing hydrologic connectivity of the road system. 

As displayed in the table above, road density values vary per alternative. Specifically, 

road densities for Management Area 4A (General Forest) are 2.4 miles per square mile 

for alternatives B and C; 3.0 miles for alternative D; and is stated as a desired condition 

for alternatives E, E Modified, E Modified Departure, and F. Standards for Rocky 

Mountain elk (Goal 2.3.1) and watershed functions (Goal 1.1) may also influence the 

national forest transportation system, and subsequently road density, through future 

project level analysis that will include public involvement and participation.

22. Concern Statement: The Forest Service should comprehensively inventory existing 

roads so sound decisions can be made regarding route density. Maps do not accurately 

depict open or closed roads (some closed due to deterioration). Reclassification or 

removing roads from maps does not address actual ecological damage from these roads. 

If the Forest Service is going to remove roads, it should have a timeline, particularly for 

culvert repairs and replacements, that impede fish passage and for road removals in 

priority or key watersheds.

Response: The individual national forests each have completed inventories of their road 

systems that include route status, road surface type, and other features. The display of 

route status on national forest user maps is up to each individual national forest, but must 

follow Forest Service regulations and policy. The current standard for roads that are 

removed from the national forest road system (decommissioned roads) is to remove all 

culverts; treatment of road surfaces of decommissioned roads varies and may range from 

barricading the road, to ripping and seeding the road surface, and may or may not restore 

the road to the original surface contour. Some roads are closed to motor vehicle use and 

are considered to be in storage. These roads are typically not shown on motor vehicle use 

maps because they are not intended for public use.

Decisions based on road inventories, and subsequent road density, are considered in a 

separate process that is completed under the Travel Management Rule (36 CFR 212) or 

through site-specific project analysis. The Forest Plans do not make travel managementrelated decisions that designate routes, trails, or areas open to motor-vehicle uses. 

23. Concern Statement: The Forest Service should gate roads needed for management 

purposes and restore unneeded roads to a natural condition. Roads should be monitored to 

address compaction and other legacy road problems. Additionally, the Forest Service 
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should close redundant roads, prohibit cross-country motorized traffic, and shorten or 

eliminate cherry-stem roads, especially on the Wallowa-Whitman National Forest. 

Response: The Forest Plans do not designate routes, trails, or areas open to motor-vehicle 

uses. These designations are considered in a separate process that is completed under the 

Travel Management Rule (36 CFR 212). Similarly, closure treatments (such as installing 

gates) on specific routes is considered in site-specific project or planning analysis and not 

in the forest plan revision process. Road restoration efforts would also be analyzed 

through site-specific analysis, and may consider a range of treatments including ripping 

and seeding the road surface, and restoring the road to the original surface contour. 

Monitoring the success of individual project implementation for road closures or 

decommissioning would be accomplished at the site-specific project level and may be 

considered effectiveness monitoring. Both the revised Forest Plans and the travel analysis 

reports resulting from the travel analysis process (Subpart A of the Travel Management 

Rule) are intended to inform the travel management process that includes analyzing the 

national forest transportation system including “redundant” roads, cross-country 

motorized traffic, and “cherry-stem” roads. 

24. Concern Statement: The Forest Service should better define how road density standards 

are connected to hydrology and will be protective of the environment. In addition, some 

commenters ask that road density targets, especially for aquatic species, not be advisory 

or only addressed through desired conditions. 

Response: The Final Environmental Impact Statement describes the hydrological effects 

of roads, recognizing that these effects vary with the nature of individual roads, how they 

are built, and where they are located. The analysis acknowledges that most attributes of 

roads, including the frequency of stream crossings, potential for sediment delivery, and 

hydrologic effects are related to road density. As described in previous responses, it is 

also true that local site factors influence how roads interact with streams and watersheds, 

and that a relatively small percentage of roads or road segments is typically responsible 

for a high percentage of the hydrological effects of roads. For these reasons, the Revised 

Plans would take the approach of first locating and treating the roads that are directly 

hydrologically connected to streams and are most likely to have the greatest effect on 

watershed hydrology and sediment delivery to streams. Relying solely on road density 

may or may not lead to the identification of roads or road segments that have the greatest 

effects on hydrology. It remains that the effects of forest roads cannot be completely 

eliminated, and that for some roads, relocation or decommissioning may be the only way 

to eliminate adverse effects.

25. Concern Statement: The Forest Service should substantially reduce road densities 

throughout the national forests to improve watershed condition and aquatic habitat, 

protect and restore wildlife corridors, key habitats, and ecological processes, especially in 

light of climate change that increases water flow over roads. A reduction in roads would 

reduce erosion, impacts on sensitive wildlife and aquatic species, and maintenance costs. 

Response: The Forest Plans have stated objectives for reducing the effects of roads, and 

specifically to reduce road-related sediment delivery to streams. Open road density is 

currently 2.1 miles per square mile on the Malheur National Forest, 1.5 miles/square mile 

on the Wallowa-Whitman National Forest, and 1.1 miles per square mile on the Umatilla 

National Forest. Open road densities on the national forests range from 2.3 to 2.5 miles 

per square mile when designated wilderness and inventoried roadless areas are excluded. 

The national forests have closed or decommissioned 45 to 55 percent of roads existing as 
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of 1990. Reduced traffic levels on closed roads should result in reduced surface erosion 

and sediment delivery to streams (Reid and Dunne 1984). Preliminary results suggest that 

road decommissioning has been shown to effectively reduce sediment delivery to streams 

on national forests in the Pacific Northwest Region and has been effective at reducing 

road surface erosion and road-related sediment delivery to streams (Black et al. 2017). As 

in the responses to previous comments, the Plans propose the approach of first locating 

and treating the roads that have the greatest effects on surface hydrology and sediment 

delivery to streams and includes objectives for treating these roads.

26. Concern Statement: The Forest Service should not look at road densities but should 

look instead at ecological conditions and at specific roads that contribute sediment issues 

to aquatic and riparian systems or impact wildlife. 

Response: As stated in the responses to previous comments, we recognize that road 

density matters, but more importantly that all roads do not have the same effect, and 

roads differ in their effects to aquatic and terrestrial species. To address hydrologic 

connectivity and sediment delivery to streams, it will be necessary to look at local factors 

that determine how roads interact with the surrounding landscape and with streams. The 

use of the 300-foot buffer is not intended to identify specific roads and is only used as a 

first approximation of the total miles of hydrologically connected roads. The resulting 

total is within the range of published studies elsewhere in Oregon. 

Access: Road Maintenance and Funding

27. Concern Statement: The Forest Service should use funds efficiently and leverage or 

supplement road maintenance by allowing users to maintain roads, charging tolls for 

paved roads, working with motorized recreationists to obtain grants, or using income 

from timber harvests. In addition, the Forest Service should accurately inventory road 

conditions and estimate the annual road maintenance shortfall, to determine the true total 

cost of deferred maintenance, to plan how to reach the desired condition. Funding should 

be prioritized by road maintenance conditions. 

Response: The Environmental Impact Statement reviews road maintenance and 

identifies varying miles of road maintenance for each alternative. Options to supplement 

road maintenance are outside the scope of the forest plan revision process. However, the 

Blue Mountains national forests use off-highway vehicle funds made available by the 

state of Oregon and managed by the Oregon Department of Parks and Recreation through 

a grant system. Each national forest competes for these funds with other entities by 

submitting annual grant applications. We recognize that these funds need to be dedicated 

to the motorized component of the road and trail system, and the National Forests 

annually honor that commitment. 

Site-specific analysis is required for the other examples presented in the concern 

statement: charging tolls, collaborating with outside groups to obtain grants, and income 

derived from timber harvests. These types of site- and activity-specific actions would 

require additional project analysis conducted outside of the forest plan revision process, 

and is some cases may exceed Forest Service authority or not align with existing 

regulation and policy.

The individual National Forests each have completed inventories of their road systems 

that include route status, road surface type, and other features. The Forest Service has 

available only about 20 percent of funds necessary to fully maintain Forest Service roads 

to intended safety, service, and environmental standards. Because of the severity of 
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deferred road maintenance throughout the National Forest Service System, approximated 

to be nearly three billion dollars, national efforts are dedicated to revising the “Deferred 

Maintenance Protocol for Roads” to ensure the integrity of the sample selection and 

projection process. Budget and funding priorities are subsequent administrative activities 

that are not part of the revised forest plan decision.

28. Concern Statement: The Forest Service should not use budgetary restrictions as a reason 

why road maintenance does not get done or why roads are closed or removed, thereby, 

restricting public access. 

Response: Road maintenance is reviewed in the plan through the objectives stated as 

miles of road maintenance per decade, with varying miles for each alternative. As stated 

in the Final Environmental Impact State: “Objectives are projections of Forest Service 

activities and program outcomes that are measurable and time specific. Like goals and 

desired conditions, objectives are not commitments or final decisions approving projects 

or activities. They are a way to measure progress towards meeting or maintaining the 

desired conditions over the life of the plan. The objectives reflect activities and program 

outcomes necessary to maintain or achieve desired conditions.” 

Objectives are further described as being “based on ecological needs, community 

capacity, and expected funding, including budgets, partnerships, and cooperative 

agreements. The actual accomplishments will be dependent on actual funding, staffing 

levels, and local infrastructure.” As stated above, budget and funding priorities are 

subsequent administrative activities that are not part of the revised Forest Plan decision. 

29. Concern Statement: The Forest Service should make funds available to maintain public 

access for Maintenance Level 1 and Maintenance Level 2 roads (or classify these and 

other roads as motorized trails) in order to assuage local animosity over the perceived 

threat of continual road closures and reduce impacts created by a lack of access.

Response: Budget and funding priorities are subsequent administrative activities that are 

not part of the revised Forest Plan decision. Forest plan approval, amendment and 

revision does not authorize, fund or carry out any projects, unless specifically stated in 

the decision document. Forest Plan objectives do identify a projected amount of road 

maintenance for maintenance level 2 roads; in contrast, no miles are projected for 

maintenance level 1 roads. These roads are kept on the transportation system for 

intermittent project use and are closed to vehicular traffic between projects. The closure 

period must exceed one year for the road to be assigned maintenance level 1 status. 

Maintenance level 1 roads are considered during program planning as a low priority for 

investment of time and funds, with limited resources focused to prevent impacts to 

resource while in closed status. 

Access: Roads-Wildlife

30. Concern Statement: The Forest Service should provide current scientific justifications 

regarding how motorized uses on trails, unpaved roads, and paved roads negatively 

impact wildlife to the point of deeming wildlife habitat unusable. In reality, wildlife uses 

roads for its own travel or migrating purposes. 

Response: The Final Environmental Impact Statement provides literature citations under 

Environmental Consequences – Terrestrial Species Viability in the “Terrestrial Wildlife 

Species” section. These references are used to support the wildlife viability analysis and 

are used in discussing general effects of national forest management, including road and 
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trail construction and use, on wildlife. Please refer to these sections for a more detailed 

discussion on motorized uses and affects to wildlife.

Access: RS 2477

31. Concern Statement: The Forest Service should acknowledge that some roads in the 

national forest are public rights-of-way, especially those set aside as part of Revised 

Statute (RS) 2477 and should not be closed by the Forest Service. 

Response: The Forest Plans do not designate routes, trails, or areas open to motor-vehicle 

uses as that process is completed through the Travel Management process. The Forest 

Service recognizes legally documented rights-of-way held by the state, county, or other 

public entities and these conditions are considered during the travel management analysis 

and planning. This includes rights-of-way under RS 2477 that have been adjudicated 

through the Federal court system or otherwise formally established such as easements 

under the Federal Roads and Trails Act (FRTA). Due to the limited role of RS 2477 

rights-of-way in the forest plan revision process, this issue does not involve discernable 

effects and is outside the scope of the forest plan revision process and analysis.

Additionally, no existing adjudicated RS 2477 routes are located within the Blue 

Mountains national forests. 

Access: Snowmobile Access

32. Concern Statement: The Forest Service should maintain access for on- and off-trail 

snowmobiling everywhere, including the Tollgate area. Snowmobilers respect the forest 

and help maintain trails, and unlike off-highway vehicles, snowmobiles leave no trace. 

Snowmobiling has a large economic impact in some small communities in the area. 

Wildlife are impacted less by snowmobiles than by hikers. The Forest Service should 

consider the impact of cross-country ski and snowshoe areas as well as snowmobiling on 

wildlife. 

Response: The revised forest plans describe motorized winter access through suitability 

ratings for each management area, and those ratings vary by alternative. In general, areas 

rated as unsuitable for motorized winter use include designated wilderness (Management 

Area 1A), recommended wilderness (Management Area 1B), and backcountry 

nonmotorized (Management Area 3A). The majority of the Blue Mountains national 

forests are rated as suitable for winter motorized access. As stated in similar responses 

presented above, the Forest Plans do not designate roads, trails, and areas for motorized 

use. These designations are completed through travel management planning and projectlevel analysis. For winter motorized use, the analysis and designation process will follow 

the regulations outlined in Subpart C of the Travel Management Rule (36 CFR 212). 

We also recognize and agree that winter motorized use significantly contributes to those 

gateway communities that promote winter sports activity, and that continued, sustainable 

access helps support these local economies. 

Winter motorized use does have varying impacts on wildlife. As stated in the Final 

Environmental Impact Statement: “Physical impacts may include effects to wildlife that 

include increased stress, reduced survival and productivity, impaired immune function, 

disruption to movement patterns, and changes to behavioral adaptations” (Smith 2013). 

Future travel management planning and analysis will likely take into consideration these 

types of effects resulting from winter motorized use. Future analysis will also include 
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important social and economic considerations as part of the travel management planning 

analysis. 

33. Concern Statement: The Forest Service should minimize over-the-snow vehicle use, as 

the 4.6 million acres currently classified as suitable for motorized recreation is excessive 

and disruptive to nonmotorized users’ experience. Restricting winter motorized recreation 

would protect wildlife, air and water quality, human health (toxins and carcinogens in 

snowmobile exhaust), human safety, peace, and quiet (soundscape). 

Response: As noted in the responses presented above, the revised Forest Plans describe 

motorized winter access through suitability ratings for each management area, and those 

ratings vary by alternative in the Final Environmental Impact Statement. Conversely, 

these alternatives present a range of nonmotorized winter use areas (acres) that provide 

for quiet recreation opportunities, and the associated challenge and solitude that users can 

expect to experience. 

We recognize and agree that certain winter recreation opportunities may conflict with one 

another. As stated in the Final Environmental Impact Statement, winter motorized use 

may create social impacts that are “...marked by increased noise and by reduced visual 

and scenic quality. Snow machines are often audible over great distances, and tracks in 

snowfields and high mark play areas may be widespread and affect natural appearance 

and sense of solitude.” Future travel management planning and analysis will likely take 

into consideration these types of social effects resulting from winter motorized use when 

designating roads, trails, and areas for winter motorized use under Subpart C of the 

Travel Management Rule (36 CFR 212).. 

34. Concern Statement: The Forest Service should provide a quantitative assessment 

showing the number of people who want snowmobile access maintained compared to 

those that don’t to support an informed decision. 

Response: The public involvement process required for the forest plan revision process 

is outlined in Chapter 1 of the Final Environmental Impact Statement, and states in part:

“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. We received more than 1,100 letters on the Draft Forest 

Plan and Draft Environmental Impact Statement from the public, and we 

identified over 4,300 comments." 

In considering the public comments received, it is important for readers and 

decisionmakers to understand that the comment analysis process does not evaluate public 

input as if it were a vote. The information requested by the commenter is not available 

and is not part of the comment evaluation process. Rather, the content analysis process 

ensures that every comment is considered during the process. 

Access: Special-Use Permits

35. Concern Statement: The Forest Service should not require private landowners, 

allotment owners or those with mining rights to acquire a special-use permit to access 

public roads. Permits limit opportunities for general public use. 
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Response: The Forest Service is required to follow all federal laws, regulations, and 

policies including those that may be enacted during the life of this revised Forest Plan. 

See response above (Access: Private Lands and Other Ownerships) for complete policy 

direction and for references and procedures by which landowners may apply for access 

across National Forest System lands. 

For permitted grazing use, the Forest Service provides access for allotment permittees 

through site-specific analysis that subsequently is incorporated into allotment 

management plans. For mining use, existing regulations require that the request for road 

access to mining claims may be granted as part of an approved plan of operations, and is 

subject to analysis of the need and the proof of a valid mineral claim. 

Access: Trail Maintenance

36. Concern Statement: The Forest Service should prioritize funding trail maintenance and 

should partner with volunteers and non-governmental organizations to address trail 

maintenance needs. 

Response: Budget and funding priorities are subsequent administrative activities that are 

not part of the revised Forest Plan decision. Forest plan approval, amendment and 

revision does not authorize, fund or carry out any projects, unless specifically stated in 

the decision document. The National Forest System Trails Stewardship Act (Public Law 

114-245) directs the Department of Agriculture to develop and publish a national strategy 

aimed at significantly increasing the role of volunteers and partners in trail maintenance. 

The national forests also uses existing authorities and policies to partner with volunteer 

groups for trail maintenance throughout National Forest System lands. 

Aquatics 

Aquatics: At-risk and Federally Listed Species

37. Concern Statement: The Forest Service should reduce impacts to bull trout by reducing 

land management uses, such as grazing, mining and logging, and road use in its habitat, 

especially in national forest lands in Pine, Indian and Wildhorse creeks and the Powder 

River. The agency should disclose risks to the fish’s small population, like genetic drift, 

and provide risk rankings of its core areas in the northwestern United States. The Forest 

Service should engage with the U.S. Fish and Wildlife Service to coordinate consistent 

monitoring of bull trout populations. 

Response: The effects of the revised Forest Plans on bull trout and their designated 

critical habitat in the Malheur, Umatilla and Wallowa-Whitman national forests are 

undergoing consultation with the U.S. Fish and Wildlife Service at present. They are 

preparing a Biological Opinion on the preferred alternative for the revised Plans. The 

content of the new Biological Opinion will be fully considered before a final decision is 

made on the preferred Plan Revision alternative. 

The Pine, Indian and Wildhorse Creek bull trout core area is predominantly located in the 

Hells Canyon National Recreation Area (HCNRA) in the Brownlee Reservoir subbasin, 

as displayed in the fisheries analysis in Volume 2 of the FEIS. Only the upper portions of 

the Pine Creek watershed (Oregon) portion of this core area would be affected by the 

revised Forest Plan for the Wallowa-Whitman National Forest. Indian and Wildhorse 

Creeks are located in Idaho and are not in the Blue Mountains Forest Plan Revision 
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planning area. Although they are in the HCNRA and part of this bull trout core area, they 

are not subject to the upcoming Biological Opinion or the preferred alternative. 

The lower end of the Pine Creek watershed lies within the Hells Canyon National 

Recreation Area, which is outside the planning area for the Blue Mountains Forest Plan 

Revision. No management changes are proposed for the HCNRA. It will continue to be 

managed under the HCNRA Comprehensive Management Plan as amended by 

PACFISH. The existing management direction for the HCNRA will be carried forward in 

its entirety under the Wallowa-Whitman National Forest’s revised Plan. Although the 

Hells Canyon National Recreation Area (HCNRA) is not part of the current planning 

area, we have reinitiated consultation; specifically for bull trout-designated Critical 

Habitat in the Oregon portion of the HCNRA as their critical habitat was designated in 

2010 after the HCNRA Comprehensive Management Plan (CMP) was consulted for bull 

trout in 2003. We are not reinitiating consultation on effects to bull trout, the species, for 

the HCNRA CMP. The new Biological Opinion may provide additional guidance for 

future management of bull trout critical habitat in the HCNRA. 

Bull trout habitat in the upper portions of the Pine Creek drainage are in the Plan 

Revision planning area and would be managed under the revised Forest Plan for the 

Wallowa-Whitman National Forest. In terms of reducing certain land uses as requested, 

we would note the following:

• Only Congress has authority to withdraw lands from mineral entry. Under existing 

laws, the Forest Service lacks legal authority to “reduce mining”. We do however 

have the legal authority to manage surface disturbances associated with mining to 

minimize effects to bull trout and other aquatic species in lands open to mining. That 

authority would be exercised through Plan components including Desired Conditions 

and relevant Standards and Guidelines in the Blue Mountains Aquatic and Riparian 

Conservation Strategy (Appendix A of the revised Forest Plan). Relevant standards 

and guidelines designed to avoid or minimize effects to bull trout from mining 

include but are not limited to MM-1G through MM-5GS, and KW-1S through KW3S.

• The preferred alternative (“The revised Plan) proposes to expand default widths of 

Riparian Management Areas beyond those established as defaults for similar streams 

under PACFISH and INFISH, and establishes additional RMAs for ephemeral 

channels, which were not always previously protected by RHCAs when they did not 

satisfy criteria defining intermittent channels which were covered by PACFISH and 

INFISH. These expanded widths, together with Desired Conditions for RMAs are 

expected to strengthen protections for bull trout and their habitats and ensure that 

timber management activities potentially affecting riparian and aquatic habitats will 

ultimately accelerate progress in meeting desired conditions for water quality, aquatic 

habitat complexity and hydrologic function relative to the near-natural rates of 

recovery ongoing under PACFISH and INFISH direction. 

• Since the Forest Plans were first signed in 1990, open road networks have been 

substantially reduced on each of the three forests. More than 11,000 miles of roads 

have been closed and more than 2,000 miles of roads have been decommissioned. As 

part of the Blue Mountains Aquatic and Riparian Conservation Strategy, Appendix A 

of the Plan, key watersheds have rigorous standards and guidelines (KW-1S in 

particular) designed to ensure that road networks in the best remaining bull trout 

habitat not only do not continue to incrementally increase negative effects from 
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sediment inputs, loss of streamside shade or reduced large wood recruitment or 

experience accelerated runoff through extension of the natural drainage networks. 

That particular standard is designed to cumulatively reduce net effects of problematic 

roads in watersheds occupied by federally listed species including bull trout. 

Restoration objectives for priority watersheds inhabited by bull trout are designed to 

identify and reduce impacts of the relatively small subset of roads identified through 

site-specific analysis as those creating the greatest impacts to water quality and 

aquatic habitats.

• So far as reducing grazing impacts to bull trout, standards and guidelines specific to 

grazing (in particular GM-3) have been developed to require more rigorous and 

timely analyses, the results of which are expected to result in management changes 

that will further reduce impacts of livestock grazing in degraded watersheds 

containing federally listed species such as bull trout, when livestock grazing is 

contributing to those degraded conditions. That standard also requires that watersheds 

with good aquatic habitat conditions are maintained in good condition, and that 

livestock grazing be managed to maintain those conditions, when grazing poses a risk 

of degrading those conditions unless management focuses on prevention of such 

effects.

Forest Service biologists regularly exchange information with the U.S. Fish and Wildlife 

Service, as well as other Federal and State agencies, regarding bull trout distribution and 

habitat conditions for bull trout populations in the planning area. That information is 

considered when U.S. Fish and Wildlife Service produces their status reviews for bull 

trout at 5-year intervals as required by law. The draft status reviews are available for 

public comment prior to being finalized in the Federal Register. The most recent 

population-status information available for the Powder River and Pine, Indian and 

Wildhorse core areas as well as all other core areas was published with the Bull Trout 

Recovery Plan (USFWS, 2015), and was considered in the fisheries analysis in Volume 2 

of the FEIS.

38. Concern Statement: The Forest Service should follow the State’s lead on bull trout by 

recognizing it does not need to be listed if a viable population exists locally. 

Response: By law, the U.S. Fish and Wildlife Service has the authority to list and delist 

resident fish species under the Endangered Species Act, and make those decisions based 

on best available information, which they update at 5-year intervals through the Federal 

Register. The Forest Service has obligations under the Endangered Species Act to use our 

authorities to help recover federally listed species. Forest management must comply with 

all applicable laws and regulations, including the Endangered Species Act (see Appendix 

D-Laws and Regulations).

39. Concern Statement: The Forest Service should make all federally listed and statesensitive aquatic species management indicator species. At the least, the agency should 

add at-risk aquatic species, such as the redband trout, bull trout, steelhead and spring 

Chinook salmon because there are no aquatic management indicator species in the forest 

revision plan. In addition, it would be beneficial to have a riparian-dependent 

management indicator species, such as an amphibian.

Response: The National Forest Management Act of 1976 assumed that population trends 

for each management indicator species would reflect the effects of forest management 

activities on that species. A management indicator species must also be distributed widely 

enough in areas where management activities will occur, to be able to tie population 
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trends for the species to the effects of forest management. For reasons discussed in 

Chapter 3, “Aquatic Species” in the Draft Environmental Impact Statement, we selected 

redband trout, steelhead, bull trout and spring Chinook salmon as aquatic focal species 

rather than as management indicator species. In the Final Environmental Impact 

Statement, focal species have been reframed as “surrogate species,” which represent 

other at-risk species with similar habitat characteristics and distributions. Our ability to 

determine the effects of forest management on population trends for these particular 

species as aquatic management indicator species has previously proven ineffective for 

reasons discussed in the “Aquatic Species” section. 

The revised Forest Plans will monitor trends in actual aquatic habitat conditions on 

National Forest System lands used by the selected surrogate aquatic species, since aquatic 

habitat conditions and trends on National Forest System lands have much more direct 

association with effects of forest management, and since numerous other factors that 

influence population trends in these species are unrelated to forest management. 

There are no amphibian management indicator and focal species. Management indicator 

and focal species were selected because they are believed to be indicative of key 

characteristics of ecological integrity and are responsive to ecological conditions in a way 

that can inform plan decisions. More explanation on the rationale for selecting focal 

species can be found in the project record.

40. Concern Statement: The Forest Service should provide for the viability of the Pacific 

and western brook lamprey. 

Response: In Chapter 3, “Aquatic Species” the “Surrogate Species” and “Sensitive 

Species” sections provide rationales for why brook lamprey and Pacific lamprey were not 

selected for in-depth analysis. It also explains why steelhead and redband trout and bull 

trout were chosen as surrogate species for analysis for these and other species with 

somewhat similar seasonal needs and habitat affinities according to their life histories 

and/or natural behaviors. Viability for these species is represented by effects to surrogate 

species for which effects were analyzed, as noted in the analysis.

41. Concern Statement: The Forest Service should improve survey protocols and 

standardize data collection methods regarding at-risk and federally listed species, with the 

National Marine Fisheries Service, the U.S. Fish and Wildlife Service and the State 

departments. In addition, the Forest Service should explain how management indicator 

species data, including surveys, are used to assess species trends.

Response: The rationale for discontinued use of the management indicator species 

concept with regard to aquatic species was explained in the “Aquatic Species” section of 

Chapter 3 in the effects analysis for alternative A, the no-action alternative of the Draft 

Environmental Impact Statement. The analysis of the revised plan alternatives focus on 

effects to habitat for aquatic surrogate species.

42. Concern Statement: The Forest Service should re-introduce federally listed fish species 

after restoring its habitat. 

Response: The Forest Service is not the lead agency with regard to management of 

federally listed fish or other native aquatic species. We are land managers. Our primary 

role and responsibility with respect to reintroductions is to protect and restore the habitat 

needed to support recovery of those species. The Forest Service is willing to assist the 

states with reintroductions of native species in those locations that the states, in 

conjunction with U.S. Fish and Wildlife Service or National Marine Fisheries Service, 
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have determined are needed, per the recovery plans for those species, when there is 

mutual agreement that habitat is capable of supporting those reintroductions. 

43. Concern Statement: The Forest Service should clarify why certain fish species (Snake 

River Basin fall Chinook salmon, Snake River Basin spring/summer Chinook salmon, 

and Snake River Basin steelhead) are identified as “likely to become endangered” if fish 

populations are generally increasing. 

Response: Snake River Basin spring, summer and fall Chinook salmon are all listed as 

threatened under the Endangered Species Act. Under the Act, “threatened” species, by 

definition, are “likely to become endangered.” Until population numbers are sufficiently 

recovered for the relevant populations, as prescribed in recovery plans for these species, 

they will remain listed as threatened under the Act. National Marine Fisheries Service is 

the agency responsible for listing and delisting these particular species when their 

populations have sufficiently recovered, based on criteria established in the recovery 

plans, which described the threats to each listed species and remedies to resolve those 

threats. Both U.S. Fish and Wildlife Service and National Marine Fisheries Service 

publish population status and trend information in recovery plans and in 5-year status 

reviews, which assess progress in reducing identified threats, including threats outside of 

National Forest System lands or outside of Forest Service authorities. The most recent 

status reviews and recovery plans are cited as the source for status and trend information 

in Tables 241-243, see the table footnotes. Threat information is extremely detailed in the 

source documents, more than can reasonably be repeated here, and thus has been 

incorporated by reference.

44. Concern Statement: The Forest Service should focus on the viability of the margined 

sculpin and potential impacts to the fish species from agency actions. 

Response: Redband trout, steelhead, bull trout and their habitats were discussed in the 

focal species section of the Draft Environmental Impact Statement, Volume 2. As 

clarified in the Final Statement, under the revised Forest Plans these species would serve 

as surrogates for other at-risk species with similar habitat requirements and distributions, 

including margined sculpins. Effects to sensitive margined sculpin are based on existing 

fair to good habitat conditions and relative effects of alternatives on habitats for these 

surrogate species in shared subbasins, as disclosed in the “Existing Condition” sections 

for the pertinent surrogate species, and in the “Environmental Consequences” and 

“Cumulative Effects to Sensitive Species” sections. These sections discuss margined 

sculpin habitat conditions, distributions, habitat requirements and effects to their habitat 

in the Tucannon, based on the corresponding analyses for redband trout and bull trout 

habitat and species characteristics as surrogates for margined sculpin habitat and species 

characteristics.

45. Concern Statement: The Forest Service should not identify national forest streams, 

particularly within the Malheur National Forest, as fishery strongholds that do not meet 

the definition of a stronghold. 

Response: The revised Forest Plans identify key watersheds as displayed in the Blue 

Mountains Aquatic and Riparian Conservation Strategy (2018 ARCS) (see Revised Forest 

Plan, Appendix A). Key watersheds are areas that either currently serve as strongholds for 

important aquatic species or have the potential to do so. Key watersheds were selected on 

the basis of relative population strength of four selected focal species, watershed, and 

aquatic habitat conditions using the process described in Reiss et al. (2008). How these 
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methods have been applied to the Blue Mountains is described in the 2018 Blue 

Mountains ARCS. 

46. Concern Statement: The Forest Service should detail how at-risk aquatic species living 

outside a priority watershed will continue their recovery. 

Response: Habitats for fish species with management concerns (at-risk species) would be 

managed consistent with the 2018 Blue Mountains Aquatic Restoration and Conservation 

Strategy. Key watersheds identified in the Forest Plans are areas with the best relative 

habitat conditions and strongest populations of one or more of four selected surrogate 

species whose distributions and habitat requirements represent distributions and habitat 

requirements of other at-risk species. Priority watersheds are key watersheds that have 

been selected by each national forest as priorities for active restoration during the life of 

each Plan. It is expected that once restoration needs in these watersheds are completed 

that other key watersheds will be selected as new priorities for active restoration. In 

addition, with few exceptions, the desired conditions for watersheds, riparian areas, 

threatened and endangered species, and aquatic habitats in the Plan apply across all 

watersheds. Most standards and guidelines apply across all watersheds, with a few 

additional standards and guidelines that apply only in key watersheds. The standards and 

guidelines that are specific to key watersheds will also be applied to watersheds not 

named as key watersheds that contain designated critical habitat for federally listed fish 

species. These watersheds are all addressed in the biological assessment for the preferred 

alternative. 

Aquatics: Habitat

47. Concern Statement: The Forest Service should facilitate migration of species, both 

aquatic and terrestrial, to historical habitat through built structures, including underpasses 

on roadways. 

Response: The Forest Service recognizes the need to provide for aquatic organism and 

fish passage. An active program to redesign stream crossings and facilitate fish passage 

has been active since at least 2001 and has resulted in the replacement of more than 200 

stream crossing culverts and reconnected several hundred miles of previously 

inaccessible habitat. 

On some roads, including Interstate Highways and State Highways, jurisdiction may fall 

to State agencies and the Forest Service may be a cooperator, but may not be the lead 

agency. 

48. Concern Statement: The Forest Service should not indicate that McClellan Creek and 

the McClellan Mountain watershed of the Malheur National Forest provide close to a 

mile of essential salmonid habitat because a cataract exists in the creek on private land 

preventing any fish passage. This misstatement causes an unnecessary burden on the 

landowner, who is also a grazing permittee. 

Response: National Marine Fisheries Service is the agency responsible for identifying 

essential fish habitat. As of 2016, they are no longer identifying essential fish habitat for 

Pacific salmon in the John Day River Basin, to which McClellan Creek and the 

McClellan Mountain watershed are tributary. The information regarding designation of 

essential fish habitat has been updated in the “Aquatic Species” section of the analysis in 

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49. Concern Statement: The Forest Service should adhere to state restoration priorities in 

the Oregon Middle Columbia River Steelhead Recovery Plan and state fish passage laws 

and best management practices (BMPs) pertaining to stream-crossing structures.

Response: The Forest Service recognizes the priorities stated in recovery plans and uses 

the best available science and best management practices in the design and construction 

of stream crossing structures. The Forest Service has a policy for providing fish and 

aquatic organism passage. On National Forest System roads, the Forest Service has had 

an active program of replacing culverts to provide for aquatic organism passage in 

streams on National Forest Systems lands in the Blue Mountains since 2001.

Oregon Department of Fisheries and Wildlife biologists are routinely invited to review 

fish passage designs as a standard procedure. Forest Service fish passage designs are 

developed by interdisciplinary teams of fisheries biologists, hydrologists and licensed 

physical engineers to provide for passage of all aquatic organisms. They are rigorously 

trained in Forest Service fish passage design methodologies, which are based on best 

available science. The Oregon Department’s screen shop staff in John Day have helped 

implement Forest Service designs for fish passage on National Forest System lands in the 

planning area since 2014. Key watersheds and applicable Forest Plan management 

direction provide protection and restoration for priority tributaries identified in the 

Oregon Middle Columbia River Steelhead Recovery Plan. Consistent with agency policy, 

we employ best management practices for all our projects including aquatic organism 

passage projects, consistent with the Oregon Middle Columbia River Steelhead Recovery 

Plan.

50. Concern Statement: The Forest Service should not claim that the remaining high-quality 

aquatic habitat is on federal lands rather than private lands.

Response: Part of the basis for the statement is that 80 percent anadromous fish species 

use habitats on Federal lands for part of their life cycle (Gregory and Bisson 1997). Lee 

et al. (1997) and Williams and Williams (1997) recognized the watersheds retaining the 

best remaining habitats are often restricted to headwater streams (and that headwater

streams are commonly located on national forests). The work done by Lee et al (1997) 

evaluated fish populations and habitat conditions throughout the Interior Columbia Basin, 

including those in the current planning area. Sedell et al. (1990) noted few reaches of 

large streams in the western U.S. were in pristine condition and that rivers in the best 

condition tended to be located within wilderness areas in national parks. Based in part on 

work by Sedell et al. (1990), and Reeves and Sedell (1992), FEMAT (1993) recognized 

the need to preserve and protect watersheds containing the best remaining habitats. This 

led to the selection of 162 key watersheds, covering 8 million acres, or one-third of the 

area of federally managed lands within the range of the northern spotted owl. The same 

principal was used to select key and priority watersheds in PACFISH and INFISH, 

respectively, and to identify key watersheds for the proposed forest plans on national 

forests in the Blue Mountains.

This is not intended to mean that habitats on the three National Forests are not also 

degraded, because we recognize that they are. It simply means that protection of 

remaining high quality habitats while restoring watersheds of lesser quality, and creating 

well-connected larger blocks of good habitat, is necessary for the long-term survival of 

threatened and endangered fish species. For example, according to recent evaluations by 

the Grande Ronde Model Watershed (2013), the north and south forks of Catherine Creek 

(“Upper Catherine Creek”) are in relatively better condition than habitat conditions in the 
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middle, and lower reaches of Catherine Creek and their tributaries. The North Fork, 

South Fork, Milk Creek and Little Catherine Creek key subwatersheds were selected as 

priority subwatersheds for restoration by the Wallowa-Whitman National Forest staff, 

which is consistent with evaluations done by the Grande Ronde Model Watershed 

working group. Note that these particular key watersheds are still in need of restoration 

based on Model Watershed assessments, but to a lesser degree than the middle and lower 

portions of the Catherine Creek watershed. Restoration work is also planned for the lower 

and middle portions of the watershed, but the majority of the needed work is expected to 

occur sometime after 2018. 

https://www.grmw.org/static/documents/data/assessment_documents/PieMapUpperGrand

eRonde_Chinook_XLS_20130530_20130701.pdf 

Aquatics: PACFISH/INFISH

51. Concern Statement: The Forest Service should follow the protective PACFISH and 

INFISH direction without adding additional constraints. PACFISH and INFISH direction 

from the 1990 plan should be carried forward. 

Response: The 2018 Blue Mountains ARCS (Appendix A of the Forest Plans) is tailored 

to conditions and concerns specific to the Blue Mountains Plan Revision area, and is 

based on lessons learned through implementation of PACFISH and INFISH over the past 

20 years. The proposal to replace PACFISH and INFISH with an updated aquatic strategy

that incorporates 20 years of updated science and lessons learned through implementation 

of PACFISH, INFISH and the Northwest Forest Plan, makes sense to us at both local and 

regional scales, as discussed in the introduction to the 2018 Blue Mountains ARCS, 

which is a variation on the 2008 and 2016 versions of the regional ARCS, which were 

developed at the request of the Regional Forester for use in revised Forest Plans. Both Emodified and E-modified-departure alternatives include the 2018 Blue Mountains ARCS 

as part of those alternatives. Alternatives B, C, D, E, and F all incorporate the 2008 

Regional ARCS. The No-Action alternative A would continue to apply PACFISH and 

INFISH. The Regional Forester will ultimately decide which alternative will go forward 

as the revised plan for each of the Blue Mountains National Forests, in the Record of 

Decision, and is free to modify the selected alternative at that time, including whether to 

continue use of PACFISH and INFISH, or to adopt the 2018 BMARCS as part of the 

selected alternative, or whether to substitute a regional version of the ARCS as part of the 

selected alternative.

52. Concern Statement: The Forest Service should detail how its PACFISH-related riparian 

management objectives can be measured to determine effectiveness of agency actions.

Response: To be effective, riparian management objectives, as originally developed for 

PACFISH, should reflect the characteristics of streams in good condition, and account for 

the variability of channel properties of different channel types in different geologic and 

climatic settings. Riparian management objectives should be able to discriminate altered 

streams and poor habitat conditions from unaltered streams and good habitat conditions. 

Riparian management objectives are clearly measurable, but some have not been 

effective at determining habitat conditions and none account for differences in the 

characteristics of different channel types, or recognize the distribution of channel types in 

different watersheds. This appears, at least in part, to have resulted from the fact that the 

channel classification systems that are currently most commonly used (Rosgen 1994, 

1996; Montgomery and Buffington 1993, 1997), were not fully developed when riparian 
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management objectives were first introduced in PACFISH. Both classification systems 

recognize differences in channel properties between different channel types and the 

Montgomery and Buffington classification, in particular, recognizes that individual 

watersheds have different distributions of channel types (Buffington et al 2004). Channel 

types in the two classification system are not strictly equivalent (Buffington and 

Montgomery 2013). 

The original riparian management objectives were developed from the attributes of 

streams with “strong” populations of native fish (Williams and Reeves 2006). It was 

assumed that the derived values, based on “broad averages” of habitat attributes of 

selected streams were representative of good conditions. The opposite argument, that 

streams that do not meet riparian management objectives must be in poor condition, is 

often untrue. For example, it has been shown that none of more than 700 PACFISHINFISH Biological Opinion managed or reference monitoring sites meet all of the 

PACFISH Riparian Management Objectives (Kershner and Roper 2010). 

Alternative E-Modified includes a standard that specifies that management actions will 

maintain riparian and aquatic habitat conditions when present conditions are properly 

functioning, and move towards desired conditions when existing conditions are not 

properly functioning. This appears to be because riparian management objectives are not 

adequate for characterizing streams in general, but also are not adequate for 

characterizing streams of any particular channel type

Most of the PACFISH riparian management objectives are included in the matrix of 

pathways and indicators, but some may be revised to reflect more appropriate values 

based on the potential characteristics of streams in the Blue Mountains. 

53. Concern Statement: The Forest Service should not follow PACFISH and INFISH 

guidance as part of its aquatic strategy because these were created as interim guidelines, 

not intended to be permanent. 

Response: See Appendix A in each Forest Plan: Blue Mountains Aquatic-Riparian 

Conservation Strategy (ARCS) for a comparison of the ARCS and how it differs from 

PACFISH and INFISH direction. 

Biological Opinions for PACFISH (NMFS 1995,1998) and INFISH (USFWS 1998) 

identified specific weaknesses of PACFISH and INFISH as long-term strategies, all of 

which have since been addressed, including:

♦ the lack of a formal process of subbasin review and prioritization (USDA Forest 

Service, Pacific Northwest Region 2005, revised 2008)

♦ the lack of a comprehensive approach for analyzing and restoring watersheds (USDA 

Forest Service 1995) 

♦ incorporation of a comprehensive restoration strategy into forest plans (USDA Forest 

Service, Pacific Northwest Region 2008, 2016, these plans) 

♦ prioritization of watersheds for restoration (Malheur National Forest. 2005, Umatilla 

National Forest 2005, Wallowa-Whitman National Forest 2005, these plans) 

The Interior Columbia River Basin Project was intended as the process for developing the 

long-term strategy for replacing PACFISH. In lieu of finalizing the Interior Columbia 

River Basin Project and preparation of a record of decision for the project, the land 

management and regulatory agencies jointly agreed to implement the Interior Columbia 
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Basin Strategy by incorporating its science and elements of the strategy into revised 

forest plans. This agreement led to the development of the Aquatic and Riparian 

Conservation Strategy (ARCS), which is incorporated into the Blue Mountains Plans in 

the form of desired conditions, standards and guidelines, and objectives for achieving 

desired conditions, and contains the elements of the long-term strategy that were lacking 

in PACFISH and INFISH. The additional elements include the identification of key 

watersheds, prioritization of watersheds for restoration, the use of watershed analysis, and 

long-term monitoring of the effectiveness of the strategy. The first three elements were 

conducted in the preparation of the plans and the results are incorporated into the Plans 

and presented in the Blue Mountains ARCS (Appendix A to the Plans). A regionwide 

monitoring strategy to track the effectiveness of implementing PACFISH and INFISH 

was implemented in 2001 (Kershner et al. 2003, 2004) and continues to the present. 

Results of that monitoring are published annually. Forest-scale monitoring is included 

with this plan.

54. Concern Statement: The Forest Service should not use the Pacific Northwest Region’s 

2008 Aquatic and Riparian Conservation Strategy (ARCS) due to its overly large riparian 

buffer widths and limited scientific relevance to the drier terrain east of the Cascades. In 

addition, the ARCS has not undergone a public NEPA review or tribal consultation. 

Response: Based on our review of the science regarding riparian buffer widths, the 

riparian habitat conservation area widths in PACFISH, as modified for the regional and 

Blue Mountains ARCS (2008, 2018) are appropriate and protective of riparian functions 

as first described in FEMAT (1993). The development of the Environmental Impact 

Statement for the revised Forest Plans represents the NEPA environmental review of the 

regional ARCS (2008) and the Blue Mountains ARCS (2018). Tribal consultations 

regarding content of both strategies reflected in the revised plan alternatives have been 

ongoing. 

The five essential elements of both the regional (2008) and 2018 Blue Mountains ARCS

consist of riparian management areas, key watersheds, watershed analysis, protection and 

restoration, and monitoring and adaptive management. These elements were incorporated 

into a suite of plan components for each of the action alternatives, by: 

♦ Setting goals and desired conditions [riparian management Areas, key watersheds, 

restoration], 

♦ Identifying suitable uses or activities that are or are not generally appropriate in 

certain management areas [riparian management areas, protection],

♦ Describing anticipated outputs in the form of objectives that are a means to measure 

progress towards achieving or maintaining desired conditions [restoration, key 

watersheds], 

♦ Constraining activities with standards or guidelines that ensure protection of physical 

and biological resources [riparian management areas, key watersheds, watershed 

analysis],

♦ Conducting monitoring and evaluation that will provide a basis for a periodic 

determination and evaluation of the effects of management practices [monitoring and 

adaptive management]. 
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The five constituent elements of the regional ARCS (2008) were embedded in Plan 

components applicable to Alternatives B through F in Appendix A of the Final 

Environmental Impact Statement. 

The Blue Mountains ARCS (2018) is based on the updated regional ARCS (2016) and 

has been adapted specifically to concerns in the Blue Mountains planning area through 

elements incorporated into plan components for the two additional alternatives, EModified and E-Modified Departure. Details of the plan components for alternatives EModified and E-Modified Departure are also provided in Appendix A of this document. 

In addition, the Blue Mountains ARCS is in Appendix A of the Revised Plans and 

provides Plan direction for use in implementation of the preferred alternative. Appendix 

A of the revised Plans contains full discussions of the science and rationales for Blue 

Mountains ARCS-derived Plan components and other direction. 

Elements of the 2008 ARCS were disclosed and addressed in the Draft Environmental 

Impact Statement. The Blue Mountains Aquatic and Riparian Conservation Strategy is 

incorporated into Alternatives E-Modified and E-Modified Departure. The Biological 

Assessment and Biological Opinion constitute consultation on the 2018 Blue Mountains 

Aquatic and Riparian Conservation Strategy and the environmental effects of the strategy 

are addressed in Chapter 3 of the Final Environmental Impact Statement.

Climate Change 

Climate Change: Aquatics 

55. Concern Statement: The Forest Service should consider the impact of climate change on 

endangered fish species, for example changes in peak flow timing and lower summer 

flows as well as the potential for shifting distribution of bull trout and the increased 

importance of core habitat on national forestlands. In addition, the Forest Service should 

consider the synergistic effects of roads, grazing and logging, and climate change on 

aquatic resources. 

Response: Climate effects to threatened and endangered fish species, including expected 

changes in stream temperature and effects to bull trout are discussed in the “Aquatic 

Species” section of the Final Environmental Impact Statement. Changes in peak 

streamflow and summer low flows are described in the “Watershed Function, Water 

Quality, and Water Uses” section. The synergistic effects of forest management and 

climate change are discussed in both sections.

The Watershed Function, Water Quality, and Water Uses section has been updated to 

describe changes in the hydrology of area streams, including peak flows and low flows. 

For example, the analysis displays that the timing of peak flows on the Grande Ronde 

River is strongly affected by the timing of rainfall. Four winter (December through 

February) peaks occurred between 1904 and 1950, while 13 winter peaks occurred after 

1950 through 1989, the extent of the record for the gage at La Grande, Oregon. McIntosh 

et al. (1994) noted an apparent change in the date of annual peaks to one month earlier 

and attributed the change to a likely land use affect. The updated analysis notes that raindriven floods account for a shift in peak flow timing of 20 days between 1904 and 1989. 

In addition, nearly all spring peaks on the Grande Ronde River after 1950 have occurred 

on days of measureable rainfall at La Grande, and that the timing of rainfall may account 

for all of the remaining difference in peak flow timing on the Grande Ronde River. 
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Climate Change: Assumptions

56. Concern Statement: The Forest Service should drop all references to climate change

because the existence of climate change and any potential negative effects are too 

uncertain. Climate models have failed to predict actual temperature and are not reliable. 

Response: In 2010, the Forest Service provided specific direction to the National Forest 

System in the form of the National Roadmap for Responding to Climate Change (USDA 

FS 2010a) and the Performance Scorecard for Implementing the Forest Service Climate 

Change Strategy (USDA FS 2010b). The goal of the Forest Service climate change 

strategy is to “ensure our national forests and private working lands are conserved, 

restored, and made more resilient to climate change, while enhancing our water 

resources” (USDA Forest Service 2010b). In the Blue Mountains, the strategy includes 

addressing climate change in our planning documents. Climate projections are currently 

based on multiple models and use the range of projected outcomes to bracket the 

expected range of future global temperatures. Using this method there is no climate 

scenario that predicts that future temperatures will be cooler (Halofsky and Peterson 

2017) and all models used to assess future temperatures in the Pacific Northwest predict 

warmer temperatures by the end of the century of at least 0.9 degrees Fahrenheit in all 

seasons (Mote and Salathé 2010). 

The Third Oregon Climate Assessment (Dalton et al. 2017) notes that Oregon’s mean 

temperature warmed by 2.2 degrees Fahrenheit per century during the period 1895-2015, 

that the Pacific Northwest warmed by between 1.1 and 1.5 degrees Fahrenheit between 

1901 and 2012, that this change was largely due to increases in atmospheric greenhouse 

gases, and that the observed warming trend accelerated after 1970. 

Oregon’s mean annual temperature is projected to increase by 2.1 to 10.7 degrees 

Fahrenheit by the 2080s (2070-2099 average) compared to the 1970-1999 average with 

the amount of warming largely dependent on the magnitude of future greenhouse gas 

emissions.

Available data indicates that climate change is already impacting the hydrology of 

streams and rivers in the Pacific Northwest. Low flows in the driest years have become 

lower in recent decades (Luce and Holden 2009); mountain snow is melting earlier 

(Cayan et al. 2001, Mote 2006), winter snowpack has been declining (Mote 2003, Hamlet 

et al. 2005), and spring runoff is occurring earlier (Mote et al. 2005, Stewart et al. 2005, 

Hamlet et al. 2007). All of these changes are expected to intensify as temperature 

increases (Littell et al. 2011, Luce et al. 2014).

57. Concern Statement: The Forest Service should focus on the next 15 to 20 years, in 

which case climate change is irrelevant, as most of the predicted changes won’t occur. 

Response: Refer to the response to the previous comment. Changes in hydrology, 

including winter snow accumulation, earlier snowmelt, earlier spring runoff, and lower 

low flows are already occurring (Hamlet et al 2005, Hamlet and Lettenmaier 2007, Cayan 

et al, 2001, Luce and Holden 2009). Increases in average temperature since 1900, and 

accelerated change since about 1970 are well documented and expected to continue. 

Earlier snowmelt and warmer spring temperatures have been associated with increased 

wildfire frequency and intensity (Westerling et al. 2006; Littell et al. 2009, 2010). The 

focus of this Forest Plan Revision is on the next 10-15 years, but all of the changes 

described in the response to the previous comment are expected to continue, if not 

accelerate.
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58. Concern Statement: The Forest Service should clarify expected changes in precipitation 

and likely effects on forests. 

Response: Expected changes in precipitation are less certain than for temperature and 

this may be because the variables that influence precipitation in the Pacific Northwest are 

more complex. Warmer air can hold more water vapor, so one effect is intensification of 

hydrologic extremes, meaning that larger floods, but also more intense droughts, are 

possible (Huntington 2006, Karl et al. 2012, Salathé et al. 2014). 

Average precipitation in Oregon increased by 0.73 inches per century between 1895 and 

2015 (Dalton et al. 2017), but high year-to-year variability is larger than the trend. 

Projected increases in precipitation are small (2 to 6 percent) and also vary with expected 

future greenhouse emissions. Recent increases in summer precipitation in the Blue 

Mountains are small and are likely to be outweighed by the effects of increased 

temperature on the water requirements of vegetation (Huntington 2008). Projections for 

Oregon are for increased precipitation in fall, winter, and spring, and decreased 

precipitation in summer (Dalton et al. 2017). Most commenters on this Forest Plan

revision effort are aware that 2015 was one of the driest and warmest years on record, 

with low winter snowfall and extended above average temperatures in late summer, and 

record fire occurrence in the Blue Mountains. The Third Oregon Climate Assessment 

suggests that 2015 may represent “average” conditions by as early as 2050 if current 

trends continue (Dalton et al. 2017).

Climate models used to assess future climate in the Pacific Northwest predict that some 

of the change will result from decreased frequency of low temperature extremes, but that 

temperatures are expected to be warmer in all seasons, with the largest increases in 

summer months. Climate models that predict the largest summer temperature increases 

also predict the largest declines in summer precipitation (Mote et al. 2013).

Climate Change: Carbon Sequestration

59. Concern Statement: The Forest Service should focus on cultivation of young trees to 

best support carbon sequestration. Older, low- productivity and dying trees should be 

harvested.

Response: Forest scientists have shown that large, old trees do not act simply as 

senescent carbon reservoirs but, along with smaller and mid-sized trees, they also actively 

fix large amounts of carbon. For example, at the extreme, a single big tree can add the 

same amount of carbon to the forest within a year as is contained in an entire mid-sized 

tree (Stephenson, et al. 2014.) Managing wildfire-prone forests that have naturally 

evolved within a frequent fire regime for carbon sequestration is complex. Large trees 

and old trees offer more than carbon sequestration; they are an essential habitat 

component for a myriad of species and play a critical role in the proper ecological 

function of fire-adapted forests. The Forest Service believes that managing for climate 

mitigation, as well as other benefits, is best approached at scales and perspectives larger 

than individual stands or trees. 

The Forest Service’s desired conditions are informed in part by a need to use carbon 

sequestration as a potential climate change mitigation benefit. The goals and desired 

conditions of the Plans must also address a myriad of other essential ecosystem services. 

Forest management activities and strategies over the life of the Plans will be guided 

largely by the desired conditions. The desired conditions pertaining to forest vegetation 

are based on moving closer to an overall forest environment that is consistent with the 
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natural range of variability. These conditions would incorporate an ecologically 

sustainable mix of age classes, tree sizes, structural stages, and species. The Forest 

Service believes that restoring and maintaining landscapes within this natural range of 

variation represents our best chance to balance potential conflicts between ecosystem 

services, including climate mitigation, while maintaining ecological integrity and 

sustainability over time. Ensuring the long-term sustainability of the forests is critical to 

meeting both the present and future needs of forest-dependent local communities.

60. Concern Statement: To protect carbon stores, the Forest Service should log less, protect 

mature and old growth forests, adopt longer rotations, retain more trees when harvesting, 

tolerate denser forests, and avoid soil disturbance. The Forest Service should incorporate 

a plan, including standards and guidelines, to increase carbon storage in the Blue 

Mountains. Each management scenario should be compared to the natural rate of carbon 

accumulation. 

Response: As discussed above, we recognize that old trees and mature forests play an 

important role in providing carbon storage, as well as providing other desired ecosystem

characteristics. However, the Forest Service believes that the complexity of managing 

fire-adapted forest ecosystems, which have naturally evolved within a frequent fire 

regime, is best approached at scales and perspectives larger than individual stands or 

trees. Managing for climate mitigation and ecosystem services like carbon storage will be 

best served by restoring and maintaining diverse and resilient forest conditions within 

their natural range of variation at the landscape scale. The Forest Service’s strategy will 

not attempt to maintain forest ecosystems in an unstable and unnaturally dense condition. 

These conditions would not be sustainable and would threaten other desired ecosystem 

services. Promoting unnaturally high levels of dense forest conditions would only lead to 

future releases of large amounts of stored carbon as natural disturbance agents like 

wildfire and insect and disease outbreaks would inevitably affect the areas and produce 

massive tree die-offs. Working toward the Plan’s desired conditions for forest vegetation 

would promote an ecologically sustainable mix of all age classes, tree sizes, structural 

stages, and species. In many, but not all areas, this will mean reducing existing stand 

densities and concentrating tree-based carbon within large, mature, fire-resistant 

individuals.

61. Concern Statement: The Forest Service should clarify how the increased emphasis on 

prescribed fire will affect carbon storage. 

Response: The Forest Plans do not necessarily call for an increased emphasis on 

prescribed fire. The role of wildland fire, both planned and unplanned, is currently 

recognized to be extremely important. It is expected to continue to play a critical role. 

Carbon sequestration and dynamics within frequent fire forest ecosystems is affected by 

many factors including wildfire and management activities. Wildfire acting on the altered 

forest conditions that are presently typical within much of the Blue Mountains represents 

a significant risk to the ability of these forests to sustainably store carbon. Prescribed 

burning is one tool that can be used to reduce the potential carbon emissions associated 

with severe wildfires. Properly designed and implemented prescribed fires consume less 

biomass and therefore release less carbon to the atmosphere than severe wildfires 

(Wiedinmyer and Hurteau 2010; Dore et al. 2010). The prescribed burns can be designed 

and implemented to reduce stand densities and support the development of low-density 

structures and large, mature, fire resistant trees. These stand characteristics reduce the 

risk of severe post-wildfire mortality and the resulting large carbon emissions.
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62. Concern Statement: The Forest Service should note that removing merchantable 

material leads to carbon storage in wood products. 

Response: The Forest Service appreciates the role forest products play in storing carbon. 

In the U.S., forest products are stored in two major forest product “pools,” products that 

are in use, and those held in landfills. Current additions of carbon to these pools from 

trees harvested in the U.S. are greater than decomposition losses from these pools, so 

carbon stored in these pools is increasing over time (Ryan et al. 2010). Forest products 

also play a role in carbon dynamics when they are used in place of more energy intensive 

materials like plastic, metal, and concrete. Carbon emissions are reduced because forest 

products require less amounts of fossil fuels to produce than many other substitute 

materials.

63. Concern Statement: The Forest Service should not endorse biomass utilization for 

energy in the forest plans because it isn’t climate neutral. 

Response: Carbon neutrality is not necessarily a desired condition incorporated into the 

Forest Plans. The use of forest biomass energy reduces carbon emissions that would 

otherwise be released from fossil fuel use. Energy produced from fossil fuels releases 

carbon into the atmosphere that had been stored within the earth for millions of years. 

While not carbon neutral, biomass energy is a renewable source that is largely fueled 

from recycling carbon that is already within the atmosphere. It uses far less of the carbon 

stored within the earth than the production and consumption of fossil fuels. The overall 

desired conditions for the forest ecosystem support managing for climate mitigation and 

ecosystem services like carbon storage by restoring and maintaining diverse and resilient 

forest conditions within their natural range of variation at the landscape scale. In the dry 

upland and mixed conifer forests of the Blue Mountains, biomass utilization technology 

can help support many of the kinds of treatments that are necessary to implement climate 

adaptation strategies and restore more resilient forest conditions.

64. Concern Statement: The Forest Service should not claim that the desired landscape will 

provide a better contribution to carbon storage because only a small fraction of the treated 

areas will actually experience fire or insects. The loss of carbon from logging would be 

greater than emissions from fire and insects alone. 

Response: The opinion that wildfire and insect disturbances only potentially affect a 

small portion of the forest landscape is not supported by the best available science 

information. Disturbances play a very large role in forest ecosystem carbon dynamics. All 

of the national forests of the Blue Mountains have evolved within an environment that 

has been, and will continue to be heavily influenced by the occurrence of natural 

disturbances like wildfire and outbreaks of native insects. The Forest Service’s 

management strategies do not attempt to predict precisely where and when these 

disturbance forces will occur. Rather, management objectives are based on the 

assumption that natural disturbance forces will inevitably return to all of the area, so 

management attempts to proactively alter the conditions that disturbances agents like fire 

will encounter when they do return. 

Most of the forests of the Blue Mountains have naturally evolved alongside wildfire 

within a frequent fire occurrence regime. The complexity of managing these kinds of 

forests for carbon storage, along with other desired ecosystem services, must consider the 

current altered condition of the forest within the context of probability of natural wildfire 

occurrence. Given these considerations, the two disturbance agents that are most likely to 

next affect the dry upland and mixed conifer forests that dominate the Blue Mountains 
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are either wildfire, or managed activities like thinning, harvesting, or prescribed fire. 

Several forest scientists studying these particular issues have found that high severity fire 

has a larger impact on ecosystem carbon uptake and storage than thinning activities or 

prescribed fire. In wildfire prone forests, overall tree-based carbon stocks will be best 

protected by management treatments that produce low-density structure dominated by 

large, mature, fire-resistant species (Hurteau and North 2008; Dore et al. 2010; 

Wiedinmyer and Hurteau 2010; Schaedel et al. 2017). 

Climate Change: Ecological Resilience

65. Concern Statement: The Forest Service should offer an accurate baseline of conditions 

that includes monitoring and forecasting of climate change over the life of the plan. 

Response: The historical baseline used in the climate literature varies. The Third Oregon 

Climate Assessment (Dalton et al. 2017) uses the period 1970-1999, while papers cited in 

Halofsky and Peterson appear to have used different base periods. The Forest Service is 

likely to rely on climate forecasts from scientists of the Climate Impacts Group at the 

University of Washington, the Oregon Climate Change Research Institute at Oregon State 

University, national assessments, and the work of Forest Service research scientists 

involved in climate change. Forecasts are currently developed for different future time 

periods. Most commonly these include the 2030s (2020-2039 average), 2050s (2040-

2059 average) and 2080s (2070-2099 average).

66. Concern Statement: The Forest Service should incorporate climate change adaptation in 

its desired future conditions. The Forest Service should support climate adaptation by 

limiting stressors, for example by reducing road density, enlarging culverts, reducing 

livestock grazing, protecting refugia at different elevations and adjacent buffer areas, 

conserving biodiversity, improving landscape connectivity, and restoring natural 

disturbance regimes. 

Response: The desired conditions of the Forest Plans have been informed by, and are 

consistent with many of the climate adaptation strategies that are being called for in this 

region of the west. Many of the forest management activities that will be used to move 

toward our desired conditions also have a recognized role as part of a climate change 

adaptation strategy (Peterson et al. 2011; Halofsky and Peterson 2016). For example, 

using a full suite of management options including mechanical thinning and prescribed 

burning will facilitate the creation of a forest mosaic of different age-classes, species, and 

structures across the three National Forests. This mitigates risk and serves as an 

adaptation strategy that will also provide functional diversity and a range of habitats at 

large spatial and temporal scales. These conditions will increase resilience to stressors 

and ensure that forests are sustainable and remain available to store sustainable levels of 

carbon over the long term.

67. Concern Statement: The Forest Service should address the potential conflict between 

climate change mitigation and climate change adaptation, including the role of mortality 

in supporting forest adaptation. 

Response: The Forest Service believes that the best balance between the goals of climate 

mitigation via increased carbon storage, versus adapting forest conditions to anticipated 

climatic conditions is achieved by restoring and maintaining resilient forest conditions 

within their natural range of variability. Attempting to maintain forest ecosystems in an 

unstable and unnaturally dense condition as a way to store additional carbon would not be 

sustainable, and would also neglect other desired ecosystem services. These conditions 
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would lead to future releases of large amounts of stored carbon, as natural disturbance 

agents like wildfire and insect and disease outbreaks inevitably return and produce severe 

die-offs of trees. Many forest scientists studying these particular issues have found that 

high-severity fire has a larger impact on ecosystem carbon uptake and storage than 

thinning or prescribed fire activities. In wildfire-prone forests, overall tree-based carbon 

stocks will be best protected by management treatments that produce low-density 

structure dominated by large, mature fire resistant species (Hurteau & North 2008; Dore 

et al. 2010; Wiedinmyer and Hurteau 2010; Schaedel et al. 2017). 

Many of the forest management activities that will be used to move toward our desired 

conditions also have a recognized role as part of a climate change adaptation strategy 

(Peterson et al. 2011; Halofsky and Peterson 2016). For example, using a full suite of 

management options including mechanical thinning and prescribed burning will facilitate 

the creation of a forest mosaic of different age-classes, species and structures across the 

three National Forests. This serves as an adaptation strategy that will provide functional 

diversity and a range of habitats at large spatial and temporal scales. These conditions 

will also increase resilience to stressors and ensure that forests remain available to store 

sustainable levels of carbon over the long term.

68. Concern Statement: The Forest Service should consider the predicted longer and drier 

fire season and factor this into desired conditions. 

Response: Historical reference conditions remain useful to guide management because 

historically forests were quite resilient to the same disturbance agents and forces that are 

predicted to increase under many climate change scenarios, namely drought, insects, 

pathogens, and wildfire. The Forest Service has considered the argument that conditions 

reflective of the pre-settlement era should no longer be used as a reference baseline 

because future conditions could be much warmer and drier due to climate change. 

However, given the enormous degree of uncertainty associated with the magnitude, 

timing, scale, and spatial extent of anticipated climate change impacts, we find that the 

historical range of variability approach is warranted and remains useful. There is 

considerably less uncertainty associated with historical range of variability, compared to 

any simulated predictions for the future. Further, it seems very unlikely that using 

historical range of variability to inform desired conditions for forest vegetation and to 

guide management efforts will result in inappropriate activities within the near and midterm time frames of the next plan period. There are broad ranges of conditions depicted 

by the historical range of variability that would allow considerable flexibility in future 

management choices. More discussion regarding historical range of variability and 

anticipated climate change effects can be found throughout the analysis in the Final 

Environmental Impact Statement.

69. Concern Statement: The Forest Service should include in its analysis the potential 

change in plant water use efficiency due to climate change. 

Response: The commenter is referred to articles by Thomas Huntington on the topic 

(Huntington 2004, 2006, 2008, 2010). Increased atmospheric carbon dioxide affects the 

water requirements of vegetation but the effect varies with temperature and is expected to 

eventually be outweighed by increased temperature (Perry et al. 2013). Research supports 

that higher concentrations of carbon dioxide in the atmosphere reduce the water 

requirements of forest vegetation. This effect needs to be tempered against the effect of 

earlier warming in spring, higher temperatures in all seasons, and lower summer 

precipitation. The effects of increased temperatures will be exacerbated by earlier 
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snowmelt and a higher percentage of precipitation falling as rain rather than snow, 

resulting in an extended summer dry season and increased drought stress to terrestrial 

vegetation, and possible riparian vegetation as well. There may be a near-term increase in 

water use efficiency, but the benefit to forest vegetation is diminished, and there are 

already cases where drought stress is increasing tree mortality from the effects of drought 

(McKenzie et al. 2008, Breshears et al. 2005, 2009) and changes in disturbance regimes 

resulting from increased temperatures (Vose et al. 2012, Adams et al. 2011). 

Climate Change: Monitoring and Adaptive Management

70. Concern Statement: The Forest Service should develop a plan that allows local land 

managers to collaboratively adapt to changing conditions. 

Response: One feature brought forth from the 2012 Planning Rule is the ability to have a 

monitoring program in each of the Plans for the three National Forests. The purpose of 

monitoring and evaluation is to ensure that management direction is being carried out, 

and that the outputs and schedules are being achieved. Monitoring allows responsible 

officials to test assumptions, track changing conditions, measure management 

implementation and effectiveness in achieving desired outcomes, and feed new 

information back to inform adaptive management. The key role that monitoring serves in 

adaptive management is that it provides the opportunity for facilitated learning to 

measure progress toward desired conditions and objectives of the land management plan 

as well as measuring effectiveness of plan components. 

71. Concern Statement: The Forest Service should incorporate monitoring questions 

directed at climate concerns and uncertainties, collect needed data, and add a mechanism 

for evaluating and modifying management strategies (annually and more formally every 

five years) as well as benchmarks or triggers for management actions. 

Response: The Forest Service uses best available science in determining monitoring 

measures. Appendix A of the Environmental Impact Statement outlines monitoring 

questions, their link to direction, and measures for answering the questions. Changes 

have been made in the Final Environmental Impact Statement to improve the monitoring, 

with some revised questions, updated measures, incorporation of links to the direction, 

frequency of measurement, precision and reliability, and the time when evaluation will be 

reported. The monitoring program described in Appendix A meets all monitoring and 

evaluation requirements under the 2012 planning regulations.

72. Concern Statement: The Forest Service should include a risk assessment to characterize 

vulnerability, informed by the Blue Mountain Adaptation Partnership Vulnerability 

Assessment, in order to address climate change. The National Roadmap for Responding 

to Climate Change (44 Fed. Reg. at 26609) identifies an adaptation dimension to assess 

vulnerability, set priorities and monitor change. 

Response: The purposes of conducting the Blue Mountains vulnerability assessment 

were to identify risks to different resources and to incorporate that information into the 

Forest Plans and Final Environmental Impact Statement. This has been done to differing 

degrees, depending on the alternative, resource, and the nature of vulnerability to climate 

change.
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Cultural37

Cultural: Analysis

73. Concern Statement: The Forest Service should consider Native American and 

traditional local knowledge in addition to academic science. 

Response: We agree that forest planning and management should include a broad range 

of scientific information based on best available science and traditional and cultural 

knowledge based systems. The revised Forest Plans recognize the need for these 

expanded science-based views and contributions and include additional language for each 

listed goal stating that resources “will be managed using traditional ecological and 

cultural knowledge and best available science.” These systems, combined with ongoing 

planning and project-level coordination and collaboration will support forest decisionmaking processes and contribute to ecological, social, and economic sustainability. 

Traditional knowledge is considered through public and Tribal participation and ongoing 

government-to-government consultation.

74. Concern Statement: The Forest Service should use a broader definition of cultural 

resources as encouraged by NEPA. The Forest Service should better identify traditional 

cultural properties and places in its existing condition description and should include new 

measures of cultural values to better represent the full spectrum of local cultural values 

communities. 

Response: We have expanded the definition for Historic Properties in Section 2.5 

Cultural Resources in both the “Background” and “Desired Conditions” sections of the 

Plans to include “properties of traditional religious and cultural importance to American 

Indian Tribes” as described in the National Historic Preservation Act, as amended. The 

expanded definition continues to recognize prehistoric, historic, or traditional cultural 

property site-type categorizations. Similarly, the definition of traditional cultural 

properties was refined in section 2.5 Cultural Resources and states “Traditional cultural 

properties, cultural landscapes, sacred sites, and other culturally significant areas and 

resources identified by Tribes and local communities provide tangible links to historically 

rooted beliefs, customs, and practices.” The enhanced definitions and desired condition 

plan components provide additional clarification and will better inform project-level 

planning and implementation to consider these cultural resource types in the planning 

process.

75. Concern Statement: The Forest Service should reconsider its method for evaluating 

priority heritage assets, particularly on the Wallowa-Whitman National Forest. 

Response: Priority Heritage Assess evaluations are a function of the Heritage Program 

Managed to Standard program outlined in Forest Service Manual 2360 (FSM 2360). The 

Forest Service defines Priority Heritage Assets as “those assets of distinct pubic value 

that are or should be actively maintained and meet one of more of the following criteria:” 

(FSM 2360.5) 

a. The significance and management priority of the property is recognized through an 

official designation such as listing on the National Register of Historic Places or on a 

State register.

 

37 Includes cultural topics related to wildlife and other categories
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b. The significance and management priority of the property is recognized through prior 

investment in preservation, interpretation, and use.

c. The significance and management priority of the property is recognized in an agencyapproved management plan. 

d. 4The property exhibits critical deferred maintenance needs and those needs have 

been documented. Critical deferred maintenance is defined as a potential health or 

safety risk or imminent threat of loss of significant resource values.

The areas that are specifically managed to protect cultural resources are allocated to 

Management Area 2E – Historical Areas. Six historical areas totaling 2,300 acres have 

been included in Management Area 2E for Alternative E-Modified for the WallowaWhitman National Forest. Cultural resources in other locations are protected through 

existing laws, regulations, policies, and existing agreements with the Oregon and 

Washington State Historic Preservation Offices. 

76. Concern Statement: The Forest Service should assess the Nez Perce National Historic 

Trail as a congressionally designated trail as well as the associated auto tour routes and 

recreational facilities. The Oregon Trail should also be considered in the discussion of 

historic properties. 

Response: The revised Forest Plans have included additional background information on 

both the Oregon Trail National Historic Trail and the Nez Perce National Historic Trail 

under Management Area 2G – Nationally Designated Trails located in Part 2, Strategy. 

These descriptions provided necessary background and describe the resource’s national 

significance, which lead to their designation in the National Trails System. Background 

information also recognizes multi-agency management and cooperative efforts by federal 

and state agencies, land owners, and private organizations to steward these nationally 

significant resources. 

To ensure these resources are preserved, two additional standards were developed that 

provide additional management direction and protection: 

MA2G-1S The Nez Perce National Historic Trail shall be managed consistently with 

the guidance in the Nez Perce National Historic Trail Comprehensive 

Management Plan (USDA Forest Service et al. 1990). 

MA2G-2S The Nez Perce National Historic Trail shall be managed as a nonmotorized 

route for primitive hiking and horseback riding for trail segments that are 

not identified as auto tour routes. 

Cultural: Managing Cultural Resources

77. Concern Statement: The Forest Service should work with the Tribes to identify 

properties of cultural and religious significance and areas that will be managed 

specifically to protect cultural resources. 

Response: The areas that are specifically managed to protect cultural resources are 

allocated to Management Area 2E – Historical Areas. Cultural resources in other 

locations are protected through existing laws, regulations, policies, and existing 

agreements with the Oregon and Washington State Historic Preservation Offices. In 

addition, the desired condition for Goal 2.5 – Cultural Resources, was modified and 

states, “Significant prehistoric and historic sites, traditional cultural properties, and 

properties of traditional religious and cultural importance to American Indian Tribes are 
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identified and protected.” Identifying these locations includes consultation with the 

affected tribes, and while many of these efforts will be completed at site-specific and 

project-level analysis, site and resource identification processes may be developed 

outside of the forest planning process and subsequent project-level analysis. 

78. Concern Statement: The Forest Service should consider designating routes used by 

Indians during the Bannock-Paiute War of 1878 as a National Historic Trail System. 

Special designation to protect burial sites and battlegrounds should also be considered. 

Response: Reviewing and recommending National Historic Trails for inclusion in the 

National Trails System is not conducted as part of the Forest Plan revision process. As 

stated in the National Trails System Act (Public Law 90-543, as amended through Public 

Law 111-11), the process for designating trails or authorizing additional studies is 

outlined in Section 5 (b): “The Secretary of the Interior, through the agency most likely to 

administer such trail, and the Secretary of Agriculture where lands administered by him 

are involved, shall make such additional studies as are herein or may hereafter be 

authorized by the Congress for the purpose of determining the feasibility and desirability 

of designating other trails as national scenic or national historic trails.” Further detail and 

criteria are outlined in section 5 (b) (1-11). Important features associated with a National 

Historic Trail are generally included within the broader trail designation and are included 

in the associated trail management plan.

79. Concern Statement: The Forest Service should establish a management area and 

standards and guidelines for historic trails, including the Nez Perce National Historic 

Trail. 

Response: Management Area 2G – Nationally Designated Trails includes those trail that 

are included in the National Trails System as established by the National Trails System 

Act (Public Law 90-543, as amended through Public Law 111-11). Additional 

background information describing the Nez Perce National Historic Trail was included in 

the Management Area 2G discussion. Two additional Standards were developed 

specifically for the Nez Perce National Historic Trail and state: 

MA2G-1S The Nez Perce National Historic Trail shall be managed consistently with the 

guidance in the Nez Perce National Historic Trail Comprehensive 

Management Plan (USDA Forest Service et al. 1990). 

MA2G-2S The Nez Perce National Historic Trail shall be managed as a nonmotorized 

route for primitive hiking and horseback riding for trail segments that are not 

identified as auto tour routes. 

80. Concern Statement: The Forest Service should provide for traditional cultural uses by 

local communities, including visiting scenic areas, hunting, fishing, camping, access to 

motorized and nonmotorized trails, and other opportunities to connect with nature. 

Response: The revised Forest Plans promote sustainable recreation uses of the forests 

through stated goals, desired conditions, and other plan components. Goal 2: Promote 

Social Well-Being provides a firm planning foundation to encourage recreational uses 

while conserving the natural resources that form the resilient and diverse ecological 

conditions that attract recreational users to the national forests. Subsections within Goal 2 

include scenery (2.1), recreation (2.2) that includes developed recreation, dispersed 

recreation, and backcountry recreation, hunting and fishing (2.3), and road and trails 

access (2.5) among others. Traditional cultural properties are discussed in Goal 2.4 
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(Cultural Resources) and are emphasized in the desired condition along with other 

cultural resource types. Further direction for identifying and evaluating traditional 

cultural properties can be found in National Register Bulletin 38 entitled Guidelines for 

Evaluating and Documenting Traditional Cultural Properties (Parker and King 1990; 

Revised 1992; 1998). 

Cultural: Tribal Consultation

81. Concern Statement: The Forest Service should meet with Tribal technical staff to better 

understand Tribal issues and priority rights. 

Response: Throughout the planning process, the Forest Service has engaged Tribal 

organizations in order to develop a better understanding of Tribal interests and rights, and 

to develop specific plan content that is responsive to these interests. Chapter 4 of the 

Final Environmental Impact Statement outlines these communications, noting that 

detailed Forest Service communications with the Tribes are available in the planning 

record and include official correspondence letters and meeting notes from the numerous 

government-to-government and staff-to-staff meetings. The revised Forest Plans are 

responsive to the Tribes’ input and consideration, and the Forest Service will continue 

working closely with American Indian Tribes to fulfill our trust responsibility and to 

better protect and conserve ecological and cultural resources that are central to the Tribes’ 

traditions

82. Concern Statement: The Forest Service should modify cultural resource guideline CUL1 to require consultation and concurrence with the affected Indian Tribe(s). 

Response: We agree that affected Indian Tribes be included in all consultation efforts. 

Based on this comment and other recommendations, we have changed the cultural 

resources guideline to a standard and included the appropriate consultation language. The 

standard now states: 

CR-1S Prehistoric, historic, and traditional cultural properties shall be protected unless 

an exemption is specified in a programmatic agreement or a project specific 

mitigation plan is developed in consultation with the appropriate State Historic 

Preservation Officer and affected Indian Tribe(s).

83. Concern Statement: The Forest Plans should include goals and objectives for 

government-to-government consultation with the Tribes. 

Response: The revised Forest Plans contain a section that focuses on Tribal coordination 

and consultation. The section, entitled “Federal Trust Responsibilities and Tribal Rights 

and Interests” is located in the revised Forest Plans under Part 2 – Strategy, Management 

Focus. The intent of this section is to highlight the Forest Service’s unique legal 

responsibility to American Indian Tribal governments as set forth in the Constitution of 

the United States (Article VI, Clause 2), treaties, statutes, Executive Orders, and court 

decisions. This section further emphasizes the unique identity that each Tribe maintains, 

the different authorities each Tribe possesses, and the importance of maintaining access 

for Tribes to culturally significant sites, to use and possess sacred objects, to protect their 

ancestral graves, archaeological sites, and cultural sites, the freedom of worship through 

ceremonial and traditional practices, and to collect native plant and animal resources for 

traditional cultural purposes. The regulatory framework outlined in this section identifies 

consultation requirements that the forests uses for both forest planning and for project-
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level analysis and decisionmaking, and underscores the priority to consult with tribes 

whenever proposed policies or management actions may affect their interests.

Cultural: Tribal Role-Desired Conditions

84. Concern Statement: The Forest Service should modify the desired conditions for 

cultural resources to better incorporate Tribal interest in the management of cultural 

resources. Desired conditions should address protection and restoration of fish, wildlife, 

native plant resources, and open space. 

Response: The desired condition for Goal 2.8 - Tribal Rights and Interests was improved

to recognize the importance and priority of consultation with the Tribes for actions that 

include not only cultural resource identification, protection, and management, but also 

consultation “to protect those rights and interests and to identify and manage areas and 

resources of tribal importance on National Forest lands.” Additionally, each goal was 

modified to recognize the interrelated importance of ecological, social and economic 

well-being to Tribal identity and cultures. 

Cultural: Tribal Role-Treaty Rights 

85. Concern Statement: The Forest Service should include a standard in the Forest Plans to 

ensure management activities are coordinated with Tribes to meet laws, regulations and 

term of Indian treaties. 

Response: The revised Forest Plans provide programmatic direction for the future 

planning and project-level decision making on the national forests. The Forest Plans do 

not change the Forest Service’s legal requirements outlined in existing regulatory 

framework including the Constitution of the United States (Article VI, Clause 2), treaties, 

statutes, Executive Orders, and court decisions. Additionally, the national forests must 

follow existing direction as set forth in the Forest Service Directive System comprised of 

the Forest Service Manual and Handbooks. In response to this comment and others, an 

additional standard was developed for the revised Forest Plans regarding American 

Indian Tribal government consultation that states: 

TRAI-1S The Forests shall use consultation processes established with American 

Indian Tribal governments to identify and manage areas and resources of 

tribal importance on national forest lands.

86. Concern Statement: The Forest Service should reference all relevant Indian treaties in 

plan revision documents, especially in the Legal Framework section and Appendix D 

sections titled “Tribal and Treaty Resources” and “Heritage Program.” Currently vague 

references to Tribal histories and treaty rights should be replaced with separate and 

specific references for each Tribe and associated treaties. 

Response: We added a specific reference/citation for each of the Tribes’ treaties 

associated with the planning area in the “Federal Trust Responsibilities and Tribal Rights 

and Interests” section in the Forest Plans. The statement, including these specific 

statutory references, states: “A significant portion of lands ceded (by virtue of multiple 

Treaties of 1855) by the Confederated Tribes of the Umatilla Indian Reservation (12 Stat. 

945), Confederated Tribes of Warm Springs (12 Stat. 963), Nez Perce Tribe (12 Stat. 

957), and Confederated Tribes and Bands of the Yakama Indian Nation of the Yakama 

Reservation (12 Stat. 951) were established as part of the National Forest System by the 

Organic Administration Act of June 4, 1897.” These statutes are also listed in Appendix B 
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(Laws and Regulations Relevant to Forest Planning) in the Final Environmental Impact 

Statement.

87. Concern Statement: The Forest Service should add a reference to the Religious 

Freedom Restoration Act to supplement the existing American Indian Religious Freedom 

Act reference in Appendix D.

Response: The Religious Freedom Restoration Act of 1993 has been added to the list of 

laws and regulations in Appendix B (formerly Appendix D) of the Final Environmental 

Impact Statement.

88. Concern Statement: The Forest Service should more fully address Tribal access for 

treaty-reserved purposes in the desired conditions for road and trail access. 

Response: The desired condition for Goal 2.5 – Roads and Trails was modified and 

states, “The need for Tribal access for treaty reserved rights is acknowledged and 

supported.” The modification better reflects the Forest Service’s existing legal 

requirements and trust responsibilities. The modified desired condition also parallels 

similar revised Forest Plan guidance under the Federal Trust Responsibilities and Tribal 

Rights and Interests section that acknowledges “the importance of maintaining access for 

Tribes to culturally significant sites, to use and possess sacred objects, to protect their 

ancestral graves, archaeological sites, and cultural sites, the freedom of worship through 

ceremonial and traditional practices, and to collect native plant and animal resources for 

traditional cultural purposes.” 

89. Concern Statement: The Forest Service should protect, restore and enhance fish, 

wildlife and native plant resources in accordance with the Treaty while also allowing for 

Tribal access to such resources. In addition, the Forest Service should support its 

conclusion that all alternatives provide adequate protection for habitat and watershed 

conditions. Plan components should encourage management actions that maintain or 

increase open space.

Response: Through implementation, the revised Forest Plans strive to achieve a set of 

integrated ecological, social, and economic goals and desired conditions that will 

contribute to a broader range of sustainable and resilient ecosystems now and in the 

future. The Forest Plans recognize that wildlife habitat, watersheds and aquatic habitat, 

fire-adapted ecosystem, climate change, and social and economic expectations 

predominate these interrelated systems. Forest Plan components were developed in light 

of the need for change and focus on restoring and maintaining terrestrial vegetation 

conditions, restoring and maintaining watershed conditions, and contributing to social 

and economic stability. These combined Forest Plan elements will contribute to restoring 

and maintaining resilient ecosystems and contribute to upholding the Forest Service’s 

trust responsibility to conserve and steward these resources for Tribal treaty-reserved 

rights and interests. 

Each of the respective resources sections for wildlife habitat and watershed conditions are 

documented in the Final Environmental Impact Statement and supporting documentation 

and include appropriate indicators and metrics that support associated forest plan 

components. 

As noted in a previous response, both Goal 2.5 – Roads and Trails Access and the 

Management Focus section entitled Federal Trust Responsibilities and Tribal Rights and 

Interests include necessary management direction that supports and acknowledges the 
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need for continued access to national forest lands for Tribal members to exercise their 

treaty-reserved rights.

90. Concern Statement: The Forest Service should recognize that the Fort Bridger Treaty 

invalidates fees for campgrounds or access for members of the Shoshone-Bannock 

Tribes. In addition, the Forest Service should include language that recognizes the 

Shoshone-Bannock Tribes’ rights to subsistence uses on lands within the planning area. 

Response: The revised Forest Plans do not invalidate existing rights, agreements, and 

special use authorizations. As these documents are renewed or reauthorized, they will 

need to comply with the revised Forest Plans. The Forest Plans provide ample direction 

to support continuing agreements with Tribal governments, and they do not contradict the 

1990s Forest Plans with regards to Tribal rights and interests. The Forest Plans similarly 

recognize, support, and acknowledge the ongoing access needs to national forest lands for 

Tribal member to exercise treaty-reserved rights.

Cultural: Wildlife and Plants

91. Concern Statement: The Forest Service should focus on providing year-round elk 

security habitat to provide year-round hunting opportunities for Tribes.

Response: In response to public comments on the Draft Environmental Impact 

Statement, additional Forest Plan components including desired conditions, standards, 

guidelines, and objectives were developed to address elk security needs. These combined 

plan components provide holistic management direction that encourages elk use of 

National Forest System lands, preserves elk security, and improves distribution of elk 

across all seasonal ranges within the planning area. Planning components further inform 

future site-specific planning and analysis to consider elk security, elk forage and 

nutrition, elk hiding cover, and elk habitat selection and distribution. In coordination with 

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

Wildlife, and Tribal biologists, areas were identified that are best suited for improving elk 

distribution by creating additional elk security. These combined Forest Plan components, 

and the collaborative intergovernmental planning efforts to develop them, are responsive 

to Tribal members’ needs to exercise treaty-reserved rights to hunt on “open and 

unclaimed lands.” 

92. Concern Statement: The Forest Service should create wildlife corridors and minimize 

General Forest land allocations to maintain Tribal wildlife resources. 

Response: The Final Environmental Impact Statement analyzes a range of alternatives 

including a range of management area allocations. Some alternatives allocate acres to 

Management Area 3C - Wildlife Corridor while others do not. The effects analysis in 

Chapter 3 describes how each alternative contributes to the connectivity of habitats for 

various wildlife species. Areas where most types of active management are generally not 

suitable will provide varying amounts of wildlife habitat connectivity. Riparian 

management areas also function as wildlife corridors for some species. Forest Plan 

components provide management direction for wildlife connectivity in Goal 1.12 - 

Landscape Patterns, and future site specific and planning analysis will implement wildlife 

connectivity/corridors and manage open motor vehicle routes at the project level as 

appropriate. 

(See also concern statements under “Wildlife,” especially “Wildlife: Standards and 

Guidelines”)
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Energy 

Energy: Generation and Transmission

93. Concern Statement: The Forest Plan should include standards and guidelines that 

streamline power generation and transmission and not preclude use of existing corridors. 

To support energy projects, the Forest Service should allow hazard trees and snags to be 

cut in existing right-of-ways. 

Response: Use of existing corridors is generally preferred, but can depend on corridor 

characteristics, the resources affected, and the nature of a proposed use. Utility corridors 

are managed under the terms of special use authorizations in which removal of hazard 

trees may or may not be allowed, depending on the terms of the authorization. The 

proposed guideline allows for the temporary offsite storage of hazard trees removed for 

safety reasons.

Energy: Suitability

94. Concern Statement: The Forest Service should make wind energy an unsuitable use on 

National Forest lands within the Blue Mountains. Wind development restricts use of 

forest by the public and would require trade-offs unsuited to the Forest Service’s 

multiple-use responsibilities, for instance impacting hunting as well as other recreation 

opportunities. Wind developments detract from the beauty of national forests and impact 

viewsheds. Windmill lights are visible for many miles and could affect designated scenic 

or wilderness areas. Wind developments negatively impact birds, bats and other wildlife; 

increase the spread of invasive plants; cause erosion and habitat fragmentation and 

degradation; and increase the potential for species to become federally listed as 

threatened or endangered. Finally, wind power is inefficient, unreliable, and would 

require road and infrastructure development as well as high voltage power lines that 

would increase fire risk.

Response: The Energy Policy Act of 2005 (sec. 201) considers the use and occupancy of 

National Forest System lands for renewable energy development appropriate and 

contributes to the energy needs of the United States. The Act further requires the 

evaluation of renewable energy potential on Federal lands, including wind, solar, and 

geothermal energy. The Draft Environmental Impact Statement displayed a total of 

388,000 acres of National Forest System lands as having potential for wind energy 

development. This estimate is revised in the Final Environmental Impact Statement to 

include acres of General Forest (MA 4A) with sufficient wind potential for commercial 

development, resulting in a revised estimate of 39,840 acres with wind energy potential 

(2,100 acres on the Malheur National Forest; 22,500 acres on the Umatilla National 

Forest; and 15,240 acres on the Wallowa-Whitman National Forest). A nationwide 

assessment of wind energy potential in each National Forest (NREL and USDA-FS 2005) 

indicated a nearly identical total of 39,420 acres with potential for wind energy 

development on National Forests in the Blue Mountains, although the acres on each 

national forest vary from the analysis in the Environmental Impact Statement.

No projects are currently proposed and none can be authorized without an analysis of the 

environmental effects of a specific proposal and issuance of a special use permit or 

authorization. Project-level analysis would follow the procedures described in the Forest 

Service Special Uses Handbook for Wind Energy (FSH 2709.11 Chapter 70) which has 

specific requirements screening criteria, siting considerations, and consideration of the 
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effects to recreation, scenery, public access, cultural resources, and species of 

management concern. The suitability and/or feasibility of wind energy development at a 

particular site can only be determined through a project-level analysis of a specific site, 

or group of sites. 

95. Concern Statement: The Forest Service should not allow wind development because it 

isn’t in the public interest and should be located on private land rather than public land. 

This would avoid the problem of mothballed windmills on the national forest landscape 

after their useful lifespan.

Response: The Energy Policy Act of 2005 considers the development of renewable 

energy resources on Federal lands to be appropriate and in the public interest by 

contributing to the energy needs of the United States. See the previous response for more 

information.

96. Concern Statement: The Forest Service should require wind developers to install nets to 

protect birds. 

Response: The primary method for protecting birds, bats, and other wildlife will revolve 

around proper siting of the wind turbines. According to FSH 2709.11 Special Uses 

Handbook Chapter 70, nesting grounds, migration corridors, habitat, security areas, and 

critical range of species of management concern should all be avoided when choosing a 

siting location along with any protected areas or areas where ecological resources are 

known to be sensitive to human activities. Examples of these areas include wetlands, 

riparian zones, streams, lakes, bogs, or fens; globally unique, rare or threatened 

ecosystems; critical habitat of wildlife protected under Federal or State law; nests of 

hawks, eagle, falcons, and owls; and prairie or shrub-steppe grouse breeding grounds. 

Other areas to be avoided include areas where topographical and landscape features may 

funnel nocturnal migrants, such as over mountain passes, along river corridors, or ridge 

tops and areas with a high incidence of mist or fog if existing information indicates a high 

risk to migratory birds or bats during these weather events. Additional needs may be 

identified during the environmental analysis for individual projects.

Forest Management 

Forest Management: Biomass

97. Concern Statement: The Forest Service should retain biomass to protect the long-term 

health of the forest and only utilize biomass for small-scale, local operations. 

Response: A Forest Plan provides programmatic guidance. It provides the basis for 

subsequent site-specific, project-level decisions to be made, but the specific types of 

timber sales and what products to include in them during the new planning period are 

decisions that would be identified and prioritized with consideration of current market 

conditions during future project-level planning efforts. We would welcome the 

participation of all stakeholders in those processes as they occur in the future.

The level of biomass removal incorporated into these future projects would have to 

consider the desired conditions and other relevant Plan components for retention of 

coarse woody debris, soil productivity, and impacts to watershed conditions. 
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98. Concern Statement: The Forest Service should incorporate a biomass target to 

encourage biomass projects. Biomass use is a significant, emerging opportunity and 

creates a use for non-commercial material that helps improve forest health. 

Response: The development of Alternative E-Modified and the final Plans did include a 

desired condition that states “Small diameter biomass provides a variety of forest 

products, such as hog fuel, fuel chips, pulp, small diameter round-wood, and firewood. 

Biomass harvesting projects are designed to both improve the resilience and health of 

forests as well as support opportunities to lead the development of innovative wood 

building products.” 

The specific types of timber sales and what products to include in them during the 

planning period are decisions that would be identified and prioritized with consideration 

of current market conditions during future project-level planning efforts. We would 

welcome the participation of all stakeholders in those processes as they occur in the 

future.

The level of biomass removal incorporated into these future projects would have to 

consider the desired conditions and other relevant Plan components for retention of 

coarse woody debris, soil productivity, and impacts to watershed conditions. 

Forest Management: Cool and Moist Forest Types

99. Concern Statement: The Forest Service should actively manage moist and cool forests 

for timber production. 

Response: The analysis outlined in the “Ecological Resilience” and “Forested

Vegetation” Affected Environment sections of the Final Environmental Impact 

Statement indicate that the dry upland forest currently exists in the most highly departed 

state when compared with desired conditions. The dry upland forest potential vegetation 

group is also the dominant vegetation group across the Blue Mountains. When the 

condition of dry upland forest vegetation is this highly altered from the historical range 

of variability it indicates that the risk of losing key ecosystem components in the future, 

including timber resources, is very high. Therefore, management focus on the dry 

upland forest is warranted. This does not imply there is any explicit restriction on 

conducting appropriate management activities within the moist upland and cold upland 

forests. Some of these moist upland forest areas are included in the designation of lands 

suitable for timber production, and would be expected to contribute timber products 

toward the allowable sale quantity. The intent of the agency preferred alternative is to 

focus restoration on where it is most needed, but the specific areas requiring and being 

scheduled for active treatment in the near term would be identified and prioritized in the 

context of the Plan’s desired conditions during future project-level planning efforts.

100. Concern Statement: The Forest Service should develop separate management 

approaches for moist forests because of the unique disturbance regimes and associated 

mix of successional stages and because these forests are a significant portion of the plan 

area. 

Response: Distinct desired conditions for the moist upland forests have been developed. 

They recognize and were developed within the context of its unique characteristics and 

disturbance regimes. The desired conditions for forest vegetation were based on an 

analysis of vegetation conditions, as they would likely have existed under the historical 

range of natural variability. These desired conditions have been developed for virtually 
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all of the diverse forest types common to the forests of the Blue Mountains. An integral 

part of the work done to estimate the characteristics of the historical range of variability 

was the incorporation of our best understanding of how natural disturbance regimes and 

stand dynamics of the different types of forest function. The desired conditions for forest 

vegetation contain quantifiable goals for structural stages, species composition and stand 

density. During the implementation of the plan, forest managers can compare the 

existing condition of the moist upland forest to the relevant measurable desired 

characteristics to gauge the need to develop management actions. However, the specific 

treatment prescriptions would be identified during future project-level NEPA planning 

efforts.

101. Concern Statement: The Forest Service should allow for the growth of late seral forest 

communities and multi-layered canopy structure in moist and wet forest types and 

should recognize microclimate variability that supports denser forest types in dry forests 

(for example, north-facing slopes and riparian areas). Large areas of moist mixed conifer 

forest should be excluded from logging to provide contiguous habitat and preserve old 

forest multi-story habitat within its historical range of variability. 

Response: The revised Forest Plans contain specific desired conditions for all forest 

vegetation structural stages (from stand initiation to late seral or old forest). These 

desired conditions were based on the results of historical or natural range of variability

analysis. This work was based on our best understanding of how natural disturbance 

regimes and the successional stand dynamics of the different types of forest naturally 

function. This analysis supported the development of distinct desired conditions for the 

moist and cold upland forests. These desired conditions recognize, and were developed 

within the context of, the unique characteristics and disturbance regimes of each distinct 

forest type. The types of prescriptions and degree of management in the moist and cold 

upland forests will differ from the dry forest, because it will be driven by the specific 

range of natural variation for these forest types.

Many areas of the National Forests are allocated to management areas like wilderness or 

backcountry, where little if any timber harvesting is expected to occur. Development of 

old forests within these areas will largely depend on natural disturbance processes and 

inherent stand development dynamics. However, it is also important to understand that 

many old forest structures of the dry and mixed conifer uplands would naturally tend to 

develop more in response to frequent disturbance rather than in response to natural 

successional processes. These types of old forest will look and function very differently 

than the somewhat stereotypical Pacific Northwest’s moist coastal model of old forest. 

As a result, under natural conditions, many old forests of the Blue Mountains would be 

expected to be made up predominantly of relatively open single-storied structures rather 

than dense multi-storied stands. However, the role of naturally developed dense dry 

forest structure classes is recognized and the revised Plans’ desired conditions do call for 

appropriate representation of these forest types.

Additional discussion and information was included in the Affected Environment and 

Environmental Consequences sections for both the “Old Forest” and “Ecological 

Resilience” Issues sections in Volume 1 of the Final Environmental Impact Statement. 

Forest Management: Ecological Resilience

102. Concern Statement: The Forest Service should not assume that the most aggressive 

management will best restore ecological resilience as management, such as logging, can 
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have negative impacts on a forest health (soil compaction and degradation, loss of snags, 

spread of invasive weeds, and potentially higher severity wildfires, for example). 

Response: The revised Forest Plans contain no presumption that active management is 

the only desirable strategy for achieving desired conditions. Many areas of the National 

Forests will remain allocated to management areas like wilderness or backcountry, 

where little if any active silvicultural management is expected to occur. In some cases, 

perhaps where a watershed is currently well-functioning and resilient, a passive, “handsoff” approach to management may be appropriate, but within a large portion of the 

National Forests, a history of fire suppression and other legacy effects of past 

management has led to conditions that will necessitate a more active approach to restore 

more natural conditions and mitigate current risks. 

When thoughtfully designed to operate along with ecological processes, or even as 

surrogates to natural disturbances, forest management techniques like timber harvesting, 

prescribed burning, pre-commercial thinning and tree-planting can be useful tools to 

help manage and move forest vegetation conditions toward the desired conditions. The 

discussion describing the harvest and stand management prescriptions common to all 

alternatives and how those treatments would produce positive changes in terms of 

ecological resilience has been expanded in the Final Environmental Impact Statement. 

This analysis can be found in the “Ecological Resilience” section of Chapter 3. The 

potential negative side effects of harvesting and other forestry treatments are 

acknowledged and disclosed in other relevant resource area sections of this document 

that discuss topics such as soil, water, aquatic resources and terrestrial wildlife habitat. 

Most of these past forestry practices and regeneration techniques were originally 

developed as part of classic silvicultural systems that were primarily concerned with 

producing and harvesting mature crops of timber products. Modern approaches to forest 

management now view timber harvest and other silvicultural techniques also as 

restoration tools that can be used to modify stand structures, species composition, stand 

density, landscape patterns and potential fire behavior. This approach is sometimes 

referred to as “ecological forestry,” or “emulation of natural disturbance,” as it attempts 

to fully incorporate an understanding of natural disturbance and stand development 

processes. This concept of using forest management to emulate natural disturbance has 

been discussed within a growing body of science literature and is often recommended as 

a technique to help restore resilient forest conditions. 

103. Concern Statement: The Forest Service should manage for a more resilient ecosystem 

and improved watershed conditions without changing existing goals or management 

area designations.

Response: We agree that the Forest Service should manage the Blue Mountains national 

forests for increased ecosystem resilience and improved watershed conditions. As stated 

in the opening sections of the Revised Forest Plans, many conditions have changed since 

the Forest Plans were approved in 1990. Changes include, but are not limited to

economic, social, and ecological conditions; new laws, regulations, and policies have 

been developed; and new information resulting from monitoring and scientific research 

are available. The Analysis of the Management Situation provides additional 

information including overviews of current direction and current management along 

with need for change summaries. The three National Forests are revising their Forest 

Plans to respond to these changed conditions and the need to meet the legal 

requirements of the National Forest Management Act of 1976. Additionally, the revised 
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Forest Plans will provide consistent management direction across the three National 

Forests.

The revised Forest Plans contain many similar goals compared to the 1990s Plans. These 

goals include management direction for multiple resource areas including cultural 

resources, air, soil and water, recreation, land ownership, wilderness, energy, minerals, 

and transportation. Other goals stated in the Forest Plans emphasize: 

♦ Riparian and Aquatic Resources

♦ Old Forest 

♦ Invasive Species

♦ Wildlife

♦ Rangeland Vegetation and Domestic Livestock Grazing

Management areas developed in the 1990s forest plans were consolidated into fewer 

categories than what is listed in the revised Forest Plans, but still there is similarity to 

those developed in past plans. As amendments have been needed since 1990 across the 

three National Forests for changes made in specific sections of management areas, 

changes need to be verified across the landscape. While management areas in the 1990s 

Forest Plans, such as botanical areas and historical areas, are not consistently described 

or identified within the three Forest Plans, the plans generally have similar management 

expectations across large areas. Management areas in the revised Forest Plan similarly 

describe broad areas where general management intent is similar (see Map Packet). The 

purpose of management areas is to provide consistent guidance for similar portions of 

national forest landscape when implementing or continuing management activities. The 

management areas generally range along a continuum from little development by 

humans in Management Area 1A to extensive human development in Management Area 

5. 

The Final Environmental Impact Statement includes a range of alternatives, with 

Alternative A representing management direction as presented in 1990s Forest Plans. 

While these plans provide adequate management direction, the direction is not as 

responsive, when compared to the other revised plan alternatives, to the observed 

changes that have accrued during the intervening 20 plus years since the first generation 

Forest Plans were approved.

104. Concern Statement: The Forest Service should consider an option that allows natural 

processes to shape the landscape. Proposed alternatives will exacerbate past overlogging and excessive grazing and roading and will simplify and homogenize complex 

forest structures and ecological niches. 

Response: Some people desire the revised Forest Plans to virtually eliminate timber 

harvesting and other human uses and human-induced impacts to the National Forests of 

the Blue Mountains. A minimum management alternative approach was considered as 

Alternative G, but not developed in detail. Outdoor recreation, range, and timber are all 

among the uses that the Multiple-Use Sustained Yield Act of 1960 requires the National 

Forests to be administered for. This minimal management approach would not address 

all of the issues identified with the purpose and need of the Forest Plan revision, and it 

would eliminate many of the multiple uses and benefits for which the National Forests 

were created.
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In some cases, perhaps where a watershed is currently well-functioning and resilient, a 

case could be made for a passive, “hands-off” approach to management, but within a 

large portion of the National Forests, a history of fire suppression and other legacy 

effects of past management has led to conditions that will necessitate a more active 

approach to restore more natural conditions. Forest management techniques like timber 

harvesting, prescribed burning, pre-commercial thinning and tree planting can be useful 

tools to help manage and move forest vegetation conditions toward the desired 

conditions. The discussion describing the harvest and stand management prescriptions 

common to all alternatives and how those treatments would produce positive changes in 

terms of ecological resilience has been expanded in the Final Environmental Impact 

Statement, and can be found in the Environmental Consequences portion of the 

“Ecological Resilience” section.

105. Concern Statement: The Forest Service should include soil health as an indicator of 

ecological resilience. 

Response: Soil health and potential effects to soils are discussed in the Final 

Environmental Impact Statement “Soils” section. While it is not expressly named as an 

indicator of ecological resilience, soil health and condition is certainly considered in this 

document; as directed by Forest Service Manual FSM 2551.5 (Soil Quality Indicators) 

“Soil quality indicators are developed to give insights as to how well the inherent soil is 

functioning (i.e., biologically, hydrologically, carbon storage, etc.) The ultimate goal of 

the soil quality indicators is to provide information on the health of the soil.” 

106. Concern Statement: The Forest Service should emphasize multiple-use management, 

not simply due to comply with the Multiple Use Sustained Yield Act and other statutes, 

but because it is ecologically beneficial to the landscape.

Response: Each alternative was developed to comply with applicable laws and 

regulations, including the Multiple Use Sustained Yield Act, Organic Act, National 

Forest Management Act and others. We agree that properly designed and implemented 

multiple-use management can be ecologically beneficial. 

107. Concern Statement: The Forest Service should not allow any new roads, including 

temporary roads, to be built to help ensure ecological integrity. All timber sales should 

require road improvements. 

Response: Forest management techniques like timber harvesting, prescribed burning, 

pre-commercial thinning and tree planting can be useful tools to help manage and move 

forest vegetation conditions toward the desired conditions. The revised Forest Plans 

provide programmatic direction as to where motorized use may or may not be suitable. 

Additionally, desired conditions for motorized use are integrated to meet other resource 

needs, provide for user safety, and to comply with existing laws, regulation, and policy. 

The revised Forest Plans do not designate routes, trails, or areas open to motor-vehicle 

uses, and similarly do not identify the specific need to construct new roads. Forest 

transportation systems are considered through the travel management process and 

subsequent site-specific analysis processes. Temporary roads are constructed only for 

short-term, non-recurrent use by a timber purchaser or contractor. 

The transportation needs for timber harvesting projects are determined on a case-by-case

basis during project level transportation planning. Forest Service policy is to plan for the 

least-cost road needed to meet the resource objectives for the sale. The timber purchaser 

pays for the cost of building or improving a road only to the standard needed for 
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consistency with applicable environmental laws and regulations and as needed for 

timber harvest. Similarly, a timber sale contractor is responsible for their fair share of 

maintenance work, commensurate with their proportional level of use. 

108. Concern Statement: The Forest Service should not use clearcutting or regeneration 

harvests to prevent homogenization and fragmentation of forests and to protect 

biodiversity, soil productivity, and ecological resilience. 

Response: Even-aged regeneration harvesting techniques like clearcutting or seed tree 

harvesting can be useful tools to help manage and move forest vegetation conditions 

toward the desired conditions. In many areas of the forests, the increasing trend toward 

homogenous, simplified stand structures is not so much due to regeneration harvesting, 

but is largely the result of the suppression of natural regeneration and maintenance 

processes like wildfire. When thoughtfully designed to operate along with, or even 

emulate natural ecological processes, forest management techniques like timber 

harvesting can be useful tools to help manage and move forest vegetation conditions 

toward more resilient heterogeneous conditions. The discussion describing the harvest 

and stand management prescriptions common to all alternatives and how those 

treatments would affect positive changes in terms of ecological resilience has been 

expanded in the Final Environmental Impact Statement and can be found in the 

Environmental Consequences portion of the “Ecological Resilience” section. The 

potential negative side effects of harvesting and other forestry treatments are also 

addressed in other relevant resource area sections of this document featuring topics such 

as soil, water, aquatic resources and terrestrial wildlife habitat. 

Forest Management: Existing and Desired Conditions

109. Concern Statement: The Forest Service should use more current data to reflect existing 

vegetation conditions within all management areas, including wilderness and roadless 

areas. In addition, the Forest Service should discuss the impact of limited recent 

management on current forest conditions. 

Response: The existing condition of the forest vegetation was characterized by 

examining the Forest Service existing vegetation polygon data. The vegetation database 

contains summarized information for each of the polygons mapped on their respective 

vegetation layers. Data sources for individual polygons vary, but include walk-through 

examinations, photo-interpretation, intensive stand examination plot data, and Most 

Similar Neighbor (MSN) modeling. The forest is continuously changing, and it is not 

possible to maintain a forestwide condition inventory in a “real-time” status. This data 

set is updated periodically and reflects the effects of both past management and 

disturbance events. This data set was used to make general forestwide descriptions of the 

overall forest vegetation. All such general characterizations of overall conditions that are 

inferred from a limited sample set include a certain amount of statistical uncertainty. The 

Forest Service believes that this degree of inherent sampling error or ambiguity is 

reasonable when analyzing at the scale of a forestwide plan revision. Furthermore, the 

issues, trends and general conditions indicated by the data are consistent with the 

conditions described in the science literature by several current regional broad-scale 

assessments. Some of these relevant science documents and reports are quite recent and 

were not included, or were not yet available when the draft Plan and Environmental 

Impact Statement documents were being prepared. They have now been taken into 

account and are referenced throughout the Final Environmental Impact Statement. 

Additional information regarding the methodology behind the characterization of the 
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existing forest vegetation was added to the “Forested Vegetation” section of Chapter 3 in 

the Final Environmental Impact Statement, and the section was reorganized to improve 

clarity and readability.

110. Concern Statement: The Forest Service should develop desired conditions for the wide 

diversity of forest types and should take into account susceptibility of these forest types 

to disturbance, such as wildfire and insects. Desired conditions should be measurable. 

Response: Distinct desired conditions for all of the diverse upland forests have been 

developed. They recognize and were developed within the context of each forest type’s 

unique characteristics and disturbance regimes. The desired conditions for forest 

vegetation were based on an analysis of vegetation conditions as they would likely have 

existed under the historical range of natural variability. An integral part of the work done 

to estimate the characteristics of the range of historical variability involved the 

incorporation of our best understanding of how natural disturbance regimes and stand 

dynamics of the different types of forest function. The desired conditions for forest 

vegetation contain quantifiable landscape-scale goals for structural stages, species 

composition, and stand density. The discussion of forest vegetation and the related 

methodology has been improved in the Final Environmental Impact Statement and 

additional information has been provided to explain the rationale behind the desired 

conditions and their relation to the historical range of variability. At any time during the 

implementation of the plan, forest managers can compare the existing condition of the 

relevant forest landscape to the measurable desired characteristics to gauge the level of

progress or to develop a purpose and need for further actions. 

111. Concern Statement: The Forest Service should not use cover as a measure for desired 

forest vegetation conditions.

Response: Ultimately, the desired conditions pertaining to stand density are related to 

objectives for certain general levels of relative stand density on the landscape. They are 

not desires for levels of canopy cover. The discussion of stand density and the related 

methodology has been improved in the final revised Forest Plans, as well as the Final 

Environmental Impact Statement. Additional information has been provided to explain 

the rationale behind the desired conditions related to stand density. The broad-scale 

analysis and modeling done in support of this forest plan revision used canopy cover as 

a surrogate to characterize stand density. The Forest Service acknowledges that canopy 

cover is somewhat different from stand density, as it represents the proportion of the 

ground covered by a vertical projection of the tree canopy. Canopy cover correlates with 

the idea of relative site occupancy, and relative density is a concept that is very 

important to forest managers. It is used to gauge the degree of inter-tree competition 

relative to some implied biological limit or “carrying capacity.” Canopy cover has an

advantage over other measures of absolute stand density, in that it can be readily 

estimated by remote sensing techniques commonly used in large-scale forest inventories. 

Canopy cover can also be indirectly estimated on the ground using attributes commonly 

collected during detailed ground examinations. Ultimately, the specific metrics used to 

quantify and analyze stand density during implementation will be chosen and explained 

during the development of individual projects, and may change over time as science, 

technology and levels of understanding continue to improve.

112. Concern Statement: The Forest Service should modify its desired conditions for forest 

products to focus on long-term sustained yield and a continuous and predictable supply 
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of timber. In addition, the desired conditions for forest vegetation should include the 

production of a product. 

Response: The desired conditions for forest products are addressed under Goal 3 of the 

revised Forest Plans. These desired conditions do recognize the importance of 

sustainability and seek to see forest products produced and utilized to provide economic 

and social support to local communities. The long-term sustained yield capacity was 

estimated for all of the alternatives. This represents the maximum amount of timber 

volume that can be sustainably harvested from the lands suitable for timber production 

under a specific management regime consistent with other multiple-use objectives. The 

base timber harvest schedules of all of the alternatives were designed not to exceed this

long-term sustained yield capacity, and to demonstrate a non-declining flow of 

sustainable forest products for at least the next five decades. The one exception to this 

was Alternative E-Modified Departure, which was developed and included in the Final 

Environmental Impact Statement. Because of the current high degree of disparity 

between the desired conditions for forest vegetation, fire regimes and insect/disease 

susceptibility versus the present state of the forest, it was believed that the exploration of 

a departure alternative was warranted. The departure version of Alternative EModified’s harvest schedule was developed outside of the constraints of non-declining 

sustainable flow or the long-term sustained yield capacity. (See “Ecological Resilience,” 

“Forested Vegetation,” and “Insect and Disease” sections of the Final Environmental 

Impact Statement, Chapter 3).

113. Concern Statement: The Forest Service should reconsider its desired condition for low 

to moderate susceptibility to insects and disease because mixed conifer forests are 

inherently more susceptible to such disturbances.

Response: The discussion of insect and disease and forest health has been improved in 

the Final Environmental Impact Statement, and considerable additional information has 

been provided to explain the rationale behind the desired conditions for insect and 

disease susceptibility. The desired conditions regarding susceptibility to insect and 

disease damage have been informed by a natural range of variability analysis and a 

science-based understanding of the ecological role of these disturbance agents. The 

Forest Service recognizes that, if vegetation conditions were within the historical range 

of variability, the range of expected susceptibility for the cold and moist upland forests 

would in some cases be relatively higher with regards to many common insect and 

disease agents (see Chapter 3 Insects and Diseases). The desired conditions in the 

revised Forest Plans have been clarified to indicated that the Forest Service seeks to see 

characteristic levels of insect and disease activity and mortality play a role within the 

forests. What is considered a characteristic level of susceptibility and activity is 

expected to vary among forest types and between the various specific disturbance 

agents. 

Goals and desired conditions must also consider societal values and desires. Significant 

losses and disruptions in these natural resources and ecosystem services caused by insect 

and disease epidemics are a major societal concern. Current landscape patterns 

characterized by large expanses of uncharacteristically dense pine forests and/or 

landscape wide expansions of shade tolerant grand fir cover types are largely the 

undesired by-product of past management practices. These conditions are contributing to 

levels of insect and disease risk that are not considered to be consistent with the Forest 

Service’s current emphasis on creating and maintaining forest conditions that promote 

long-term forest resiliency. There is a desire to create stand conditions with largely low 
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to moderate vulnerability to insects and diseases across the majority of the upland forest 

potential vegetation groups, but only to the extent that those forest stand conditions are 

consistent with the natural range of variation. 

114. Concern Statement: The Forest Service should add the production of timber and other 

goods to the desired condition for General Forest Management Areas (MA 4A). 

Response: While all of the lands classified as suitable for timber production are 

contained within Management Area 4A, not all areas within Management Area 4A are 

suitable for timber production. For that reason, the desired conditions related to timber 

production are not listed under the MA 4A direction, but can be found in the revised 

Plans under “Goal 3 – Goods and Services.” The desired conditions related to forest 

products aspire to see lands classified as suitable for timber production having a 

regularly scheduled timber harvest program that provides social and economic benefits 

while contributing toward ecosystem health and sustainability. The desired conditions 

also look for non-timber forest products, such as berries and mushrooms, to continue to 

be available for gathering in sustainable amounts for public, commercial, and tribal use. 

Forest Management: Forest Products

115. Concern Statement: The Forest Service should increase firewood opportunities and 

reduce restrictions, for example by allowing all dead trees to be offered as free firewood 

and by offering small, low-impact firewood sales. 

Response: The desired conditions of the revised Plans include providing a variety of 

forest products, such as firewood, and also providing non-timber forest products, such as 

berries and mushrooms, in sustainable amounts for public use. While the revised Forest 

Plans would include some restrictions on firewood gathering in areas like riparian 

management zones and special botanical areas, the revised Forest Plans do not contain 

forestwide restrictions on firewood gathering. The plans are programmatic in nature and 

any subsequent site-specific decisions regarding further restrictions on, or changes to 

firewood gathering policy would be informed by the revised plan components and 

determined on a case-by-case basis. Personal use firewood gathering is permitted largely 

in response to demand and is expected to continue at levels similar to those seen in the 

recent past. 

116. Concern Statement: The Forest Service should offer post and pole sales to meet high 

demand for rounds. 

Response: A Forest Plan provides programmatic guidance. It provides the basis for 

subsequent site-specific, project-level decisions to be made, but the specific types of 

commercial timber sales and what products to include in them during the new planning 

period are decisions that would be identified and prioritized with consideration of 

current market conditions during future project-level planning efforts. We would 

welcome the participation of all stakeholders in those processes as they occur in the 

future.

Forest Management: Historical Range of Variability (HRV)

117. Concern Statement: The Forest Service should not focus on managing forests toward 

the historical range of variability. Managing for conditions that occurred with far 

different populations and socio-economic interests isn’t reasonable and would 
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negatively affect local economies. Instead, the Forest Service should manage stands for 

the culmination of mean annual increment. 

Response: Historical or natural range of variability analysis is based on disturbance 

process state and transition modeling. This modeling program was developed by a cadre 

of multiple ecological scientists in order to evaluate the effects of disturbance regimes 

over time and develop a range of variation for forest conditions based on those effects. 

The results represent broad ranges of conditions depicted by the historical range of 

variability that would allow considerable flexibility in future management choices. This 

range of variability is then used as an ecological basis for comparison to current 

conditions to assist in determining the current forest health and associated resiliency to 

disturbance. The main idea is that if landscapes are restored to and maintained within 

this natural range of variability, then this represents our best chance to maintain 

ecological integrity and sustainability over time. Ensuring the long-term sustainability of 

the forests is critical to meeting both the present and future needs of the forestdependent local communities. 

Culmination of mean annual increment is the age at which a stand would be harvested if 

the sole management objective is to maximize long-term timber production. This is a 

useful metric in the context of timber management and to help ensure long-term 

sustainability of the timber resource. Forest Service regulations require that even-aged 

regeneration harvesting generally be limited to only occurring in those stands that have 

achieved or surpassed the culmination of mean annual increment (CMAI). However, 

management of the forests would also be shaped by other multiple use goals, in addition 

to timber production, like restoring the natural resilience of forest ecosystems on the 

landscape.

118. Concern Statement: The Forest Service should focus on maintaining landscape 

integrity in the face of anticipated climate change, or a future range of variability, 

instead of focusing on the historical range of variability. 

Response: The Forest Service has considered the argument that the pre-settlement era 

should no longer be used as a reference baseline because future conditions could be 

much warmer and drier than the mid-1800s due to climate change. However, given the 

enormous degree of uncertainty associated with the magnitude, timing, scale, and spatial 

extent of anticipated climate change impacts, we find that the historical range of 

variability approach is warranted because it has considerably less uncertainty associated 

with it compared to any simulated predictions for the future. Given the nature of the 

primary forest stressors outlined by recent climate change risk assessments, it seems 

unlikely that using the historical range of variability to inform desired conditions and 

guide management efforts will result in inappropriate activities within the near and midterm time frames of the next plan period. Historical reference conditions remain useful 

to guide management because forests were historically resilient to the same disturbances 

that are predicted to increase under many climate change scenarios, namely drought, 

insects, pathogens and severe wildfire. Many of the forest management activities that 

will be used to move toward our desired conditions have a recognized role as part of a 

climate change adaptation strategy. For example, using a full suite of management 

options including mechanical thinning and prescribed burning will facilitate the creation 

of a forest mosaic of different age-classes, species and structures across the three 

National Forests. This mitigates risk and serves as a climate adaptation strategy that will 

also provide functional diversity and a range of habitats at large spatial and temporal 

scales. These conditions will increase resilience to stressors and ensure that forests are 
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sustainable in the face of possible climate changes. More discussion regarding the 

historical range of variability and anticipated climate change effects can be found in the 

Final Environmental Impact Statement.

119. Concern Statement: The Forest Service should use an earlier point of reference for 

historical range of variability – prior to Euro- American logging, homesteading, grazing, 

mining, and so on. 

Response: The forest vegetation historical range of variability analysis completed for 

the revised Forest Plans was based on our understanding of conditions and ecological 

processes prior to Euro-American influence. Historical or natural range of variability

analysis is based on disturbance process state and transition. This modeling program was 

developed by a cadre of multiple ecological scientists in order to evaluate the effects of 

disturbance regimes over time and develop a range of variation for forest conditions 

based on those effects. Although the disturbance regimes are based on pre-settlement 

conditions, the model itself is not based on a static timeframe and is not meant to 

represent a specific “snapshot” in time. Selecting a single temporal point would be 

inconsistent with the range of variability concept, as it is not intended to characterize a 

static, unchanging environment. Forests of the Blue Mountains region evolved with a 

combination of natural disturbances, natural forest succession and native human uses. 

The historical range of variability of forest conditions is designed to characterize the 

broad range of vegetation composition, structure, and densities that would have likely 

resulted from these agents of change as they would have operated prior to EuroAmerican settlement. This timeframe is often defined as the early to mid-1800s because 

it coincides with the era when significant Euro-American influences began in the Blue 

Mountains. However, the actual range of variability values were the result of dynamic 

landscape modeling, and were not based on a specific description of historical 

conditions. 

120. Concern Statement: The Forest Service should clarify how it determined what 

“characteristic” levels of insects and disease were and what information it used to 

determine that levels of insect and disease mortality are above historical levels. 

Response: The discussion of insect and disease and forest health has been improved in 

the Final Environmental Impact Statement and considerable additional information has 

been provided to explain the rationale behind the desired conditions for insect and 

disease susceptibility. The desired conditions regarding susceptibility to insect and 

disease damage have been informed by a natural range of variability analysis and a 

science-based understanding of the ecological role of these disturbance agents. To help 

provide more perspective regarding what might be considered historically normal levels 

of susceptibility, reference conditions for insect and disease susceptibility were 

developed based on the forest vegetation conditions that are believed to have existed

within the historical range of variability. The resulting ranges of susceptibility are 

assumed to represent the inherent insect or disease susceptibility associated with forest 

vegetation having little or no departure from reference conditions. While these ranges 

for the insect and disease susceptibility do reflect some degree of professional judgment, 

they are also generally consistent with information from other published reports 

characterizing the susceptibility associated with historical forest conditions.

121. Concern Statement: The Forest Service should not assume that all mechanical 

treatments have positive effects on returning the landscape toward the historical range of 
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variability as this fails to account for logging impacts and the exacerbation of departure 

of wet and moist forests. 

Response: When thoughtfully designed to operate along with ecological processes, or 

even as surrogates to natural disturbances, forest management techniques like timber 

harvesting, prescribed burning, pre-commercial thinning and tree-planting can be useful 

tools to help manage and move forest vegetation conditions toward the desired 

conditions. The potential negative side effects of harvesting and other forestry 

treatments are addressed in relevant resource area sections of the Final Environmental 

Impact Statement covering topics such as soil, water, aquatic resources and terrestrial 

wildlife habitat. The discussion describing the harvest and stand management 

prescriptions, and how those treatments would affect positive changes in terms of 

ecological resilience has been expanded in the Final Environmental Impact Statement 

and can be found in the Environmental Consequences portion of the “Ecological 

Resilience” section. Most of these forestry practices and regeneration techniques were 

originally developed as part of classic silvicultural systems, which were primarily 

concerned with producing and harvesting mature crops of timber products. Modern 

approaches to forest management now view timber harvest and other silvicultural 

techniques as restoration tools that can be used to modify stand structures, species 

composition, stand density, landscape patterns and potential fire behavior. This approach 

is sometimes referred to as “ecological forestry,” or “emulation of natural disturbance,” 

as it attempts to fully incorporate an understanding of natural disturbance and stand 

development processes.

122. Concern Statement: The Forest Service should refine landscape pattern objectives to 

protect large patches of underrepresented and rare habitat and move the landscape 

toward the historical range of variability.

Response: The discussion and content of the desired conditions for landscape pattern 

have been significantly revised and improved in the revised Forest Plans. These desired 

conditions call for forest vegetation to be managed sustainably within the range of 

variability of disturbance and successional patterns as caused by fire, insects and 

disease, and weather without a decline in soil or vegetation productivity, biodiversity, or 

in water quantity and quality.

Forest Management: Level, Pace and Scale

123. Concern Statement: The Forest Service should create an alternative to increase the 

pace and scale of active management (for example, doubling the number of acres 

treated) so that more of the national forest landscape is managed. Managing additional 

acres would improve scenic and ecological conditions by reducing fire hazard, 

improving forest resistance to insects and disease, protecting soils, and supporting 

climate adaptation. Re-treatments could maintain desired stand densities and surface fuel 

levels. Improvement of watershed and aquatic conditions could be accelerated as well. 

Response: A wide range of alternatives were developed for the Draft Environmental 

Impact Statement, and the draft revised Forest Plan was designed around potentially 

increasing the current harvesting acres by 2 to 3 times. We subsequently received many 

comments about increasing the pace and scale of restoration on the national forests to 

help prevent catastrophic fires, improve habitat for big game animals, and provide a 

flow of forest products to local mills to stimulate local economies. As a result, two 

additional alternatives, designed to support an increased pace and scale of restoration, 
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were developed and analyzed in the Final Environmental Impact Statement. Alternative 

E-Modified would maintain an overall level of harvesting similar to Alternative E, but 

would envision a focus of these harvest acres more intently on the portions of the dry 

upland forest that currently show the greatest need for immediate treatment. This 

alternative would allow for considerable increases in the thinning of the dense-dry 

upland forest within 20 years while still being consistent with the sustainability 

principles of the non-declining flow rules.

A departure version of Alternative E-Modified was also developed, unconstrained by 

non-declining flow requirements. Because of the current high degree of disparity 

between the desired conditions for insect/disease susceptibility, forest vegetation and fire 

regimes, versus the present state of the forest, it was believed that the exploration of a 

departure alternative was warranted. 

Planning regulations allow Alternative E-Modified Departure to temporarily waive the 

non-declining flow rules. Without this constraint, the alternative was able to 

accommodate thinning essentially all of the acres of dense-dry upland forest located 

within the lands suitable for timber production within 20 years. When combined with 

additional restoration thinning taking place on other lands that are suitable for harvest, 

the Alternative would plan for thinning roughly 70 percent of the dense-dry upland 

forest acres that are available for harvest treatment within the next 20 years. This would 

represent approximately 35 percent of the entire forest land that is designated as suitable 

for harvesting. The effects of this alternative were analyzed across all resource areas, 

and these effects will be considered by the responsible official.

124. Concern Statement: The Forest Service should increase the predicted annual timber 

harvest to capture a higher percentage of annual growth and thus reduce biomass 

accumulation and overstocked forest stands. 

Response: A wide range of alternatives were developed for the Draft Environmental 

Impact Statement, and the draft revised Forest Plan was designed around potentially 

increasing the current harvesting acres by two to three times. We subsequently received 

many comments about increasing the pace and scale of restoration on the forests to help 

prevent catastrophic fires, improve habitat for big game animals, and provide a flow of 

forest products to local mills to stimulate local economies. We understand that the rate 

and scale at which active management attempts to move toward the desired conditions is 

important because in the past, the pace of restoration activities has not kept up with the 

negative impacts resulting from continued forest ingrowth, fuel accumulation and a 

changing climate. As a result, two additional alternatives, including a departure 

alternative, which is unconstrained by non-declining flow rules were developed. The 

agency’s preferred alternative, E-Modified, would plan to accommodate some kind of 

active management treatment on most of the available forest landscape within 40 to 50 

years. Every alternative includes some management areas that do not permit timber 

harvest. None of the alternatives, not even E-Modified Departure, would make every 

acre available for timber harvesting, and these constraints make the goal of treating 

every acre of national forest land unrealistic. Treatment schedules for timber harvesting 

cannot be prepared in isolation from the other desired conditions and multiple use 

objectives of the plan alternatives.

125. Concern Statement: The Forest Service should increase timber harvest (225-300 

million board feet, for example) to sustain the local harvesting and milling 
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infrastructure, support current collaborative efforts and stewardship contracts, and fund 

schools. The timber program should provide a continuous supply of timber. 

Response: Analysis done to support the Final Environmental Impact Statement shows 

that increasing timber harvest levels to 225 – 300 million board feet annually would not 

be sustainable over time. These unsustainable harvest levels would not meet the goal of 

providing a continuous supply of timber. A wide range of alternatives was developed for 

the Draft Environmental Impact Statement. Subsequent to the release of the draft Plan, 

we received many comments about increasing the flow of forest products to local mills 

to stimulate local economies. As a result, two additional alternatives, including a 

departure alternative, which is unconstrained by non-declining flow rules were 

developed, and the methodology behind the calculation of estimated timber yields was 

re-examined and improved for the Final Environmental Impact Statement. The final 

versions of the revised Forest Plans would accommodate increasing the timber volume 

objectives across the three National Forests to roughly 150 to 200 percent of their recent 

accomplishment levels.

126. Concern Statement: The Forest Service should consider alternatives unconstrained by 

the idea of non-declining flow or budget limitations to allow for innovation that could 

increase the pace and scale of restoration. 

Response: Many people commented that the planned objectives should not be 

constrained by budget. It is not realistic or reasonable to ignore expected funding levels 

and capacity. A forest plan does not influence or control the budget for a National Forest, 

but the range of alternatives analyzed included varying budget levels for some program 

areas that would exceed the most recent budgets.

A departure version of Alternative E-Modified was also developed, which was 

unconstrained by non-declining flow requirements. Because of the current high degree 

of disparity between the desired conditions for insect and disease susceptibility, forest 

vegetation and fire regimes, versus the present state of the forest, it was believed that the 

exploration of a departure alternative was warranted.

Planning regulations allow Alternative E-Modified Departure to temporarily waive the 

non-declining flow rules. Without this constraint, the alternative was able to 

accommodate potentially thinning essentially all the acres of dense-dry upland forest 

located within the lands suitable for timber production within 20 years. When combined 

with additional restoration thinnings taking place on other lands suitable for harvest, the 

alternative would accommodate thinning roughly 70 percent of the dense-dry upland 

forest acres that are available for harvest treatment within the next 20 years. This would 

represent approximately 35 percent of the entire forest land base that is designated as 

suitable for harvesting.

127. Concern Statement: The Forest Service should optimize the plan for maximum 

sustainable timber harvest. 

Response: Alternatives proposing exclusive use or production of one resource at the 

expense of other resources were not considered. Several laws mandate that the Forest 

Service manage public lands for multiple uses and sustained yield. This legal and 

regulatory framework eliminates exclusive-use alternatives. As such, the estimated 

harvest and related treatment schedules behind the allowable sale quantity and timber 

sale program quantity were not prepared in isolation from the other desired conditions 

and multiple use objectives of the plan alternatives. The basis for the harvest schedule is 
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the overall design of the alternatives being considered. Analysis of harvest scheduling to 

estimate forest product output levels is not limited to being a timber volume 

optimization exercise, but also considered and evaluated the ability of the harvests to 

move toward or maintain a set of desired conditions through sustained silvicultural 

activity over a long time horizon. In addition to providing timber products, these desired 

conditions and related design elements also include reducing the risk of uncharacteristic 

fire, reducing insect and disease susceptibility, providing habitat for specific species and 

controlling the cumulative impact of harvest activity to maintain watershed health. All of 

these considerations provide potential reasons for timber harvest activities, but also may 

impose limitations on the overall harvest schedule.

Forest Management: Old Forests and 21-Inch Rule 

128. Concern Statement: The Forest Service should drop the arbitrary 21-inch rule that 

prevents harvest of trees with a diameter more than 21 inches because it is not sound 

science. Eliminating the 21-inch rule would allow harvest to help fund roads, schools, 

and local services. It would support local mills and create more economically viable 

projects. Retaining all 21-inch trees converts thousands of acres of ponderosa pine, larch 

and dry forests to forests dominated by species like white fir that are shade tolerant and 

fire intolerant. 

Response: The Forests received various comments on the draft Plan and Environmental 

Impact Statement either advocating for, or criticizing different approaches to old forest 

conservation and management that were considered in the alternatives. In response, 

additional discussion and information was included in the Affected Environment and 

Environmental Consequences sections for the Old Forest Issue in the Final 

Environmental Impact Statement. These changes were made to improve the 

understanding of the definitions, ideas and context surrounding this issue as well as the 

trade-offs involved with the different management strategies such as diameter limits. A 

wide range of alternative approaches to old forest management were explored with the 

Draft Environmental Impact Statement alternatives, and two additional alternatives are

included in the Final Environmental Impact Statement. Plan components in the final 

revised Forest Plans are designed to allow sufficient management flexibility in order to 

address desired conditions for forest vegetation structure class, density, and species 

composition as well as those pertaining to old forest.

129. Concern Statement: The Forest Service should retain the 21-inch Rule and Old Forest 

Management Areas (MA 4C) to protect and increase old and large trees which are deficit 

on the landscape, help achieve the stated goal of increasing ecological resilience, and 

protect large snags. Retaining the 21-inch Rule and Old Forest Management Areas 

would protect biodiversity and water quality; support nutrient cycling, carbon 

sequestration and other ecosystem functions; increase resilience to wildfire; and 

conserve habitat for wildlife. Protecting old forest structure would also conserve natural 

heritage and regional cultural identity.

Response: Additional discussion and information were included in the Affected 

Environment and Environmental Consequences sections for the “Old Forest” section in 

the Final Environmental Impact Statement. These changes were made to improve the 

understanding of the definitions, ideas and context surrounding this issue as well as the 

trade-offs involved with the different management strategies such as diameter limits, 

harvesting restrictions and designated old forest areas. The plethora of values associated 

with old forest are acknowledged within the Affected Environment section as well as in 
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the desired conditions of the final Forest Plans. A wide range of alternative approaches 

to old forest management were explored with the Final Environmental Impact Statement 

alternatives, including Alternative C, which would include designated old forest 

management areas, old forest harvesting restrictions and a 21-inch diameter cap. The 

analysis results regarding old forest conservation approaches and expected increases in 

old forest structures over time indicate these types of strategies do not offer the best 

expected results in terms of old forest conservation. Plan components in the final revised 

Forest Plans are designed to allow sufficient management flexibility in order to address 

desired conditions for forest vegetation structure class, density and species composition 

as well as those pertaining to old forest.

130. Concern Statement: The Forest Service should remove Old Forest Management Areas 

(MA 4C) and allow harvest within older forests to reduce losses of these stands to 

wildfire or insect mortality.

Response: Additional discussion and information relevant to this topic was included in 

the Affected Environment and Environmental Consequences sections for both “Old 

Forest” and “Ecological Resilience” sections in the Final Environmental Impact 

Statement. These changes were made to improve the understanding of the definitions, 

ideas and context surrounding this issue as well as the trade-offs involved with the 

different management strategies such as diameter limits, harvesting restrictions and 

designated old forest areas. A wide range of alternative approaches to old forest 

management were explored with the Final Environmental Impact Statement alternatives, 

including Alternative C which would include designated old forest management areas 

(MA 4C) and strict restrictions on harvesting within old forest. However, none of the 

other plan revision alternatives would include old forest management areas. Alternative 

D would include many old forest areas with the lands designated as suitable for timber 

production. The final revised Forest Plans do not classify old forest stands as suitable for 

timber production, but they consider harvesting within old forest to be a suitable activity 

if designed to support resource objectives other than timber production. Modern 

approaches to forest management now view timber harvest and other silvicultural 

techniques as restoration tools that can be used to modify stand structures, species 

composition, stand density, landscape patterns, insect/disease susceptibility and potential 

fire behavior. Plan components in the final revised Forest Plans are designed to allow 

sufficient management flexibility in order to address desired conditions for forest 

vegetation structure class, density, and species composition as well as those pertaining 

to old forest. 

131. Concern Statement: The Forest Service should prevent logging in mature forests to 

allow these stands to age and replace old forests lost to disturbance. 

Response: Management activities, including carefully designed harvesting treatments, 

are not necessarily incompatible with the continued development of forest stands into 

old forest structural stages. Additional discussion and information was included in the 

Affected Environment and Environmental Consequences sections for the “Old Forest” 

section in the Final Environmental Impact Statement. These changes were made to 

improve the understanding of the definitions, ideas and context surrounding this issue 

as well as the trade-offs involved with the different management strategies such as 

diameter limits, harvesting restrictions and designated old forest areas. A wide range of 

alternative approaches to old forest management were explored with the Final 

Environmental Impact Statement alternatives, including Alternative C, which would 

include designated old forest management areas and strict restrictions on harvesting 
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within old forest. The analysis results regarding old forest conservation approaches and 

expected increases in old forest structures over time indicate these types of strategies do 

not offer the best expected results in terms of old forest conservation. The indicators 

show that the approaches used in Alternative C would, in all probability, result in 

maintaining old forest structures at low levels that are highly departed from the desired 

conditions. 

132. Concern Statement: The Forest Service should focus on developing all structural 

stages of forest rather than focusing on conserving and developing old forest structure. If 

the forests manage for the high end of the desired condition range, 80 percent of dry 

upland forests could be in old forest structural stages. 

Response: The desired conditions for the final Forest Plans do contain specific desired 

conditions for all of the major forest vegetation structural stages from stand initiation to 

old forest. These desired conditions were based on the results of historical or natural 

range of variability analysis and they represent broad ranges of conditions that would 

allow considerable flexibility in future management choices. An analysis of existing 

conditions (see Final Environmental Impact Statement, “Old Forest” section, Affected 

Environment) shows that the old forest single-story stage of the dry upland forest 

potential vegetation group has been greatly reduced from historical levels. At the same 

time, other structural stages, the mid-aged understory reinitiation phase are grossly 

overrepresented. This is the most striking area of departure from natural conditions in 

terms of old forest structure within the Blue Mountains potential vegetation groups. 

When the condition of forest vegetation structures are this highly altered from the 

historical range of variability it indicates that the risk of losing key ecosystem 

components in the future, including timber resources, is very high. Therefore,

management consideration on old forest is warranted. These ideas are discussed more in 

Chapter 3 of the Final Environmental Impact Statement in the sections concerning “Old 

Forest” and “Ecological Resilience.”

133. Concern Statement: The Forest Service should avoid having a policy of retaining trees 

over 150 years old because the age limit is arbitrary and age limits are difficult to 

implement. Nor should the Forest Service use the complex Van Pelt guidelines or the 

ambiguous policy of retaining trees with “old tree characteristics.” 

Response: Additional discussion and information was included in the Affected 

Environment and Environmental Consequences sections for the “Old Forest” Issue in 

the Final Environmental Impact Statement. These changes were made to improve the 

understanding of the definitions, ideas and context surrounding this issue. A wide range 

of alternative approaches to old forest management were explored with the plan revision 

alternatives, including using age-based limits and age-related characteristics to conserve 

old trees and old forest. The various trade-offs associated with these and other strategies 

are discussed within the “Old Forest” Environmental Consequences section of the Final 

Environmental Impact Statement. The final revised Forest Plans do not include a firm 

age-limit, but do contain a guideline that generally requires retention and recruitment of 

old trees, large trees and legacy trees, with specific exceptions to allow for progress 

toward other related desired conditions of forest vegetation. Plan components in the final 

revised Forest Plans are designed to allow sufficient management flexibility in order to 

address desired conditions for forest vegetation structure class, density and species 

composition as well as those pertaining to old forest. Specific methods to identify old 

trees could be developed at the project level during implementation, but should take into 
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account things like species-specific characteristics, geographic context and the potential 

of a site to grow large trees.

134. Concern Statement: The Forest Service should protect old forest structure and create 

enforceable targets for historic levels of older forests. The Forest Service should create a 

standard to protect all trees over 150 years of age as well as all trees over 21-inch 

diameter breast height (d.b.h.). 

Response: In addition to being guided by desired conditions, old forest management 

direction and conservation would also include at least one specific guideline in all the 

alternatives except Alternative D. The agency preferred Alternative E-Modified would 

not include a specific land management area allocation for old forest stands, but neither 

would old forest stands be included as lands considered suitable for timber production. 

Alternative E-Modified would also contain a revised version of guideline OF-1 that 

requires retention and recruitment of old trees, large trees and legacy trees, wherever the 

individual trees occur, with specific exceptions to allow for progress toward other 

related desired conditions of forest vegetation. Considerable additional discussion and 

information were included in the Affected Environment and Environmental 

Consequences sections for the “Old Forest” section in the Final Environmental Impact 

Statement. These changes were made to improve the understanding of the definitions, 

ideas and context surrounding this issue as well as the trade-offs involved with the 

different management strategies such as diameter limits, harvesting restrictions and 

designated old forest areas.

135. Concern Statement: The Forest Service should clearly define terms related to old forest 

management (for example, old forest characteristics, old forest stands, legacy trees) and 

how it will identify old forests.

Response: Additional discussion and information were included in the Affected 

Environment and Environmental Consequences sections for the “Old Forest” Issue in 

the Final Environmental Impact Statement. These changes were made to improve the 

understanding of the definitions, ideas and context surrounding this issue. The Affected 

Environment section for “Old Forest” explains the terms used and why. Further changes 

related to the development of Alternative E-Modified in the Final Environmental Impact 

Statement, as well as the final revised Forest Plans include a guideline that contains 

specific definitions of relevant terms like “large” tree, “old” tree and “legacy” tree.

Definitions in the glossary have also been updated and clarified.

136. Concern Statement: The Forest Service should incorporate monitoring of wildlife 

species that require old forest habitat. 

Response: Two focal species that depend on old forest will be monitored. The whiteheaded woodpecker is a species that depends on dry single-story old forest and the 

pileated woodpecker depends on multi-story mixed conifer old forest.

Forest Management: Restoration

137. Concern Statement: The Forest Service should prioritize restoration of mixed conifer 

and cool/moist forests to increase resilience and restore structural heterogeneity and 

early seral habitat conditions. 

Response: The analysis outlined in the “Ecological Resilience” and “Forest Vegetation” 

Affected Environment sections of the Final Environmental Impact Statement indicate 

that the dry upland forest currently exists in the most highly departed state when 
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compared with desired conditions. The dry upland forest potential vegetation group is 

also the dominant vegetation group across the Blue Mountains. When the condition of 

dry upland forest vegetation is this highly altered from the historical range of variability,

it indicates that the risk of losing key ecosystem components in the future, including 

timber resources, is very high. Therefore, management focus on the dry upland forest is 

warranted. These ideas are discussed at more length in Chapter 3 of the Final 

Environmental Impact Statement in the sections concerning “Ecological Resilience” and 

“Forested Vegetation.” This does not imply that no management is needed or is foreseen 

to occur within the cool/moist upland forests. The intent of the final revised Forest Plans 

is to focus restoration on areas where it is most needed, but the specific areas requiring 

and being scheduled for active treatment in the near term would be identified and 

prioritized in the context of the Plan’s desired conditions during future project-level 

planning efforts.

138. Concern Statement: The Forest Service should prioritize restoration of dry forest types 

most departed from desired conditions and should concentrate restoration in areas with 

established roads.

Response: The proximity to existing transportation infrastructure can facilitate 

opportunities to use active management as a restoration tool, but it does not drive the 

need for restoration in and of itself. The intent of the final revised Forest Plans is to 

focus restoration on areas where it is most needed. The analysis outlined in the 

“Ecological Resilience” and “Forested Vegetation” Affected Environment sections of the 

Final Environmental Impact Statement shows that the dry upland forest currently exists 

in the most highly departed state when compared with desired conditions. The dry 

upland forest potential vegetation group is also the dominant vegetation group across the 

Blue Mountains. When the condition of dry upland forest vegetation is this highly 

altered from the historical range of variability, it indicates that the risk of losing key 

ecosystem components in the future is very high. Therefore, a restoration management 

focus on the dry upland forest is warranted. 

139. Concern Statement: The Forest Service should focus restoration where it is needed 

ecologically rather than limiting restoration treatments to areas where previous harvests 

occurred that already have roads.

Response: The intent of the agency preferred alternative and the final revised Forest 

Plans is to focus restoration on where it is needed ecologically, but the issue of cost 

effectiveness must also be considered. The proximity to existing transportation 

infrastructure can facilitate opportunities to use active management as a restoration tool, 

but it does not drive the need for restoration in and of itself. The specific areas requiring 

and being scheduled for active treatment in the near term would be identified and 

prioritized in the context of the Plans’ desired conditions during future project-level 

planning efforts.

140. Concern Statement: The Forest Service should not build roads or conduct mechanical 

treatments in areas that have never been harvested. 

Response: In many cases, even areas that have never been harvested in the past have 

been significantly altered by human-influenced disruptions to natural disturbance 

regimes. For example, the continuous effects of fire suppression and livestock grazing 

are pervasive and have negatively changed areas that have never been harvested. Many 

of these areas that have never been harvested are located within wilderness or other 

primitive management areas where very little, if any, road building or mechanical 
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treatments are allowed. The intent of the final revised Forest Plans is to focus restoration 

on areas where it is most needed. The proximity to existing transportation infrastructure 

can facilitate opportunities to use active management as a restoration tool, but it does not 

drive the need for restoration in and of itself. The specific areas requiring and being 

scheduled for active treatment in the near term would be identified and prioritized in the 

context of the Plan’s desired conditions during future project-level planning efforts.

141. Concern Statement: The Forest Service should not “restore lands” by logging as this 

practice is scientifically controversial, doesn’t address impacts to aquatic resources, and 

is primarily designed to benefit local economies. The Forest Service should consider 

“passive restoration” (such as prescribed fires and wildfires) that has less impact on

forest habitats and wildlife. 

Response: A variety of restoration and management strategies were considered and 

Alternative C presumes significant use of passive management a way to move toward 

the desired conditions. The revised Forest Plans contain no presumption that active 

management is the only desirable strategy for achieving desired conditions. Many areas 

of the National Forests will remain allocated to management areas like Wilderness or 

Backcountry, where little if any active silvicultural management is expected to occur. In 

these areas, the objective is to allow ecosystems to continue to be influenced by natural 

processes with little or no human intervention. In some cases, perhaps where a 

watershed is currently well-functioning and resilient, a passive, “hands-off” approach to 

management may be appropriate, but within a large portion of the National Forests, a 

history of fire suppression and other legacy effects of past management has led to 

conditions that will necessitate a more active approach to restore more natural 

conditions and mitigate current risks. When thoughtfully designed to operate along with 

ecological processes, or even as surrogates to natural disturbances, forest management 

techniques like timber harvesting, prescribed burning, pre-commercial thinning and treeplanting can be useful tools to help manage and move forest vegetation conditions 

toward the desired conditions. 

The discussion describing the effects of Alternative C and all the other alternatives in 

terms of achieving desired conditions and improving ecological resilience is detailed in 

the Environmental Consequences sections discussing “Forested Vegetation,” “Ecological 

Resilience,” and “Old Forest,” all of which can be found in Chapter 3 of the Final 

Environmental Impact Statement. The potential impacts of harvesting and other forestry 

treatments are also addressed in relevant resource area sections of Chapter 3 under 

topics such as soil, water, aquatic resources, and terrestrial wildlife habitat. 

Most of these forestry practices and regeneration techniques were originally developed 

as part of classic silvicultural systems, which were primarily concerned with producing 

and harvesting mature crops of timber products. Modern approaches to forest 

management now view timber harvest and other silvicultural techniques as restoration 

tools that can be used to modify stand structures, species composition, stand density, 

landscape patterns and potential fire behavior. This approach is sometimes referred to as 

“ecological forestry,” or “emulation of natural disturbance,” as it attempts to fully 

incorporate an understanding of natural disturbance and stand development processes. 

This concept of using forest management to emulate natural disturbance has been 

discussed within a growing body of science literature and is often recommended as a 

technique to help restore resilient forest conditions. 
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142. Concern Statement: The Forest Service should aggressively reduce juniper to historic 

levels. 

Response: The goals and desired conditions of the Forest Plans support restoring or 

maintaining terrestrial vegetation, which would include juniper, within the range of 

historical variability.

Forest Management: Salvage

143. Concern Statement: The Forest Service should clarify anticipated annual mortality and 

support expedited salvage logging, including allowance to exceed allowable sale 

quantity after large wildfires and analysis. Salvage logging mitigates impacts to 

sustained yield production after large disturbances. 

Response: When salvage harvesting occurs, it is in reaction to unplanned disturbance 

events, so there is no planned or anticipated objective to salvage. Unplanned salvage 

volumes are not considered “chargeable” volumes and do not count against the 

allowable sale quantity limit. The desired conditions included in the Forest Plans and 

Final Environmental Impact Statement have been revised to recognize a need for 

salvage harvest to be used to supplement the regularly scheduled timber harvest program 

and recover the economic value of dead and dying trees following disturbance events. 

Salvage harvesting can potentially play a constructive role in terms of economic 

benefits, fuels management and reforestation, however, the need for salvage will also 

have to be balanced against the desired conditions for specific types of wildlife habitat 

as well as any resulting resource effects. The specific areas requiring salvage treatment 

under the new planning period would be identified and prioritized in the context of the 

Plan’s desired conditions during future project-level planning efforts. Additional 

discussion regarding salvage harvesting has been included in various sections of Chapter 

3 in the Final Environmental Impact Statement including the “Ecological Resilience” 

and “Timber and Forest Products” sections.

144. Concern Statement: The Forest Service should not limit salvage logging to 100 acres, 

no more than 50 percent of burned areas, and trees less than 21-inch diameter because 

this will increase wildfire and insect outbreak risk. In addition, the Forest Service should 

not require retention of snags when salvage logging because this puts loggers at risk. 

The Forest Service should allow as much salvage as possible to meet the economic 

needs of local communities. 

Response: Salvage logging projects will be designed to provide economic benefit to 

communities while also balancing the need to leave standing and down wood for 

sediment and flood control as well as habitat for populations of species that depend on 

snags. Human safety will always be the primary concern in project design. Salvage 

logging guidelines have changed between the Draft and Final Environmental Impact 

Statement to reflect an approach that is informed by the best available science and the 

historical range of variability. Plan components included in the final revised Forest Plans 

related to snag retention and salvage harvesting avoid using many of the wholesale 

restrictions that were included in the draft Forest Plan. The final revised Forest Plans are 

designed to balance habitat and salvage needs by using a comparison of the current 

condition (i.e. post-fire condition) to the desired conditions for snags on the landscape in 

order to inform what level of salvage harvesting would be appropriate in an area. 

145. Concern Statement: The Forest Service should coordinate with affected counties to 

identify areas for salvage logging. 
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Response: Salvage harvesting can potentially play a constructive role in terms of 

economic benefits, fuels management and reforestation, however, the need for salvage 

will also have to be balanced against the desired conditions for specific types of wildlife 

habitat as well as any resulting negative side effects. The specific areas requiring salvage 

treatment under the new planning period would be identified and prioritized in the 

context of the Plans’ desired conditions during future project-level planning efforts. We 

would welcome the participation of affected County governments in those processes as 

they occur in the future.

146. Concern Statement: The Forest Service should limit or eliminate salvage logging and 

develop plan components to define if, how, when and why salvage will be conducted by 

each burn severity class and patch size in order to preserve desired conditions and 

protect soils, aquatic resources, natural processes, snags, and complex early-seral 

habitat. 

Response: Salvage harvesting can potentially play a constructive role in terms of 

economic benefits, fuels management and forest regeneration; however, the need for 

salvage will also have to be balanced against the desired conditions for specific types of 

wildlife habitat (such as recently burned dense forest) as well as any resulting resource 

effects. The final revised Forest Plans are designed to balance habitat and salvage needs

by using a comparison of the current condition (i.e. post-fire condition) to the desired 

conditions for snags on the landscape in order to inform what level of salvage harvesting 

would be appropriate in an area. Additional discussion of the role of salvage harvesting 

in the timber production program and in terms of ecological resilience has been included 

within those sections of Chapter 3 in the Final Environmental Impact Statement. The 

ecological concerns raised about salvage harvesting typically involve effects to soils, 

terrestrial wildlife, riparian systems and aquatic ecology. Many of these concerns can be 

mitigated with well-designed and properly implemented projects, but the potential 

effects to these resource areas are discussed within other sections of the Final 

Environmental Impact Statement.

Forest Management: Snags 

147. Concern Statement: The Forest Service should re-evaluate large snag density across 

the landscape (including wilderness and roadless areas) and consider the high level of 

snags from recent disturbances. The Forest Service should base the desired condition for 

snags on current snag density, scientific information about proper snag levels, and 

modeling. No diameter limits for snag retention should be used. 

Response: The desired conditions and guidelines related to snag retention recognize the 

important role that snags play in terms of habitat and they address the potential loss of 

snags that could result from certain vegetation management activities. The desired 

conditions for snag retention included in the final revised Forest Plans represent 

revisions of the desired conditions that were included in the draft Forest Plan. The 

desired conditions in the final revised Forest Plans were developed using a sciencebased analysis of plot data contained in the DecAID database. Additionally, a natural 

range of variability analysis was completed to provide an ecologically based framework 

to characterize the natural level of recently burned forest land. 

Plan components included in the final revised Forest Plans related to snag retention and 

salvage harvesting avoid using many of the wholesale restrictions, like diameter limits,

that were included in the draft Forest Plan. The final revised Forest Plans are designed to 
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balance habitat and salvage needs by using a comparison of the current condition (for 

example, post-fire condition) to the desired conditions for snags on the landscape in 

order to inform what level of salvage harvesting would be appropriate in an area. 

148. Concern Statement: The Forest Service should assess how the retention of additional 

snags will impact firewood gathering. 

Response: The desired conditions of the Forest Plans include providing a variety of 

forest products, such as firewood and also providing non-timber forest products, such as 

berries and mushrooms in sustainable amounts for public use. The final revised Forest 

Plans include some restrictions on firewood gathering in areas like riparian management 

zones and special botanical areas. The revised Forest Plans provide the basis for 

subsequent site-specific, project-level decisions to be made, but site-specific restrictions 

on firewood gathering would be determined by individual ranger districts on a case-bycase basis. Firewood gathering is permitted largely in response to demand and is 

expected to continue at levels similar to those seen in the recent past.

149. Concern Statement: The Forest Service should retain Eastside Screen protections for 

snags and should assess various levels of protection for coarse woody debris. The Forest 

Service should retain all snags greater than 21-inch diameter at breast height and 50 

percent of snags between 12-inch and 21-inch diameter at breast height.

Response: The revised Forest Plans contain desired conditions shown in tables that 

detail the levels of retained snags and down woody debris that are wanted across the 

forest landscape. These desired condition tables cover ranges for retained smaller snag 

size classes as well as snags over 20-inches diameter. Additional guidelines are included 

in the revised Plans that will require management activities like salvage logging projects 

to be balanced with the need to leave standing and down wood for sediment and flood 

control, as well as habitat for populations of species that depend on snags or woody 

debris. Plan components included in the revised Forest Plans related to snag retention 

and salvage harvesting avoid using many of the wholesale restrictions that were 

included in the draft Forest Plans, but reflect an approach that is informed by the best 

available science and an analysis of the historical range of variability. The revised Forest 

Plans are designed to balance habitat and management needs by using a comparison of 

the current condition to the desired conditions for snags and downed wood on the 

landscape to inform what level and type of management activities would be appropriate 

in an area.

Forest Management: VDDT Model 

150. Concern Statement: The Forest Service should not rely on Vegetation Dynamics 

Development Tool modeling as it is not based on local, ground-truthed data so the 

conclusions are not reliable. In addition, the Forest Service should clarify the data sets 

and base assumptions used for the Vegetation Dynamics Development Tool modeling 

(especially related to pre-European settlement conditions, wildfire occurrence and forest 

mortality from wildfire). 

Response: The existing condition of the forest vegetation was characterized by 

examining existing vegetation polygon data for the three National Forests. The existing 

vegetation database contains summarized information for each of the polygons mapped 

on their respective vegetation layers. Data sources include walk-through examinations, 

photo-interpretation, intensive stand examination plot data, and Most Similar Neighbor 

modeling. The Vegetation Dynamics Development Tool model is a state and transition 
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model that was used to simulate the effects of future management, disturbances, and 

natural succession over time. It was also used to develop the historical range of 

variability. All of the initial condition vegetation data sets and base assumptions used in 

the modeling were applied consistently across all of the alternatives. As a result, the 

different output sets for the alternatives were reflective of the relative differences 

between the various management strategies and proposed plan components. This 

enabled the results to be used to support decisionmaking between the alternatives.

While admittedly imperfect, as all models are, this modeling program was developed by 

a cadre of multiple ecological scientists in order to evaluate the effects of disturbance 

regimes over time and develop a range of variation for forest conditions based on those 

effects. The Vegetation Dynamics Development Tool model was designed to project 

changes in vegetation over long periods of time, based on the combined effects of forest 

succession, natural disturbance events, and management activities. The interaction of 

these factors can be quite complex and sometimes counterintuitive, but projecting these 

changes and incorporating how they interact with one another is a very important part of 

a landscape scale analysis. All of the results of the models were interpreted by various 

interdisciplinary experts, and were used to provide comparison information sufficient to 

make a reasoned choice among alternatives.

Using computer models to quantify the natural historical range of variability is a 

common method. It involves using the models to simulate historical dynamics to 

produce a time series of simulated data to compute historical range of variability 

statistics and metrics. This approach relies on the best available science based on 

understanding of natural forest succession and disturbance processes. The methods used 

for this analysis were generally consistent with previous historical range of variability 

characterizations completed by scientists in the inland Northwest. Additional 

information regarding the role of the Vegetation Dynamics Development Tool modeling 

was added to the “Forested Vegetation” section of Chapter 3 in the Final Environmental 

Impact Statement, and the section was reorganized to improve clarity and readability. 

Timber: Allowable Sale Quantity and Timber Sale Program 

Quantity

151. Concern Statement: The Forest Service should use realistic timber harvest numbers to 

help create more trust of agency leadership and employees. The Blue Mountains Forests 

have not met or barely met the timber harvest goals in the current forest plans, and the 

new plans propose to increase those numbers. 

Response: Several different programmatic timber harvest schedules and resulting 

volume levels are developed during a forest plan revision, including the allowable sale 

quantity and the timber sale program quantity. The allowable sale quantity is the upper 

limit of the amount of timber volume potentially available for harvest on forestlands 

suitable for timber production during a specified time period, and its estimation is not 

constrained by assumptions about capacity. The timber sale program quantity is the 

actual planned objective level of harvest volume for each alternative, assuming full 

implementation. The actual volume offered over the next planning period would be the 

aggregate of individual project proposals, and would be dependent upon a number of 

factors, including annual budget and organizational capabilities. Some of the “full 

implementation” timber sale program quantity harvest schedules and resulting volume 

levels would represent substantial increases over the levels produced in recent years. 
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This is largely a result of the recognition that the rate and scale at which active 

management has been attempting to move toward desired conditions has not kept up 

with the impacts resulting from continued forest ingrowth, fuel accumulation and a 

changing climate. As a result, several of the alternatives, including Alternative EModified, were designed to support an increased pace and scale of restoration, and 

would thus result in increased timber volumes if they were fully funded and 

implemented.

152. Concern Statement: The Forest Service should update its analysis to accurately reflect 

current harvest levels, including the broadly supported 75 million board feet Malheur 

timber program target. 

Response: The depiction of recent harvest levels has been updated within the final 

Environmental Impact Statement to depict more recent timber volumes for the three 

National Forests. 

The large-scale 10-year Stewardship Contract that was awarded by the Malheur National 

Forest in 2013 was developed and is being implemented under the provisions of the 

1990 Forest Plan, until such time as the revised forest plans are finalized. 

153. Concern Statement: The Forest Service should base harvest level on the level of 

management needed to restore the proper range of variability. 

Response: The estimated harvest and related treatment schedules behind the allowable 

sale quantity and timber sale program objectives were not prepared in isolation from the 

other desired conditions and multiple-use objectives of the plan alternatives. The Forest 

Service agrees that the timber harvesting program, as well as other silvicultural 

treatments, should be used as tools to improve the ecological condition of the national 

forests. All the harvest schedules of the eight fully developed alternatives were designed 

to maintain or move the forest vegetation toward the desired conditions, which are based 

on the natural range of variability. The Environmental Consequences sections discussing 

“Forested Vegetation,” “Ecological Resilience,” and “Old Forest,” all found in Chapter 3 

of the Final Environmental Impact Statement, provide more detail regarding the relative 

effects of the different alternatives in terms of achieving desired conditions and 

improving ecological resilience. The potential impacts of harvesting and other forestry 

treatments are also addressed in other relevant resource area sections of Chapter 3, under 

topics such as soil, water, aquatic resources, and terrestrial wildlife habitat. 

Analysis of harvest scheduling to estimate forest product output levels is not limited to 

being a timber volume optimization exercise, but also considered and evaluated the 

ability of the harvests to move toward or maintain a set of desired conditions through 

sustained silvicultural activity over a long time horizon. Most of the desired conditions 

related to forest vegetation, insect and disease susceptibility and wildfire regimes were 

related to the historical range of variability. In addition to providing timber products, 

these desired conditions and related design elements also include reducing the risk of 

uncharacteristic fire, reducing insect and disease susceptibility, providing habitat for 

specific species and controlling the cumulative impact of harvest activity to maintain 

watershed health. All of these considerations can provide reasons for timber harvest 

activities, but also may impose limitations on the harvest schedule.

154. Concern Statement: The Forest Service should lower the allowable sale quantity to 

account for expected losses from wildfire, to store carbon, and to support viability of 

species associated with dense forests and dead wood. In addition, the Forest Service 
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should acknowledge the small diameter of most trees currently on the landscape and the 

lack of commercial viability in harvesting such stands. The proposed pace of logging is 

ecologically unsustainable. 

Response: All of the allowable sale quantity levels associated with the eight alternatives 

analyzed in full in the Final Environmental Impact Statement represent reductions from 

the allowable sale quantity levels of the 1990 plans. With the inclusion of two additional 

plan revision alternatives, including a “departure” alternative, the range of timber 

harvest schedules that was explored among the different alternatives is considerable.

The modeling done to develop the harvest schedules and related timber outputs included 

the context of anticipated natural disturbance effects, and was run on a data set that

represented the current condition of the three National Forests. All of the alternatives 

(with the exception of Alternative E-Modified Departure) were designed to harvest 

volumes within the long-term sustained yield capacity of each respective National 

Forest. The long-term sustained yield represents the maximum amount of timber volume 

that can be sustainably harvested from the lands suitable for timber production under a 

specific management regime consistent with other multiple-use objectives. The base 

timber harvest schedules of all of the alternatives were also designed to be able to 

provide a non-declining flow of sustainable forest products for at least the next five 

decades. The one exception to this scenario was Alternative E-Modified Departure, 

which was developed and included in the Final Environmental Impact Statement. 

Alternative E-Modified Departure’s allowable sale quantity was purposely developed 

outside of the constraints of non-declining flow and it was allowed to temporarily 

exceed the long-term sustained yield capacity in order to explore the effects of using this 

management approach. Because of the current high degree of disparity between the 

desired conditions for forest vegetation, fire regimes and insect and disease 

susceptibility compared with the present state of the National Forests, it was believed 

that the consideration of a departure alternative was warranted. (See “Ecological 

Resilience,” “Forested Vegetation,” and “Insect and Disease” sections of Chapter 3).

155. Concern Statement: The Forest Service should reduce the level of logging and manage 

forests as little as possible because the majority of the landscape is already overmanaged. 

Response: Many commenters expressed a desire for the revised forest plans to virtually 

eliminate timber harvesting and other human uses within the National Forests of the 

Blue Mountains. A variety of restoration and management strategies were considered. 

This minimum management alternative approach was considered as Alternative G, but 

not developed in detail. Outdoor recreation, range, and timber are all among the uses 

that the Multiple-Use Sustained Yield Act of 1960 requires the National Forests be 

administered for. This minimal approach would not address all the identified issues, and 

it would eliminate most of the multiple uses and benefits for which the National Forests 

were created. Alternative C was developed and analyzed in detail, and it presumes a 

significant shift away from active management, like harvesting, toward more use of 

passive restoration as a way to move the landscape toward the desired conditions. The 

discussion describing the effects of Alternative C and all the other alternatives in terms 

of achieving desired conditions is detailed in the Final Environmental Impact Statement, 

Environmental Consequences section of Chapter 3. The potential impacts of harvesting 

and other forestry treatments are addressed in relevant resource area sections of this 

document under topics such as soil, water, aquatic resources, and terrestrial wildlife 

habitat. 
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When thoughtfully designed to operate along with ecological processes, or even as 

surrogates to natural disturbances, forest management techniques like timber harvesting 

can be useful tools to help manage and move forest vegetation conditions toward the 

desired conditions. It is true that most commonly used forest harvesting techniques were 

originally developed as part of classic silvicultural systems primarily concerned with 

producing and harvesting mature crops of timber products. Modern approaches to forest 

management now view timber harvest and other silvicultural techniques as restoration 

tools that can be used to modify stand structures, species composition, stand density, 

landscape patterns and potential fire behavior. This approach is sometimes referred to as 

“ecological forestry,” or “emulation of natural disturbance,” as it attempts to fully 

incorporate an understanding of natural disturbance and stand development processes. 

This concept of using forest management to emulate natural disturbance has been 

discussed within a growing body of science literature and is often recommended as a 

technique to help restore resilient forest conditions. 

Timber: Standards and Guidelines

156. Concern Statement: The Forest Service should make standards FOR-1, FOR-2, FOR-3, 

FOR-5 into guidelines until forests can respond to disturbances within the historical 

range of variability. 

Response: The inclusion of these restrictions on timber harvesting represent the 

implementation of harvesting restrictions that are mandated by Federal statute (National 

Forest Management Act). However, as part of the development of the final revised 

Forest Plans, wording has been revised so that the extent of the restrictions is clearer, 

and is limited to only that which is required under the Federal regulations and Forest 

Service policy that implement these sections of the Act. Standard FOR-5 has been 

changed to a guideline and it has been clarified to make it clear that it only applies to 

even-aged harvesting on lands suitable to timber production. The other three standards 

were not changed to guidelines because timber harvest activities can only comply by 

being in accord with the explicit terms of the standard.

157. Concern Statement: Because economics should be a top priority, the Forest Service 

should remove Guideline FOR-8, which requires silvicultural treatments be developed 

through interdisciplinary review, and also prohibits harvest systems from being selected 

primarily because they yield the greatest dollar return or the greatest output of timber. . 

Response: The Forest Service has little flexibility in regards to implementing the 

prescriptive elements of the National Forest Management Act related to timber 

harvesting. The terms of the draft version of FOR-8 have been revised to comply with 

Federal regulations implementing portions of the National Forest Management Act, 

which requires that clearcutting and other even-aged harvests may be used only when 

developed through interdisciplinary review to assess the project’s impacts through 

appropriate environmental documentation, and a finding that the project is consistent 

with the multiple uses of the general area. The final wording of FOR-8 has been refined 

to ensure that the extent of the restrictions is clear, and is limited to only that which is 

required under the Federal regulations. Because the revised Forest Plans must comply 

with the terms of these Federal regulations, this direction, which was presented as a 

guideline in the draft Plans, has been changed to a standard. An additional new standard 

has also been added to comply with Federal regulations implementing portions of the 

National Forest Management Act, which require that harvesting systems chosen for a 
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project shall not be selected primarily because they give the greatest dollar return or the 

greatest output of timber.

158. Concern Statement: The Forest Service should remove standard FOR-1 and FOR-2, 

which require special consideration for use of clearcuts and limit the size of clearcuts. 

Early seral stands are lacking on the landscape and the full spectrum of potential 

silvicultural techniques should be retained. 

Response: The inclusion of these restrictions on timber harvesting represent the 

implementation of harvesting restrictions that are mandated by Federal statute (National 

Forest Management Act). However, as part of the development of the final revised 

Forest Plans, wording has been revised so that the extent of the restrictions is clearer, 

and is limited to only that which is required under the Federal regulations and Forest 

Service policy, which implement these sections of the National Forest Management Act. 

These restrictions do allow for considerable management flexibility in regards to 

managing for desired conditions pertaining to early seral structural stages on the 

landscape. The plan components allow even-aged regeneration harvesting of units larger 

than 40 acres if they are considered likely to produce a more desirable combination of 

net public benefits. If that can be demonstrated, then harvest openings larger than 40 

acres may be permitted on an individual timber sale basis after 60 days public notice and 

review by the Regional Forester. This maximum opening size limitation does not apply 

to areas harvested as a result of natural catastrophic conditions such as fire, insect and 

disease attack, or windstorm.

159. Concern Statement: The Forest Service should remove FOR-9, the guideline that calls 

for no irreversible damage to soils and watersheds, as it is unnecessary. 

Response: The inclusion of these restrictions on timber harvesting represents the 

implementation of harvesting restrictions that are mandated by Federal statute (National 

Forest Management Act). However, as part of the development of the final revised 

Forest Plans, their wording has been revised so that the extent of the restrictions is 

clearer, and is limited to only that which is required under the Federal regulations and 

Forest Service policy, which implement these sections of the National Forest 

Management Act.

160. Concern Statement: The Forest Service should consider the opportunity costs and 

trade-offs associated with the timber standards and guidelines and the 21-inch Rule. 

Response: The inclusion of the general restrictions on timber harvesting represent the 

implementation of harvesting restrictions that are mandated by Federal statute (National 

Forest Management Act). These restrictions fundamentally function as sideboards on the 

way timber harvesting projects are planned and implemented. 

The “21-inch rule” is actually management direction included by forest plan amendment 

as part of the 1990 Forest Plans. A wide range of alternative approaches to old forest 

management was explored within the alternatives analyzed in Final Environmental 

Impact Statement. The analysis examines opportunities and trade-offs associated with 

different types of management direction proposed under the different alternatives for the 

revised Forest Plans. Additional discussion regarding the pros and cons of the various 

approaches to old forest management, including the continuation of a 21-inch diameter 

limit, has been included in the “Old Forest” section of Chapter 3 of the Final 

Environmental Impact Statement. Plan components in the final revised Forest Plans are

designed to allow sufficient management flexibility in order to address desired 
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conditions for forest vegetation structure class, density and species composition as well 

as those pertaining to old forest.

161. Concern Statement: The Forest Service should create a standard or guideline to ensure 

economically viable forestry and range projects within the General Forest Management 

Areas (MA 4A). 

Response: The issue of cost effectiveness certainly will be considered during future 

project planning and prioritization, but it is outside the scope of a forest plan revision to 

ensure that all future forestry projects are economically viable. Broad-scale economic 

forces affecting timber, labor, and fuel prices along with forest product markets cannot 

be controlled or predicted by the final revised Forest Plans. Also, Federal regulations 

implementing portions of the National Forest Management Act dictate that the 

harvesting systems chosen for a project shall not be selected primarily because they give 

the greatest dollar return or the greatest output of timber. The overall intent of the final 

revised Forest Plans is to focus restoration on where it is most needed, but the specific 

areas requiring and being scheduled for active treatment would be identified and 

prioritized in the context of the Plan’s desired conditions during future project-level 

planning efforts. The financial or economic efficiency of different project alternatives 

would be evaluated and compared at that time as part of the project-level decisionmaking process.

Timber: Suitability

162. Concern Statement: The Forest Service should deem more land suitable for timber 

harvest and should clarify its rationale as to why there is less land suitable for timber 

harvest in the new forest plan compared to the current forest plans. Only 35 percent of

the planning area is considered suitable for timber production yet 60 percent has a 

moderate to high potential for uncharacteristically severe wildlife. In addition, many of 

the areas designated unsuitable for timber harvest may be more productive and higher 

quality than some of the suitable areas. 

Response: The discussion and explanation related to the determination of which lands 

are suitable for timber production and which other lands are suitable for timber harvest 

has been improved in the Final Environmental Impact Statement. This information can 

be found within the “Timber and Forest Products” section of Chapter 3. 

As part of the forest plan revision, a timber suitability analysis following the 

requirements of the National Forest Management Act was completed. This process is 

basically a series of subtractions of land from the total forest land base using four broad 

categories to identify lands not available for timber production (such as areas withdrawn 

by Congress, areas incapable of supporting forest, areas physically inappropriate and 

areas that cannot readily be restocked). Forestlands remaining after identifying and 

subtracting these subsets of unsuitable forestlands described above are those that are 

tentatively available for and potentially capable of being classified for timber 

production. Since the adoption of the 1990 Forest Land and Resource Management 

Plans, many changes to timber suitability have occurred. For example, the final adoption 

of Federal regulations for the protection of inventoried roadless areas resulted in large 

areas, which were included as timber production areas in the 1990 plans no longer being 

considered suitable for timber production. 

Each alternative started with these areas identified as tentatively suitable for timber 

production. Design parameters for each alternative resulted in further subtractions from 
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the tentatively suitable acres to determine the final acres suitable for timber production. 

Under most of the alternatives, the objectives of areas like riparian management zones, 

old forest stands, research natural areas and other backcountry areas were not considered 

compatible with regularly scheduled timber production. 

It is also important to note that many of the areas not designated as suitable for timber 

production would still consider timber harvesting a generally suitable activity if it was 

necessary to achieve multiple use objectives other than regularly scheduled timber 

production. Timber harvest may be the best tool to accomplish fuels reduction, 

vegetation improvement, or some other management objective. 

163. Concern Statement: All non-wilderness lands should be considered suitable for timber 

harvest, including backcountry areas, inventoried roadless areas, and riparian habitat 

conservation areas. Management Area 4C, Old Forest, should also be suitable. 

Response: The final revised Forest Plans consider timber harvesting as a management 

tool to be a generally suitable activity within most areas outside of wilderness. Under 

most of the alternatives, the objectives of areas like riparian management zones, old 

forest stands, research natural areas, and other backcountry areas were not considered 

compatible with regularly scheduled timber production. However, many of these areas 

would still consider timber harvesting a generally suitable activity if it was necessary to 

achieve multiple-use objectives other than regularly scheduled timber production. If 

timber harvesting was determined to be the best tool to accomplish fuels reduction, 

change forest structures, or meet some other resource objective, it could be considered 

for use, subject to any other restrictions specific to those areas. 

164. Concern Statement: The Forest Service should designate more areas as suitable for 

timber to increase contributions to local economies and support forest sector 

infrastructure and county governments. 

Response: Between the eight different alternatives that were fully developed and 

analyzed, the range of areas considered as suitable for timber production is considerable. 

The range varied between Alternative C, with around 1.1 million acres (all three 

National Forests) of suitable timber production land to Alternative D, with almost 2.5 

million acres designated as suitable for timber production. All of the alternatives were 

constrained by significant amounts of forest land being eliminated from consideration as 

suitable for timber production due to regulations related to the protection of inventoried 

roadless areas. 

Under most of the alternatives, and within the final revised Forest Plans, the objectives 

of areas like riparian management zones, old forest stands, research natural areas, and 

other backcountry areas were not considered compatible with regularly scheduled timber 

production. While little timber harvesting is expected to occur within these areas, if 

removal of products for commercial value is decided as the best means to meet the 

desired conditions for the forest vegetation of these areas, any timber product outputs 

that resulted from those restoration treatments could also be available to contribute to 

local economies and industry infrastructure. 

165. Concern Statement: The Forest Service should prohibit commercial logging in old 

forests, potential wilderness areas, roadless areas, riparian zones, backcountry areas 

(Management Areas 3A and 3B), and riparian habitat conservation areas. 

Response: Timber harvesting would not be allowed in existing or recommended 

wilderness areas. Within areas of the National Forests that are allocated to management 
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areas like backcountry, or riparian areas, little, if any, timber harvesting is expected to 

occur. Timber harvesting would not be allowed within these areas for the purpose of 

increasing timber production, but could still be allowed if it was determined to be the 

best way to achieve the management objectives of those specific areas. Any potential 

tree cutting activities within inventoried roadless areas would also remain subject to 

existing Federal regulations regarding the protection of those areas. When thoughtfully 

designed to operate along with ecological processes, or even as surrogates to natural 

disturbances, forest management techniques like timber harvesting can be useful tools to 

help manage and move forest vegetation conditions toward the desired conditions. 

Grazing 

Grazing: Allotment Monitoring and Compliance

166. Concern Statement: The Forest Service should develop a more comprehensive, 

representative monitoring strategy, including quantitative measures and enforceable 

benchmarks that would trigger changes in grazing levels or suspension or elimination 

of grazing. The agency should monitor allotments to ensure compliance with 

regulations. 

Response: The Forest Service uses nationally accepted monitoring protocols such as 

those in the Bureau of Land Management Technical references 1737-23 and 

BLM/RS/ST-96/004+1730. Site-specific allotment monitoring and frequencies are 

determined at the allotment management plan level and through the environmental 

analysis process, or through the Endangered Species Act consultation process. 

167. Concern Statement: The Forest Service should enforce off-dates and cancel 

allotments when standards are not being met. 

Response: These are administrative issues, dealt with through a specific noncompliance process identified in Forest Service Handbook 2209.13.

168. Concern Statement: The Forest Service should coordinate with counties and 

permittees to determine a science-based monitoring method. 

Response: The protocols each National Forest uses for monitoring are nationally 

accepted by the Forest Service, but we welcome any science-based monitoring 

methodology submitted for review. Permittees and counties are welcome to participate 

in the development of allotment management plan monitoring strategies through the 

appropriate process.

169. Concern Statement: The Forest Service should not use PACFISH-INFISH Biological 

Opinion parameters for individual sites as they were developed for use on a regional 

scale. 

Response: We agree that the established PACFISH-INFISH Biological Opinion

statistical sampling protocol was set up first and foremost to detect statistically valid

trends in PACFISH-INFISH Biological Opinion parameters at the scale of the Interior 

Columbia River Basin. The fisheries biologists who developed the protocol have tested 

their methods over the years in terms of statistical reliability. As more data are collected 

at individual sites and across individual national forests and watersheds over time 

through repeat sampling per the established protocol, the statistics to determine trends 

at smaller scales such as individual sites become more robust and the data become 
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more useable at those smaller scales for that purpose. The most recent reports (2016) 

for individual national forests are beginning to detect statistically reliable trends for 

some parameters at the national forest scale, and in some cases at the subbasin scale or 

reach-scale within an individual national forest. Allotments with federally listed species 

are required to consult on the grazing activity, where site-specific data is used to 

determine site-specific indicators for monitoring, and the allowable use associated with 

them.

Grazing: Animal Unit Months (AUMs) and Production

170. Concern Statement: The Forest Service should use a more accurate method for 

estimating total animal unit months available in each alternative (such as through longterm trend monitoring and field data). The Forest Service should clarify both capacity 

and current use information and ensure consistency in these numbers. 

Response: Animal unit months were based on permitted livestock numbers for 2013. 

The animal unit months were obtained from a report in the Natural Resource 

Management Infra database, based on the permitted use. These numbers were provided 

to all specialists for their resource sections.

171. Concern Statement: The Forest Service should address why estimated animal unit 

months in the plans are less than current grazing levels yet the Environmental Impact 

Statement states there is no anticipated reduction in grazing. 

Response: Animal unit months were based on permitted livestock numbers for 2013. 

Permitted numbers may be higher than authorized numbers on any given year due to 

non-use by permittees. The Natural Resource Management database was used to 

compile these numbers. Decreases reflected in these numbers may indicate an active 

allotment becoming vacant through the waiver of the permit back to the Forest Service, 

or a recent allotment decision, which may have changed animal unit month numbers, or 

season of use. Reductions would occur at the allotment management plan level, not in 

the Forest Plans.

172. Concern Statement: The Forest Service should maximize the level of grazing and plan 

for range improvement to provide more forage. 

Response: At least one alternative includes the acreage of both active and vacant 

allotments, which would be the maximum capacity or use. Projects to improve 

rangeland forage would occur at the ranger district level.

173. Concern Statement: The Forest Service should clip and weigh forage as a basic part of 

allotment management rather than relying on Holechek estimates of forage production 

that are inappropriate for Blue Mountains forests.

Response: Forage production and utilization analysis methodologies are described in 

the “Livestock Grazing and Grazing Land Vegetation” section, referencing the data and 

analysis of Countryman, Justice, and Quimby specifically for the Blue Mountains plant 

species. Best available science was used to determine appropriate allowable use levels 

for forage species.

Grazing: Benefits

174. Concern Statement: The Forest Service should recognize the benefits of grazing, 

including economic and social well-being of communities, weed control, fine fuels 
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reduction, forage improvements, water improvements for wild ungulates, and potentially 

increased species richness.

Response: Existing monitoring data is used to present the current effects of livestock 

grazing on the National Forests. That information and information related to the effects 

of the plan revision alternatives on the National Forests and surrounding communities is 

presented in the “Livestock Grazing and Grazing Land Vegetation” and the “Economic 

and Social Well-being” sections in the Final Environmental Impact Statement. The 

effects discussion also indicates that with the implementation of best management 

practices and other grazing management undesirable effects are mitigated, though it also 

points out some areas that need improvement from past effects.

Grazing: Climate Change

175. Concern Statement: The Forest Service should analyze how grazing could exacerbate 

the effect of climate change on resources such as riparian vegetation, water turbidity, 

and stream temperatures. 

Response: Climate change effects on the aquatic environment are discussed in the 

Climate Change section of the Final Environmental Impact Statement. Rangeland 

carbon stocks are lower than forests and are less directly affected by rangeland 

management practices than timber harvests in forestlands (U.S. EPA 2011).

Grazing: Current and Desired Condition 

176. Concern Statement: The Forest Service should not use “natural conditions” as the 

desired condition as it is not achievable. Nonnative plant species should not be excluded 

from the desired condition. 

Response: The desired condition is described as, “Rangelands reflect native or desired 

nonnative plant composition and cover at near-natural levels defined by the site

potential.” This includes nonnative plant species and the rate is near-natural levels, 

which we believe to be achievable since the current forest plant composition contains 

native plants in most cases. 

177. Concern Statement: The Forest Service should develop desired conditions for 

improving the ecological state of sensitive areas like springs, headwater streams, and 

grasslands. 

Response: There are desired conditions for springs, headwaters and grasslands 

described in the Forest Plans in 1.2 Watershed Function, 1.1.3 Wetland Function, and 1.7 

Plant Species Composition.

178. Concern Statement: The Forest Service should better assess current conditions (for 

example by using field data) and should provide information supporting the claim that 

the current desired condition and trend is undesired or in the wrong direction. 

Response: Existing monitoring data is used to describe the effects of permitted livestock 

grazing on the National Forests. That information is presented in the “Livestock Grazing 

and Grazing Land Vegetation” section in the Final Environmental Impact Statement. 

Livestock grazing has the potential to impact forest resources and that potential is also 

portrayed in the effects discussion. The effects discussion also indicates that with the 

implementation of best management practices and other grazing management, 
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undesirable effects are mitigated. The Environmental Impact Statement effects 

discussion also points out some areas that need improvement from past impacts.

Grazing: Fees/Permits

179. Concern Statement: The Forest Service should charge more for range permits or range 

improvements on public lands. 

Response: The question of fees on National Forest System lands is outside of the scope 

of a Forest Plan revision. The formula used for calculating the grazing fee, which was 

established by Congress in the 1978 Public Rangelands Improvement Act, has continued 

under a presidential Executive Order issued in 1986. Under that order, the grazing fee 

cannot fall below $1.35 per animal unit month, and any increase or decrease cannot 

exceed 25 percent of the previous year’s level.

Grazing: Fire

180. Concern Statement: The Forest Service should completely exclude livestock from 

burned areas after a fire for up to five years or more after a fire.

Response: Both the Draft and Final Environmental Impact Statements include a “Fire 

Exclusion and Extinguishment” section in the Affected Environment of the “Livestock 

Grazing and Grazing Land Vegetation” section. The impacts of grazing management 

before and after a fire have a dramatic effect on the response of vegetation to the fire and 

to what can be expected in the long term. The need for increased intensity of grazing 

management on burned areas can be understood by realizing the potential change in the 

plant community and associated animal response that can result from a burn (Clark and 

Miller 2001). 

The response of individual plant species to fire varies significantly between and within 

species. This response is influenced by a variety of fire parameters, including intensity, 

severity (influencing amount of organic matter consumed), residence time, soil heating, 

season of burn, and time since last fire. These parameters can vary significantly among 

fires and within a fire. These variations can and will cause differences in the response of 

individual species and the community as a whole. In addition, numerous physical and 

climatic factors (such as fuel condition, weather, slope, and aspect), as well as biological 

factors (plant morphology and physiology) will influence post-fire effects on plant 

communities. This includes direct effects, such as the ability of individual species to 

recover from the effects of fire.

Expected recovery potential is a function of fire severity. Johnson (1998) reported that in 

lightly burned areas (low severity fires) the expected recovery is fairly quick and a 

natural recovery of one to two years would be expected. Moderately burned areas 

(medium severity fires) have a modest recovery rate of two to five years. Heavily burned 

(high severity fires) have a slow natural recovery and may require five or more years to 

recover.

181. Concern Statement: The Forest Service should allow for site-specific prescriptions for 

grazing after wildfire. 

Response: Both the Draft and Final Environmental Impact Statements include a “Fire 

Exclusion and Extinguishment” section in the Affected Environment of the “Livestock 

Grazing and Grazing Land Vegetation” section. See the response above for more 

information.
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182. Concern Statement: The Forest Service should change guideline RNG-1 G-43 to a 

standard and modify it to state that grazing after wildland fire will be deferred until 

vegetation recovers to a condition where grazing will not cause a downward trend in key 

species. 

Response: Standards are mandatory constraints upon project and activity 

decisionmaking. They are established to help achieve or maintain the desired condition 

or conditions, to avoid or mitigate undesirable effects, or to meet applicable legal 

requirements. 

Guidelines are a constraint on project and activity decisionmaking that allow for 

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

Guidelines are established to help achieve or maintain a desired condition or conditions, 

to avoid or mitigate undesirable effects, or to meet applicable legal requirements. 

Guidelines serve the same purpose as standards but they differ from standards in that 

they provide flexibility in defining compliance, while standards are absolute constraints. 

It would not be appropriate to make this a standard because factors such as fire intensity 

and vegetation composition make the timing of grazing reintroduction after a wildland 

fire highly variable.

183. Concern Statement: The Forest Service should encourage grazing to reduce fuel loads 

and fire risk. 

Response: In the short-term, livestock grazing can result in reduced fire frequency 

within an area, by reducing herbaceous surface fuel loads and creating denuded areas 

that can act as firebreaks. However, a great deal of scientific evidence exists suggesting 

that over longer time frames, grazing within many western forests may actually 

contribute to unintended negative consequences in terms of fire behavior and forest 

health. Many of the ponderosa pine and mixed-conifer forests that are typical of the Blue 

Mountains region have undergone substantial structural and compositional changes 

since settlement of the West. Many of these changes have resulted in impacts in terms of 

increased vulnerability to severe fire and susceptibility to insect and disease outbreaks. 

Historically, these forests largely consisted of widely spaced, fire-tolerant trees underlain 

by dense grass. Over the last 100 years, they have developed into dense stands 

consisting of more fire-sensitive and disease-susceptible species. Livestock grazing has 

contributed to these problems because livestock consume and lower the density of 

grasses that would otherwise compete with and regulate the development of new tree 

seedlings. Livestock also remove the herbaceous understory, which historically would 

have provided fuel for frequent mild surface fires that would normally kill and thin out 

regenerating trees. As this process continues over time, in conjunction with aggressive 

suppression of natural fire starts, forest stands previously dominated by fire-tolerant 

species such as ponderosa pine and western larch shift to dominance by Douglas-fir and 

true fir species. This process is also exacerbated by selective logging of the original 

large, fire resistant trees. The individuals within these crowded new stands of smaller 

trees and saplings compete intensely with each other, and consequently have a reduced 

ability to fend off attacks by forest insects and diseases. These dense multi-storied 

structures also tend to support uncharacteristically severe fire behavior when 

suppression efforts are no longer able to be effective, and long excluded fire returns to 

the area.
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Grazing: Listed and Sensitive Plant Species

184. Concern Statement: The Forest Service should drop the standards that restrict grazing 

timing and location to protect Spalding’s catchfly (PL-TES-1 and PL-TES-2) because it 

severely limits flexibility to manage the range resource, is duplicative of guidance to 

avoid listed plant species when possible, and is inappropriate for a species that thrives 

after disturbance. The relationship between grazing and Spalding’s catchfly populations 

is unclear and grazing shouldn’t automatically be assumed to be a threat. The Forest 

Service should not require a conservation strategy, agreement or recovery plan for the 

species. Rather than restrictions, the Forest Service should intensively monitor the sites 

to see if any change in grazing is needed or should fence sites. 

Response: To simplify management while ensuring the continued viability and recovery 

of Spalding’s catchfly, the Forest Service modified Alternative E and omitted the 

standard that would have not authorized grazing in pastures that were moderately or 

more departed from the desired conditions for grasslands. Alternative E-Modified would 

adjust the season of use within occupied habitat to exclude the catchfly’s floweringfruiting period, which is approximately from July 1 to September 30. This would allow 

catchfly flowers to be pollinated and its seed to ripen and disperse.

185. Concern Statement: The Forest Service should manage grazing to protect sensitive 

plant species and communities, such as Spalding’s catchfly and should classify all areas 

containing known populations of Spalding’s catchfly as unsuitable for livestock grazing. 

Instead, such areas should be classified as botanical areas. 

Response: Standards and guidelines were developed to help maintain or achieve desired 

conditions. An analysis of how plan components (including standards and guidelines for 

all alternatives) is found in Chapter 3 of the Final Environmental Impact Statement. 

Alternative E was modified to adjust the timing of grazing in occupied Spalding’s 

catchfly habitat. Grazing would not be authorized in occupied habitat of Spalding’s 

catchfly from July 1 through September 30 to allow catchfly plants to complete 

flowering, seed set and dispersal. A separate standard would limit grazing outside this 

period to a maximum 30 percent of key forage species to maintain or move the species’ 

grassland habitat toward desired conditions and maintain ample pollinator habitat. See 

Volume 1, Chapter 3 of the Final Environmental Impact Statement for the complete 

discussion and analysis. 

186. Concern Statement: The Forest Service should assess the impact of grazing on 

Spalding’s catchfly populations at the project level rather than creating detailed 

prescriptions in the Forest Plans. 

Response: Standards and guidelines were developed to help maintain or achieve desired 

conditions. Guidelines provide managers flexibility, during project-level design and 

analysis, to achieve the intent of the guideline. Standards, while mandatory, are practices 

that are necessary to maintain or move toward desired conditions in every situation 

regardless of a given location at the project level. An analysis of how plan components

(including standards and guidelines for all alternatives) achieve desired conditions for 

Spalding’s catchfly is found in Chapter 3 of the Final Environmental Impact Statement.

187. Concern Statement: The Forest Service should eliminate guidelines discouraging 

grazing in fen and bog plant habitats (PL-TES-3); limiting utilization in habitat for 

threatened, endangered, and sensitive plants (PL-TES-4); and discouraging water 
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developing within a quarter of a mile of threatened, endangered, or sensitive plant 

species (PL-TES-5). 

Response: Alternatives C and D have no standards or guidelines restricting grazing in 

fen habitats or restricting water development within one-quarter mile of occupied habitat 

for threatened, endangered, or sensitive plant species or limiting utilization levels of key 

forage species within occupied habitat of threatened, endangered, or sensitive plant 

species. Standards and guidelines for other action alternatives were developed to help 

maintain or achieve desired conditions. Peatlands, which include fen and bog habitats, 

are too fragile to support livestock grazing. The intent of the guideline restricting water 

development near threatened, endangered and sensitive plants is to avoid concentrating 

livestock in these locations. Given uncertainties around the levels of grazing that can be 

sustained by threatened, endangered and sensitive plants, a level of 30 percent maximum 

utilization, which is characterized as the upper limit of “light” grazing, provides these 

species a margin of protection over higher use levels (e.g., 50% utilization for uplands). 

An analysis of how plan components (including standards and guidelines) achieve 

desired conditions, for all alternatives, is found in Chapter 3 of the Final Environmental 

Impact Statement.

Grazing: Modeling

188. Concern Statement: The Forest Service should use an inventory and sampling 

approach rather than state and transition modeling, which doesn’t accurately reflect 

conditions on the ground or reduced cattle use on steeper grounds, for instance. 

Alternately, models should be used with caution and verified. In addition, the analysis 

should describe vegetation plots used, how reference areas were selected, and the 

number of plots used for each vegetation category. 

Response: Long-term condition and trend vegetation monitoring data is used to 

determine which plant community may fall into in the State and Transition model. These 

determinations are made at the site-specific allotment management plan and 

environmental analysis level, not in the Forest Plans.

189. Concern Statement: The Forest Service should not use the concepts of ‘phases model’ 

and ‘state and transition model’ interchangeably. 

Response: The Final Environmental Impact Statement has had more language and a 

schematic added to further explain that phases are part of a state and transition model to

better clarify the discussion and relationship between phases, models, and states when 

vegetation is mentioned in “Issue 3: Livestock Grazing and Grazing Land Vegetation.” 

Grazing: No Reduction or Restrictions 

190. Concern Statement: The Forest Service should not reduce livestock grazing as it would 

affect county revenues and detract from the Forest Service’s multiple-use balance. 

Response: Livestock grazing is proposed in every alternative. Some alternatives have a 

lesser emphasis, or more areas of restriction. Potential reductions to animal unit months 

would occur at the allotment management plan and environmental analysis level, not in 

the Forest Plans. Alternatives E-Modified and E-Modified Departure both include 

vacant allotments and the historic animal unit months and suitable acres of rangelands.

191. Concern Statement: The Forest Service should not apply further unjustified grazing 

restrictions (for example, cutting cattle numbers, allowing only native grasses, 
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restricting utilization), especially in light of improved conditions under current standards 

and management practices. 

Response: Current range management practices may be showing improvement in some 

areas, but may not in others. Desired conditions may not have been reached within the 

last planning period from 1990 to present. Standards and guidelines have been 

developed to move us toward attainment of desired conditions.

192. Concern Statement: The Forest Service should not broadly blame cattle for multifaceted resource issues (for example, poor riparian conditions or ineffective fish 

recovery) and should not consider all grazing to be unmanaged or poorly managed. In 

addition, the forest should not be viewed as currently “over-used.” 

Response: The text being referenced is one of four background sections that describe 

the documented watershed-related effects of forest roads, timber harvest (logging), fire, 

and livestock grazing as these are four of the prevalent uses on the National Forests that 

have effects on watershed conditions. The material is for background only and describes 

the kinds of effects, and potential magnitudes of effects, associated with each activity, 

but does not make conclusions as to the effect of livestock grazing in the Blue 

Mountains. 

The watershed analysis recognizes that past land uses are often listed without reference 

to the magnitude of the effects of different land uses. Some details of these effects have 

been added to the watershed environmental consequences and cumulative effects 

sections of the Final Environmental Impact Statement.

Skovlin (1991), among others, cited several sources that describe historic range 

conditions of the Starkey range, the Wallowa Mountains, and western foothills of the 

Blue Mountains that describe heavy livestock use and heavily overgrazed range 

conditions that were documented between 1882 and 1900. Skovlin estimated that 

livestock numbers were reduced by about half between 1900 and 1910 and following the 

establishment of the Blue Mountains Forest Reserve. McIntosh (1992) reported that 

livestock numbers in the upper Grande Ronde River were reduced from 211,000 animal 

unit months in 1911 to 51,000 animal unit months in 1990 and 18,250 animal unit 

months in the same area as of 2013. Present (2013) livestock numbers represent a 96 

percent reduction from 1900 levels and 91 percent reduction from levels at the time the 

national forests were established. This information is included in the watershed effects 

analysis of the Final Environmental Impact Statement.

Grazing: Range of Alternatives

193. Concern Statement: The Forest Service should consider a broader range of grazing 

alternatives including: (1) no grazing, (2) increasing herd numbers, (3) removing cattle 

from rangelands with streams containing listed fish species, (4) altering the amount of 

exclusions, and (5) requiring a minimum 6-inch stubble height. 

Response: A broad range of alternatives are provided with various levels of grazing 

available, detailing suitable acres for livestock grazing and animal unit months for both 

sheep and cattle. These alternatives are compared and broken down by National Forest 

in the Comparison of Alternatives section in Volume 1 of the Environmental Impact 

Statement. The No Grazing Alternative was Alternative J, which was considered, but 

eliminated from detailed study because while the National Forest Management Act 

requires the Forest Service to address rangeland capability and suitability, stocking 
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decisions for specific grazing allotments are made through site-specific environmental 

analyses.

Grazing: Restocking Allotments

194. Concern Statement: The Forest Service should allow for the use of vacant allotments 

as a tool to increase management flexibility.

Response: All vacant allotments are included in the suitable acres for grazing and 

animal unit months in Alternatives E-Modified and E-Modified Departure. Site-specific

environmental analysis and Endangered Species Act consultation may be needed to 

reauthorize livestock grazing, independent of the Forest Plans, to determine appropriate 

capacities for these allotments if they have been vacant for a long period. Vacant 

allotments are listed in the Rescission Act schedule.

195. Concern Statement: The Forest Service should not allow livestock grazing to occur in 

vacant allotments, particularly without opportunity for public comment. 

Response: Forest Service Handbook 2209.13 gives the Forest Service the authority to 

stock vacant allotments in emergency situations until environmental analysis can be 

completed. Permanent stocking of these allotments will not occur without environmental 

analysis, which allows the public to comment during scoping.

Grazing: Restrict or Eliminate Grazing 

196. Concern Statement: The Forest Service should reduce or eliminate grazing because of 

low ratings in survey plots; irreversible ecological impacts (soils, water quality, plant 

communities, wildlife, fish and hydrology); declines in suitable habitat for sensitive 

species; woody shrub recruitment; and difficulty achieving desired conditions for 

grasslands. A reduction in grazing would create healthy landscapes, restore fish and 

populations, protect water quality, protect soils (including water storage capacity), limit 

weed spread, restore sagebrush ecosystems, support recreation, and limit extensive and 

severe livestock damage.

Response: The long-term Forest Service condition and trend data indicates 

improvement of vegetation conditions in most areas. The PACFISH-INFISH Biological 

Opinion data reports suggest similar improvement in fish habitat. Removal of livestock 

grazing would not eliminate effects from other ungulates or activities on the National 

Forests, and will not automatically improve conditions to a recovered or restored state 

ecologically. Some irreversible impacts were not caused by livestock grazing, but other 

historic practices. Some sensitive species require a certain level of stimulation to 

survive, and actually prefer grazed sites. The allotments with some areas of unsuitable 

for grazing acreage reflect areas the livestock trail through but don’t necessarily graze, 

or are fenced out administrative sites such as campgrounds.

A wide range of alternatives is included in the analysis, with various levels of animal 

unit months and suitable rangelands acres.

197. Concern Statement: The Forest Service should significantly reduce grazing, for 

example 75 percent less animal unit months or cutting seasonal use by half. 

Response: Alternative C greatly reduces animal unit months by designating riparian 

management areas as unsuitable for livestock grazing. The Forest Service is required to 

consult with the U.S. Fish and Wildlife Service and National Oceanic Atmospheric 
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Administration, National Marine Fisheries Service for grazing activities, in which they 

have given us terms and conditions or accepted our mitigation measures, and supported 

our continuation of livestock grazing. The Forest Service has no data to support such a 

large reduction in animal unit months. Each allotment is analyzed individually to 

determine appropriate stocking levels and grazing seasons.

198. Concern Statement: The Forest Service should reduce the area considered suitable for 

livestock grazing. Grazing should not be suitable in areas with steep slopes, high canopy 

closure, low productivity, Phase D conditions (grasslands have crossed an ecological 

threshold), or reaches with federally listed fish. Additionally, there should be no 

livestock use in wilderness area, roadless areas, bighorn habitat, riparian areas, and 

seasonally saturated meadows with fine-grained non-cohesive soils and no woody 

vegetation. No grazing should be allowed in unsuitable areas. 

Response: The suitability and capability analysis described in the Methodology section 

of the “Livestock Grazing and Grazing Land Vegetation” section accounts for steep 

slopes, areas that produce less than 200 pounds per acre of forage, and other factors. 

These areas are considered unsuitable for livestock grazing: however, livestock may trail

through them on an allotment. Stream reaches with federally listed fish are managed 

very intensively and coordinated through consultation with the U.S. Fish and Wildlife 

Service and National Oceanic and Atmospheric Administration/National Marine 

Fisheries Service. Other areas mentioned are managed intensively or are currently 

considered unsuitable for livestock grazing. The wilderness areas in the analysis have 

specific determinations as to whether livestock grazing was grandfathered into the area 

when it was designated.

199. Concern Statement: The Forest Service should consider complete elimination of 

grazing or multi-year rest to recover damaged riparian systems. The Forest Service 

should meet the requirements of Executive Order 11990 to minimize the destruction, 

loss and degradation of wetlands by cattle and sheep and preserve and enhance the 

natural values of wetlands.

Response: We do not believe we have any of these areas that have been destroyed, lost

or degraded. The Forest Service must follow all laws, regulations, and policy direction, 

such as the Clean Water Act, National Forest Management Act, State regulations, and 

Forest Service handbook and manual direction. This direction has not been repeated in 

standards or guidelines. Grazing authorizations are determined at the site-specific 

allotment level, requiring environmental analysis, including no grazing.

200. Concern Statement: The Forest Service should eliminate grazing in areas not meeting 

standards or where conditions have not improved substantially in the past two years. 

Available forage estimates should be based on historic minimum years to prevent 

damage during drought cycles; every third year should be a rest year. 

Response: Long-term condition and trend monitoring of rangeland and riparian 

vegetation shows improvement in most areas, but not in all. Desired conditions may not 

have been reached within the last planning period from 1990 to present. The Final 

Environmental Impact Statement developed desired conditions and goals, as well as 

standards and guidelines used to monitor progress toward attainment of desired 

conditions. Grazing systems are determined at the allotment and environmental analysis 

level, based on site-specific conditions.
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201. Concern Statement: The Forest Service should eliminate livestock grazing in 

watersheds that don’t meet substrate standards or where 10 percent or more of soils have 

been compacted. The Forest Service should incorporate a discussion of the impact of 

livestock grazing on water quality. 

Response: The elimination of grazing from any allotment is a site-specific decision that 

is made through allotment environmental analysis. The first request is taken from 

Rhodes et al. (1994, Table B), a report that is now more than 20 years old. Conditions 

have changed since the report was written. Livestock numbers have been reduced by as 

much as two-thirds; some allotments have been closed; more than 11,000 miles of roads 

have been closed and more than 2,000 miles of roads have been decommissioned, most 

of them since the Rhodes report was published. 

Livestock grazing is discussed in the Final Environmental Impact Statement with respect 

to water quality. As described in the analysis, the most recent (2012) 305(b) integrated 

report for Oregon lists 66 streams miles as water quality limited for Fecal Coliform or E. 

coli and 395 miles for unspecified Biological Criteria, which may be from sources other 

than livestock grazing.

Livestock numbers have already been reduced to roughly one-third of 1990 levels and 

by more than 90 percent from 1910 levels. Livestock grazing remains a pervasive use on 

the National Forests but is only one of several past and ongoing land uses that have 

affected streams in the Blue Mountains (placer mining, stream channelization, splash 

dams, log drives, railroad logging, roads, logging, water diversions, floodplain 

conversion, and irrigated agriculture are among the others). Some past activities are no 

longer practiced, but continue to affect stream channel and riparian conditions in the 

Blue Mountains. Livestock grazing has been shown to be a source of soil compaction 

(Kauffman et al. 2004), but there are multiple other sources of impact on soils, erosion, 

and water quality within the National Forests. The Blue Mountains Aquatic and Riparian 

Conservation Strategy comprises Appendix A of the preferred alternative (“the Plan”). 

Guideline GM-3G focuses livestock concerns on watersheds where the preponderance 

of evidence for water quality, riparian and aquatic habitat indicators suggests that their 

conditions are less than optimal, and establishes specific timeframes for closer analysis 

and requires revised management of grazing to reduce any ongoing impacts that are 

slowing or preventing recovery for those indicators. Appendix B of the ARCS includes 

criteria for evaluating and identifying good substrate conditions, and outlines the process 

for revising those criteria when they do not fit inherent capabilities of a watershed or 

stream channel type or healthy sediment transport processes in certain landscape 

settings.

202. Concern Statement: The Forest Service should incorporate best available science in its 

analysis which shows that livestock grazing: alters forest dynamics, species 

composition, and natural fire regimes; reduces the biomass and density of understory 

grasses; alters forest ecosystem processes by reducing the cover of herbaceous plants 

and litter; disturbs and compacts soils, reducing water infiltration rates and increasing 

soil erosion; negatively affects water quality and seasonal quantity, stream channel 

morphology, hydrology, instream and stream vegetation and aquatic fish and wildlife.

Response: The Final Environmental Impact Statement incorporates the best available 

science. The effects of livestock grazing to different resources are discussed separately 

in the sections covering topics such as watersheds, water quality, soils, forest vegetation, 

aquatics, plant species diversity, and wildlife. The historic effects of livestock grazing 
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are presented in the introductory and existing conditions sections in the “Livestock 

Grazing and Grazing Land Vegetation” section of the Final Environmental Impact 

Statement.

Grazing: Scale

203. Concern Statement: The Forest Service should analyze grazing at a site-specific scale 

because ecological impacts are washed out at too large of a scale. Decisions about 

animal unit months and grazing should take place site specifically under an allotment 

management plan Environmental Assessment. 

Response: The revised Forest Plans will not change current uses. Those uses may be 

modified by future site-specific analysis and decision-making as required by the 

National Environmental Policy Act. In the interim, implementation of the livestock 

grazing and grazing vegetation standards and guidelines will be consistent with the 

desired conditions described in the Plans, and consistent with current allotment 

management planning environmental analysis and/or consultation.

Grazing: Soils

204. Concern Statement: The Forest Service should revise its analysis of the impact of 

grazing on soils to include a soils map, a description of soil types, soil survey data, and 

data or literature to support its assumptions and conclusions, including that sites with 

over 40 percent slope are unsuitable for grazing. 

Response: A Forest Plan is a programmatic level document and as such does not include 

site-specific decision determinations. When projects are proposed at a site-specific 

allotment management plan level, each of the recommended items would be included in 

the associated environmental analysis before a determination can be made (for example, 

a soils map, with descriptions of the soil types, soil survey data, and data or literature to 

support assumptions and conclusions, along with areas that have slope gradients 

exceeding 40 percent). The exclusion of slopes greater than 40 percent is built into the 

Capability analysis described in the Methodology section of the “Livestock Grazing and 

Grazing Land Vegetation” section in the Final Environmental Impact Statement.

205. Concern Statement: The Forest Service should establish a soil quality index and 

measure indicators of soil health before, during and after grazing. 

Response: It is a normal practice for district range specialists to conduct range readiness 

surveys prior to livestock turnout on allotments, to make sure soils are not saturated and 

will not be impacted by grazing. There are standards and/or guidelines proposed for 

management of soils in the revised Plans.

Grazing: Spatial Data and Grazing Analysis 

206. Concern Statement: The Forest Service should provide spatially explicit information 

on capability and suitability determinations. 

Response: A map of active and vacant allotments has been created and is included in the 

Final Environmental Impact Statement. The methodology for determining capability and 

suitability is included in the Final Environmental Impact Statement “Livestock Grazing 

and Grazing Land Vegetation” section. 

207. Concern Statement: The Forest Service should incorporate recent science that 

acknowledges that changes in management have improved conditions. In addition, the 
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Forest Service should clearly demonstrate: (1) grazing actually has negative impacts on 

existing conditions, (2) exclusionary livestock fences are the most effective means for 

improving habitat (rather than managing for desired conditions, for example), (3) 

livestock actually trample redds, (4) cowbirds are a real issue within the plan area, (5) 

Johnson’s research is relevant for extrapolating pounds per acre of forage, and (6) 

Countryman 2010 data methods are reliable. Finally, the Forest Service should use "best 

available science" to take all impacts into account, not just impacts from ranching.

Response: Long-term condition and trend monitoring of rangeland and riparian 

vegetation shows improvement in most areas, but not in all. Desired conditions may not 

have been reached within the last planning period from 1990 to present. The Draft and 

Final Environmental Impact Statements developed desired conditions and goals, as well 

as standards and guidelines to monitor progress toward attainment of desired conditions. 

The Aquatic and Riparian Conservation Strategy incorporates the best available science.

In response to items 1-4, existing monitoring data is used to present the current effects of 

livestock grazing on the National Forests. That information is presented in the 

“Livestock Grazing and Grazing Land Vegetation” section in the Final Environmental 

Impact Statement. Livestock grazing has the potential to impact forest resources and that 

potential is portrayed in the effects discussion. The effects discussion also indicates that 

with the implementation of best management practices and other grazing management 

those effects are mitigated, though it also points out some areas that need improvement 

from past impacts. We acknowledge that several uses other than grazing (for example, 

timber production, roads, or fire) cause riparian and other aquatic resource damage. All 

of these activities, including their consequences, are outlined and detailed in the Final 

Environmental Impact Statement under the various headings for those listed activities.

Johnson’s ecology research and long-term monitoring of plant communities was 

instrumental in determining and documenting the plant community composition, 

condition, trend, and related production per acre. Countryman and Justice used local 

vegetation databases to analyze plant communities based on the vegetation data 

collected in the Blues Mountains.

Grazing: Standards and Guidelines 

208. Concern Statement: The Forest Service should change all grazing guidelines to 

standards, including RNG-2 G-44, RNG-3 G-45, RNG-4 G-46, RNG-5, RNG-6 G-47, 

and RNG-7 (new). 

Response: In order to provide protection of resources, projects must follow all 

guidelines. A guideline is defined in the glossary as “a constraint on project and activity 

decision making 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.” Guidelines are an important component of plan 

direction, allowing some flexibility (with proper documentation) while still providing 

guidance to protect resources. Guidelines are commitments that the National Forest staff 

will follow during plan implementation. The project analysis will document how the 

project is meeting all applicable guidelines.

209. Concern Statement: The Forest Service should eliminate Range Standards and 

Guidelines 1-19 because they are arbitrary and restrict management ability to respond to 

changing site-specific conditions. 
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Response: RNG-1, 2, 3, 4, 5, 6, 7, and 8 have been replaced by BHSM-1S, 2S, 3S, 4S, 

and 5S. These standards are designed to allow for management flexibility to use the best 

available science, while combining site-specific qualitative and quantitative factors that 

influence the risk of contact between domestic sheep and bighorn sheep. These 

standards and the areas identified as “suitable for domestic sheep grazing” will ensure 

that the Forest Service supports a domestic sheep grazing program in a manner that does 

not impeded the recovery of bighorn sheep.

210. Concern Statement: The Forest Service should eliminate the standard that prohibits 

trampling of redds by livestock (RMA-RNG-5, G-118). 

Response: This has been a requirement of the U.S. Fish and Wildlife Service and

National Marine Fisheries Service since we began consulting with the Services for 

various listed fish species, starting in the 1990s with Snake River Basin Chinook 

salmon, followed by Snake River Basin and Middle Columbia River steelhead and 

Columbia River bull trout.

211. Concern Statement: The Forest Service should adjust guideline RNG-4 G-46 to clarify 

that grazing will only be allowed in suitable areas of grazing allotments (only 42 percent

of acreage in allotments currently classified as suitable). The Forest Service should 

define “less than fully capable or suitable.” 

Response: An allotment may contain both suitable and unsuitable areas for grazing, in 

which the livestock may trail through unsuitable areas (such as those that are forested) to 

access the suitable range. It would be impractical to try to manage and limit livestock 

from accessing those areas they need to travel through. Less than fully capable or 

suitable areas are those that produce less than 200 pounds of forage per acre, are an 

administrative site, or otherwise a management area designated not suitable for grazing.

Grazing: Utilization

212. Concern Statement: The Forest Service should replace utilization standards with levels 

of use (for example, light, moderate, and heavy) because of the high measurement 

variability with utilization standards and little relation to fish habitat quality or 

rangeland ecological conditions. 

Response: Percent forage utilization wheels are based on height-weight curves by plant 

species. Stubble heights are also measured on key hydric greenline species. Monitoring 

is conducted by following accepted national protocols. The terms “light, moderate and 

heavy” are used during assessments or ocular observations, not actual data collection. 

There is a direct correlation to the amount of forage utilization and residual stubble 

heights to ecological conditions, which are listed in the “Livestock Grazing and Grazing 

Land Vegetation” section and reference sections in the Final Environmental Impact 

Statement.

213. Concern Statement: The Forest Service should base utilization levels on site-specific 

data and science, which supports higher utilization (45-55 percent) because of the 

dominance of elk sedge, pine grass, and needle grass. A seasonal range of use (for 

example 40-60 percent) should be applied, and utilization levels for riparian woody 

plants should not be required because methods are unreliable. Forage height and weight 

relationships should be used rather than ocular estimates. 

Response: The utilization guides for these recommendations are based on use in 

pastures in good to high ecological status and on information in Appendix 11 of General 
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Technical Report INT-263 (May 1989 within Clary and Webster 1989). Clary and 

Webster (1989) also recommend for Environmentally Sensitive Areas that:

♦ Streambanks subject to early season grazing damage: 

Where a combination of high soil moisture and fine soil texture results in 

streambanks susceptible to trampling damage, grazing may need to be delayed to a 

late season period. The herbaceous stubble height criterion would still apply. 

♦ Habitats where threatened, endangered, or sensitive species occur, or where 

streambank/channels are highly erodible: The herbaceous stubble height criterion 

may need to be increased to greater than 6 inches. Under extreme conditions, the 

area may need permanent protection, or at a minimum, grazing may need to be 

removed for long periods. 

For subwatersheds that are functioning properly, GM-3G specifies maximum utilization 

rates of 30-45 percent in the active floodplain and, as needed, in other critical portions of 

the riparian management area. These values generally correspond with “moderate” 

grazing intensity (Clary and Leininger 2000, Holechek et al. 1999). Values of 30-35 

percent are specified for subwatersheds that are functioning-at-risk or have impaired 

function. These ranges of utilization are considered “conservative” or somewhere 

between “moderate” to “light” grazing intensity, respectively (Clary and Leininger 2000, 

Holechek et al. 1999). They are comparable to guidelines from some other Regions (e.g., 

less than 30-40 percent on national forests in the Sierra Nevada, depending on seral state 

of vegetation). 

These ranges of values were informed by the work of multiple researchers. Clary (1995), 

for example, found utilization rates greater than 30 percent in riparian meadows can 

reduce herbage production significantly, while Crider (1955) found root growth stops 

when 50 percent of aboveground biomass is removed. In addition, Holechek et al. 

(1999) concluded “moderate” utilization rates of 40-45 percent may maintain range 

conditions, while use less than 30-35 percent was needed to improve rangeland 

vegetation. These values were further informed by the findings of Freitas et al. (2014) 

and Kauffman et al. (2004). Freitas et al. (2014), for example, concluded riparian 

herbaceous utilization rates of 35 percent, when combined with other use limitations 

(such as streambank alteration or willow browse), neither degraded nor hampered 

recovery of meadow plant communities on the Inyo National Forest. In contrast, 

Kauffman et al. (2004), found at a site in the John Day River Basin, utilization rates on 

the order of (and likely less than) 64 percent in dry meadows and 42 percent in wet 

meadows may affect or hinder recovery of stream channel structure, water quality, and 

aquatic biota by substantially altering below ground biomass, soil porosity, infiltration 

rates, and other key ecological processes.

Specific monitoring indicators and levels of allowable use will be determined at the 

allotment pasture level during implementation of the decision. 

214. Concern Statement: The Forest Service should eliminate the utilization guideline in 

Riparian Management Areas (G-115), including bank alteration guidance, and drop its 

bias against grazing. The Forest Service should adapt management based on riparian 

conditions and trend. The Forest Service should consider other impacts to riparian areas, 

the upward trend in riparian condition with current management, that cattle are either 

neutral in preference or avoid riparian areas, and means of protecting riparian habitat 

other than fencing. If utilization guidance is retained, the same guideline should be used 

for all fish species. 
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Response: The Final Environmental Impact Statement Alternatives E-Modified and EModified Departure no longer recommend different guidelines for different federally 

listed species, but rather bases the guidelines on the Watershed Condition Framework 

parameters most affected by livestock grazing, as described in the Aquatic and Riparian 

Conservation Strategy.

The indicators were chosen because they generally: (1) have demonstrated or plausible 

relationships to grazing intensity, (2) are representative of cumulative impacts 

throughout the season, (3) have demonstrated or plausible relationships to long-term 

stream conditions, (4) are regularly used by field personnel, and (5) have readily 

implementable field protocols that are reasonably repeatable.

The guideline explicitly specifies that these annual livestock use and disturbance 

indicators should be applied to help achieve, over longer timeframes, conditions at site 

and watershed scales that enable attainment and maintenance of aquatic and riparian 

desired conditions. They are not long-term management objectives, but a means to 

achieve them, when properly specified, applied and adapted over time (Bryant et al. 

2006, Clary and Leininger 2000). Because rangelands, riparian areas, and streams are 

extremely diverse (Sayre et al. 2012, Swanson et al. 2015), the guideline explicitly 

recognizes that not all indicators are appropriate to every situation (Bryant et al. 2006, 

Clary and Leininger 2000). The new guideline specifies that only indicators and 

indicator values appropriate to a particular site should be used. In addition, indicators 

and associated values are to be selected, prescribed and adjusted based on site-specific 

conditions (such as natural site potential, similarity of existing conditions to desired 

conditions, ability of the area to resist livestock impacts and to recover once disturbed).

215. Concern Statement: The Forest Service should consider lowering utilization rates to 

protect ecological integrity.

Response: The proposed riparian forage utilization rates are based on the Watershed 

Condition Class, which should reflect a lower allowable use along streams in less than 

proper functioning condition. Upland forage utilization rates are less than the 1990 

Forest Plans.

216. Concern Statement: The Forest Service should modify guideline RNG-2 G-44 to 

manage for a minimum residual stubble height of six inches where compatible with the 

utilization standard. 

Response: The riparian grazing guidelines have been updated in the Forest Plans and 

Final Environmental Impact Statement to reflect values based on the watershed 

condition; therefore, if the watershed condition is not properly functioning, a higher 

stubble height would be prescribed. Stubble heights are collected along the greenline, 

whereas percent forage utilization is collected on the floodplain. The two measurements 

are not interchangeable. The Forest Service does not collect percent allowable use on the 

greenline, nor stubble heights in the floodplain. Each are key forage species specific and 

identified on the monitoring forms. 

217. Concern Statement: The Forest Service should monitor utilization with a science-based 

protocol that measures leader growth intervals throughout the growing season and 

compares utilization levels to reference vegetation. 

Response: The utilization wheels that are used to collect percent forage use by species 

are based on height-weight curves for each species. Visual estimates are only used to 

determine if allowable use is nearing, and if actual measurements need to be collected if 
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required. These are annual tools and are not used to determine a condition or long-term 

trend in vegetation. 

Grazing: Water Quality

218. Concern Statement: The Forest Service should deter water pollution from nonpoint 

sources, primarily bacterial contamination from livestock grazing, to ensure the water 

quality requirements of the Clean Water Act and the National Forest Management Act.

Response: The Forest Service must follow all laws, regulations, and policy direction, 

including the Clean Water Act, National Forest Management Act, State regulations, and 

Forest Service handbook and manual direction. Livestock are generally excluded from 

water sources used primarily for human consumption, including designated municipal 

watersheds and public source watersheds identified by Oregon Department 

Environmental Quality and Washington Department of Ecology. By law, livestock 

grazing is an allowed use and livestock watering is a state-designated beneficial use of 

water in all subbasins in the Blue Mountains. 

As of 2012, the most recent year of the 305(b) report for Oregon, lists 3,244 miles of 

streams on the three National Forests as water quality limited. Included in this total are 

1,493 stream miles on the National Forests listed for stream temperature, 293 stream 

miles were listed for sedimentation, 65.6 miles were listed for total coliform and 0.6 

miles were listed for fecal coliform, out a total of approximately 31,000 stream miles 

(including the HCNRA). As of 2012, water quality limited streams are listed in three 

categories, as follows:

♦ Category 4A, water quality limited, total maximum daily loads approved (1,557 

miles)

♦ Category 4B, water quality limited, not a pollutant, (460 miles)

♦ Category 5, water quality limited, 303(d) list, total maximum daily loads needed. 

Total maximum daily loads are reports prepared by designated State agencies 

(Department of Environmental Quality in Oregon and Ecology in Washington) that 

identify the level of pollutants in a waterbody that can be allowed while still meeting 

State-designated water quality criteria, and any measures needed to reduce a specific 

pollutant. The role of the Forest Service is to implement the actions identified in the total 

maximum daily loads, if any, that are applicable to National Forest System lands. On 

national forests in Oregon, this is accomplished by the development and implementation 

of water quality restoration plans once total maximum daily loads are completed for a 

given subbasin. Long-term condition and trend monitoring of rangeland and riparian 

vegetation shows improvement in most areas, but not in all. Desired conditions may not 

have been reached within the last planning period from 1990 to present. The Draft and 

Final Environmental Impact Statements developed desired conditions and goals, as well 

as standards and guidelines to monitor progress toward attainment of desired conditions. 

We acknowledge livestock grazing is one of many activities that may affect water 

quality. These effects are discussed in the Final Environmental Impact Statement in 

Volume 1. There is a portion of the “Land Uses Affecting Watershed Function” section 

devoted to livestock grazing, and watershed function is also mentioned throughout the 

section “Issue 3: Livestock Grazing and Grazing Land Vegetation.”
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Grazing: Wildlife 

219. Concern Statement: The Forest Service should take a hard look at the impacts of 

livestock grazing on conservation of listed and sensitive species and should not assume 

that wildlife needs can be met outside of the allotments. 

Response: The analysis of effects to surrogate wildlife species in the Final 

Environmental Impact Statement discusses impacts to wildlife from the varying levels of 

grazing proposed in each alternative. 

220. Concern Statement: The Forest Service should not reduce animal unit months to 

protect wild ungulates. 

Response: The only situation where animal unit months could be reduced is where 

bighorn sheep may begin to occupy an active sheep allotment. The Forest Service is 

directed to provide viable habitat for bighorn sheep and must ensure separation between 

the two species.

221. Concern Statement: The Forest Service should manage for desired conditions for sagegrouse rather than impractical, politically determined utilization levels. 

Response: Sage-grouse direction changed between the Draft and Final Environmental 

Impact Statements. See Appendix A of the Final Environmental Impact Statement for 

sage-grouse standards and guidelines.

222. Concern Statement: The Forest Service should not allow fence construction within one 

mile of known sage-grouse leks and seasonal high-use areas nor should fence 

construction on the crest of low hills be authorized unless the fence is marked with antistrike markers. 

Response: Guideline GRSG-LG-GL-038 addresses fence construction: “Fences should 

not be constructed or reconstructed within 1.2 miles from the perimeter of occupied leks, 

unless the collision risk can be mitigated through design features or markings (e.g., 

mark, laydown fences, or other design features).” 

223. Concern Statement: The Forest Service should loosen Range Guideline 8 because 

historic livestock turnout may not effect sage-grouse activity. 

Response: Range Guideline 8 has been replaced with Guideline GRSG-LG-GL-037: 

“During the breeding and nesting season (March 1 to June 15), trailing livestock through 

breeding and nesting habitat should be minimized. Specific routes should be identified, 

existing trails should be used, and stopovers on active leks should be avoided.” This 

guideline will minimize impacts to breeding sage grouse while still accommodating 

livestock grazing. 

Range: Feral Horses

224. Concern Statement: The Forest Service should support management of feral horses due 

to their impact on grassland habitats and should work with State agencies to achieve 

desired outcomes.

Response: The Malheur National Forest is updating the 2007 Management Plan for the 

Murderers Creek herd. The desired condition is described as “A viable, free-roaming 

wild horse herd (consistent with the desire of the herd management plan in effect at the 

time of project-level planning) that is genetically diverse and is in ecological balance 

with other approved multiple uses is present within the Murderers Creek Wild Horse 
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Territory. In concert, this leads toward stable or improving habitat conditions.” 

Management actions for wild or feral horses will be described in that plan. 

225. Concern Statement: The Forest Service should stop all management activities to 

control feral horse populations as their impact to rangeland values is minimal, 

particularly as compared to cattle.

Response: The Malheur National Forest is updating the 2007 management plan for the 

Murders Creek herd. The desired condition is described as “A viable, free-roaming wild 

horse herd (consistent with the desire of the herd management plan in effect at the time 

of project level planning) that is genetically diverse and is in ecological balance with 

other approved multiple uses is present within the Murderers Creek Wild Horse 

Territory. In concert, this leads toward stable or improving habitat conditions.” 

Management actions for wild or feral horses will be described in that plan. 

Lands and Special Uses 

Land and Special Uses: Land Acquisition

226. Concern Statement: The Forest Service should not acquire additional lands because it 

cannot adequately manage existing lands and it wouldn’t support economic well-being. 

Response: Land transactions play a direct and indirect role in management and in 

resources use through increased manageability of lands made possible through 

acquisition and disposal. The Forest Service’s existing legislative authorities provide 

them with the tools and safeguards to discharge their responsibility to the public for the 

acquisition, disposal, and prudent administration of the National Forest System lands 

(see Appendix B: Laws and Regulations Relevant to Forest Planning for a partial listing 

of the applicable statutes).

227. Concern Statement: The Forest Service should include plan language that encourages 

the acquisition of as much suitable private land as possible, with a focus on inholdings, 

adjacent private lands, the Nez Perce National Historic Trail, and the Oregon National 

Historic Trail sections. 

Response: The revised Forest Plans contain desired conditions and guidelines to support 

landownership adjustment by purchase, exchange, or other authority to improve 

management of the Blue Mountains national forests. As stated in the desired condition: 

“Priorities for land acquisition include non-federal inholdings within congressionally 

designated areas, when landowners are willing sellers and the property will enhance the 

values of the congressionally designated areas, and acquiring lands support known 

populations of threatened, endangered, proposed, or sensitive species.” The desired 

condition also prioritizes acquisitions, conveyances, and land exchanges that resolve and 

improve fragmented federal and non-federal land ownership and benefit local 

communities. The guideline in the revised Forest Plans supports this framework and 

states: 

LO-2G Landownership adjustments should emphasize the following objectives: a) 

acquisition to meet identified resource management needs, b) acquisition 

contributing to consolidation that reduces administrative problems and costs 

and further enhances public use, and c) conveyance of land better suited for 

non-federal ownership. 
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Land and Special Uses: Land Disposition

228. Concern Statement: The Forest Service should not sell or dispose of any federal lands. 

Response: As noted above, the Forest Service’s existing legislative authorities provide 

them with the tools and safeguards to discharge their responsibility to the public for the 

acquisition, disposal, and prudent administration of the National Forest System lands. 

Land acquisitions, exchanges, and conveyances would be evaluated at project level 

planning and comply with the National Environmental Policy Act including public 

involvement and participation and tribal consultation.

Land and Special Uses: Land Ownership

229. Concern Statement: The Forest Service should manage lands near boundaries with 

private lands to prevent impacts to private lands and to provide access, such as through 

easements, temporary special use access, and utility corridors. In addition, the Forest 

Service should partner with State and private interests to address such issues and to 

address forest, fish and wildlife issues across land ownership boundaries. 

Response: Multiple goals in the Forest Plans acknowledge the challenges and 

opportunities presented by resource considerations that span across national forest 

boundaries and adjoin other Federal, State, and private land ownership. This principle is 

established in the Forest Plans and identified in the Determination for the Need to 

Establish or Change Management Direction. Goal 1.1.5 – Aquatic Habitat Function 

recognizes the importance of high quality habitat regardless of type or ownership. 

Similarly, Goal 1.4.1 – Wildland Fire states, “Partnerships with other countries, 

agencies, States, Tribes, local governments, and landowners maximize wildfire response 

capabilities and meet multiple land management objectives across ownership 

boundaries.” Goal 3.2 – Land Ownership notes there is national emphasis on open space 

preservation, protecting the most ecologically and socially important lands, conserving 

working lands as sustainable forests and grasslands, and working with communities and 

private land owners to preserve and maintain existing open space (USDA Forest Service 

2007). 

The Forest Plans similarly recognize the importance of maintaining access to National 

Forest System lands. Goal 2.5 – Roads and Trails Access emphasizes continued right-ofways and easements to provide adequate and legal access to National Forest System 

lands; cooperative road agreements with states and counties to maintain and provide a 

seamless public road system to access private, state and public lands; and that the 

jurisdiction of county, state, and local access roads is appropriate to ensure management 

objectives are met for both private and state lands. 

The Blue Mountain national forests have developed a strong collaborative relationship 

between the Forest Service, Oregon Department of Forestry, Oregon Department of Fish 

and Wildlife, and the Natural Resources Conservation Services, and honors our 

participation in the formal collaborative groups throughout Eastern Oregon and 

Southeastern Washington. These collaborative relationships offer opportunity to apply 

compatible vegetation and fuels treatments, wildlife management, and watershed 

restoration across forest boundaries. Projects conducted under the National Cohesive 

Wildfire Strategy offer an example of project-level planning that includes Bureau of 

Land Management, State, and private lands, to seek national, all-lands solutions to 

wildland fire management issues, and similar project-level actions would continue under 

the revised Forest Plans.
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Management Areas

MA 2B: Research Natural Areas

230. Concern Statement: The Forest Service should not designate research natural areas. 

These areas need to be managed rather than serving as de facto wilderness areas. The 

research natural areas standards that limit mining exploration, development and removal 

of common mineral materials should be dropped. 

Response: As stated in the Forest Service’s planning regulations at 36 CFR 219.25 – 

Research natural areas (1982), “Forest planning shall provide for the establishment of 

research natural areas. Planning shall make provision for the identification of examples 

of important forest, shrubland, grassland, alpine, aquatic, and geologic types that have 

special or unique characteristics of scientific interest and importance and that are needed 

to complete the national network of research natural areas.” Research natural areas are 

available for research, study, observation, monitoring, and educational activities, uses 

that typically are non-destructive and non-manipulative. Management Area 2B – 

Research Natural Areas, generally comprise less than 1 percent of the planning area and 

do not detract significantly from management activities associated with General Forest 

allocations: specifically, Management Area 2B comprises 0.6 percent of the Malheur 

National Forest, 0.8 percent of the Umatilla National Forest, and 0.5 percent of the 

Wallowa-Whitman National Forest. Activities proposed within or adjacent to 

Management Area 2B lands would be evaluated through project level planning and 

comply with the National Environmental Policy Act including public involvement and 

participation.

MA 2C: Botanical Areas

231. Concern Statement: The Forest Service should not designate botanical areas because 

they limit other uses, including silvicultural treatments, removal of common mineral 

materials, firewood collecting, and utility corridors. Moreover, the Forest Service has no 

authority to create such management areas. 

Response: The revised Forest Plans comply with and are constructed through existing 

regulatory frameworks including law, regulation, and policy. The Forest Service Manual 

defines botanical areas as “a unit of land that contains plant specimens, plant groups, or 

plant communities that are significant because of their form, color, occurrence, habitat, 

location, life history, arrangement, ecology, rarity, or other features” (Forest Service 

Manual 2372.05). Designation of such areas, as outlined in the set of manual direction, 

states: “If a decision in the forest plan recommends designation, include management 

direction in the plan or in an amendment to the plan later. Except for those areas 

approved by the Secretary, approval by the Regional Forester of the forest plan 

constitutes designation of the area” (Forest Service Manual 2372.2). 

Management Area 2C – Botanical Areas total 2,000 acres with the planning area, 

representing 0.04 percent of the planning area. This relatively small amount of land 

allocation does not detract from other management activity conducted within other 

general forest areas. Activities proposed within or adjacent to Management Area 2C 

lands would be evaluated through project-level planning and comply with the National 

Environmental Policy Act including public involvement and participation.
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MA 2E: Historical Areas

232. Concern Statement: The Forest Service should list historical resources from the

National Historic Register in its table of historical areas, and these areas should be 

designated Management Area 2E: Historical Areas. 

Response: The areas that are specifically managed to protect cultural resources are 

allocated to Management Area 2E – Historical Areas, and may or may not contain those 

resources listed on the National Register of Historic Places. Cultural resources in other 

locations outside of Management Area 2E are protected through existing laws, 

regulations, policies, and existing agreements with the Oregon and Washington State 

Historic Preservation Offices. Evaluating cultural resources for their National Register 

of Historic Places eligibility is not conducted as part of forest plan revision and is 

usually conducted as part of project-level planning and site-specific analysis that comply 

with the National Environmental Policy Act and the National Historic Preservation Act, 

and includes public involvement and participation and Tribal consultation.

233. Concern Statement: The Forest Service should turn over all historic areas and 

resources to an organization like the Oregon State Historic Preservation Office for 

management because managing historic resources is not within the Forest Service 

mission and they don’t have the required expertise. The Forest Service should provide 

explanation as to why designated lands qualify to be Historical Areas. 

Response: There currently is no legal authority to transfer lands, specifically historic 

areas and resources, to the Oregon or Washington State Historic Preservation Office for 

management. The U.S. Congress provides the Forest Service a charter to preserve and 

steward historic properties through the National Historic Preservation Act of 1966. The 

Forest Service strives to meet this mandate through heritage program management to 

ensure historic properties are preserved, and these properties may inspire and benefit 

present and future generations. 

Individual State Historic Preservation Offices were established after passage of the 

National Historic Preservation Act in 1966. Their role is to advise and assist Federal 

agencies in reviewing potential effects from federally assisted projects. As stated in 36 

CFR 800.2: “The State Historic Preservation Officer reflects the interests of the State 

and its citizens in the preservation of their cultural heritage. In accordance with section 

101(b)(3) of the act, the State Historic Preservation Office advises and assists Federal 

agencies in carrying out their section 106 responsibilities and cooperates with such 

agencies, local governments and organizations and individuals to ensure that historic 

properties are taken into consideration at all levels of planning and development.” 

The description and background section for Management Area 2E, Historical Areas, 

included in the Forest Plans provides a discussion of the types of resources that are 

allocated to this management area. 

234. Concern Statement: The Forest Service should use forest planning as a way to identify 

areas for cultural resource management so tribes aren’t required to consult on every 

single NEPA project. This is particularly relevant on the Wallowa-Whitman National 

Forest where no historical areas have been identified. 

Response: The areas that are specifically managed to protect cultural resources are 

allocated to Management Area 2E – Historical Areas. Cultural resources in other 

locations are protected through existing laws, regulations, policies, and existing 

agreements with the Oregon and Washington State Historic Preservation Offices.
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Identifying archaeological sites, traditional cultural properties, and properties of 

religious and cultural significance to tribes includes consultation with the affected tribes, 

and while these efforts are completed at site-specific and project-level analysis, site and 

resource identification processes may be developed outside of the forest planning 

process to better facilitate pre-planning in advance of project development.

MA 2F: Scenic Byways and All-American Roads and MA 2G: 

Nationally Designated Trails

235. Concern Statement: The Forest Service should transfer Scenic Byways and AllAmerican Roads to the State of Oregon or the appropriate county as they can be 

maintained with lower costs that way. The Forest Service should consider adding the 

Nez Perce National Historic Trail and the Oregon National Historic Trail auto tour 

routes to this designation.

Response: There currently is no legal authority to transfer lands, specifically Scenic 

Byways and All-American Roads, to the State of Oregon for management. Scenic 

Byways and All-American Roads are established by Oregon Administrative Rules and 

Title 23, Section 162 of the United States Code, respectively. These programs represent 

grass-root collaborative efforts to help recognize, preserve and enhance selected roads 

throughout the United States, and as stated in the Oregon Administrative Rules (734-

023-0010), the goals and objectives of the program “create a comprehensive statewide 

multi-agency program to identify Oregon’s most outstanding scenic transportation 

corridor.” The Blue Mountains national forests participate in this “multi-agency” 

partnership through Scenic Byway Committee membership, and strive to preserve, 

protect, enhance, interpret, and promote the intrinsic qualities of designated byways. 

Auto tour routes associated with the Nez Perce National Historic Trail and the Oregon 

Trail National Historic Trail are discussed in Management Area 2G – Nationally 

Designated Trails as these routes are considered components of these nationally 

recognized trails. 

236. Concern Statement: The Forest Service should develop standards and guidelines for 

the Scenic Byways and All-American Roads Management Area (2F) and Nationally 

Designated Trails Management Area (2G).

Response: Based on internal reviews of the Forest Plan and Environmental Impact 

Statement, and on public concerns and comments, the following guidelines were 

developed for Management Area 2F – Scenic Byways and All-American Roads and 

Management Area 2G – Nationally Designated Trails. These guidelines, combined with 

the stated desired conditions for each management area, help inform future project-level 

development and site-specific analysis 

MA2F-1G The desired landscape character of the area should be retained or 

enhanced. 

MA2F-2G Visual impacts from vegetation treatments, recreation uses, rangeland 

developments, and other structures should blend with the overall 

landscape character along scenic byways.

MA2F-3G Signs, kiosks, and other exhibits should provide interpretive, education, 

and safety information along scenic byways and in adjacent recreation 

sites.
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MA2G-1S The Nez Perce National Historic Trail shall be managed consistently with 

the guidance in the Nez Perce National Historic Trail Comprehensive 

Management Plan (USDA Forest Service et al. 1990). 

MA2G-2S The Nez Perce National Historic Trail shall be managed as a 

nonmotorized route for primitive hiking and horseback riding for trail 

segments that are not identified as auto tour routes.

Activities proposed within or adjacent to Management Areas 2F and 2G would be 

evaluated through project level planning and comply with the National Environmental 

Policy Act including public involvement and participation. 

Mining 

Mining: Authorities and Law 

237. Concern Statement: The Forest Service should comply with the National Mining and 

Minerals Policy Act of 1970 and General Mining Act of 1872 to facilitate the 

development of mineral resources and provide for open access and occupation of lands 

for prospecting and developing minerals. 

Response: The policy of the Forest Service is to honor and protect the right of the 

public to prospect, mine, and develop valuable minerals under the mining laws of the 

United States. The Organic Act of 1897 allows for these rights to be exercised within the 

national forests subject to the rules regulating the national forests.

238. Concern Statement: The Forest Service should clarify why it believes 30 U.S.C. 

section 21(a) applies to the Department of Agriculture. Others suggested the Forest 

Service should amend the plans to consider economics and comply with 30 U.S.C. 

sections 21(a), 1801 and 1803; 43 U.S.C.; 16 U.S.C. sections 428, 475, 482, 528, and 

551; and Executive Order 12630. 

Response: The Organic Administration Act of 1897 (16 U.S.C. 473-475, 477-482, 551) 

authorizes the Secretary of Agriculture to issue rules and regulations for the use and 

occupancy of the National Forests and to protect them from unnecessary environmental 

impacts. The Multiple Use Mining Act of 1955 (30 U.S.C. 611-615) authorizes the 

Forest Service to restrict mining operations on National Forest System lands to only 

those uses reasonably incident to mining and in a manner that minimizes adverse 

environmental impacts. Regulations through which the rules and procedures for use of 

National Forest System lands in connection with United States mining laws are found in 

36 CFR 228, Subpart A. Further, the Forest Service is required by law to prevent or

eliminate unauthorized use of the national forests.

239. Concern Statement: The Forest Service should describe minerals using the three lawful 

categories of mineral classes. 

Response: The categories locatable, leasable, and saleable were used in the Proposed 

Forest Plan and Draft Environmental Impact Statement, are used in the Final 

Environmental Impact Statement and Final Forest Plans.

240. Concern Statement: The Forest Service should clarify that when a mineral withdrawal 

occurs, mining operations on claims that predate the withdrawal may continue. In 

addition, all lands not lawfully withdrawn from mineral exploration or development 

must remain open to such use. If recommending a withdrawal, the value of the minerals, 
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and the loss to the local, state and national interests by precluding mining activity should 

be calculated.

Response: This was stated in the Draft Environmental Impact Statement and clarified in 

the Final Environmental Impact Statement. In general, mining may continue in areas 

withdrawn from mineral entry if a valid mineral claim exists prior to the date of the 

withdrawal. Mining activity in withdrawn lands is still subject to an approved plan of 

operation and may require a special use permit depending on the type of operation and 

where it is located.

The Draft Environmental Impact Statement stated that lands withdrawn from mineral 

entry cannot be utilized for mining “subject to valid existing rights.” This means that 

locatable mineral development can occur in wilderness areas, wild river corridors, areas 

of unique and special characteristics, and other lands withdrawn from mineral entry, 

provided valid existing rights have been determined. The Draft and Final Environmental 

Impact Statements also state, “. . . all other National Forest System lands would be 

classified as generally suitable for locatable mineral development.” 

Mining: General

241. Concern Statement: The Forest Service should protect the mining heritage of Baker, 

Grant, and Malheur Counties. Likewise, the Forest Service should recognize the 

importance of mining and mining reclamation to social well-being (Goal 2). 

Response: Mining laws of the United States specify the right to prospect, develop, and 

mine valuable minerals. The Organic Act of 1897 allows these continued rights as long 

as the rules regulating use of the national forests (36 CFR 228) are followed. Forest 

Service policy is to protect authorized uses granted by these statutory rights but the 

agency is also required by law to prevent and eliminate unauthorized use. 

The Blue Mountains Revised Forest Plans discusses the social and economic importance 

of mineral and energy resources on the National Forests under Goal 3 (economic wellbeing). The Forest Plans identify as a desired condition, “Exploration, development, and 

production of mineral and energy resources contribute to the social and economic needs 

as well as local communities, and are conducted to minimize adverse environmental 

effects on national forest surface resources. Reasonable access is provided to valid 

existing mineral claims, as well as for exploration and production of leasable and 

locatable mineral resources. Congressionally designated wilderness, wild rivers, 

municipal watersheds, or other areas of important natural or cultural resource value are

withdrawn from mineral entry, subject to valid existing rights.” (Revised Forest Plans, 

Goal 3).

242. Concern Statement: The Forest Service should incorporate goals to encourage mining 

and preserve access for mining exploration and production. 

Response: It is Forest Service policy to honor and protect the right of the public to 

prospect for, develop, and mine valuable minerals. All plan revision alternatives include 

a desired condition that mineral and geological resources contribute to the social and 

economic needs of the local communities as well as the Nation.

243. Concern Statement: The Forest Service should support mining by defining "significant 

surface disturbance" as over 5 acres and “mechanized earthmoving mining equipment” 

as being able to move greater than 20 yards of material per operational hour. The Forest 

Service should automatically approve all Notice of Operations if not approved within 15 
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days and should approve all Plans of Operation within 30 days, unless an EIS is 

required. Others suggested an objective of approving Notice of Operations or Plans of 

Operation within 90 days or 1 year. 

Response: “Significant disturbance can only be determined through fair, reasonable, and 

consistent evaluation” of proposed plans of operation and is made on a case-by-case 

basis as described in the Forest Service Manual (FSM 2817.11) and 36 CFR 228.4. The 

time needed for review and approval of proposed plans of operation varies with the 

nature of the proposed plan and the resources that may be affected. Current Forest 

Service regulations allow 30 days, with possible extension not to exceed 60 additional 

days (36 CFR 228, Part A).

244. Concern Statement: The Forest Service should include mining in the suitability matrix 

and should add locatable minerals to the goods and services discussion. It should also 

include an overview of the management challenges related to mining. 

Response: The suitability matrix describes the suitability of various management 

activities within each management area under the proposed Forest Plans. The mining 

laws of the United States create exceptions in several instances, because Federal lands 

are available for mining unless they are specifically withdrawn from mineral entry. All 

lands not specifically withdrawn from mineral entry are available for exploration, 

prospecting, and development by the mining laws of the United States. For example, 

designated wilderness areas are withdrawn from mineral entry when they are designated, 

but the exercise of mineral rights that exist at the time of designation are allowed. 

Similarly, rivers designated as wild under the Wild and Scenic Rivers Act are withdrawn 

from mineral entry, subject to the same exercise of valid existing rights, but rivers 

designated as scenic are recreational under the Act and are not withdrawn, but activities 

that may affect the scenic or recreational values for which a given river is designated 

may be limited under the Act. Other areas that may be suitable for mining may be 

withdrawn from mineral entry if mining is not compatible with the protection of 

resource values identified for a specific area and this may occur regardless of the 

management area designation.

Mining is included in the discussion of goods and services (Section 3.3 in the Forest 

Plan). However, income generated from mining operations in the Blue Mountains cannot 

be verified unless it is done by a company that reports its earnings. It is primarily for this 

reason that the discussion of locatable minerals is limited in the goods and services 

section.

The discussion in the Final Environmental Impact Statement related to mining is limited 

to the lands available for mining of locatable minerals and the laws and regulations that 

apply. Mining is allowed on the National Forests in accordance with the mining laws of 

the United States, but the laws establishing the National Forests give the agency the 

authority and obligation to manage and protect surface resources. Subsequent Federal 

and State laws provide for the protection of threatened and endangered species and 

protection of water quality. 

Mining: Impacts

245. Concern Statement: The Forest Service should acknowledge that heavy metals and 

acid discharges do not occur at levels that adversely affect fish or human health. Natural 

background levels of mercury should be noted. 
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Response: The Forest Service does not have the information to make such a claim. 

Whether heavy metals exist in high enough concentration to be harmful to aquatic life or 

human health depends on the concentration of metals, the determination of which would 

require a specific analysis and comparison to State water quality criteria. Low pH, by 

itself may be an indicator that metals are present but not necessarily which metals, 

although this can often be inferred from the type of mineral deposit, if known. Low pH 

alone may be harmful to aquatic life depending on the duration of exposure and the 

species that are affected. The Final Environmental Impact Statement acknowledges that 

there are natural sources of metallic mercury in the Blue Mountains, but mercury is also 

recognized as a substance with no known physiological function and one that can be 

harmful at very low concentrations with prolonged exposure.

246. Concern Statement: The Forest Service should include standard MM-1 to avoid 

adverse impacts to listed species and designated critical habitat from mining operations. 

Response: Standard MM-1 is included in the preferred alternative as Standard MM-5. 

Three additional guidelines and one additional standard related to minerals management 

are contained in the preferred alternative intended for the protection of water quality and 

habitat for aquatic and riparian-dependent species, location of mine waste, location of 

support facilities, structures, and roads, and the implementation of best management 

practices.

Mining: Motorized Access

247. Concern Statement: The Forest Service should create exceptions for mining in areas 

unsuitable for motor vehicle use. Likewise, an exception for new road construction for 

mining operations should be noted and cross-country travel for prospecting should be 

allowed. 

Response: Such an exception might be granted in response to a specific request, and 

evaluation of the basis and demonstrated need on which the request is based. Such an 

analysis is necessarily site-specific and is outside the scope of decisions made in a forest 

plan. Nothing currently prevents such a request from being made and evaluated on its 

merits. By regulation, the request for a road may be granted as part of an approved plan 

of operations, and is subject to analysis of the need and the proof of a valid mineral 

claim. 

Mining: Wildlife

248. Concern Statement: The Forest Service should recognize that mining may benefit fish 

habitat and other uses. 

Response: In general, the adverse effects of suspended sediment and turbidity on 

salmonid fishes are well known. Clean gravel for spawning habitat is a known 

requirement of all salmonids, but it is not clear that this is outweighed by the effects of 

fine sediment, the downstream transport and eventual deposition of fine sediment, or the 

disruption of bed sediments that is typically associated with placer mining.
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Planning 

Planning: 1982 Rule

249. Concern Statement: The Forest Plan revision should remove its inclusion of 

“ecological integrity” because the concept is from the 2012 Planning Rule and is not 

legally defensible under the 1982 rule. If the plan is going to blend the use of the two 

planning rules, it should declare which rule is being used when in the document. 

Response: The Blue Mountains National Forest Plans have been revised under the legal 

framework of the National Forests Management Act and the provisions of the 1982 

Planning Rule, as allowed by the 2012 Planning Rule language at 36 CFR 129.17 (b)(3). 

The Forest Service followed requirements for revising land management plans (forest 

plans), as required by the Forest and Rangeland Renewable Resources Planning Act of 

1974, as amended by the National Forest Management Act of 1976. The Act reinforces 

the multiple use purposes of the National Forest System as specified in the Forest and 

Rangeland Renewable Resources Planning Act and the Multiple Use Sustained Yield 

Act. The National Forest Management Act specifies that forest plans provide for 

“multiple use and sustained yield of the products and services obtained therefrom in 

accordance with the Multiple-Use Sustained-Yield Act of 1960, and in particular, 

include coordination of outdoor recreation, range, timber, watershed, wildlife and fish, 

and wilderness.” 

“Multiple use” is defined in the implementing regulations for the 1982 planning rule as 

“The management of all the various renewable surface resources of the [National Forest 

System] so that they are used 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 land 

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, consistent with the Multiple-Use SustainedYield Act of 1960 ( 16 U.S.C. 528- 531).” 

“Sustained-yield of products and services” is defined in the implementing regulations 

for the 1982 planning rule as “the achievement and maintenance in perpetuity of a highlevel annual or regular periodic output of the various renewable resources of the 

National Forest System without impairment of the productivity of the land.” 

Ecological integrity is defined as “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). The Forest Service uses 

the concept of ecological integrity as a means to achieve the goals set forth in both the 

National Forest Management Act and Multiple-Use Sustained-Yield Act to manage the 

forest resources in a “harmonious and coordinated” manner, “without impairment of the 

productivity of the land.” 

250. Concern Statement: The Forest Service should incorporate analysis of economic 

benefits and costs, opportunity costs, and cost-efficient alternatives as required by the 
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1982 Planning Rule (36 CFR 219.12(f)). The plan also fails to show, per the 1982 rule, 

the impact on present net value.

Response: The planning record contains a cost-benefit analysis that estimates the 

present net value of Forest Service expenditures and receipts over the life of the forest 

plans. A more detailed cost-benefit analysis that addresses, for instance, costs per unit of 

treatment or the cost of closing roads, cannot be estimated with available information. 

As a plan revision, this document does not contain site-specific management actions. 

Treatment costs or road costs cannot be known without site-specific information. More 

detailed cost-benefit analysis will be included in subsequent project-level environmental 

analysis documents where economic efficiency is identified as an issue.

251. Concern Statement: The Forest Service should adjust its limited timber harvest 

suitability that violates the 1982 Planning Rule, requiring “[e]ach sale schedule shall 

provide for a forest structure that will enable perpetual timber harvest which meets the 

principle of sustained-yield and multiple-use objectives of the alternative” 36 CFR 

§219.16(a)(2)(iv). 

Response: The base timber harvest schedule in the alternatives are designed to maintain 

the long-term sustained yield capacity and to demonstrate a non-declining flow of 

sustainable forest products for the next five decades, consistent with the forest planning 

regulations. The one exception to this was Alternative E-Modified Departure. Because 

of the high degree of disparity between the desired conditions for susceptibility to 

insects and disease, forest vegetation, and fire regimes, compared to existing conditions 

of the forests, the Forest Service modified Alternative E as a “departure” alternative. 

Alternative E-Modified Departure’s harvest schedule was developed outside of the 

constraints of non-declining flow or the long-term sustained yield capacity. (See 

“Ecological Resilience,” “Forested Vegetation,” and “Insects and Diseases” sections of 

Chapter 3 in the Final Environmental Impact Statement). All of the alternatives except 

E-Modified Departure comply with requirements for non-declining flow.

Planning: Alternatives-Range

252. Concern Statement: The Forest Service must evaluate a reasonable range of 

alternatives, per Council on Environmental Quality and National Environmental Policy 

Act regulations. The agency did not do this as evidenced by its use of the same standards 

and guidelines in all action alternatives.

Response: The Council on Environmental Quality regulations (40 CFR 1502.14 (a)) 

require that agencies “Rigorously explore and objectively evaluate all reasonable 

alternatives,” not a “reasonable range” of alternatives. However, with eight alternatives 

considered in detail, we believe the Final Environmental Impact Statement presents a 

range of reasonable alternatives. Each alternative was designed to meet the purpose and 

need and address one or more of the issues. Many standards and guidelines do not vary 

among alternatives because they were designed to meet statutory obligations under the 

National Forest Management Act, Endangered Species Act, Clean Water Act, and other 

laws and regulations. Management area acreages and suitability for specific activities 

vary among the alternatives. Each alternative is described in Chapter 2 along with an 

explanation of how the alternative responds to the issues. For example, Alternative C 

was designed to take a largely passive approach to restoration, whereas Alternative D 

was designed to maximize outputs of goods and resources while minimally meeting 

requirements to conserve forest resources. With the exception of Alternative E-Modified 
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Departure, the key indicators for the other plan revision alternatives are intermediate 

between Alternative C and D. Tables 1, 2, and 3 in Chapter 2 of the Final Environmental 

Impact Statement summarize how the alternatives respond to the issues, as measured by 

the key indicators for each National Forest. Appendix A displays the full components of 

all alternatives.

253. Concern Statement: The Forest Service should include alternatives that reflect a more 

aggressive pace and scale of vegetation management. 

Response: The Forest Service received many comments about increasing the pace and 

scale of restoration on the National Forests to help prevent catastrophic fires, improve 

habitat for big game animals, and provide a flow of forest products to local mills to 

stimulate local economies. The Forest Service developed and analyzed two additional 

alternatives in the Final Environmental Impact Statement designed to support an 

increased pace and scale of restoration. Alternative-E Modified would maintain an 

overall level of harvesting similar to Alternative E, but would focus these harvest acres 

more intently on the portions of the dry upland forest with the greatest need for 

immediate treatment. This alternative would allow for considerable increases in the 

thinning of the dense-dry upland forest within 20 years while still being consistent with 

the sustainability principles of the non-declining flow rules. 

The Forest Service also developed Alternative E-Modified Departure, which is not 

bound to the non-declining flow or the long-term sustained yield capacity. Alternative EModified Departure was developed because of the high degree of disparity between the 

desired conditions for susceptibility to insect and diseases, forest vegetation, and fire 

regimes, compared to the existing conditions of the forests.

Planning regulations allow Alternative-E Modified Departure to temporarily waive the 

non-declining flow rules. Alternative-E Modified Departure was designed to thin 

essentially all of the acres of dense-dry upland forest located within the lands suitable 

for timber production within 20 years. When combined with additional restoration 

thinning that would occur on other lands that are suitable for harvesting, the AlternativeE Modified Departure would allow for thinning roughly 70 percent of the dense-dry 

upland forest acres that are available for harvest within the next 20 years.

254. Concern Statement: The Forest Service should develop and choose a pro-motorized 

recreation alternative, to conform to Public Law 91-190 that maintains existing levels of 

use. 

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. These designations are considered in a separate process that is completed 

under the Travel Management Rule (36 CFR 212). Access is analyzed in the Final 

Environmental Impact Statement and includes a range of alternatives that vary the 

amount of area (acres) that are rated suitable for either motorized or nonmotorized use, 

and rated for both summer and winter use. Subsequent analyses of projects under the 

Forest Plan will have site-specific data to show differences among project alternatives 

and their effects on motorized travel.

The revised Forest Plans do not make site-specific route decisions and do not intend to 

limit or reduce access. Where appropriate, motorized recreation opportunities may be 

maintained or expanded.

255. Concern Statement: The Forest Service should consider the alternative not constrained 

by budget—as represented by Alternative K—that was eliminated from consideration. 
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Each alternative should be analyzed with and without budget constraints. The 1982 

Planning Rule does not require constraining alternatives based on potential budgets. 

Response: The National Forest Management Act and its implementing regulations 

require the Forest Service to consider reasonable alternatives. The Forest Service 

eliminated Alternative K from detailed analysis because the assumption of an 

unconstrained budget under Alternative K is not reasonable. Both the Draft and Final 

Environmental Impact Statements include an explanation of why alternative K was 

eliminated from consideration (see Chapter 2, “Description of Alternatives Considered 

but Eliminated from Detailed Study”). Alternatives D, E, E-Modified, E-Modified 

Departure and F include reasonable budget assumptions although these exceed current 

budgets. Even so, national forest land management plans cannot commit the Federal 

Government to make additional budget allocations. 

256. Concern Statement: The Forest Service should fully consider Alternative A and include 

it in all comparisons and tables. 

Response: Chapter 2 and Appendix A of the Final Environmental Impact Statement 

describe the plan components for Alternative A. Tables 1, 2, and 3 in Chapter 2 detail

how the alternatives, including Alternative A, vary by alternative according to the key 

indicator measures. The effects of Alternative A are described in Chapter 3 – 

Environmental Consequences.

Planning: Best Available Science

257. Concern Statement: The Forest Service should use current, peer-reviewed science and 

not rely on dated studies to assess on-the-ground conditions. The use of non-relevant 

scientific information merits a need for a change in the assessment (FSH 1909.12 Chap 

20). When computer model outputs provide a 10- to 20-year estimate for a resource, the 

plan should explain how these estimates or assumptions were made.

Response: The Draft and Final Environmental Impact Statements and revised Forest 

Plans explain how scientific information has been compiled and used. The 

Environmental Consequences section in Chapter 3 of the Final Environmental Impact 

Statement identifies the methods used and references the scientific sources relied upon. 

This documentation identifies what information the Forest Service determined to be the 

best available scientific information, explains the basis for the determination, and 

explains how the information was applied to the issues considered. 

258. Concern Statement: The Forest Service should not use the dated 1997 Interior Basin 

Ecosystem Management Project (ICBEMP) research as “best available science” for the 

forest revision plan, in part, because the ICBEMP never had a final decision. 

Response: Although there was no final decision for Interior Columbia Basin Ecosystem 

Management Project, the project compiled valuable scientific information. Scientific 

studies conducted by the Interior Columbia Basin Ecosystem Management Project 

(Quigley et al. 1996, Quigley and Arbelbide 1997) were incorporated in the 

development of the revised Forest Plans and alternatives as directed in an interagency 

memorandum signed April 18, 2014 by the Deputy Regional Foresters in Forest Service 

Regions 1, 4, and 6; State Directors for the Bureau of Land Management in 

Oregon/Washington and Idaho; the Environmental Protection Agency Region 10; the 

Fish and Wildlife Service, Pacific Region; and NOAA Fisheries, West Coast Region. 

This memorandum is titled “The Interior Columbia Basin Strategy: A strategy for 
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applying the knowledge gained by the Interior Columbia Basin Ecosystem Management 

Project to the revision of land use plans and project implementation.” The Strategy 

provides principles that incorporate the science data and resource information developed 

by the Interior Columbia Basin Management Project, as well as more recent science, 

into land use plans (Forest Service land management plans and Bureau of Land 

Management resource management plans) and project implementation. The Strategy 

identifies key principles that are relevant to future planning efforts including an update 

of ecological principles. The Blue Mountains forest plans revision activities and 

products have been designed to be responsive to the guidance and expectations 

identified in the Strategy. For more information on the Strategy, including expectations 

for incorporating guidance from the Strategy in Forest Plan revisions, go to: 

https://icbemp.gov/html/ICBEMP_Frameworkmemorandum-and-strategy_2014.pdf

259. Concern Statement: The Forest Service should incorporate a variety of citations, 

provided from public comment letters, into the forest revision plan. 

Response: The Draft and Final Environmental Impact Statements and revised Plans 

explain how scientific information has been compiled and used. The environmental 

consequences in Chapter 3 of the Final Environmental Impact Statement identifies the 

methods used and references the scientific sources relied on. Where comment letters 

have included substantive comments and full and relevant scientific citations, the Forest 

Service has incorporated those citations that reflect the best-available science.

260. Concern Statement: The Forest Service should not require use of “best available 

science” for the forest revision plan because the National Forest Management Act and 

the National Environmental Protection Act do not require it, and case law allows the 

Forest Service to make natural resource decisions based on its discretion in weighing 

multiple-use objectives. 

Response: The Forest Service has an obligation under the National Environmental 

Policy Act to insure the scientific integrity of the discussions and analyses in 

environmental impact statements. This includes identifying the methodologies used and 

citing the scientific and other sources of information relied upon for conclusions in the 

Environmental Impact Statement (40 CFR 1502.24). The Draft and Final Environmental 

Impact Statements and Revised Forest Plans explain how scientific information has been 

compiled and used. Chapter 3, Environmental Consequences, in the Final Environmental 

Impact Statement identifies the methods used and references the scientific sources relied 

on to disclose the effects of the alternatives.

Planning: Budget

261. Concern Statement: The Forest Service should not approve the forest revision plan if 

funding is not available. The Forest Service should not blame the budget as to why it 

cannot accomplish the plan’s three goals—ecological, social, and economic.

Response: According to the National Forest Management Act and its implementing 

regulations, Forest Plans do not commit the Federal Government to make new budget 

allocations, nor may forest plans compel specific activities to occur, including 

monitoring, if funding is unavailable. A forest plan may be used to help develop budget 

proposals, which subsequently must be approved by Congress and signed into law by 

the President. National Forests in the Blue Mountains will continue to prioritize projects 

and activities, given available funding, to achieve progress toward desired conditions.
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262. Concern Statement: The Forest Plan should allow for achieving the desired condition 

at a faster pace and scale if budgets increase.

Response: Each alternative includes a predicted total sale program quantity for each 

National Forest. The total sale program quantity under Alternatives E-Modified and EModified Departure is significantly higher than current or recent harvest levels and 

would move toward desired conditions at a faster pace and larger scale than Alternative 

E. The Forest Service developed Alternative E-Modified Departure specifically to 

respond to this and similar comments. Each alternative has sufficient flexibility to 

accommodate increases in budgets for managing forests at a faster pace and scale.

Planning: Goals and Desired Conditions

263. Concern Statement: The Forest Service should establish desired future conditions 

linked to objectives or enforceable standards so that they will be more than aspirational 

guidance. 

Response: Plan components (goals, standards, guidelines, objectives) in each resource 

area work together to move the National Forests toward desired conditions. Based on 

public input and revised recommendations by resource specialists, we strengthened 

many plan components to be more specific and measurable. For example, to protect 

aquatic and riparian ecosystems, we strengthened relevant plan components based on 

best-available science and compiled them under a Blue Mountains Aquatic and Riparian 

Conservation Strategy (2018 ARCS).

264. Concern Statement: The Forest Service should not develop desired conditions that seek 

to achieve unattainable conditions, for example, in the 1.1.3 Wetland Function that seeks 

undisturbed surface and subsurface flow paths. 

Response: The Forest Service reviewed the desired conditions to ensure long-term 

feasibility. For the example cited in the above comment, the word “undisturbed” has 

been replaced with “functional” in Goal 1.1.3: Wetland Function, because disturbance 

can play a natural role in wetlands.

265. Concern Statement: The Forest Service should do more active management if it 

intends to achieve desired conditions. Failure occurs due to the emphasis on backcountry 

and wilderness management areas and unnecessary budget constraints. 

Response: In response to public input, the Forest Service developed a range of 

alternatives representing different levels of active management. Two additional 

alternatives, E-Modified and E-Modified-Departure, include an increase in active timber 

and vegetation management objectives.

266. Concern Statement: The Forest Service should provide timelines for the forest revision 

plan’s goals and desired conditions to hold Forest Service management accountable. 

Response: Objectives, rather than goals and desired conditions, are measurable timespecific statements expressing the desired rate of progress toward attainment of desired 

conditions. The Final Environmental Impact Statement, Appendix A and the revised 

Forest Plans explain that the objectives (as displayed in the tables) cover the first 10 

years of the plans, except where noted. 

267. Concern Statement: The Forest Service should improve its vague definition for 

“ecological integrity,” as part of the Goal 1 introduction, and note that the definition 
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differs from what is in the forest revision plan’s glossary. It should also improve its use 

of the terms “ecological function,” “ecological structure,” and “ecological processes.” 

Response: The Forest Service agrees that terms in the Environmental Impact Statement 

should be consistent with glossary definitions. The Forest Service has edited the 

definitions for the scientific terms expressed under Goal 1 to improve consistency and 

clarity. 

Ecological integrity is defined as “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) The Forest Service uses 

the concept of ecological integrity as a means to achieve the goals set forth in both the 

National Forest Management Act and the Multiple Use Sustained-Yield Act to manage 

the forest resources in a “harmonious and coordinated” manner, “without impairment of 

the productivity of the land.” 

268. Concern Statement: The Forest Service should not refer to Goal 1.12 Landscape 

Patterns, 1.13 Special Habitats, and 1.14 Snags and Down Wood as indicators of 

sustainability.

Response: The Forest Service has adjusted text related to Goal 1 (Promote Ecological 

Integrity) for landscape patterns, special habitats, and snags and down wood to say they 

are key components of healthy ecosystems in the Blue Mountains National Forests. 

Although the primary focus of these sections in Goal 1 is ecological integrity, the goal 

and the desired conditions are interrelated with the social and economic components of 

sustainability. Resources that contribute to ecological integrity are interrelated with 

Tribal interests and treaty-reserved resources. 

Planning: Laws, Regulations, Policy

269. Concern Statement: The Forest Service should minimize conflicts between revised 

Forest Plans and travel management decisions. The Forest Service should draft the travel 

management plan in conjunction with forest plan revision, and it should include plan 

elements that clarify how future travel management plans will tier to the forest plans. 

Response: The Forest Service is required to manage roads, trails, and areas consistent 

with the laws, regulations, and policies governing the National Forest transportation 

system, including the Travel Management Rule. Alternatives E-Modified and EModified Departure affirm this ongoing requirement based on current regional and 

national direction. Based on public input and recommendations by resource specialists, 

these alternatives include additional detail to address forestwide issues related to 

motorized uses, such as elk security intended to encourage elk use of public lands, and 

key watershed function.

The two planning processes—forest plan revision and travel management planning—are 

distinct and separate. In March 2015, direction was given by Jim Peña, Pacific 

Northwest Regional Forester, that directs the Blue Mountains National Forests to defer 

any additional work required under Subpart B of the Travel Management Rule until after 

the Blue Mountains Plan Revision is completed. In line with the Regional direction, the 

Wallowa-Whitman and Malheur National Forests have paused Subpart B analysis until 

the Forest Plan Revision is complete. The Forests completed Subpart A of Travel 
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Management Planning in the latter part of 2015. All three National Forests will continue 

to address natural resource concerns and public access needs as part of ongoing projectlevel decisions and forest restoration efforts, and base these analyses on existing 

regulation and the guidance contained in Forest Plans

The revised Forest Plans will provide programmatic direction for the National Forests 

for future planning and site-specific analysis. Travel Management Planning, as required 

under 36 CFR 212, provides for identification of a road system: “The minimum system 

is the road system determined to be needed to meet resource and other management 

objectives adopted in the relevant land and resource management plan (36 CFR 219)” 

(36 CFR 212.5). The Forest Service anticipates that future travel management planning 

would conform to these regulations, incorporating a science-based roads analysis at the 

appropriate scale, including broader “landscape-wide level” analysis. 

270. Concern Statement: The Forest Service should remove all references to road closures, 

new road construction, and a sustainable road system as all are beyond the scope of 

forest plan revision. Access issues and their environmental impacts should be addressed 

through travel management planning. 

Response: The National Forests will continue to operate under the revised Forest Plans 

consistent with applicable laws, regulations, and policies. The revised Forest Plans will

provide strategic direction and guidance to manage a variety of resources on the 

National Forests, including motorized routes and areas. The Forest Plans, on their own, 

will not open or close motorized routes and areas. Site-specific decisions on motorized 

routes and areas require additional analysis at the project level. Under the planning 

regulations (1982) the revised Forest Plans examine and analyze, programmatically, 

roads and the forest transportation system as it relates to management requirements, 

recreation resources, fish and wildlife resources, and mineral resources. No site-specific 

recommendations result from this analysis, and future travel management planning will 

provide detailed, site-specific analysis that is expected to conform to direction in the 

Forest Plans.

271. Concern Statement: The Forest Service should abide by Executive Order 11644 that 

requires the agency to minimize effects from motorized routes and from over-snowvehicles. Others suggested over-snow-vehicle use should be addressed in travel 

management planning. 

Response: The National Forests will continue to operate under the revised Forest Plans 

consistent with applicable laws, regulations, and policies. The revised Forest Plans will 

provide strategic direction and guidance to manage a variety of resources on the 

National Forests, including motorized routes and areas. The Forest Plans on their own 

will not open or close motorized routes and areas. Site-specific decisions on motorized 

routes and areas require subsequent site-specific analysis. Designating routes and areas 

for over-snow vehicles must comply with the agency’s travel management regulations 

(36 CFR 212), specifically Subpart C—Over-Snow Vehicle Use. The travel management 

process includes adhering to the National Environmental Policy Act guidance and 

includes opportunity for public involvement and participation. 

272. Concern Statement: The Forest Service should recognize the National Route 

Designation rule so that motorized recreationists retain existing motorized routes rather 

than seeing additional closures of routes. Likewise, the Forest Service should not limit 

road access because a variety of laws and regulations require that the public be able to 
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access public lands. The Forest Service should not compromise the human environment, 

per the National Environmental Policy Act, through the forest plan revision. 

Response: The National Forests will continue to operate under the revised Forest Plans 

consistent with applicable laws, regulations, and policies. The revised Forest Plans will 

provide strategic direction and guidance to manage a variety of resources on the 

National Forests, including motorized routes and areas. However, the Forest Plans on 

their own will not open or close motorized routes and areas. Site-specific decisions on 

motorized routes and areas require subsequent site-specific analysis. 

Subsequent to the adoption of the revised Forest Plans, historic uses of the national 

forest transportation system will be reviewed and analyzed through a site-specific 

analysis that will comply with the agency’s travel management regulations (36 CFR 

212). As stated in the Summary of the Travel Management Rule (Federal Register, Vol. 

70, No. 216, 2005), “The clear identification of roads, trails, and areas for motor vehicle 

use on each National Forest will enhance management of National Forest System lands; 

sustain natural resource values through more effective management of motor vehicle 

use; enhance opportunities for motorized recreation experiences on National Forest 

System lands; address needs for access to National Forest System lands; and preserve 

areas of opportunity on each National Forest for nonmotorized travel and experiences.” 

273. Concern Statement: The forest plan revision should explain how it defines “needs” of 

future generations and how those needs were determined. 

Response: The Forest Service does not attempt to determine what the specific needs of 

future generations would be. The Multiple Use-Sustained Yield Act (1960) provides for 

the sustainability of the multiple uses of natural resources in ways that presently best 

meet the needs of the public, while maintaining the long-term productivity of the land, 

such that the goods and services that flow from lands would be available to future 

generations. The analysis of “Economic and Social Well-Being” in Chapter 3 of the 

Final Environmental Impact Statement provides further discussion.

274. Concern Statement: The Forest Service should honor the intent of the National 

Environmental Policy Act to ensure “productive and enjoyable harmony between man 

and his environment” by preventing ecological damage rather than simply mitigating 

actions through the forest plan revision. 

Response: The Forest Service has developed the Blue Mountains Forest Plans 

consistent with the spirit and letter of the National Environmental Policy Act. Plan 

Components (such as goals, desired conditions, standards, and guidelines) have been 

developed to maintain the ecological integrity and long-term productivity of the land 

while honoring the sustainable multiple-use mandate of National Forests.

275. Concern Statement: The Forest Service should require a continuous supply of timber 

and resource commodities, per the Organic Act, the Multiple Use Sustained Yield Act, 

the National Forest Management Act, the Forest and Rangeland Renewable Resource 

Planning Act of 1974, and Public Law 86-517. 

Response: All alternatives except Alternative E-Modified Departure have been

developed to provide a non-declining or stable flow of wood products over time. The 

draft revised Forest Plan proposed increasing the timber volume objectives to roughly 

150 percent of their recent levels across the three National Forests. The Forest Service 

received many comments on the draft revised Forest Plan expressing a desire to increase 

the flow of forest products to local mills to stimulate local economies. As a result, two 
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additional alternatives, including a “departure” alternative, which is unconstrained by 

the non-declining flow requirement, were developed. The methodology behind the 

calculation of estimated timber yields has been re-evaluated and improved for the Final 

Environmental Impact Statement. The timber volume objectives of the agency preferred 

alternative, E-Modified, would represent an approximate doubling of the volume sold in 

recent years from the three National Forests.

276. Concern Statement: The Forest Service should comply with Executive Order 13575, 

Establishment of the White House Rural Council, which supports expanding outdoor 

recreational activities on public lands. 

Response: To avoid duplication, the Forest Plans do not repeat all existing laws, 

policies, and regulations that govern national forest management. However, the National 

Forests will continue to operate under the revised Forest Plans consistent with applicable 

laws, regulations, and policies. Executive Order 13575 established a White House Rural 

Council. Since its inception, the Council has advanced numerous policy initiatives that 

strive to make investments in rural America and are designed to promote job growth. As 

noted above, the National Forests will remain consistent with applicable policies, 

including those developed by the White House Rural Council. 

277. Concern Statement: The Forest Service should comply with Executive Order 13443, 

Facilitation of Hunting Heritage and Wildlife Conservation, particularly Section 2, when 

concerning actions that may affect hunting and fishing opportunities. 

Response: Executive Order 13443, along with other existing laws, regulations and 

policies, influenced the design and development of Forest Plan components (Final 

Environmental Impact Statement, Appendix A) for each plan revision alternative. 

Alternatives E-Modified and E-Modified Departure include new standards and 

guidelines to increase elk security and distribution across all seasonal ranges to 

encourage elk use of National Forest System Lands, thereby improving hunting 

opportunities. Similarly, plan components including desired conditions, standards, 

guidelines, management areas, and objectives for watershed function and riparian 

management areas, would promote improved water quality and overall stream 

conditions, thereby improving fishing opportunities. 

278. Concern Statement: The Forest Service should more fully assess its “no adverse 

effects” statement of forest revision plan actions on low-income populations, as related 

to Executive Order 12898, Federal Actions to Address Environmental Justice in 

Minority Populations and Low Income Populations, because the Blue Mountains forests 

encompass counties at or below the poverty level. The plan should present accurate 

population data and work with locals on the best mitigation strategies to minimize 

impacts, such as by retaining full access. 

Response: The Final Environmental Impact Statement “Economic and Social Wellbeing” section, Environmental Justice discloses how the alternatives may affect lowincome and minority populations. Relative to current management, only Alternative C 

was found to have the potential to disproportionately and adversely affect low-income 

and minority populations across the three socio-economic impact zones.

279. Concern Statement: The Forest Service should revise the forest plan to comply with 

the Migratory Bird Treaty Act. 

Response: The final plans comply with the Migratory Bird Treaty Act. The effects of 

the final revised Forest Plans and alternatives to migratory birds are analyzed in the 
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Final Environmental Impact Statement, Chapter 3, Environmental Consequences, in the 

Terrestrial Wildlife Species section.

280. Concern Statement: The Forest Service should explain how the forest plan complies 

with the Safe Drinking Water Act. 

Response: The Safe Drinking Water Act applies to public water systems that can be 

either community or non-community water systems, depending on the number of service 

connections or year-round users. The Forest Plans identify five municipal watersheds 

that are named as Management Area 2J and supply water to the communities of Long 

Creek, Canyon Creek, Baker City, La Grande and Walla Walla. In addition, the State of 

Oregon identifies six public source watersheds that supply water to the communities of 

Richland, Joseph, Sumpter, Prairie City, Pendleton, and Hermiston. The Forest Plans 

contain standards that require that all management actions are designed to protect water 

quality in all public supply watersheds and limit the use of fertilizers and other chemical 

that could harm water quality. Additional restrictions needed to protect water quality in 

these watersheds may be requested by individual communities and are subject to 

approval by the Regional Forester. 

281. Concern Statement: The Forest Service should abide by the Taylor Grazing Act that 

limits the agency’s ability to change the purpose of grazing areas. 

Response: The Taylor Grazing Act of 1934 intended to “stop injury to the public 

grazing lands [excluding Alaska] by preventing overgrazing and soil deterioration; to 

provide for their orderly use, improvement, and development; [and] to stabilize the 

livestock industry dependent upon the public range.” 

Planning for units of the National Forest System involves two levels of decisionmaking. 

The first level of planning involves the development of a forest plan that provides 

direction for resource management of the entire planning unit. Forest plans set out 

forestwide and management area direction with standards and guidelines for future 

decision-making and are adjustable through amendment and revision. Forest plan 

management area and forestwide direction are the “zoning ordinances” under which 

future site-specific project-level planning decisions are made, the second level of forest 

planning. Forest plan approval establishes multiple-use goals, desired conditions, and 

objectives for the planning unit. Forest plan-level actions are approval, amendment, and 

revision (16 USC 1604(d) and (j), 1604(f)(4), and 1604(f)(5)). 

Forest Plan approval results in the following: Establishment of management areas and 

management area direction applying to future activities in that management area, 

including the suitability of lands for resource management (16 USC 1606(g)(2)(A) and 

1982 Rule Provision 36 CFR 219.11(c)). The Forest Service therefore is acting within its

authority when the purpose, or suitability, of a grazing area is changed. 

282. Concern Statement: The Forest Service should adhere to the Rescission Act of 1995 by 

completing the grazing allotment management plans. 

Response: Allotment management plans are site-specific actions and are not included in 

the Forest Plan revision planning procedures. 

283. Concern Statement: The Forest Service failed to develop a grazing suitability analysis 

on environmental consequences and alternative uses forgone in violation of Forest 

Service planning regulations.
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Response: The results of the suitability analysis were included in the Methodology 

section in Appendix B of the draft Environmental Impact Statement. The suitability 

analysis and methodology has been moved to the “Livestock Grazing and Grazing Land 

Vegetation” section in Chapter 3 of the Final Environmental Impact Statement. 

As stated, “a suitability determination is the process of evaluating a land area through a 

modeling of suitability and capability for a specified land use (such a permitted livestock 

grazing).” The resulting suitability determination—in this particular case for permitted 

livestock grazing—does not foreclose other land uses as directed by the Multiple Use 

Sustained Yield Act of 1960 (Public Law 86-517). Management activities for timber, 

range, outdoor recreation, watershed, wildlife, and fish purposes may be conducted 

concurrently and within the same area. The Multiple Use Sustained Yield Act directs the 

Forest Service to manage various renewable resources so that they may be used in 

combinations to best meet the needs of the American people. 

284. Concern Statement: The Forest Service should minimize degradation of wetlands, 

required by Executive Order 11990 Protection of Wetlands and Executive Order 11988 

Floodplain Management, by eliminating livestock use in riparian and floodplain areas. 

Response: To protect aquatic and riparian ecosystems, while supporting multiple uses 

such as livestock grazing, the Forest Service strengthened plan components for aquatic 

and riparian ecosystems under Alternatives E-Modified and E-Modified Departure. 

These plan components make up the 2018 Blue Mountains Aquatic and Riparian 

Conservation Strategy (ARCS). Alternative C would make riparian areas unsuitable to 

livestock grazing.

285. Concern Statement: The Forest Service should emphasize use of federal lands for fish 

and wildlife, per the Federal Land Policy and Management Act of 1976, rather than for 

livestock. 

Response: The revised Forest Plans will be consistent with existing law, regulation, and 

policy governing national forest management. The Forest Service has followed planning 

requirements for revising land management plans (forest plans), as required by the 

Forest and Rangeland Renewable Resources Planning Act of 1974 (RPA), as amended 

by the National Forest Management Act of 1976 (see 36 CFR part 219). The National 

Forest Management Act reinforces the multiple-use purposes of the National Forest 

System as specified in the Forest and Rangeland Renewable Resources Planning Act and 

the Multiple Use Sustained Yield Act. The National Forest Management Act specifies 

that forest plans provide for “multiple use and sustained yield of the products and 

services obtained therefrom in accordance with the Multiple-Use, Sustained-Yield Act of 

1960, and in particular, include coordination of outdoor recreation, range, timber, 

watershed, wildlife and fish, and wilderness.” 

Multiple use is defined in the planning regulations (36 CFR 219.19) as “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 land 

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 
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dollar return or the greatest unit output, consistent with the Multiple-Use SustainedYield Act of 1960 ( 16 U.S.C. 528- 531).” 

Planning: Management Areas

286. Concern Statement: The Forest Service should reduce or eliminate all General Forest 

Management Areas (4A).

Response: The Final Environmental Impact Statement alternatives include a range of 

management area allocations. The acreage of Management Area 4A – General Forest 

varies between alternatives. Compared to the other alternatives, Alternative C would 

reduce the acres of land allocated to Management Area 4A – General Forest by 

approximately one half. 

287. Concern Statement: The Forest Service should not propose any new “special area” 

designations. 

Response: The Wilderness Act and National Forest Management Act, together with 

their implementing regulations and policy, require the Forest Service to identify and 

evaluate lands that may be suitable for inclusion in the National Wilderness Preservation 

System and determine whether to recommend any such lands for wilderness designation. 

There are three tests in the evaluation process: capability, availability, and need. The 

identification and evaluation of areas for wilderness recommendation are included as an 

appendix in the Final Environmental Impact Statement. Proposals are preliminary 

administrative recommendations that will be further reviewed and possibly modified by 

the Chief of the Forest Service, Secretary of Agriculture, and the President of the United 

States. Congress has reserved the authority to make final decisions on wilderness area 

designation. 

Other special area designations may be made administratively through the forest plan 

revision process (36 CFR 219). These areas often conserve unique biophysical 

environments and contribute to the planning area’s distinctive role within the broader 

landscape, offering additional recreational opportunity not usually encountered in 

general forest settings.

Planning: Monitoring

288. Concern Statement: The Forest Service should invest in robust multi-scale monitoring 

and adaptive management for each resource, including benchmarks and triggers for 

changes in management. Management activities should only occur if monitoring is 

funded. Monitoring should be done, at the watershed and landscape level, to track the 

progress toward planning goals. 

Response: The Responsible Official has the discretion to set the scope and scale of the 

monitoring program after considering, among many factors, the financial and technical 

capabilities of the Forest Service, to collect information most critical for the informed 

management of resources in the plan area. Each Forest Plan includes a monitoring 

section, designed to evaluate both the implementation and effectiveness of plan 

components. The evaluation of monitoring results may be used to assess progress toward 

achieving desired conditions and could lead to changes in forest plan direction. The 

monitoring program, however, does not apply to projects or activities. Project and 

activity monitoring may be used to gather information for the plan monitoring program, 

and information gathered through plan monitoring may be used to inform development 
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of projects or activities. However, monitoring is not a prerequisite for making a decision 

to carry out a project or activity [36 CFR §219.12(a)(7)]. 

289. Concern Statement: The Forest Service should develop key indicators that can be 

measured within the plan’s 15- to 20-year timeframe and should re-evaluate its 

monitoring frequencies as it is difficult to determine resource trends in a short period of 

time like 1 or 5 years.

Response: The Forest Service has both implementation and effectiveness monitoring 

that apply to projects after they are completed. Time requirements vary depending upon 

the type of project and the resources that are impacted. The Revised Forest Plans for the 

three National Forests are also proposing that adaptive management practices be 

implemented, thus encouraging the need for increased managed activities should 

monitoring results make such recommendations. 

290. Concern Statement: The Forest Service should add more economic-based monitoring 

questions in the 37 questions within the Monitoring Plan Framework for the Action 

Alternatives for Each National Forest table. 

Response: Goal 3 of the plans is to “promote economic well-being.” The Forest Service 

is one of many actors in both public and private sectors that influence social and 

economic conditions in the Blue Mountains region. National Forests contribute to 

economic well-being by providing jobs via a range of uses, products and services, and a 

quality of life, with the caveat that the Forest Service contributes to but does not, by 

itself, maintain the economic well-being of surrounding communities. 

The monitoring question related to economic well-being would assess whether the 

outputs of goods and services are being produced consistent with levels anticipated in 

the plans. This question addresses the outputs of many goods and services, for a variety 

of forest management activities, including the development of forest products; livestock 

grazing; special uses; mineral, energy and geological resources; and water uses. In other 

words, the economic monitoring question asks several questions in one.

Planning: Process

291. Concern Statement: The Forest Service should consider how adjacent non-federal 

landowners and resources may be affected by various alternatives. 

Response: We considered the potential effects of Forest Plan alternatives on 

neighboring non-federal landowners and resources. We consulted with federally 

recognized Tribes, engaged with State and County governments, and private 

landowners. We also consulted with other Federal agencies, particularly the U.S. Fish 

and Wildlife Service and National Marine Fisheries Service regarding the Endangered 

Species Act. In accordance with 36 CFR 219.7(c) of the 1982 Planning Rule, the Forest 

Service reviewed the “planning and land use policies of other Federal agencies, State 

and local governments, and Indian Tribes” with respect to the Forest Plans, and included 

the results of this review in the Final Environmental Impact Statement. As each National 

Forest develops projects under its revised Forest Plan, the Forest Service would continue 

to reach out to various stakeholders for their input to help us consider the potential 

effects of proposed projects on lands and resources affected by management actions 

undertaken on these National Forests. 

292. Concern Statement: The Forest Service should not identify the preferred alternative in 

the draft forest revision plan before the public has a comment opportunity. 
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Response: Section 1502.14(e) of the Council on Environmental Quality regulations 

requires the section of the Environmental Impact Statement on alternatives to “identify 

the agency's preferred alternative if one or more exists, in the draft statement, and 

identify such alternative in the final statement . . .” This means that if the agency has a 

preferred alternative at the Draft Environmental Impact Statement stage, that alternative 

must be labeled or identified as such in the Draft Environmental Impact Statement. If the 

responsible official has no preferred alternative at the Draft Environmental Impact 

Statement stage, a preferred alternative need not be identified there. At the time the Final 

Environmental Impact Statement is filed, Section 1502.14(e) presumes the existence of a 

preferred alternative and requires its identification in the Final Environmental Impact 

Statement “unless another law prohibits the expression of such a preference.” 

293. Concern Statement: The Forest Service should not cumulatively assess environmental 

impacts in the affected environment of the forest plan because it shows a disproportional 

impact on current resources that gives a false impression of the amount of degradation 

on the landscape.

Response: Under National Environmental Policy Act regulations, we are required to 

analyze the cumulative effects on resources. It helps to account for past activities and 

place resource conditions in a historical context to inform management choices. For 

some resources, past activities have resulted in lasting impacts reflected in current 

conditions.

294. Concern Statement: The Forest Service should determine how a programmatic forest 

plan can provide specific project locations and activities so that the Tribes can analyze 

impacts. 

Response: As a programmatic plan conducted at a landscape-scale, Forest Plans provide 

broad direction for management but they do not direct site-specific activities and 

locations, except to designate management areas that are suitable for some, but not all, 

management activities. Upon adoption of the plans, project-level site-specific analysis 

would be conducted, at which time the Forest Service would consult with the Tribes for 

their review of potential impacts to Tribal resources and other concerns.

295. Concern Statement: The Forest Service should include the Hells Canyon National 

Recreation Area in this forest plan revision because this management plan has been in 

place since 2003, and it is due to be replaced every 10-15 years. Without the Hells 

Canyon National Recreation Area included, access issues are misstated.

Response: The Hells Canyon National Recreation Area would continue to be managed 

per the 2003 Record of Decision. The Forest Service reviewed the Hells Canyon 

National Recreation Area Comprehensive Management Plan to determine if there was a 

need for change to revise that plan. The Analysis of the Management Situation (reflected 

in the 2004 Current Management Situation) for the Hells Canyon National Recreation 

Area showed there was no need for change in this area of the Wallowa-Whitman 

National Forest. As a special area, the management direction for the Hells Canyon 

National Recreation Area may be brought forward, unmodified, as part of the WallowaWhitman National Forest Plan, under provisions of the 1982 planning rule at section 

219.2(b). The 2003 decision achieves the objectives of the Hells Canyon National 

Recreation Area Act (PL 94-199) establishing the Hells Canyon National Recreation 

Area, the Hells Canyon Wilderness, and the Rapid and Snake Wild and Scenic Rivers; 

the Oregon Wilderness Act of 1984 (PL 98-328); the Omnibus Oregon Wild and Scenic 

Rivers Act (PL 100-552); Public and Private Land Use Regulations (36 CFR 292); and 
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Forest Plan content regulations (36 CFR 219.11). Existing management direction for the 

Hells Canyon National Recreation Area has been considered under cumulative effects 

where appropriate for given issues and resource areas, including access.

Planning: Separate Plans

296. Concern Statement: The Forest Service should create a separate land management plan 

for each national forest to better address community input and socio-economic factors. 

Desired conditions for resources differ across forests, and managers would be 

unnecessarily limited by plan-wide elements. 

Response: Based on public and internal comments, we have decided to create three 

individual Forest Plans for each National Forest (Malheur, Umatilla, and WallowaWhitman). 

Planning: Standards and Guidelines

297. Concern Statement: The Forest Service should use measurable standards rather than 

guidelines to minimize Forest Service interpretation. Standards, required by the National 

Forest Management Act and providing for legal accountability, should be written using 

best management practices and best available science. More standards and guidelines 

would help ensure the plan’s success.

Response: Although current Forest Plans may have not clearly distinguished between 

standards and guidelines, and given the public impression that guidelines may be 

optional, the proposed Plans have carefully defined standards and guidelines in the Blue 

Mountains Forest Plans:

♦ Standards are mandatory constraints upon project and activity decisionmaking. They 

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

avoid or mitigate undesirable effects, or to meet applicable legal requirements. 

♦ Guidelines are a constraint on project and activity decisionmaking that allows for 

departure from its terms, so long as the purpose of the guideline is met. Guidelines 

are established to help achieve or maintain a desired condition or conditions, to 

avoid or mitigate undesirable effects, or to meet applicable legal requirements. 

In other words, guidelines serve the same purpose as standards but they differ from 

standards in that guidelines provide some flexibility to comply (i.e., meet the intent of 

the guideline) while standards are absolute constraints. Guidelines are not optional and 

must be followed unless alternative methods that meet the intent or purpose of the 

guidelines are adopted and documented in the project record. The Forest Service 

reviewed guidelines and standards in the draft Forest Plans to verify whether some 

guidelines should be standards, and vice versa. Additionally, the Forest Service has 

clarified the intent of each guideline.

298. Concern Statement: The Forest Service should make edits, insertions, and deletions, to 

the draft forest revision plan’s existing standards and guidelines using italics, 

strikethroughs or other means to show exactly what was changed between the Draft and 

Final Environmental Impact Statements.

Response: Tracking changes in the document using italics and strikethroughs was not a 

practical way to display changes because, due to the volume of edits, it would leave the 

final statement too difficult to read. A summary of what has changed between the Draft 
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and Final documents is available in the Preface of Volume 1 of the Final Environmental 

Impact Statement. In addition, Forest Plan components for the modified alternatives can 

be compared to the other alternatives in Volume 3, Appendix A of the final 

Environmental Impact Statement.

299. Concern Statement: The Forest Service should use fewer standards and guidelines in 

the revised forest plans to avoid restricting active management and to allow projectspecific flexibility to meet objectives. 

Response: The Forest Service designed the Blue Mountains Forest Plans with degrees 

of flexibility to limit the need for future amendments. The Forest Plans include a variety 

of components (desired conditions, standards, guidelines) that serve as management 

tools. These plan components provide consistency, where appropriate, across the 

National Forests. They also provide flexibility, where appropriate, for project-level 

decisions. Standards and guidelines are a case in point. Although some past Forest Plans 

have blurred the meaning between what is a standard versus a guideline, the Forest 

Service carefully defined both terms in the Blue Mountains Forest Plans:

♦ Standards are mandatory constraints upon project and activity decisionmaking. They 

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

avoid or mitigate undesirable effects, or to meet applicable legal requirements. 

♦ Guidelines are a constraint on project and activity decisionmaking that allows for 

departure from its terms, so long as the purpose of the guideline is met. Guidelines 

are established to help achieve or maintain a desired condition or conditions, to 

avoid or mitigate undesirable effects, or to meet applicable legal requirements. 

In other words, guidelines serve the same purpose as standards but they differ from 

standards in that guidelines provide some flexibility to be comply with the intent of the 

guideline, while standards are absolute constraints. The Forest Service has reviewed the 

guidelines and standards in the draft Forest Plans to verify whether some guidelines 

should be standards and vice versa. Furthermore, the Forest Service has clarified the 

intent of each guideline. 

300. Concern Statement: The Forest Service should rely on the 1990 land and resource 

management plan’s standards and guidelines rather than making new ones. In addition, 

the Forest Service should assess if the 1990 standards and guidelines have been met and 

how effective they have been.

Response: The 2010 Revised Need for Change and the project purpose and need (Final 

Environmental Impact Statement, Chapter 1) explain the reasons for revising the forest 

plans. Much of the need for change is driven by a need to (1) apply new science 

findings, particularly for terrestrial and aquatic habitats; (2) manage fuels and fire risk; 

(3) build ecological resiliency in the face of a changing climate; and (4) adequately 

recognize the interdependency of social and economic conditions with national forest 

management. The important issues today are somewhat different than the issues 

addressed by the Forest Plans of 1990. The proposed plan components reflect these 

differences. Many existing plan components have corollary components in each of the 

action alternatives. These components can be compared across all alternatives, including 

Alternative A (or no change) in Volume 3, Appendix A of the Final Environmental 

Impact Statement.
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Plants 

Plants: Current Inventories

301. Concern Statement: The Forest Service should survey, map, monitor and buffer all 

sensitive plants. It should also disclose known locations and grazing areas that will be 

affected.

Response: To help conserve sensitive plants during the design and implementation of 

management activities, the Forest Service modified or added new standards and 

guidelines to Alternative E-Modified and E-Modified Departure. Grazing activities that 

may be affected by the presence of sensitive plants would be determined during sitespecific environmental analysis at that time. 

Plants: Diversity

302. Concern Statement: The Forest Service should provide for plant diversity as required 

by NFMA by eliminating grazing in riparian areas, limiting herbicide use, and 

prohibiting clear-cutting and managing forests as plantations.

Response: The Forest Service highlighted species diversity in the purpose and need to 

revise the Forest Plans (Final Environmental Impact Statement, Chapter 1). The goals 

and desired conditions for species diversity for all alternatives are found in Appendix A 

of this document (1.2 Species Diversity). The revised plan alternatives direct the 

management of riparian ecosystems through several standards and guidelines (see 

Appendix A). Additionally, the plan revision alternatives include guideline IS-4G that 

would require measures to prevent the establishment and spread of invasive species be 

developed during site-specific project planning.

303. Concern Statement: The Forest Service should create standards to protect peatlands 

from all management activities that may degrade such habitat. 

Response: Alternative E-Modified provides desired conditions for groundwaterdependent ecosystems, which include peatlands, at 1.1.3 and 3.3.5. Alternatives B, E, EModified, E-Modified Departure and F include a guideline (FLS-2G) that would not 

authorize grazing in the sensitive peatland habitat. As a type of wetland, peatlands 

would be managed through additional standards and guidelines for riparian management 

areas described under Management Area 4B. These plan components and other plan 

content would: 

♦ Protect and maintain the ecological integrity of terrestrial and aquatic ecosystems 

and watersheds, riparian areas, and water quality and water resources,

♦ Restore the ecological integrity of terrestrial and aquatic ecosystems and 

watersheds, riparian areas, and water quality and water resources, 

♦ Contribute to the recovery of Federally-listed species, conserve proposed or 

candidate species, and maintain viable populations of species of conservation 

concern, and 

♦ Identify watershed(s) that are a priority for protection, maintenance or restoration.

Please refer to the direction for Management Area 4B in Appendix A for the full set of 

standards and guidelines directing riparian area management for all alternatives.
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Plants: Nonnative

304. Concern Statement: The Forest Service should treat noxious weeds to protect 

watershed function, species diversity and productive capacity. Treating weeds would 

also prevent weed spread from national forests to private lands. Ventenata, medusa head, 

and non-native fungi should be considered in addition to cheat grass. 

Response: All plan revision alternatives include objectives for treating invasive plants, 

which include noxious weeds, as well as standards and guidelines for projects planning 

to treat noxious weeds. The decision of what, where, when, and how to treat invasive 

plants is not made in a forest plan, but during project-level planning.

305. Concern Statement: The Forest Service should consider preventing new invasive plant 

infestations, detecting new invaders early, and the feasibility of eradication or control. It 

should use trained observers, sampling, and monitoring based on invasive plant biology 

and dispersal vectors. Adaptive management should be used, and the cost and 

effectiveness of treatment should be considered. Several commenters suggested spread 

of invasive plants by wildlife and water should also be considered. 

Response: All alternatives include objectives for treating invasive plants. Alternative E 

has been modified to include additional standards and guidelines that direct project-level 

actions be planned and implemented to prevent the establishment or spread of invasive 

plants. Alternative E-Modified plan standards further require an integrated approach to 

invasive species management, including the early detection of new invaders. The 

decision of when, where and how to treat invasive species, including a cost-benefit 

analysis considering treatment options, would be undertaken during project-level 

planning and analysis.

306. Concern Statement: The Forest Service should control and prevent spread of invasive 

plants by not building new roads, not opening closed roads, applying herbicides by 

hand, and hand-pulling weeds whenever possible. Others suggested keeping roads open 

to ease monitoring and treatment of invasive plants and using approved herbicides and 

biocontrol. 

Response: The alternatives include several forestwide standards and guidelines to 

prevent the establishment and spread of invasive plants. Alternative E-Modified and EModified Departure include guideline (IS-3G) to consider all methods, including 

prevention and treatment using manual, cultural, mechanical, chemical and biological 

agents as methods when planning invasive plant control actions. The decision of when, 

where and how to treat invasive species would be undertaken during project-level 

analysis.

307. Concern Statement: The Forest Service should consider allowing use of non-native 

seeds to reduce erosion, supply short-term forage, prevent establishment and spread of 

invasive weeds, and provide cover for surviving native plants. Native seeds have lower 

success rates than non-natives, and the total cost of management may increase over time 

if invasive plants are allowed to establish. Oregon Certified Seeds should be considered.

Response: The Forest Service determines during project-level planning the composition 

of seed mixes to be used for revegetation, restoration and rehabilitation. Current Forest 

Service policy (FSM 2070.3) places primary consideration on native species when 

planning projects but allows for the use of non-native species in certain circumstances.
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308. Concern Statement: The Forest Service should change the standard that requires 

minimizing or preventing the establishment or spread of invasive plants to a guideline. 

Response: The Forest Service modified the revised Plans (Alternative E-Modified) and 

changed this standard to a guideline (see guideline IS-4G).

309. Concern Statement: The Forest Service should create a standard to measure soil 

disturbance in order to prevent invasive plant establishment and spread. 

Response: The plan revision alternatives, including Alternative E-Modified, include 

components to prevent the establishment and spread of invasive plants. Several 

forestwide guidelines (IS-4G, IS-5S, IS-6S, IS-8G), address the prevention and 

restoration of disturbed sites when conducting management activities.

Plants: Sensitive

310. Concern Statement: The Forest Service should discuss the difference between Forest 

Service and Nature Conservancy estimates of Spalding’s catchfly populations. 

Response: The Forest Service modified the Final Environmental Impact Statement

(Volume 2, Chapter 3, “Plant Species Diversity and Threatened, Endangered, and 

Sensitive Plants”) to clarify the differences between the Forest Service and Nature 

Conservancy estimates for the Spalding’s catchfly population sizes.

311. Concern Statement: The Forest Service should develop standards rather than 

guidelines to protect sensitive plant species, particularly those found in the sagebrush 

shrubland habitat group. 

Response: The Forest Service modified or added new forestwide guidelines to 

Alternative E-Modified to reduce impacts to sensitive plants. The plan defines a 

guideline as “a constraint on project and activity decision-making that allows for 

departure from its terms, so long as the purpose of the guideline is met. Guidelines are 

established to help achieve or maintain a desired condition or conditions, to avoid or 

mitigate undesirable effects, or to meet applicable legal requirements. Guidelines serve 

the same purpose as standards but they differ from standards in that they provide 

flexibility in defining compliance, while standards are absolute constraints.”

312. Concern Statement: The Forest Service should not assume that logging will improve 

aspen habitat. 

Response: The Forest Service modified the Final Environmental Impact Statement to 

elaborate how the alternatives would affect sensitive plants inhabiting aspen habitat.

313. Concern Statement: The Forest Service should consider eliminating grazing and 

motorized use from fragile lithosol plant habitats. 

Response: The Forest Service considered but eliminated from detailed study 

alternatives that would have halted grazing (Alternative G – Minimum Management and 

Alternative J – No Grazing). The Forest Service modified the Environmental Impact 

Statement to elaborate how the alternatives would affect sensitive plants inhabiting 

lithosols. Site-specific decisions regarding motorized use on the National Forests is not 

within the scope of forest planning and would be conducted through a subsequent 

planning effort.

314. Concern Statement: The Forest Service should not manage for sensitive species. 
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Response: The Forest Service has a statutory and policy requirement to manage 

sensitive species. The Final Environmental Impact Statement identifies the need to 

maintain diversity of species, including plants, in the purpose and need to revise the 

forest plans (Chapter 1). The Forest Service manages for sensitive species as one means, 

among several, to satisfy the species diversity requirements under the National Forest 

Management Act at 36 CFR 219.26. “Sensitive species” are defined (Forest Service 

Manual 2670.5) as “plant and animal species identified by a regional forester for which 

population viability is a concern, as evidenced by: 

♦ Significant current or predicted downward trends in population numbers or density. 

♦ Significant current or predicted downward trends in habitat capability that would 

reduce a species' existing distribution.” 

Plants: Standards and Guidelines

315. Concern Statement: The Forest Service should create an exception for human health 

and safety to the guideline discouraging wildland fire suppression lines in threatened, 

endangered, and sensitive plant species habitat. 

Response: The Forest Service modified the guideline for Alternative E-Modified (FLS8G) to include an exception when necessary to provide for the protection of human life 

and public safety.

316. Concern Statement: The Forest Service should monitor and require buffering and 

protection for Macfarlane’s four o’ clock. 

Response: The Forest Service determines the need to survey for threatened, endangered 

and sensitive plants during project-level planning and analysis. Alternative E-Modified 

and E-Modified Departure include several standards (RE-5S, FLS-3S, FLS-5G, FLS-6S, 

FLS-7G, FLS-8G, FLS-9S, FLS-10G, FLS-11S, FLS-13G, FLS-14G, LH-4G), for the 

protection of threatened and endangered species, including the federally listed 

(threatened) MacFarlane’s four o’clock.

317. Concern Statement: The Forest Service should remove guidelines discouraging road 

construction, timber harvest, slash piles and fuels management, and trail construction in 

threatened, endangered and sensitive plant species habitat because such issues will be 

resolved by project-level consultation. The buffers associated with these guidelines have 

no scientific basis. 

Response: The Forest Service modified the standards and guidelines designed to reduce 

impacts to threatened, endangered, proposed, candidate, and sensitive species plants in 

Alternative E-Modified. Specific avoidance buffers have been removed and replaced 

with a standard or guideline specifying that management actions avoid adverse effects or 

impacts to these categories of plant species. The means by which adverse effects or 

impacts would be avoided would be determined during project-level planning.

Public Involvement 

Public Involvement: Collaboration and General 

318. Concern Statement: The Forest Service should not state that the plan, including its 

goals and desired conditions, were developed through a collaborative process. The plan 

should detail, however, how the Forest Service will ensure and improve engagement of 
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local collaboratives and new partnerships to achieve the plan’s vision, for example by 

partnering with existing collaboratives to create restoration and monitoring synergies 

across agencies. 

Response: Because “collaboration” may connote a unique process in Forest Service 

planning, specifically working with local collaborative groups, the Forest Service has 

revised our language to state that the Forest Plans have benefited from extensive public 

input. Moving forward, the Forest Service has strengthened the discussion regarding the 

value of local collaborative groups and partnerships in achieving the goals and desired 

conditions of the Forest Plans. 

319. Concern Statement: The Forest Service should listen to the voices of neighboring small 

forestland owners, including ranchers and loggers, and add a consulting requirement to 

the plan to consider their needs. To assist private landowners, it should partner with the 

Natural Resources Conservation Service and the Oregon Department of Forestry.

Response: The Forest Service regularly listens to and considers the needs of 

neighboring landowners. At the programmatic level, the forest plan revision process has 

included opportunities for neighboring landowners to provide input during the scoping 

and formal comment periods as well as during public meetings. At the project level, the 

Forest Service provides additional opportunities for public input, including formal 

comment periods. Outside of formal planning processes, the Forest Service seeks to 

assist neighboring landowners by working with other agencies such as the Natural 

Resources Conservation Service and State Departments of Forestry. Also, through its 

State and Private Forestry division, the Forest Service provides technical and financial 

assistance to States, Tribes, communities, and non-industrial private landowners.

320. Concern Statement: The Forest Service should weight comments by local community 

members and those who would be affected economically more heavily than others. 

Response: National forests are managed for the benefit of all Americans; therefore, we 

consider all substantive comments received, regardless of the source. Substantive 

comments are those that are within the scope of the proposal, are specific to the 

proposal, and have a direct relationship to the proposal. If local community members 

and those who would be affected economically submitted substantive comments, then 

those comments were considered in the planning process.

321. Concern Statement: The Forest Service should equally consider all public voices, 

including the range of recreation interests as well as ranchers, farmers, wood gatherers, 

and hunters. 

Response: We consider all substantive comments received, regardless of the source. See 

the previous response regarding substantive comments.

Public Involvement: Cooperation-NEPA

322. Concern Statement: The Forest Service should share draft NEPA documents with 

cooperating agencies prior to full public release. The Forest Service should include an 

accurate list of cooperating agencies, reflecting current memoranda of understanding, in 

the Forest Plans. 

Response: We shared the Draft Environmental Impact Statement with cooperating 

agencies prior to full public release. The revised Forest Plans and this Final 
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Environmental Impact Statement include an accurate list of cooperating agencies based 

on current memoranda of understanding. 

Public Involvement: Coordination-NFMA

323. Concern Statement: The Forest Service should recognize and give standing to county 

and state ordinances, laws, and plans that address natural and cultural resource 

management, through coordination. The forest revision plan should show how it has 

involved each coordinating county in the process and discuss its attempts to resolve any 

conflicts that exist with local plans, ordinances, or laws. In addition, commenters 

requested adherence to a variety of county and state laws, including the Oregon 

Department of Fish and Wildlife’s waste regulations and Washington’s Growth 

Management Act and OHV use laws.

Response: Because national forest management may affect other government 

jurisdictions, the Forest Service seeks input from Tribes, States, Counties, and other 

government entities in a number of ways. The formal comment period is an important 

source of government input. Additional opportunities exist for the Forest Service and 

other government agencies to cooperate and coordinate. 

Cooperation: Under the National Environmental Policy Act (NEPA) and implementing 

regulations, government agencies can agree to serve as cooperating agencies. 

Cooperating agencies work with the Forest Service to share information and shape 

successful plans. Cooperating agencies may participate in special briefings and 

discussions with the Forest Service during the planning process. Cooperating agencies 

may also have access to select draft documents in advance of the publication of the Final 

Environmental Impact Statement and revised Forest Plans. Where they have special 

expertise, cooperating agencies can provide information to the Forest Service (such as 

social and economic information), which is interpreted by a technical expert on the 

revision team. Moreover, cooperating agencies are listed in the Final Environmental 

Impact Statement and revised Forest Plans.

Coordination: The National Forest Management Act (NFMA) and its implementing 

regulations state that “the responsible line officer shall coordinate regional and forest 

planning with the equivalent and related planning efforts of other federal agencies, state, 

and local governments, and Indian tribes” (36 CFR 219.7, 1982). As part of the forest 

plan revision process, the Forest Service reviews government planning and land-use 

policies; considers the objectives expressed in those plans and policies; assesses the 

interrelated impacts of the plans and policies; determines how the revised Forest Plans 

should deal with the identified impacts (consistent with federal laws, policies, and 

regulations); and considers alternatives for resolving conflicts with the Revised Forest 

Plans (36 CFR 219.7(c), 1982). The results of Forest Service coordination reviews with 

respect to the Blue Mountains Forest Plans are included in the project record. 

To conclude, the Forest Service is the lead agency and maintains decision-making 

authority on the Forest Plans. The Forest Service also strives to work with neighboring 

governments on forest management activities by exchanging information and seeking 

win-win solutions whenever possible, including through cooperation and coordination. 

324. Concern Statement: The Forest Service should coordinate with County governments to 

determine what impacts Forest Service road closures will have on County land 

management plans. 
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Response: See the response above regarding coordination. In addition, road closures 

are determined through site-specific project analysis and decisions that occur outside of 

the forest plan revision process. Consistent with existing law, policy, and regulation, the 

Forest Service will continue to work with County governments regarding site-specific 

decisions.

Recreation and Scenery 

Recreation: Developed Recreation

325. Concern Statement: The Forest Service should create a desired condition for the 

continued maintenance of developed facilities. 

Response: We recognize the need for continued maintenance of developed facilities, 

while also recognizing a high level of deferred maintenance for recreational facilities. 

Considering these existing conditions, the desired condition for Goal 2.2.1 – Developed 

Recreation states: “Developed facilities, such as campgrounds, restrooms, picnic areas, 

trailheads, snow parks, and boating and fishing sites, are well maintained, fully 

functional, provide for visitor safety, and are accessible to people with disabilities.” The 

type of use typical at developed facilities requires ongoing maintenance to meet user 

expectations. The stated desired condition is responsive to these facility conditions and 

user expectations.

326. Concern Statement: The Forest Service should create a developed recreation 

management allocation for the area around the Wallowa Lake Tramway. 

Response: For all alternatives analyzed in the Environmental Impact Statement, the 

existing Wallow Lake Tramway permit area is allocated to Management Area 5 – 

Developed Sites and Administrative Sites. The area allocated to MA 5 includes the tram 

line and the summit area operations. Desired conditions for this allocation include the 

subheading “Permitted Recreation Facilities,” which includes such permitted sites as 

lodges, organization camps, and trams. The area adjacent to the permitted area is 

allocated to varying management areas, ranging from general forest to backcountry 

nonmotorized, and is based on the theme for each of the different alternatives. Future 

developed recreation activity in the adjacent area would be analyzed through a separate, 

site-specific process that would include project-level analysis and public involvement 

and participation.

Recreation: Dispersed Recreation

327. Concern Statement: The Forest Service should not require visitors to go through 

private providers to access dispersed recreation sites and should not turn popular 

dispersed recreation sites into fee areas. 

Response: The desired condition for Goal 2.3.3 – Backcountry Recreation was reviewed 

and edited for clarity. The revised Forest Plans do not intend to or provide management 

direction to privatize dispersed recreational opportunities. The revised desired condition 

states: “Partnerships with private providers sustain specialty services, such as 

backcountry skiing, jet boat and raft trips, aircraft, and big game outfitting and guiding 

services.” These types of uses are usually provided through special use permit holders to 

operate specialty outfitting and guide services under special use authorizations, forming 
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a partnership to provide additional services beyond the Forest Service’s operating 

capabilities.

Recreation: Increase Opportunities

328. Concern Statement: The Forest Service should strengthen recreation access and 

opportunities because of the impact of recreation on local economies and the recent 

growth of this sector. 

Response: We recognize the importance of national forest access for its contribution to 

local economies and for providing access for recreation- and subsistence-related 

activities for visitors and users. The “Economic and Social Well-being” section in 

Chapter 3 of the Final Environmental Impact Statement describes economic impact 

zones and the contributions provided by recreation-related activity in the Blue 

Mountains national forests. As stated in the Final Environmental Impact Statement, “For 

all alternatives, the quantity of recreation visits to the national forests in not expected to 

vary from current use levels. The current supply of recreational opportunities is expected 

to exceed demand for the foreseeable future.” 

Recreation: Mountain Bike Support

329. Concern Statement: The Forest Service should allow mountain biking in all areas that 

aren’t wilderness and should directly reference mountain biking rather than using the 

phrase “nonmotorized mechanized travel” to avoid confusion. 

Response: We agree that mountain biking represents a legitimate recreational use of the 

national forests and provides benefits for both users and Forest Service management. 

Though not specifically listed in the Suitability Matrix for Management Areas in the 

revised Forest Plans, mountain biking is generally suitable in all forest management 

areas, except for designated wilderness (Management Area 1A – Congressional 

Designated Wilderness Areas). As stated in the Final Environmental Impact Statement

regarding bicycle use in Management Area 1B (Preliminary Administratively 

Recommended Wilderness): “Mechanized use (bicycles) would be restricted to system 

roads and trails until Congressional designation, and then mechanical use would be 

prohibited.” An additional guideline was developed for the revised Forest Plans to 

provide additional management direction regarding mountain bicycle use in 

Management Area 1B. The new guideline states: 

MA1B-2G Mechanized (bicycle) use on existing trails and nonmotorized travel 

may occur in recommended wilderness areas. 

Edits were made to the revised Forest Plans and Environmental Impact Statement that 

added the term “bicycle” in parentheses to follow instances of “mechanized use” for 

improved clarity.

330. Concern Statement: The Forest Service should develop plans to build more mountain 

bike trails in all three national forests to improve opportunities and benefit local 

economies. Roads closed to motorized use could be converted to mountain bike trails. 

Response: The revised Forest Plans do not develop specific plans for specific 

management and user activities, but instead provide programmatic management 

direction that guides future management activity on the three National Forests. Sitespecific and project-level planning for recreational uses on the National Forests must 
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comply with the revised Forest Plans, and would conform to direction in the National 

Environmental Policy Act including public involvement and participation. 

The desired condition for Goal 2.6 – Roads and Trails Access states: “Opportunities for 

trails where motor vehicle use is prohibited are emphasized in backcountry and 

wilderness areas and provide a range of difficulty for a variety of recreational 

experiences, including mechanized transportation (except in wilderness areas), foot 

travel, and pack or riding stock. Trails are located to provide experiences in different 

ecosystem types and scenic settings and do not contribute to natural resource damage.” 

Additionally, the desired condition includes management direction recognizing that 

“Forest Service recreation sites are connected to each other and to adjacent communities 

through pathways, trails, bike lanes, and waterways providing opportunities for both 

motorized and/or nonmotorized modes of travel and providing for loop-riding 

opportunities.” 

Based on these desired conditions contained within the Forest Plans and other 

recreation-related plan components, the revised Forest Plans do not prohibit trail 

expansion for mountain bike activity.

Scenery

331. Concern Statement: The Forest Service should not manage for scenery because it will 

restrict public use and resource management. The Forest Service should define “scenic 

integrity levels” (SCEN-1). 

Response: The Forest Service provides for scenery management as outlined in Forest 

Service Manual 2380 – Landscape Management. The directives result from complying 

with statutory requirements including the Multiple-Use Sustained Yield Act of 1960, the 

Forest and Rangeland Renewable Resources Planning Act of 1974, as amended by the 

National Forest Management Act of 1976, and rules at Title 36 of the Code of Federal 

Regulations, Part 219, among others. 

In 1995, the Forest Service replaced its previous scenery management system, the Visual 

Management System, with the Scenery Management System. These systems are both 

structured to primarily emphasize “natural appearing” scenery, but the Scenery 

Management System recognizes the positive scenic values associated with some human 

modified (cultural) features and settings that are valued for their scenic influence. The 

Scenery Management System allows for a “seamless” analysis and conservation of 

aesthetic values, and provides a systematic approach for determining the relative value 

and importance of scenery on National Forest System lands.

Definitions related to the Scenery Management System are located in Volume 3 of the 

Final Environmental Impact Statement in the Glossary.

332. Concern Statement: The Forest Service should conserve “in-depth” scenery, add large 

trees and mature forest as important scenic attributes, and acknowledge that nature 

viewing is the fastest-growing nature-based recreation. It should also quantify scenic 

character and scenic stability.

Response: We recognize the importance of conserving scenic values for ecological 

considerations and for the economic contributions relating to recreation. The most recent 

findings of the National Visitor Use Monitoring report (2014) indicate that viewing 

natural features ranked second for activity participation, with 39.2 percent of 
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respondents selecting this activity; and 9.9 percent of respondents citing this as their 

main activity for the Blue Mountain national forests. 

The desired condition for Goal 1.14 – Old Forest and Individual Old/Large Trees 

provides additional management direction for this resource that supports social value: 

“Old forests and trees provide a variety of ecosystem services and social values and old 

forest conservation is integrated and balanced with other ecological and economic 

desired conditions to the extent practicable.” 

Scenery is quantified in the revised Forest Plans in Goal 2.1 – Scenery, through the use 

of the Scenery Management System, and includes forestwide desired conditions for 

scenic integrity and scenic stability. Additionally, each scenic class includes desired 

conditions specific to each class.

333. Concern Statement: The Forest Service should not classify areas as Scenic Class I that 

have existing transportation or utility infrastructure or proposed transmission lines. 

Response: Scenery is inventoried and categorized into one of seven scenic classes with 

Scenic Class 1 being highly valued and distinctive and Scenic Class 7 being not 

distinctive and valued the least. The Environmental Impact Statement provides the 

percent distribution of scenic classes for each of the Blue Mountains national forests

(see table next page). As noted in the effects section in Chapter 3 for Scenery Resources: 

“Visual disturbances can include road construction, mining, utilities development, 

recreation facilities, ski areas, and other special uses. These types of activities generally 

would not improve scenic integrity or stability in the long term . . . The level of 

development of these activities is anticipated to only have negligible variations between 

alternatives and not to an extent that would result in different scenic integrity of 

stability.” Utility developments would be evaluated during project-level planning to 

achieve scenic integrity and stability desired conditions.

334. Concern Statement: The Forest Service should provide information on all scenic 

classes and the current condition of the landscape as it relates to those scenic classes so 

the public can better understand management objectives and direction. 

Response: Information for scenic classes is presented in the Final Environmental Impact 

Statement. Scenery is inventoried and categorized into one of seven scenic classes with 

Scenic Class 1 being highly valued and distinctive and Scenic Class 7 being not 

distinctive and valued the least. The Environmental Impact Statement provides the 

percent distribution of scenic classes for each of the Blue Mountains national forests in 

the Affected Environment – Scenery Resources section and is also presented in the table 

below. 

Percent distribution of scenic classes for each national forest 

Scenic Class Malheur Umatilla Wallowa-Whitman

1 15 37 46

2 45 37 36

3 32 18 14

4 2 1 NA

5 6 7 4 

6 NA NA NA

7 NA NA NA
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The scenic class map for each National Forest is contained in the Forest Plan appendix 

illustrating the scenic class distribution for each respective national forest.

Social and Economic 

Social and Economic: Analysis

335. Concern Statement: The Forest Service should focus more on the impact the Forest 

Plans have on local governments and economies – including loss of industry 

infrastructure. Social and economic cumulative effects should be described, including 

impacts from the Sage-grouse Plan. 

Response: The Blue Mountains Forest Plans and Environmental Impact Statement 

address the relationship between Forest Service management and local economies. “The 

quantity and quality of forest products and services provided by the national forests 

contribute to the local economy and the maintenance of local infrastructure. 

Infrastructure and the local workforce, in turn, play a critical role in the capacity of 

national forests to conduct forest management activities. The mix of uses, products, and 

services the Forest Service expects to provide over time will be stated in the forest 

plans” (Vol. 1). Many comments requested that the Environmental Impact Statement 

recognize the economic importance of public lands to local economies. The 

Environmental Impact Statement does include an economic impact analysis of national 

forest outputs to the three socio-economic impact zones. The economic analysis uses the 

finest geographic scale possible, functional economic areas containing multiple counties, 

using standard methodologies. The social and economic cumulative effects have been 

updated between the Draft Environmental Impact Statement and the Final 

Environmental Impact Statement to include greater sage-grouse planning efforts and 

other past, present, and reasonably foreseeable actions. 

336. Concern Statement: The Forest Service should incorporate more detail in its social 

analysis and assess how forest management affects employment, schools, mental health, 

addiction, domestic violence, as well as the safety, welfare, subsistence uses, and 

cultural ties of local residents. Indicators of impact on social well-being should reflect 

local values. 

Response: The Environmental Impact Statement does estimate how national forest 

management actions contribute to employment and labor income in the areas that 

surround the three National Forests (Vol. 1). The Forest Service cannot make cause-andeffect statements about the relationship between forest management and schools, mental 

health, addiction, poverty, domestic violence, and public safety because existing 

literature does not identify causal relationships between Forest Service management and 

these measures of social well-being. In response to comments, the Affected Environment 

section has been updated to track more indicators of social well-being, including those 

mentioned in the above comment.

337. Concern Statement: The Forest Service should account for economic and social 

conditions of individual communities. 

Response: The best available information on demographic and economic conditions in 

areas that surround the Blue Mountains national forests are at the county level. 

Therefore, the social and economic Affected Environment section presents baseline data 

for counties in the three socio-economic impact zones. Additionally, the economic 
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impact analysis relies on functional economic areas, which are an aggregation of 

counties. Attempting to estimate community-level economic effects would be inaccurate 

because it would fail to account for the flow of goods, services, and people among 

communities in the Blue Mountains planning area.

338. Concern Statement: The Forest Service should analyze the effect of management 

activities on community structure. 

Response: The Environmental Impact Statement does estimate how national forest 

management actions contribute to employment and labor income in the areas that 

surround the three National Forests (Vol. 1). We identify how the Forest Service 

contributes to local economies. The Forest Service cannot make cause-and-effect 

statements about the relationship between national forest management and changes in 

community structure because existing literature does not identify such effects. In 

response to comments, we have updated the Affected Environment section to track more 

indicators of social well-being.

339. Concern Statement: The Forest Service should conduct a cost-benefit analysis for each 

alternative (including on the issue of closing roads) and should include information on 

cost per unit of treatment, return on investment, and certainty of success. Cost-efficient 

alternatives, impacts on net present value, and impacts on local jobs should be 

described. The magnitude of effect (positive and negative) should be described. Longterm effects and externalities should be considered. 

Response: The Environmental Impact Statement includes a cost-benefit analysis that 

addresses the Forest Service expenditures and receipts. A more detailed cost-benefit 

analysis that addresses, for instance, costs per unit of treatment or the cost of closing 

roads, cannot be estimated with available information. As a plan revision, this document 

does not consider site-specific management actions. Treatment costs or road costs 

cannot be known without site-specific information. More detailed cost-benefit analysis 

will be included in subsequent project-level environmental analysis documents, where 

economic efficiency is identified as an issue.

340. Concern Statement: The Forest Service should quantify the value of fish, wildlife, 

plants, and ecosystem service losses and gains resulting from each alternative. 

Response: The Forest Service estimates how agency management activities outlined in 

the Forest Plan including opportunities for fishing, hunting, wildlife viewing, and forest 

products gathering contribute to the regional economy. Data do not show differences in 

opportunities for fishing, hunting, wildlife viewing, and forest products gathering among 

the alternatives analyzed in the Environmental Impact Statement; however, subsequent 

analyses of site-specific projects will have data to show differences among project 

alternatives and outcomes on the ground. The Environmental Impact Statement does 

include a viability assessment for threatened, endangered, Forest Service sensitive, and 

surrogate species (Vol. 2) and evaluates trade-offs among alternatives.

341. Concern Statement: The Forest Service should analyze the effect of road closures and 

limiting motorized use on local economies and communities’ ability to attract new 

industry. Motorized recreation has a significant positive impact on local economies. The 

impact of trail closures and changes in recreation management on the economies of local 

communities should also be assessed.

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. That will be done through travel management planning as defined by the 
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Travel Management Rule. Access is analyzed in the Final Environmental Impact 

Statement and includes a range of alternatives that vary the amount of area (acres) that 

are rated suitable for either motorized or nonmotorized use, and rated for both summer 

and winter use. Subsequent analyses of projects under the Forest Plan will have sitespecific data to show differences among project alternatives and their effects on 

motorized travel. Recreation visitation in general, related to motorized travel 

specifically, is not expected to change under any alternative analyzed in the 

Environmental Impact Statement. Visitor expenditures in rural communities would not 

change under any alternatives. Specifically, the Environmental Impact Statement states:

“For all alternatives, the quantity of recreation visits, including wildlife-related 

recreation, and local visits, to the national forests is not expected to vary from current 

use levels. The current supply of recreational opportunities is expected to exceed 

demand for the foreseeable future. Therefore there is no estimated change to the overall 

level of recreation related expenditures, so no change is estimated for jobs and income 

supported by these expenditures.” (Vol. 1)

342. Concern Statement: The Forest Service should reconsider its assumption that 

recreational visits won’t change regardless of how lands are managed and should 

incorporate an assessment of recreation-related jobs in its analysis of economic and 

social well-being. 

Response: Based on professional judgement and best available information, regional 

office specialists conclude that the supply of recreation opportunities on the three 

National Forests would continue to exceed demand for recreation opportunities under all 

alternatives. Only when demand exceeds supply does a change in recreation 

opportunities have an economic effect. As stated in the Environmental Impact 

Statement: “For all alternatives, the quantity of recreation visits, including wildliferelated recreation, and local visits, to the National Forests is not expected to vary from 

current use levels. The current supply of recreational opportunities is expected to exceed 

demand for the foreseeable future. Therefore there is no estimated change to the overall 

level of recreation related expenditures, so no change is estimated for jobs and income 

supported by these expenditures.” (Vol. 1)

343. Concern Statement: The Forest Service should provide a more complete analysis of the 

social and economic impacts of the alternatives including any reasonably foreseeable 

impacts to the industry infrastructure, local dependent communities, and jobs (logging, 

treating weeds, conducting watershed restoration, etc.). The relationship between 

National Forest management and wood products manufacturing (Goal 3.3.1) should be 

recognized, and details regarding sawlog, non-sawlog and biomass components of the 

current and planned timber harvest should be incorporated. 

Response: The Final Environmental Impact Statement provides analysis of social and 

economic impacts of the alternatives in terms of infrastructure, local communities, and 

natural resource-related jobs. Based on this comment and similar comments, Forest 

Service specialists added more information related to social and economic impacts 

associated with changes in infrastructure as well as the effects of changes in 

infrastructure on local communities and natural resource jobs.

Specifically, the Environmental Impact Statement describes trends related to changes in 

infrastructure, local communities, and natural resource-related jobs. For example, 

“There was a decrease in sawmill production capacity of almost 60 percent” from 1989-

2008. “Manufactured board processing decreased by about 30 percent, and there was 
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close to a 10 percent reduction in plywood and veneer processing. Pulp processing 

capacity remained about the same. Processing capacity is important for several reasons. 

It generates value added jobs and income in addition to those jobs associated with 

logging. Local processing capacity increases the net value of stumpage since it costs 

more to ship logs to distant mills. A higher stumpage value means projects are more 

likely to be economically viable.” (Vol. 1) The effects analysis calculated changes in 

employment and labor income associated with timber harvest on the National Forests.

344. Concern Statement: The Forest Service should consider the social and economic 

impact of reduced grazing. 

Response: The Environmental Impact Statement estimates how the changes in 

permitted animal unit months (AUMs) would affect grazing-related employment and 

labor income. In particular, the analysis describes how: “Changes in forest management 

can affect traditions, lifestyles, and the economic livelihood of residents and 

communities. Those who depend on the national forests for their livelihoods and 

recreation opportunities are concerned that their relationship with the national forests 

may be compromised by other uses and restrictions. Forest Service managers depend on 

their relationships with local communities, people and their institutions to help 

administer the national forests by providing a skilled workforce, labor, manufacturing 

infrastructure, business support, and other services cost effectively. All of these 

relationships are important to sustaining and restoring the ecological integrity of the 

national forests as well as the social and economic conditions of the communities.” ( 

Vol. 1) 

Based on this and similar comments, interdisciplinary team members added more 

detailed descriptions of how changes in permitted animal unit months could affect local 

people’s ability to practice long-held traditions as well as affect lifestyles and the 

livelihoods in local communities.

345. Concern Statement: The Forest Service should include mining in its discussion of 

economic and employment contributions. 

Response: The data indicate that mining accounts for less than 1⁄2 of 1 percent of 

employment in all three socio-economic impact zones. Mining is not a major use on any 

of the three National Forests. None of the alternatives would limit opportunities for 

future mining.

346. Concern Statement: The Forest Service should disclose the rationale and economic 

impact for requiring new or replaced stream crossings to accommodate 20 percent 

greater than 100-year flood events (RMA-RD-5). 

Response: The revised Forest Plan changed the label for this standard to RF-7 and 

updated the standard (RF-7S) as follows: “New or replaced permanent stream crossings 

shall be designed to allow for the 100-year flood and its bedload and debris. 100-year 

flood estimates will reflect the best available science regarding potential effects of 

climate change.” The associated Blue Mountains Aquatic Restoration and Conservation 

strategy modified some standards and guidelines from the existing PACFISH/INFISH 

direction for MA 4B Riparian Management Areas. Revised standard RF-7 (and RF-8 and 

RF-9) help implement direction to incorporate climate change into decision-making, 

especially that pertaining to infrastructure (e.g., USDA Forest Service 2015, Executive 

Order-11988). 
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347. Concern Statement: The Forest Service should more fully address the diversity of 

public opinions on how national forests should be managed in its section on “Social and 

Economic Expectations”. 

Response: The Final Environmental Impact Statement addresses the diversity of public 

opinions in a new section titled “Values, Attitudes, and Beliefs,” which touches on a 

variety of public comments, including comments on access and wilderness.

Social and Economic: Balance with Ecological Analysis

348. Concern Statement: The Forest Service should not allow ecological considerations to 

trump social and economic considerations. Social and economic issues should be a top 

priority. The Forest Service should develop standards, guidelines and additional 

monitoring questions related to social and economic vitality. Social and economic values 

should be reflected in ecological goals and desired conditions. 

Response: The 1982 Planning Rule, and other laws, regulations, and policies direct the 

Forest Service to provide for multiple uses and a sustained yield of goods and services 

from National Forest System lands in a way that maximizes long-term net public 

benefits in an environmentally sound manner. The Federal Land Management Act of 

1976 defines multiple use as “the management of the public lands and their various 

resource values so that they are utilized in the combination that will best meet the 

present and future needs of the American people.” 

The Environmental Impact Statement addresses the variety of national forest resources 

and uses that contribute to employment and income in communities surrounding the 

three National Forests. The social and economic environmental consequences section 

estimates employment and income related to recreation, livestock grazing, timber 

harvesting, Forest Service expenditures, and payments to counties under each alternative 

(Vol. 1). The Environmental Impact Statement analyzes a range of alternatives, which 

differ in their emphases on ecological protection and economic activity. The 

Environmental Impact Statement addresses the economic impact of each alternative and 

describes the effects in the context of each county in the socioeconomic impact zone 

(Vol. 1.). The Environmental Impact Statement describes a variety of human values 

related to biological, ecological, cultural, recreational, economic, and subsistence values, 

among others (Vol. 1). The Environmental Impact Statement assesses how the various 

alternatives would contribute to the values of the residents of the Blue Mountains 

socioeconomic impact zone (Vol. 1). 

349. Concern Statement: The Forest Service should not promote ecological integrity (Goal 

1) at the expense of promoting social well-being (Goal 2) and economic well-being 

(Goal 3). 

Response: The 1982 Planning Rule, and other laws, regulations, and policies direct the 

Forest Service to provide for multiple uses and a sustained yield of goods and service 

from National Forest System lands in a way that maximizes long-term net public 

benefits in an environmentally sound manner. The 1982 Planning Rule maximizes longterm net public benefits in an environmentally sound manner.

350. Concern Statement: The Forest Service should prioritize economics over ecology, and 

the effects of forest plan revision on local residents and communities should be the 

primary decision making criteria for selecting the chosen alternative.
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Response: The 1982 Planning Rule, and other laws, regulations, and policies, direct the 

Forest Service to provide for multiple uses and a sustained yield of goods and service 

from National Forest System lands in a way that maximizes long-term net public 

benefits in an environmentally sound manner. The 1982 Planning Rule maximizes longterm net public benefits in an environmentally sound manner for local residents, 

communities, and regions. Prioritizing economics over ecology would go against law, 

regulation, and policy.

351. Concern Statement: The Forest Service should work to maintain social and economic 

conditions rather than just contribute to these values. 

Response: The Blue Mountains Forest Plans are consistent with law, regulation, and 

policy. Because the Forest Service is one of many factors (including both public and 

private sector factors) that influence social and economic conditions in the Blue 

Mountains region, it is beyond the capacity of the Forest Service to maintain social and 

economic conditions and values. Forest plan decisions do create the framework for a 

range of uses and products and services provided by the Blue Mountains national forests 

that contribute to the economic and social well-being of local communities, counties, 

and American Indian tribes (Vol. 1). In other words, it is possible for the Forest Service 

to contribute to social and economic well-being, but it is not possible for the Forest 

Service to maintain social and economic well-being.

Social and Economic: Coordination

352. Concern Statement: The Forest Service should improve its working relationship with 

people to benefit the forest. 

Response: The Blue Mountains forest plan revision planning team engaged in a series 

of public outreach activities, including public workshops between June and December of 

2015, to understand the interests and concerns of communities near the three National 

Forests. The public workshops addressed the topics of access and wilderness, the pace 

and scale of restoration, and livestock grazing. As a result of these workshops, the 

interdisciplinary team developed two modified alternatives to address public concerns.

Goal 3 of the Plans, Promote Economic Well-being, addresses a variety of national 

forest resources and uses that contribute to human well-being. The desired conditions in 

section 3.3, Goods and Services, emphasize the continued contribution of national forest 

management to private economic activity. The desired condition for 3.3.1, Forest 

Products, is for “a predictable supply of timber outputs, known as the allowable sale 

quantity, contributes to a local forest products industry.” The desired condition for 3.3.2, 

Livestock Grazing, is for “a predictable supply of livestock forage that contributes to 

local ranching operation sustainability.” The desired condition for 3.3.4, Mineral and 

Geological Resources, is that “exploration, development, and production of mineral and 

energy resources contribute to the social and economic needs of the nation, as well as 

local communities.” Opportunities to use national forest resources for economic 

development on the National Forests will only occur if private interest exists and market

conditions allow individuals to take advantage of these opportunities.

Social and Economic: Desired Conditions

353. Concern Statement: The Forest Service should clarify how it determined desired 

conditions and should acknowledge that the plans do not meet the desired conditions of 

local residents. 
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Response: The desired conditions are based on best available scientific information, 

law, regulations, and policy, and the interests of the public and other stakeholders. Local 

residents’ comments are one of many inputs in the decision-making process. Some local 

communities and stakeholders have different interests than others related to the 

management of national forests. The social analysis includes a “Values, Beliefs, and 

Attitudes” section that highlights these differences among the desires of local residents 

and communities. The Forest Plans, the Environmental Impact Statement, and the 

decisionmaker strive to balance the different desires among stakeholders and local 

communities. Based on public comments, the Final Environmental Impact Statement

includes modified alternatives to better capture the range of public values. 

The mission of the Forest Service is “To sustain the health, diversity, and productivity of 

the Nation's forests and grasslands to meet the needs of present and future generations.” 

National forests are managed for the benefit of all Americans. The Blue Mountains 

Forest Plan is consistent with law, regulation, and policy, and addresses ecological, 

social, and economic consequences of forest management. The forest plan revision 

balances a broad spectrum of laws, regulations, and policies, including the Multiple-Use 

Sustained-Yield Act, which emphasizes a sustainable flow of benefits to communities, 

and the Endangered Species Act, which mandates protection of endangered species. 

Forest Service decisions balance the desires of local residents and communities with 

national goals and seek to provide the greatest good for the nation as a whole in the long 

run. 

354. Concern Statement: The Forest Service should include county services and schools in 

its desired condition for community resilience and should acknowledge the importance 

of Forest Service management for these issues. 

Response: The Plans identify community resilience as a desired condition. Local 

counties and communities that rely on the resources of the Blue Mountains national 

forests are resilient and adapt well to changing conditions (Forest Plan, Goal 2.9). For 

example, the management of the Blue Mountains national forests contributes to outputs 

and opportunities that support county infrastructure. The national forests foster healthy 

and resilient communities by providing sustainable ecological services and products. In 

turn, communities use their infrastructure (which includes manufacturing facilities, local 

knowledge, skilled workers, and social networks/relationships) to support natural 

resource management and restoration activities. 

While the Plans identify community resilience as a desired condition, the Forest Service 

cannot quantify the relationship between forest management and community resilience 

due to lack of data. In response to comments on community resilience, the Social 

Affected Environment section was updated with data that show trends in available social 

well-being in the Plan Area.

355. Concern Statement: The Forest Service should add an overarching desired condition 

for goods and services that focuses on providing meaningful, quantifiable and 

sustainable goods and services on annual basis. 

Response: The Environmental Impact Statement provides a quantitative evaluation of a 

range of alternatives that are based on desired conditions in the Forest Plans. Desired 

conditions themselves are qualitative and not quantifiable elements of Forest Plans. 

Within the Goods and Services section of the Forest Plans, there are desired conditions 

for forest products, livestock grazing, special uses, mineral and geological resources, 

and water use.
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356. Concern Statement: The Forest Service should include desired conditions for goods 

and services like clean water and recreation. 

Response: The Forest Plans contain direction for protecting soil, water, and air 

resources consistent with the Clean Water and Clean Air Acts. The information is 

located in the sections entitled: Water Use (section 3.3.5), Recreation (2.3), Community 

Resilience (2.11), and Scenery (2.1). All of the alternatives described in the 

Environmental Impact Statement are designed to provide adequate opportunities for 

motorized and nonmotorized recreation. 

Social and Economic: Economic Well-being 

357. Concern Statement: The Forest Service should revise Goal 3 (Promote Economic Wellbeing) to focus on the development of a strong relationship between the Forest Service 

and local communities, people, and institutions to help manage National Forests. 

Response: The Forest Service is working on developing stronger relationships with 

local communities and stakeholders. For example, local communities requested greater 

recognition of the important ties between social and economic well-being. The revised 

Forest Plans now recognize that social well-being is inextricably linked to economic 

well-being. In section 2.9 on Community Resilience, the Forest Plans state, “The Forests 

are important to the resiliency of local communities and Tribes because residents benefit 

from jobs and income produced from management activities, such as timber harvesting, 

livestock grazing, and mining. The Forests also provide the context and source for clean 

water and air, culturally significant foods relating to treaty-reserved rights, wildlife, 

recreation opportunities, and landscape settings that contribute to residents’ quality of 

life and the character of local communities and Tribes.” The Forest Plans identify goals 

for multiple forest resources and uses, including outdoor recreation (sections 2.2, 2.3, 

2.4, 2.5, 2.7, 3.1, 3.3.3), range (section 3.3.2), timber (sections 2.9, 3.3.1), watershed 

(sections 1.1, 1.11, 3.3.5), and wildlife and fish (sections 1.2, 1.13, 2.3.1, 2.4, 2.6). As a 

result of public workshops and meetings with cooperating agencies, the interdisciplinary 

team developed two additional modified alternatives to address the public concerns.

Goal 3, Promote Economic Well-being, addresses a variety of forest resources and uses 

that contribute to human well-being. The desired conditions in section 3.3, Goods and 

Services, emphasize the continued contribution of forest management to private 

economic activity. The desired condition for 3.3.1, Forest Products, is for “a predictable 

supply of timber outputs, known as the allowable sale quantity, contributes to a local 

forest products industry.” The desired condition for 3.3.2, Livestock Grazing, is for “a 

predictable supply of livestock forage that contributes to local ranching operation 

sustainability.” The desired condition for 3.3.4, Mineral and Geological Resources, is 

that “exploration, development, and production of mineral and energy resources 

contribute to the social and economic needs of the nation, as well as local communities.” 

Opportunities to use national forest resources for economic development will only occur 

if private interest exist and markets conditions allow individuals to take advantage of 

these opportunities. 

The Environmental Impact Statement addresses the variety of national forest resources 

and uses that contribute to employment and income in communities surrounding the 

National Forests. The social and economic environmental consequences section 

estimates employment and income related to recreation, livestock grazing, timber 

harvesting, Forest Service expenditures, and payments to counties under each alternative 
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(Vol. 1). Additionally, the Environmental Impact Statement analyzes a range of 

alternatives, which differ in their emphases on ecological protection and economic 

activity. The Environmental Impact Statement addresses the economic impact of each 

alternative and describes the effects in the context of each county in the socioeconomic 

impact zone (Vol. 1). Additionally, the Environmental Impact Statement describes a 

variety of human values related to biological, ecological, cultural, recreational, 

economic, and subsistence values, among others (Vol. 1). The Environmental Impact 

Statement assesses how the various alternatives would contribute to the values of the 

residents of the Blue Mountains socio-economic impact zones (Vol. 1).

To further improve the Forest Service’s relationship with local communities and 

stakeholders, the Blue Mountains revision planning team engaged in a series of public 

outreach activities, including public workshops between June and December of 2015, to 

understand the interests and concerns of communities near the Blue Mountains national 

forests. The public workshops addressed the topics of access and wilderness, the pace 

and scale of restoration, and livestock grazing.

358. Concern Statement: The Forest Service should not include “facilities and 

infrastructure” and “land ownership” in its goal of promoting economic well-being. The 

importance of tourism, access and recreation to local economies should be recognized. 

Response: Facilities, infrastructure, and land ownership are key to human interaction 

with National Forest System lands and, therefore, the provision of goods and services. 

For example, roads (infrastructure) enable access for logging, recreation, and grazing 

permittees. Additionally, the Environmental Impact Statement addresses the economic 

impact of multiple resource uses on National Forest System lands, including timber, 

recreation, and grazing (Vol. 1). 

In the decision-making process, the Forest Service strives to balance the different 

interests of stakeholders related to the management of National Forests, including 

economic interests associated with facilities, land ownership, and infrastructure. The 

social analysis includes a “Values, Beliefs, and Attitudes” section that highlights these 

differences among the desires of local residents and communities. The Forest Plans, 

Environmental Impact Statement and the decision-maker strive to balance the different 

desires among stakeholders and local communities. Based on public comments, the 

Final Environmental Impact Statement includes modified alternatives to better capture 

the range of public values.

359. Concern Statement: The Forest Service should not combine social and economic 

considerations in its management. 

Response: The social and economic considerations are enumerated separately in the 

Forest Plans. The revised, “Social and Economic Well-being” section of the 

Environmental Impact Statement analyzed some social and economic considerations 

separately. However, many social and economic considerations are inextricably linked 

together, therefore separating them is not appropriate. In addition, the Final 

Environmental Impact Statement addresses social conditions, including the diversity of 

public opinions. There is a section on “Values, Attitudes, and Beliefs” based on public 

comments in the Final Environmental Impact Statement. 

In the decision-making process, the Forest Service strives to balance the different 

interests of stakeholders related to the management of National Forests, including the 

relationship between social and economic concerns. While some commenters requested 
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that the social and economic concerns are separated, others requested that the social and 

economic concerns are linked. The “Values, Beliefs, and Attitudes” section highlights 

these differences among the desires of local residents and communities. The Forest 

Plans, Environmental Impact Statement and the decisionmaker strive to balance the 

different desires among stakeholders. 

360. Concern Statement: The Forest Service should recognize the inextricable links 

between social well-being and economic well-being, for example through living-wage 

jobs, and should do a better job of demonstrating the link between ecological integrity 

and the social and economic components of the plan. The Forest Service should also 

recognize that the plan’s desired conditions inhibit the ability of the Forest Service to 

promote social well-being and meet its multiple use mandate. 

Response: See the previous response to the comment above this one.

361. Concern Statement: The Forest Service should not be compelled to incorporate special 

management areas, especially those with limited motor or no vehicle use that conflict 

with social and economic well-being. These include MA2A Wild and Scenic River, 

MA2B Research Natural Areas and MA 2J Municipal Watersheds. 

Response: While the Forest Service recognizes that some stakeholders believe that the 

Agency should not be compelled to incorporate special management areas in the Plan 

Area, the Forest Service must balance access and resource protection according to law, 

regulation and policy. The Forest Service strives to meet user needs and accessibility 

guidelines. The Forest Service also recognizes that motorized access is an important 

component of forest management. In forest planning, the Agency balances a variety of 

resources affected by open roads and motorized use. 

The planning regulations (36 CFR 219.2, 1982) state: “The regulations in the subpart 

apply to the National Forest System, which includes special areas, such as wilderness, 

wild and scenic rivers, national recreation areas, and national trails.” Special 

management areas are generally established either administratively or congressionally 

and are intended to conserve areas with unique characteristics, and that represent special 

attributes that compel additional management considerations outside of those prescribed 

for general forest settings. 

For research natural areas, the Forest Plan is designed to comply with planning 

regulations at 36 CFR 219.25 – Research natural areas (1982), “Forest planning shall 

provide for the establishment of research natural areas. Planning shall make provision 

for the identification of examples of important forest, shrubland, grassland, alpine, 

aquatic, and geologic types that have special or unique characteristics of scientific 

interest and importance and that are needed to complete the national network of research 

natural areas.” Research natural areas are available for research, study, observation, 

monitoring, and educational activities, uses that typically are non-destructive and nonmanipulative. Management Area 2B – Research Natural Areas, generally comprise less 

than one percent of the Planning Area and do not detract significantly from management 

activities associated with General Forest allocations: specifically, Management Area 2B 

comprises 0.6 percent of the Malheur National Forest, 0.8 percent of the Umatilla 

National Forest, and 0.5 percent of the Wallowa-Whitman National Forest. 

Similarly, Management Area 2A (Wild and Scenic River) comprises less than four 

percent of the Planning Area (Malheur is 0.7%, Umatilla is 3.2%, and WallowaWhitman is 3.0%). Motor vehicle use is considered a suitable use in river segments 
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classified as either scenic or recreational; river segments classified as wild generally 

overlap with designated Wilderness, where prohibitions provided in The Wilderness Act 

apply. While roughly three percent of MA 2A is rated unsuitable for motor vehicle use, 

the actual value is less given the consideration for river segments classified as scenic 

and recreational. 

Management Area 2J (Municipal Watersheds) is an administrative determination, and in 

some cases is established by the Department of Agriculture. These areas generally 

comprise less than one percent of the Planning Area with the Malheur at 0.03%, and 

both the Umatilla and Wallowa-Whitman at 1.4%. 

The combined management area allocations for Management Areas 2A, 2B, and 2J for 

the three National Forests is 3.8 percent, and does not detract significantly from 

management activities associated with General Forest allocations and general access 

across the National Forests. Activities proposed within or adjacent to these management

areas would be evaluated through project level planning and comply with the National 

Environmental Policy Act including public involvement and participation. 

362. Concern Statement: The Forest Service should not support economic well-being at the 

expense of conservation. The natural beauty and protected areas National Forests 

provide are important to the well-being of city dwellers and support recreational use and 

local economies. 

Response: The Forest Service balances social, economic, and ecological well-being as 

well as the desires of local and non-local stakeholder groups. The projected 

consequences to well-being and the economy, along with the ecological consequences, 

are all given consideration by the decision-maker. The Environmental Impact Statement 

presents analysis for a range of alternatives.

Social and Economic: Grazing 

363. Concern Statement: Grazing plays a key role in supporting the economies of local Blue 

Mountains communities and should not be reduced because of a “likely benefit” to 

aquatic species and their habitats. Grazing numbers could fall below those characterized 

in the plan because the proposed plan would make grazing less viable. 

Response: Livestock grazing plays an important role in the economies of the Blue 

Mountain communities. 

The Final Environmental Impact Statement evaluates a range of alternatives related to 

livestock grazing and addresses the economic impact of changes in livestock numbers 

on the three National Forests (Vol. 1). The Forest Plans propose some potential changes 

to grazing practices, but no reduction in livestock grazing is expected to result due to the 

standards and guidelines that are designed to protect fish and their habitat. Management 

actions under the preferred alternative would not reduce permitted livestock grazing 

relative to current conditions. Below are the estimated jobs supported by livestock 

grazing on the three National Forests.

Estimated jobs supported by livestock grazing on national forests, by alternative

National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

Malheur 426 435 204 432 426 426 460 460
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National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

Umatilla 187 155 23 165 165 165 244 244

WallowaWhitman282 264 112 292 274 274 379 379

Estimated labor income supported by livestock grazing on national forests, by alternative 

(thousands of dollars, 2014)

National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

Malheur $7,690 $7,875 $3,851 $7,814 $7,690 $7,690 $8,296 $8,296

Umatilla $2,653 $2,445 $301 $2,481 $2,481 $2,481 $3,453 $3,453

WallowaWhitman$5,077 $4,820 $1,858 $5,262 $5,005 $5,005 $6,959 $6,959

Based on the values presented in the above tables, Alternative E-Modified presents the 

highest values for both estimated jobs and estimated labor income supported by 

livestock grazing compared to the other action alternatives, and is an increase compared 

to current values presented for Alternative A, the “No Action” alternative. The National 

Forest Management Act requires the Forest Service to address rangeland capability and 

suitability, but stocking decisions for specific grazing allotments are made through sitespecific environmental analyses.

364. Concern Statement: The Forest Service should analyze the impact to local economies 

from reduced grazing to recover anadromous fish and bull trout restrictions and the 

difference in stream impact between the detrimental grazing levels of the past and 

current levels. The Forest Service should clearly state the relationship between animal 

unit months and economic effect. 

Response: Livestock grazing plays an important role in the economies of the Blue 

Mountain communities. 

The Final Environmental Impact Statement evaluates a range of alternatives related to 

livestock grazing and addresses the economic impact of changes in livestock numbers 

on the three National Forests (Vol. 1). The Forest Plans propose some potential changes 

to grazing practices, but no reduction in livestock grazing is expected to result due to the 

standards and guidelines that are designed to protect fish and their habitat. Management 

actions under the preferred alternative would not reduce permitted livestock grazing 

relative to current conditions. Below are the estimated jobs supported by livestock 

grazing on the three National Forests.

Estimated jobs supported by livestock grazing on national forests, by alternative

National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

Malheur 426 435 204 432 426 426 460 460

Umatilla 187 155 23 165 165 165 244 244
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National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

WallowaWhitman282 264 112 292 274 274 379 379

Estimated labor income supported by livestock grazing on national forests, by alternative 

(thousands of dollars, 2014)

National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E Alt. F

Alt. E 

Mod

Alt. E 

Mod 

(Dep)

Malheur $7,690 $7,875 $3,851 $7,814 $7,690 $7,690 $8,296 $8,296

Umatilla $2,653 $2,445 $301 $2,481 $2,481 $2,481 $3,453 $3,453

WallowaWhitman$5,077 $4,820 $1,858 $5,262 $5,005 $5,005 $6,959 $6,959

Based on the values presented in the above tables, Alternative E-Modified presents the 

highest values for both estimated jobs and estimated labor income supported by 

livestock grazing compared to the other action alternatives, and is an increase compared 

to current values presented for Alternative A, the “No Action” alternative. The National 

Forest Management Act requires the Forest Service to address rangeland capability and 

suitability, but stocking decisions for specific grazing allotments are made through sitespecific environmental analyses.

Concern Statement: The Forest Service should analyze the effect of both forest plan 

grazing restrictions and sage grouse amendments on local communities. 

Response: The Final Environmental Impact Statement includes updated social and 

economic cumulative effects analysis, which addresses sage-grouse amendments. 

Social and Economic: Manage for Social and Economic Benefits 

365. Concern Statement: The Forest Service should make the desires of local communities 

the primary decision-making criteria for selecting an alternative and should develop an 

alternative that better reflects the desired conditions of local residents. 

Response: The Blue Mountains forest plan revision planning team engaged in a series 

of public outreach activities, including public workshops between June and December of 

2015, to understand the interests and concerns of communities near the Blue Mountains 

national forests. The public workshops addressed the topics of access and wilderness, 

the pace and scale of restoration, and livestock grazing. The Final Environmental Impact 

Statement has been updated to include two additional alternatives, Alternative EModified and Alternative E-Modified Departure. These alternatives were developed at 

public request to address the desires of local communities. They respond to concerns 

about the pace and scale of forest restoration as well as community well-being. 

Local residents’ comments are one of many inputs in the decision-making process. Some 

local communities and stakeholders have different interests than others related to the 

management of national forests. The social analysis includes a “Values, Beliefs, and 

Attitudes” section that highlights these differences among the desires of local residents 

and communities. The Forest Plans, Environmental Impact Statement, and the decisionmaker strive to balance the different desires among stakeholders and local communities. 
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The mission of the Forest Service is “To sustain the health, diversity, and productivity of 

the Nation's forests and grasslands to meet the needs of present and future generations.” 

National forests are managed for the benefit of all Americans. The Blue Mountains 

Forest Plans are consistent with law, regulation, and policy, and addresses ecological, 

social, and economic consequences of forest management. The forest plan revision 

balances a broad spectrum of laws, regulations, and policies, including the Multiple-Use 

Sustained-Yield Act, which emphasizes a sustainable flow of benefits to communities, 

and the Endangered Species Act, which mandates protection of endangered species. 

Law, regulation, and policy prevents the Forest Service from making the desires of local 

residents and communities the primary decision-making criterion. 

366. Concern Statement: The Forest Service should increase the plan’s focus on supporting 

social and economic well-being of local communities through grazing, logging, mining 

and access for recreation and subsistence needs. Managing for economic outputs would 

support rather than hinder healthy and vibrant rural communities, such as through timber 

payments to support county services. Logging levels to support local mill infrastructure 

and increased promotion of access for hunting and recreation would help provide 

community stability and support high quality local jobs. 

Response: The Final Environmental Impact Statement has been updated to include two 

additional alternatives, Alternative E-Modified and Alternative E-Modified Departure. 

These alternatives were developed at public request to address concerns about the pace 

and scale of forest restoration. The table below shows the total number of jobs 

attributable to timber volume sold, livestock grazing, and outdoor recreation on each 

national forest under each alternative considered in the Final Environmental Impact 

Statement. 

Total direct, indirect, and induced employment contribution by national forest

National 

Forest Alt. A Alt. B Alt. C Alt. D Alt. E

Alt. EModified

Alt. EModified 

Departure Alt. F

Malheur 644 726 338 1,241 921 959 1,225 787

Umatilla 483 550 195 1,234 750 818 1,174 655

WallowaWhitman520 596 268 1,323 923 1,043 1,342 715

The primary source of variation in the number of jobs across alternatives is the expected 

volume of timber sold. Alternative E-Modified and Alternative E-Modified Departure 

would increase the pace and scale of forest restoration relative to current management.

367. Concern Statement: The Forest Service should consider the socio-economic 

importance of increasing landscape fire resilience to protect recreational areas and other 

investments from wildfire. In addition, it should recognize that utilization of surface 

fuels would support economic development of the biofuels industry. 

Response: The planning team engaged in a series of public outreach activities, including 

public workshops between June and December of 2015, to understand the interests and 

concerns of communities near the three National Forests. The public workshops 

addressed the topics of access and wilderness, the pace and scale of restoration, and 

livestock grazing.
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Based on public input and best available science, the Final Environmental Impact 

Statement includes a range of alternatives related to managing for fire resilience. The 

social and economic analysis evaluates the employment and labor income consequences 

of active restoration and the forest products produced by these treatments, including 

woody biomass (non-sawtimber, see Vol. 1). Small-diameter trees may be used in the 

development of a biofuels industry. The existing forest products industry infrastructure 

could be used in the development of a woody biomass industry. The Final 

Environmental Impact Statement captures the expected economic contribution of forest 

product harvesting on the National Forests. 

368. Concern Statement: The Forest Service should address the Custom and Culture 

statements developed by Grant and Wallowa Counties. 

Response: The Forest Service recognizes a local belief in independence and selfsufficiency of land owners. The Final Environmental Impact Statement includes an 

expanded “Values, Beliefs, and Attitudes” section, which incorporates information from 

county officials and a variety of other stakeholders, including the custom and culture 

statements of Grant and Wallowa Counties. 

369. Concern Statement: The Forest Service should not log forests as they contribute to 

quality of life and are valuable economic assets that provide water purification, flood 

control, slope stability, habitat, and other services. 

Response: The mission of the Forest Service is “To sustain the health, diversity, and 

productivity of the Nation's forests and grasslands to meet the needs of present and 

future generations.” National Forests are managed for the benefit of all Americans. The 

Blue Mountains Forest Plans are consistent with law, regulation, and policy, and 

addresses ecological, social, and economic consequences of forest management. The 

Forest Plan revision balances a broad spectrum of laws, regulations, and policies, 

including the Multiple-Use Sustained-Yield Act, which emphasizes a sustainable flow of 

benefits to communities and the Endangered Species Act, which mandates protection of 

endangered species. Active restoration of the Blue Mountains national forests is an 

important part of improving forest resilience. 

We recognize that some stakeholders are opposed to any timber harvest activities on the 

National Forests, while other stakeholders urge additional timber harvesting on the 

National Forests. Local residents’ comments are one of many inputs in the decisionmaking process. Some local communities and stakeholders have different interests than 

others related to the management of national forests. The social analysis includes a 

“Values, Beliefs, and Attitudes” section that highlights these differences among the 

desires of local residents and communities. The Forest Plans, Environmental Impact 

Statement and the decisionmaker strive to balance the different desires among 

stakeholders and local communities. Based on public comments, the Final 

Environmental Impact Statement includes two additional alternatives to better capture 

the range of public values.

370. Concern Statement: The Forest Service should provide an economic assessment of a 

recovered bighorn sheep population. 

Response: The Final Environmental Impact Statement addresses a range of alternatives 

that consider reducing the risk of disease transmission from domestic sheep to bighorn 

sheep. The Forest Service lacks the data necessary to conduct a quantitative economic 

impact analysis of bighorn sheep populations in the planning area. Changes in economic 
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305

activity due to changes in the bighorn sheep population are unknown. Furthermore, 

potential changes in the bighorn sheep population are unknown. Population goals for 

bighorn sheep are established by the Oregon Department of Fish and Wildlife.

Social and Economic: Mining

371. Concern Statement: The Forest Service should re-assess the local economic benefits of 

mining, including from small operations, in terms of jobs and money spent on fuel, food 

and other supplies. Such analysis should consider economic benefits and potential losses 

(from precluding mining) for road construction, building stone, and valuable minerals. 

The Forest Service should include mining on the list of jobs created on public lands. 

Response: None of the alternatives would limit opportunities for future mining. The 

economic section of the Final Environmental Impact Statement includes data on the 

current size of the mining sector in each of the three socio-economic impact zones and 

the Forest Service’s contribution to employment and labor income in the mining sector 

(Vol. 1). The data indicate that mining accounts for less than 1⁄2 of 1 percent of 

employment in all three socioeconomic zones. Mining is not a major use on any of the 

three National Forests.

Social and Economic: Social Well-being

372. Concern Statement: The Forest Service should disclose how past management has 

affected community resilience in terms of lost jobs and poverty levels due to a lack of 

utilization of natural resources. In addition, it should support maintenance of permanent 

community infrastructure that provides living-wage jobs and use true attributes of 

community resilience rather than scenery and old forests, for instance. It should 

acknowledge that reductions in access, recreation opportunities, timber harvest and 

grazing negatively affect community resilience. Rather than limit these opportunities, 

the Forest Service should increase them. 

Response: The Final Environmental Impact Statement describes current conditions and 

trends related to community resilience, including both demographic characteristics and 

changes in natural resource utilization (e.g., changes in forest product removal and 

processing capacity). Additionally, the Final Environmental Impact Statement estimates 

how forest management actions contribute to employment and labor income in the areas 

that surround the National Forests (Vol. 1). The alternatives offer a range of natural 

resource utilization and Alternative E-Modified would increase timber volume sold 

relative to current management. 

The Forest Plans recognize the positive contributions to local communities to national 

forests. For example, Goal 3 of the Forest Plans recognizes “the interdependency 

between the Forest Service’s need for forest management work and the degree to which 

local industries, infrastructure, employment (including youth), skilled workforce, and 

other factors provide for this need is important to sustaining and restoring the ecological 

integrity of the national forests and social and economic conditions of the 

communities...Recognizing mutual benefits of the relationships between local 

communities and the national forests is critical to understanding the contributions to the 

maintenance and enhancement of other desired conditions, such as healthy forests, clean 

water and air, scenery, cultural and historic resources, skilled workforce, and 

manufacturing infrastructure in the context of other local, regional, and national 

conditions.” 
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The Environmental Impact Statement address the relationship between Forest Service 

management and local economies. “The quantity and quality of forest products and 

services provided by the national forests contribute to the local economy and the 

maintenance of local infrastructure. Infrastructure and the local workforce, in turn, play 

a critical role in the capacity of national forests to conduct forest management activities. 

The mix of uses, products, and services the Forest Service expects to provide over time 

will be stated in the forest plans” (Vol. 1). Many comments requested that the 

Environmental Impact Statement recognize the economic importance of public lands to 

local economies. The Environmental Impact Statement includes an economic impact 

analysis of forest outputs to the three socio-economic impact zones. The economic 

analysis uses the finest geographic scale possible, functional economic areas containing 

multiple counties, using standard methodologies. The Final Environmental Impact 

Statement includes a revised and expanded social and economic cumulative effects 

analysis (Vol. 1). 

373. Concern Statement: The Forest Service should include subsistence needs as an 

attribute of social well-being and community resilience. Such needs include access for 

firewood and other resources. A more comprehensive list of services provided by the 

ecosystems should be included (for example as a table), which could be clearly linked to 

benefits for local residents. 

Response: The social values section of the final EIS addresses the relationship between 

subsistence and well-being (Vol 1). The final EIS includes more detail on subsistence 

needs, access for firewood, and other resources in the social and economic section. 

374. Concern Statement: The Forest Service should not include old forest and old trees as a 

social well-being issue. 

Response: As the management direction and plan components relating to old forest are 

primarily driven by its ecological importance, this section has been placed under the 

goal of “Promoting Ecological Integrity” within the Forest Plans. As described in the 

“Values, Attitudes, and Beliefs” portion of the Final Environmental Impact Statement, 

stakeholders have a variety of views and preferences related to old forest management. 

The alternatives adopt a range of management actions to address forest health. We 

acknowledge that a wide spectrum of social and ecological values are associated with 

old forests. Old forests are some of the most ecologically and socially valuable 

successional stages in the Pacific Northwest. Old forests of the Blue Mountains are 

expected to provide myriad benefits to humans. Various groups find old forests 

aesthetically pleasing, culturally significant, ecologically important, economically 

valuable as a sustainable timber resource, and necessary for a landscape that is healthy 

and resilient to natural disturbances.

Social and Economic: Timber

375. Concern Statement: The Forest Service should provide a predictable flow of timber to 

support mills, loggers, truckers, other local jobs, county government and public services. 

Better support of logging and milling infrastructure will help retain the capacity needed 

to restore national forest lands. The Forest Service should provide incentives to foster 

development of new forest-related industry and should support more mill competition. 

Response: The Final Environmental Impact Statement has been updated to include two 

additional alternatives. These alternatives were developed at public request to address 

concerns about the pace and scale of forest restoration. Alternative E-Modified would 
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support increased timber sale volumes relative to current management while also 

providing a predictable (non-declining) flow of timber. 

The analysis shows that most of the counties in the Blue Mountains Forest Plan 

Revision socio-economic impact zones have medium high to high dependence on timber 

and relatively low socio-economic resiliency (Vol. 1). The analysis also notes that 

natural disturbances and market conditions, largely outside the control of Forest Service 

management, can affect the flow of timber from the national forests (Vol. 1). The 

alternatives analyzed in the Environmental Impact Statement provide a range of 

predicted timber outputs, with Alternative D offering the most volume and Alternative C 

the least (Vol. 1). The range of alternatives enables a comparison of the socio-economic 

consequences of timber management on the Blue Mountains national forests. The 

Environmental Impact Statement discloses the expected timber-related employment and 

labor income contributions from management under each alternative (Vol. 1). The 

economic impacts of timber harvested from National Forest System lands are analyzed 

in the context of timber dependency and low socioeconomic resiliency. The analysis 

notes under which alternatives timber output may be adequate to support existing wood 

manufacturing infrastructure (Vol. 1).

376. Concern Statement: The Forest Service should support increased timber harvest that 

has been made possible through the collaborative process and should meet its 

commitment of providing 75 MMBF for the 10-year stewardship contract.

Response: The Final Environmental Impact Statement has been updated to include two 

additional alternatives. These alternatives were developed at public request to address 

concerns about the pace and scale of forest restoration. Alternative E-Modified would 

support increased timber sale volumes relative to current management. 

377. Concern Statement: The Forest Service should not state that levels of timber harvest 

and resulting employment under alternatives D and E may be enough to support and 

possibly expand wood manufacturing infrastructure and that many people in the timber 

industry are adapting their skills and infrastructure to support a restoration-based 

economy. 

Response: The social and economic environmental consequences analysis has been 

revised in the Final Environmental Impact Statement. The analysis notes that Alternative 

D, Alternative E-Modified, and Alternative E-Modified Departure would increase timber 

volume sold and timber-related employment and labor income in the socio-economic 

impact zones. However, the analysis no longer states that wood manufacturing 

infrastructure may be expanded due to Forest Service management actions. 

Social and Economic: Tribal Economics

378. Concern Statement: The Forest Service should incorporate the Tribe’s role and 

contribution to the economy of the Blue Mountains National Forests. 

Response: Forest plan decisions create the framework for the range of uses and products 

and services provided by the Blue Mountains national forests that contribute to the 

economic and social well-being of local communities, counties, and American Indian 

Tribes (Vol 1). While we recognize the Tribe’s role and contribution to the economy of 

the Blue Mountain National Forests, the Environmental Impact Statement does not 

enumerate these roles and contributions because the Blue Mountain Forest Plan does not 

affect the contributions.
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Social and Economic: Vision

379. Concern Statement: The Forest Service should represent social and economic 

expectations and issues in a positive light and should recognize that local residents rely 

greatly on “recreational” use of public lands to fulfill social and economic needs. 

Response: The Forest Plans recognize the positive contributions of local communities to 

national forests. For example, Goal 3 of the Forest Plan recognizes “the interdependency 

between the Forest Service’s need for forest management work and the degree to which 

local industries, infrastructure, employment (including youth), skilled workforce, and 

other factors provide for this need is important to sustaining and restoring the ecological 

integrity of the national forests and social and economic conditions of the 

communities...Recognizing mutual benefits of the relationships between local 

communities and the national forests is critical to understanding the contributions to the 

maintenance and enhancement of other desired conditions, such as healthy forests, clean 

water and air, scenery, cultural and historic resources, skilled workforce, and 

manufacturing infrastructure in the context of other local, regional, and national 

conditions.” 

The Final Environmental Impact Statement includes a “Values, Attitudes, and Beliefs” 

section, which aims to capture the diverse views of local community members and other 

stakeholders regarding national forest management. This section addresses values, 

beliefs, and attitudes related to access, economic and social well-being, livestock 

grazing, old forests, recommended additions to the National Wilderness Preservation 

System, and ecological resilience. The Final Environmental Impact Statement considers 

a range of alternatives, all of which will continue to provide plentiful recreation 

opportunities on the Blue Mountains national forests. 

380. Concern Statement: The Forest Service should manage the national forests for the 

benefit of the people. 

Response: The mission of the Forest Service is “To sustain the health, diversity, and 

productivity of the Nation's forests and grasslands to meet the needs of present and 

future generations.” National forests are managed for the benefit of all Americans. 

As stated in the Forest Plans, the Forest Service balances a variety of public interests as 

well as law, regulation, and policy. The Forest Plans describe the challenges of this 

balance in the “Vision” section, noting that “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.” 

Social and Economic: Wilderness

381. Concern Statement: The Forest Service should protect wildlands, including roadless 

areas and wild rivers, due to economic, social, and ecological reasons, particularly to 

provide important recreation opportunities. 

Response: The Environmental Impact Statement provides a range of alternatives, 

including two alternatives with no preliminary administratively recommended 

wilderness (Alternatives A and D) and one that recommends more than half a million 

additional acres of wilderness (Alternative C). The economic impact analysis show the 
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economic consequences of wilderness designation (Vol. 1). Alternative C has the highest 

shares of preliminary administratively recommended wilderness areas across the three 

National Forests. As a result of increased wilderness and other management actions 

under Alternative C, this alternative would support lower levels of employment and 

labor income in forest resource extraction (timber and grazing). The effect of 

preliminary administratively recommended wilderness on ecological integrity is 

addressed in resource analyses throughout the Environmental Impact Statement. 

In the decision-making process, the Forest Service strives to balance the different 

interests of stakeholders related to the management of national forests, including 

preliminary administratively recommended wilderness areas. While some commenters 

requested more recommended wilderness, others requested that the Forest Service 

consider no recommended wilderness. The updated analysis includes a “Values, Beliefs, 

and Attitudes” section that highlights these differences among the desires of local 

residents and communities. The Forest Plans, Environmental Impact Statement and the 

decision-maker strive to balance the different desires among stakeholders. 

382. Concern Statement: The Forest Service should limit wilderness because it has negative 

economic impacts, in several ways: (1) minimizes the number of natural resourcerelated jobs, (2) loss of income from motorized users, and (3) loss of county tax 

revenues. An economic analysis for proposed wilderness must be part of the 

environmental, economic and social well-being analysis.

Response: The Environmental Impact Statement provides a range of alternatives, 

including two alternatives with no preliminary administratively recommended 

wilderness (Alternatives A and D) and one that recommends more than half a million 

additional acres of wilderness (Alternative C). The economic impact analysis show the 

economic consequences of wilderness designation (Vol. 1). Alternative C has the highest 

shares of preliminary administratively recommended wilderness areas across the three 

National Forests. As a result of increased wilderness and other management actions 

under Alternative C, this alternative would support lower levels of employment and 

labor income in forest resource extraction (such as timber and grazing).

In the decision-making process, the Forest Service strives to balance the different 

interests of stakeholders related to the management of national forests, including 

preliminary administratively recommended wilderness areas. While some commenters 

requested more recommended wilderness, others requested that the Forest Service 

consider no additional wilderness. The updated analysis includes a “Values, Beliefs, and 

Attitudes” section that highlights these differences among the desires of local residents 

and communities. The Forest Plans, Environmental Impact Statement and the decisionmaker strive to balance the different desires among stakeholders.

Soil 

Soil: Productivity and Health

383. Concern Statement: The Forest Service should clarify where soils currently vary from 

desired soil conditions and how soils will be monitored to determine if the desired 

condition is met. The Forest Service should establish a soil quality index for the Blue 

Mountains to support measurement of soil health and damage. 
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Response: A forest plans is a programmatic level document and as such does not 

include site-specific or decision determinations. When projects are proposed at a sitespecific level, supporting documents will be provided to accompany proposed 

recommendations in the associated environmental analysis before a determination can 

be made (i.e., a soils map with descriptions of the soil types, soil survey data, and data 

or literature to support assumptions and conclusions, along with records of how 

vegetation has moved toward desired conditions (or not) over time).

The reasons for why desired conditions may not be met are typically associated with 

high levels of disturbance. Roads, timber harvest, developed and undeveloped 

recreation, and animal grazing (both managed and unmanaged) are common causes of 

disturbance. This is not to say all disturbance is detrimental, since the soil has some 

level of inherent resilience. However, the greater the disturbance, the more opportunity 

for detrimental conditions to arise. 

Monitoring to determine a change from desired condition is in place and will continue in 

the form of best management practices monitoring (throughout various forest practices), 

after-action activity assessments, and environmental analysis of existing and estimated 

detrimental soil conditions.

384. Concern Statement: The Forest Service should include a discussion of landslides as 

well as goals, objectives, and standards and guidelines to manage landslide-prone areas. 

Response: Information about detrimental soil mass wasting has been added to the Final 

Environmental Impact Statement, Physical Environment, in the “Soils” section. When 

areas of instability are identified, these areas are assessed and a site determination made. 

Project-level site determinations will then include a determination of extra evaluation to 

minimize additional disturbance (including, but not limited to, the possibility of 

mitigation measures), or avoidance. 

385. Concern Statement: Highly productive soils should be managed for a higher degree of 

soil quality to protect long-term productivity, and volcanic soils should be managed 

more protectively because they are difficult to restore once damaged. Management and 

monitoring should reflect microclimate variability and the 80 different land type 

associations in the Blue Mountains region. In addition, the Forest Service should aim for 

better than minimum soil productivity standards to create a buffer against impacts.

Response: For the purposes of the plan revision, the Blue Mountains Landtype 

Association was used to analyze the soil resource for a variety of factors: soil 

productivity, site suitability, detrimental conditions and soil development. The Landtype 

Association was used due to its continuous coverage across the analysis area and a 

logical generalization of the complex landscapes in the Blue Mountains. For grounddisturbing projects planning and implementation, a finer level of soil survey has been 

done on two of the National Forests, and is being completed on the third. The Blue 

Mountains Terrestrial Ecosystem Unit Inventory has been completed and certified by the 

Natural Resources Conservation Service for the Wallowa-Whitman National Forest. The 

Wallowa-Whitman National Forest portion of the Terrestrial Ecosystem Unit Inventory 

has the recognition of the largest map legend in terms of map unit numbers, for any soil 

survey in the Natural Resources Conservation Service system. This level of detail allows 

a high degree of information for planning and implementation of projects and this 

information is also comparable with private land Natural Resources Conservation 

Service county surveys. The Umatilla National Forest has been mapped to the same 

standard and is currently being correlated for certification. Additionally the Malheur 
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National Forest is actively being mapped. In the absence of Terrestrial Ecosystem Unit 

Inventory mapping, finer detail soils information is available in the form of the Soil 

Resource Inventory. 

Additionally, the Plans will be including monitoring on Mollisols under certain 

conditions to begin documenting that desired conditions are being sustained or 

exceeded, such that adaptive management can be implemented in the event they are not.

386. Concern Statement: The Forest Service should recognize that subsoiling leaves the 

landscape vulnerable to erosion and invasive weeds. 

Response: Soil compaction and displacement are often considered cumulative effects 

following managed activities that can result in detrimental soil conditions across the 

landscape, although they can also follow natural events. These conditions open up 

affected areas both directly and indirectly to more vulnerability for additional erosion 

and for the establishment of invasive weeds, as well as factors that prohibit desired plant 

growth and development. These combined factors over time may serve to reduce the 

volume of a forest stand by reducing overall height and diameter of trees, especially on 

productive soils. 

Typically, if soil compaction prevents moisture infiltration into the compacted soil, relief 

from freeze/thaw conditions does not occur, leaving the site either in detrimental 

conditions or with subsoiling as a needed mitigation option to move the site toward

desired conditions. Use of effective ground cover (another mitigation option) in concert 

with subsoiling can minimize most risk of compaction recurring from subsidence or 

rain-induced soil sealing (potential anticipated effects from subsoiling). Straw waddles, 

water bars, or other appropriate recommendations can also be made to minimize impacts 

caused by erosion. Recommending keeping tires cleaned during construction and 

seeding from areas with invasive species, using weed-free seed, and applications for two 

seasons following seeding with approved herbicide treatment to target specified invasive 

species are examples of mitigations for invasive weeds. 

Soil: Wildfire and Prescribed Fire

387. Concern Statement: The Forest Service should reconsider its post-fire seeding strategy 

as seeding can be ineffective. Nonnative plant seeding following disturbance should be 

allowed to protect soil stability.

Response: A common concern following a wildfire is soil stability. There may be a 

specific case or conditions that could warrant seeding, but typically it is not justified for 

slope stabilization. Environmental conditions within the Blue Mountains are such that 

seeding for soil stabilization has a very small window of opportunity before the first 

damaging storm. It is likely that most “seeding has a low probability of reducing erosion 

the first wet season after a fire” (Robichaud, Beyers and Neary 2000) since fires in the 

area are typically controlled (late summer/early fall) and the duration of seedling 

emergence to effective ground cover is highly variable. Couple that with the amount of 

growing season left before the first damaging storm (mid to late fall) and vegetative 

growth that might be effective as a ground cover has a very small window of 

opportunity, making for a low likelihood of stabilization from a seeding project. 

Furthermore, within the Blue Mountains, erosion modeling (supported by monitoring) 

has shown that the likelihood of elevated erosion risk may be low depending upon the 

site modeled. In many cases, utilization of seeding following a wildfire disturbance for 

the purposes of slope stabilization is not justified. The mention and use of the 
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Robichaud, Beyers and Neary 2000 citation have been added between the Draft and 

Final Environmental Impact Statements.

388. Concern Statement: The Forest Service should account for soil impacts from fire 

suppression and prescribed fire. 

Response: Prescribed fire is tracked in the FACTs database quantitatively for acres and 

geographic area affected. This information can be assessed against the variety of soil 

types where prescribed fire has taken place. 

As a point of clarification, an assessment of less than 80 percent soil productivity (or 

more than 20 percent detrimental soil conditions) within an activity area, does not 

prevent a proposed activity from occurring. If an activity area has less than 80 percent

productive soil conditions, then the project should include restorative actions to bring 

the site above the 80 percent productive soil conditions. If the activity area, with the 

combination of existing detrimental soil conditions and proposed activity detrimental 

soil conditions estimates, falls below the 80 percent sustainable soil productivity, then 

restorative actions should return the site to above 80 percent sustainable productivity. 

These limits have been included within the standards and guidelines. 

Water Quality

Water Quality: Pollutants

389. Concern Statement: The Forest Service should deter water pollution from nonpoint 

sources, primarily bacterial contamination from livestock grazing, and avoid herbicide 

use, to meet the water quality requirements of the Clean Water Act and the National 

Forest Management Act.

Response: Livestock grazing is one of several factors contributing, or that have 

contributed, to the identification of streams on the National Forests as water quality 

limited. As of 2004, no stream within the three National Forests was listed for bacterial 

or chemical contamination, though there were 1,237 stream miles 303(d) listed for other 

reasons. In 2012, the most recent year reported, 40 stream miles on the three National 

Forests were 303(d) listed for E. coli or bacterial pollution (0.14 percent of all streams), 

237 stream miles were listed for elevated stream temperature (0.83 percent of all 

streams) and 146 stream miles were listed for sedimentation (0.5 percent of all streams). 

A total of 1,226 stream miles (4 percent) were 303(d) listed in 2012. In addition, as of 

2012, 1,557 stream miles on the National Forests were considered water quality limited, 

with total maximum daily load) approved (Category 4A), and 460 stream miles were 

considered water quality limited with total maximum daily load needed (Category 4B) 

for a total of 3,240 miles of water quality limited streams (11.4 percent). Requirements 

of the Clean Water Act will be met when all identified actions needed in order to meet 

state water quality criteria have been met and these streams are no longer considered 

water quality limited.

Water Quality: Sediment

390. Concern Statement: The Forest Service should not blame road construction for longterm sediment delivery and should acknowledge that road obliteration leads to sediment 

issues. Baseline conditions and historic norms for “clean and cold” water should be 

provided. 
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Response: Sediment production from roads declines following initial construction, but 

the majority of sediment produced from forest roads is from unsurfaced roads. Sediment

increases proportionally with the level of traffic, and is most strongly related to the 

approaches to stream crossings and to the outlets of cross drain culverts that deliver 

water and sediment from inboard ditches. Road-related erosion has been documented to 

be as much as 200 times higher than the rest of the watershed, meaning that 1⁄2 of 1 

percent of watershed area in roads can double the erosion rate in some cases. In any 

case, road surface erosion accounts for the majority of sediment delivered to streams in 

most forested watersheds, and the effects have been extensively documented. Roads 

intercept and reroute subsurface flow and increase the rate of watershed runoff. When 

water diverted from roads is concentrated, as at the outlet of cross drain culverts, it may 

result in gully formation downslope of the road (Wemple 1994, Wemple 1998) and has 

been documented to carry sediment derived from road surfaces more than 600 feet. 

The purpose of decompacting road surfaces is to allow vegetation to become established 

and this ultimately reduces surface erosion rates relatively quickly.

391. Concern Statement: The Forest Service should explain its protocols for sedimentation 

estimates, especially for the Umatilla National Forest’s Wall Creek watershed. Some 

protocols can produce errors regarding how particles are dispersed across a stream 

substrate. 

Response: The methods used in the Wall Creek study are available at: 

https://www.fs.fed.us/GRAIP/manuals.shtml. Office and field procedures are described 

in Cissell et al. (2012) and Black et al. (2012). 

392. Concern Statement: The Forest Service should install water-bars and implement other 

road management techniques, including out-sloping and sediment traps, to minimize 

sediment flow into streams.

Response: This is the intent described in the Draft Environmental Impact Statement and 

clarified in the Final Environmental Impact Statement. 

Water Quality: Stream Temperatures

393. Concern Statement: The Forest Service should reduce permitted uses on agency lands 

in order to minimize disturbance and improve water quality regarding stream 

temperature under the Clean Water Act. Altered stream temperatures can impact at-risk 

fish species.

Response: Any determination of present condition should be based, not just on current 

or recent land use, but on the sequence of events and magnitude of past events that have 

led to existing conditions. As described in the watershed analysis of the Final 

Environmental Impact Statement, the alteration of streams and riparian areas began 

more than a century ago, and in several cases began before the national forests were 

established. 

Using the upper Grande Ronde River as an example, an estimated 11 to 13 million tons 

of sediment have eroded from stream channels and floodplains upstream of La Grande. 

The Grande Ronde River does not have the transport capacity to move this much 

sediment in any single flood, but is capable of having transported this much sediment in 

response to the multiple floods that have occurred since records began in 1904. The 

initial impacts to the Grande Ronde River were placer mining beginning in the 1860s, 

construction of the State Ditch in 1870, use of the river for log drives as early as 1874, 
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splash dams and log drives from 1889 through 1919, and overgrazing by livestock that 

led to the recognition of poor range conditions by the 1880s. In response to these 

actions, channel and floodplain erosion was likely well underway by the time logging 

activity and road construction were greatly increased on National Forest System lands 

between 1950 and 1995. Livestock numbers in the upper Grande Ronde River were 

reduced from 211,000 animal unit months to 51,000 between 1911 and 1990 (McIntosh 

1992), a decline of 78 percent. Since 1990, livestock use has been further reduced to just 

over 18,000 animal unit months, a reduction of 64 percent from 1990, and representing a 

92 percent decrease from 1911 levels. Existing road miles have been reduced by roughly 

10 percent and open road density has been reduced by roughly 50 percent since 1990. As 

indicated by these changes, management activities have already been reduced. 

Stream temperature is affected by shade, groundwater inflow, channel morphology 

(channel width and depth in particular), the quantity and velocity of stream flow, the 

amount of water removed from channels by flow diversion, and other factors, all of 

which need to be considered in conjunction with the magnitude and sequence of past 

disturbance. Some form of channel and floodplain alteration has occurred in every river 

basin in the Blue Mountains. In most, if not all cases, this has led to differing degrees of 

channel incision, followed by channel widening as rivers adjust to accommodate the full 

range of flows (Leopold et al. 1964). The path forward from here has to include a 

recognition of the magnitude and sequence of past impacts, with an understanding of the 

degree to which present land use is compatible with the achievement of desired 

conditions.

Watershed 

Watershed: Assessments

394. Concern Statement: The Forest Service should analyze effects from land management 

activities, including grazing, logging, and recreation, on the watershed’s peak and base 

flows, hyporheic zones, groundwater function, stream downcutting, wetlands, seeps and 

springs. Activities should be disallowed in riparian areas and in watersheds where 

streams are listed on the Clean Water Act’s 303(d) list.

Response: A discussion of the effects of timber harvest, grazing, and roads on 

watersheds was included in the Draft Environmental Impact Statement and is expanded 

in the Final Environmental Impact Statement to include descriptions of streamflow 

characteristics in the Blue Mountains and the effects of land use on streamflow.

The Clean Water Act distinguishes between point sources and non-point sources of 

pollution. Point sources are regulated by National Pollutant Discharge Elimination 

System permits which limit the amount of a pollutant allowed to enter a given 

waterbody, and under which activities that exceed the allowed pollutant limit may be 

disallowed. Activities on the national forests are generally treated as non-point sources 

of pollution. Existing laws do not require disallowing activities in watersheds with 

303(d) listed streams. Rather, the Clean Water Act specifies the completion of total 

maximum daily loads by the States that identify measures needed to restore water 

quality to levels that meet the specified water quality criteria. By agreement with the 

Oregon Department of Environmental Quality, the national forests in Oregon prepare 

Water Quality Restoration Plans for affected watersheds within the national forests, once 
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total maximum daily loads are completed, that identify watershed-specific actions 

needed to restore water quality.

In addition, the Forest Plans include a standard, RMA-1S, which requires forests to 

adjust management practices in areas where desired conditions have not been met and 

existing management contributes to those conditions. 

The analysis in the Draft Environmental Impact Statement suggested that watershed 

conditions are likely to be improved under all of the alternatives but that the rate varies 

in each alternative. The analysis in the Final Environmental Impact Statement makes a 

similar finding, but based on revised vegetation data the improvements are not as strong 

as described in the Draft. 

395. Concern Statement: The Forest Service should explain at what point a watershed is 

considered restored and what tools are used in restoration, ideally detailed in a chart 

format by key watershed. More specifically, how does the Forest Service develop 

improved subwatershed assumptions for a 10-year period for each alternative and each 

national forest, as presented in Table 115 (Volume 1 of Draft Environmental Impact 

Statement). 

Response: The watershed analysis in the Draft Environmental Impact Statement 

assessed watershed conditions based on available data on road density, vegetation 

condition, livestock use, and channel and aquatic habitat conditions. Roads, vegetation, 

and livestock use were used to describe hillslope conditions; riparian livestock use, and 

available stream survey data were used to evaluate channel and riparian conditions. 

Analysis methods were included in Appendix B of the Draft Environmental Impact 

Statement and are incorporated into the analysis in the Final Environmental Impact 

Statement. 

As described in the Draft Environmental Impact Statement, computed model scores 

based on these attributes range between +1 and -1. Scores above +0.33 are assumed to 

represent good conditions, scores between +0.33 and -0.33 are assumed to represent fair 

conditions, and scores less than -0.33 represent poor conditions. Scores in each range are 

grouped into condition classes 1, 2, and 3 and displayed in the Draft and Final 

Environmental Impact Statements. The analysis in the Final Environmental Impact 

Statement follows the same steps, but also displays the average difference in computed 

scores for all watersheds, key watersheds, and priority watersheds. The Draft reported 

the number of watersheds improved as the sum of watersheds that are expected to 

change from Class 2 to 1 and Class 3 to 2 during the life of the plan. The analysis in the 

Final follows the same steps. Condition classes, as used in the Draft and Final 

Environmental Impact Statements, are intended to be analogous to properly functioning, 

functioning at risk, and impaired as used in the Watershed Condition Framework 

(USDA-FS 2011). 

The analysis used to select key and priority watersheds is based on an analysis of 

watershed, riparian, and habitat conditions of all watersheds within the national forests 

following methods described in Reiss et al. (2008) and is described in the 2018 Blue 

Mountains Aquatic and Riparian Conservation Strategy included as an appendix to the 

individual Forest Plans.

The analysis used in the Draft and Final Environmental Impact Statements is a broadscale assessment of watershed, stream channel, riparian, and aquatic habitat conditions. 

Identification of specific restoration measures for individual watersheds will be 
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identified by the forests during plan implementation and is outside the scope of the Final 

Environmental Impact Statement and Forest Plans. Objectives in the plan describe the 

types of actions needed to move different resources towards desired conditions. The 

forests will identify specific actions in Water Quality Restoration Plans and Watershed 

Restoration Action Plans and will implement those actions following the appropriate 

environmental analysis.

396. Concern Statement: The Forest Service should acknowledge that restoration of 

watersheds, including aquatic habitat function, have not proven effective or cost 

efficient.

Response: Methods of stream, riparian, and watershed restoration have evolved over 

time. The failure of some methods of stream restoration in the Pacific Northwest and the 

cost of restoration efforts is recognized by Federal Agencies, environmental groups, and 

organizations with interest in stream, riparian, wetland, and watershed restoration. 

Some of the failures have been recognized in published papers by Elmore and Beschta 

(1989), House and Boehne (1996), and Roper et al. (1997, 1998), among others. There 

are many others. The development of monitoring plans to evaluate the effectiveness of 

different restoration techniques, sharing of information on methods and both successes 

and failures have all been suggested as ways to improve the methods used in stream and 

improve the effectiveness of restoration measures in general.

The cost of restoration is often used as an argument for avoiding the impacts that would 

result in the need for restoration. The watershed analysis in the Final Environmental 

Impact Statement points out that stream and watershed degradation can often be traced 

to a response to impacts that occurred a century ago or earlier. Understanding the 

processes active in individual watersheds, how streams respond to disturbance, and the 

present state of streams and riparian areas with respect to past and ongoing disturbance 

are all necessary to the success of any restoration plan. Many restoration projects have 

failed to achieve desired results because of failure to recognize watershed, stream 

channel, or sediment transport dynamics. One example is the placement of log weirs in 

Camp Creek on the Malheur National Forest, a practice that was implemented on rivers 

throughout the western United States. The failure of the method is widely known and is 

no longer in practice. 

Watershed, stream, aquatic, and riparian habitat restoration are evolving fields in which 

it is recognized that not all past attempts have been successful at achieving the desired 

outcomes. The Forest Service is committed to improving stream and watershed 

conditions with the goal of attaining fully functioning watersheds, as evidenced by 

implementation of the Watershed Condition Framework (USDA-FS, 2011) and the 

agency’s continued cooperation with multiple State, Tribal, Federal, and other partners 

to implement habitat improvements and improve watershed conditions. Forest Service 

policy is to use the best available science, recognizing that science also evolves with 

time, and that new information is made available on a nearly continuous basis. Future 

watershed and habitat restoration will continue to be guided by watershed analysis based 

on the best available science, the development of watershed restoration action plans, and 

will be implemented following the appropriate environmental analysis.

Watershed: Key and Priority Watersheds

397. Concern Statement: The Forest Service should more clearly define key vs. priority 

watersheds, including their mapped locations and assigned management areas, and 
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explain how their designations will affect day-to-day use. Key watershed designation 

should be scientifically defensible. The Forest Service should not designate key 

watersheds without first going through the NEPA (environmental analysis) process. 

Some comments suggested the presence of salmonids in a stream during a portion of 

their life history should not merit a key watershed designation.

Response: The rationale for key watersheds was described in the Proposed Forest Plan 

in the “Watershed” and “Management Focus” sections. Methods used to select key 

watersheds were included in Appendix B of the Draft Environmental Impact Statement 

along with a table listing the key watersheds identified for each National Forest. A map 

and table of key watersheds, including the key watersheds identified as priorities for 

restoration are included in the 2018 Blue Mountains ARCS (Appendix A of the Forest 

Plan). The process leading to the development of the Draft and Final Environmental 

Impact Statements represents the environmental analysis process for the selection of key 

watersheds for the national forests of the Blue Mountains.

In general, the desired conditions, standards, and guidelines in the Forest Plans apply to 

all watersheds. Three desired conditions and three standards apply to key watersheds 

and watersheds containing critical habitat for federally listed fish species and can be 

found in the Forest Plans and 2018 Blue Mountains ARCS (Appendix A of each Plan).

398. Concern Statement: The Forest Service should explain its method to rate watersheds, 

including aquatic and riparian management prioritization. 

Response: The rationale for key watersheds and the direction to include them in the 

Forest Plans was provided in the 2008 Aquatic Riparian Conservation Strategy (USDA 

Forest Service 2008) and in the 2018 Blue Mountains ARCS (Appendix A) included 

with the Forest Plans. As described in the Draft Environmental Impact Statement, the 

methods for identification of key watersheds are described in Reiss et al. (2008); the 

specific process used to identify key watersheds for the Malheur, Umatilla, and 

Wallowa-Whitman national forests was adapted from Reiss et al. (2008) and described 

in the 2018 ARCS (Appendix A) in each Forest Plan.

399. Concern Statement: The Forest Service should not designate subwatersheds as key that 

do not meet the requirements of a key watershed.

Response: This does not match our assessment. Watersheds were selected as key 

watersheds on the basis of watershed conditions, the population status of four selected 

focal species (chinook salmon, steelhead, bull trout and inland redband trout), and 

restoration potential in the judgement of forest fish biologists and hydrologists on the 

three National Forests. Based on our analysis, in nearly all cases, watersheds selected as 

key watersheds contain the best remaining habitat in any given subbasin. The occurrence 

of 303(d) listed streams is not by itself a criterion for exclusion as a key watershed, but 

is one of the criteria used in determining restoration needs.

400. Concern Statement: The Forest Service should remove standard KW-1 that seeks no 

net increase in road mileage in any key watershed. The standard implies that roads will 

be decommissioned, which should not occur through this plan. In addition, KW-2 

(requiring in-stream flows and maintenance of habitat when developing hydroelectric or 

surface water opportunities) and KW-3 (prohibiting new water developments in key 

watersheds) should be dropped because they detract from multiple-use opportunities. 

Response: The standard has been reworded for the preferred alternative. Road density 

reached a maximum soon after the 1990 Plans were implemented and construction of 
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new roads has been rare in recent years in any watershed, not just in key watersheds. 

More often, roads are reconstructed following storm or other damage. Reconstructed 

roads may be realigned and are designed to have less of an effect on aquatic and riparian 

habitats than the existing road. Standard KW-1 is a product of Endangered Species Act

consultation on the 1990 Plans as amended by PACFISH and INFISH, and was given to 

the Forest Service as a mandatory term and condition for key and priority watersheds, in 

Forest Plan Biological Opinions in 1995 and 1998 from National Marine Fisheries 

Service and U.S. Fish and Wildlife Service for Snake River Basin Chinook and 

Steelhead and for Columbia River bull trout. We have implemented those terms and 

conditions to the extent our authorities and multiple-use land management obligations 

permit, since 1995. The Endangered Species Act requires that Federal agencies use their 

authorities to help achieve recovery for federally listed species and we have done that as 

opportunity, funding and other legal obligations allowed. 

It is possible that we would not receive this requirement as a mandatory term and 

condition of a Biological Opinion on the revised Forest Plans if we did not voluntarily 

include it as a standard for the revised Plans. It is foreseeable that National Marine 

Fisheries Service and U.S. Fish and Wildlife Service would still require it through a 

Biological Opinion term and condition again. 

While we do not anticipate many miles of road decommissioning on any of the National 

Forests over the life of the plan, we do anticipate some reductions in places where they 

may no longer be needed, may be contributing to degraded water quality and inhibiting 

achievement of desired conditions for water quality, or other watershed function 

parameters. Net increases in the road network would detract from that desired condition, 

as research from the Interior Columbia Basin and other research has shown over the 

years that aquatic habitat, aquatic species populations, and water quality tend to decline 

as road densities increase at the subwatershed scale. Site-specific and project-level 

planning for both road construction and road decommissioning on the National Forests 

must comply with the revised Forest Plans, and would conform to direction in the 

National Environmental Policy Act including public involvement and participation

Watershed: Monitoring

401. Concern Statement: Water quality monitoring objectives should be developed through 

a multi-agency process and address multiple scales. The Forest Service should not use 

State-listed impaired waters, on the 303(d) list, as parameters to inform water quality 

monitoring because impaired streams and rivers are never removed from these lists once 

added. Others suggested the Forest Service should monitor 303(d) streams to assess 

sediment and pollutants where agency land management activities occur. 

Response: The commenter is referring to the bi-annual integrated reports prepared by 

the Oregon Department of Environmental Quality at: 

http://www.oregon.gov/deq/wq/Pages/WQ-Assessment.aspx. Each report lists streams 

that are added to 303(d) lists and streams that are removed from the list, and includes the 

rationale for de-listing. In Oregon, streams are placed in one of three categories: (4A) 

water quality limited and Total Maximum Daily Load completed; (4B) water quality 

limited and total maximum daily load needed; or (5) water quality limited 303(d) list, 

total maximum daily load needed. The Department of Ecology in Washington, prepares 

similar lists. Streams are often, but not always removed from the 303(d) list once a total 

maximum daily load has been approved by the Environmental Protection Agency. 

Streams may also be removed from the 303(d) list if the listing criteria have changed, if 
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new data does not support the listing, or if the stream was originally listed for a 

parameter that is not considered a pollutant (habitat modification, for example). 

Removal from state 303(d) lists does not imply that water quality is restored. The status 

of individual streams is reviewed after all measures identified in total maximum daily 

load analyses have been implemented, at which time additional measures may be taken, 

if needed.

402. Concern Statement: The Forest Service should address why it has not completed or 

implemented its total maximum daily loads or water quality restoration plans for Forest 

Service subbasins and watersheds, as listed in the forest revision plan. 

Response: The Forest Service is not involved directly in the completion of total 

maximum daily loads. Total maximum daily loads are required by the Clean Water Act 

to determine the amount of a pollutant allowable in a stream or stream reach that would 

result in meeting State water quality criteria. By law, total maximum daily loads are 

completed by the States. The authorized agencies are the Department of Environmental 

Quality in Oregon and Department of Ecology in Washington. By agreement with 

Oregon Department of Environmental Quality, national forests in Oregon complete 

Water Quality Restoration Plans once total maximum daily loads are complete. The 

completion of Water Quality Restoration Plans is not a Forest Plan issue and depends on 

staffing, funding, and present priorities of the individual national forests. Total 

maximum daily loads are typically written to address a specific parameter (temperature, 

sediment) but streams may be listed for multiple parameters and there may be cases in 

which the parameter addressed in the total maximum daily load is not a listing criteria 

for streams within a given national forest.

403. Concern Statement: The Forest Service should strengthen its watershed monitoring to 

support adaptive management and well-defined adjustments, tied to the 2002 Oregon 

Department of Environmental Quality memorandum of understanding with the Forest 

Service. The Forest Service should not use “proper functioning condition” in its 

monitoring framework. 

Response: The use of the term “properly functioning condition” is not strictly linked to 

assessments of riparian and wetland condition developed by the Bureau of Land 

Management (Prichard et al 1993, Prichard 1999) and has been accepted for use in other 

contexts. 

The terms “properly functioning,” “functioning at risk,” and “impaired function” are 

defined and used to categorize streams in the Forest Service Watershed Condition 

Framework (USDA-FS 2011). The categories “functioning,” “functioning at risk” and 

“functioning at unacceptable risk” were introduced in PACFISH and INFISH for use in 

the Matrix of Pathways and Indicators (NMFS 1996, USFWS 1998). 

Best management practices are described in (USDA-FS 2012) and the language used in 

the Forest Plans is as written in the National Best Management Practices for Water 

Quality, National Core BMP Technical Guide.

Watershed: Riparian- Riparian Management Areas (RMAs) 

404. Concern Statement: The Forest Service should not change Riparian Habitat 

Conservation Areas (RHCAs) to Riparian Management Areas (RMAs) as the change 

would allow for more uses of the land. Such a change also marginalizes PACFISH and 

INFISH direction, which could harm Native American treaty rights.
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Response: Riparian management areas for Alternatives B, E, and F would use the same 

basic definitions as riparian habitat conservation areas to define extent. Riparian 

management areas are designated as management areas where specific desired 

conditions, standards, and guidelines apply. Riparian goals in PACFISH and INFISH are 

rearticulated as desired conditions for the action alternatives. Riparian management area

widths and extent are similar to riparian habitat conservation areas 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. The management of riparian management areas and 

riparian habitat conservation areas would be similar in that work within riparian 

management areas would have to show progress towards desired conditions, and any 

management activity conducted within them would have to be designed specifically for 

the benefit of aquatic and riparian-dependent resources, whereas management of riparian 

habitat conservation areas currently requires that attainment of riparian management 

objectives not be delayed (USDA Forest Service 1995). 

405. Concern Statement: The Forest Service should not underrepresent the number of acres 

in Management Area 4B Riparian Management Areas by only counting those that exist 

within Management Area 4A General Forest.

Response: This has been corrected in the Final Environmental Impact Statement and the 

Forest Plans. The omission was not intentional, but was based on how best to display 

where the management direction associated with riparian management areas would 

apply. Riparian areas within wilderness and roadless areas, wild and scenic river 

corridors, among others, already have management direction that protects the resources 

values within them. The comment is correct in that the desired conditions for riparian 

management areas are intended to apply to all riparian areas. Standards and guidelines 

are intended to constrain which management actions may be used and how they are 

implemented and are most applicable to General Forest.

406. Concern Statement: The Forest Service should allow for the adjustment of riparian 

area zones within Management Area 4B over time through adaptive management, 

especially as scientific knowledge evolves.

Response: The intent of riparian habitat conservation areas in PACFISH and INFISH

was that the boundaries could be adjusted as long as aquatic and riparian resources 

remained protected. Adjusting the boundaries has been difficult in practice. The intent of 

riparian management areas is that the boundaries will be delineated during project 

planning. Boundaries of riparian management areas are intended to include unstable 

slopes and landslides so it is likely that at least some riparian management area

boundaries will be expanded. Riparian areas provide a number of functions (FEMAT 

1993). Changes to riparian management area boundaries may have to display that 

riparian areas will be able to provide these functions if riparian management area widths 

area changed, just as management actions will be required to either maintain riparian 

conditions or display progress towards desired conditions, whichever is applicable.

407. Concern Statement: The Forest Service should not have riparian management area 

widths of 100 feet for ephemeral and intermittent streams in Management Area 4B 

because these areas are not true riparian areas. In addition, the excessive buffer width 

could reduce lands available for timber harvest.

Response: Ephemeral and intermittent streams together may comprise 70-80 percent of 

the channel network and generate most of the streamflow in any given watershed 

(MacDonald and Coe 2006). Ephemeral streams flow for a few days to several weeks 
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each year, on average. It is during this period that approximately 80 to 90 percent of 

sediment transport occurs. These streams are important sources of organic matter, 

sediment, and large wood, some of which is only delivered from intermittent and 

ephemeral headwater tributaries to higher order streams by catastrophic events such as 

debris flows (Benda 1990). The provision of large wood from these streams is all the 

more critical given the apparently large deficit of wood in managed streams in the Blue 

Mountains, as displayed in the “Watershed Function, Water Quality and Water Uses” 

section of the Final Environmental Impact Statement. Most of the wood delivered to 

streams is expected to come from a zone that is roughly 100 feet wide on either side of 

streams (Reeves et al. 2016). The fact that some streams do not support true riparian 

vegetation belies their importance to the channel network. While channel and bank 

stability in larger, low gradient streams is strongly influenced by true riparian 

vegetation, stability of steep headwater streams is derived from tree roots, log steps, and 

coarse woody material.

408. Concern Statement: The Forest Service should not use 300 feet as the width of a 

riparian buffer because scientific support for the 300-foot buffer is linked to factors like 

steep slopes. Others suggested the Forest Service should use the Oregon Forest Practices 

Act to inform riparian widths. 

Response: Riparian management area widths are based, in large part, on the functions 

provided within this zone, including the recruitment of large wood, microclimate, shade, 

and the filtering of sediment and nutrients. FEMAT (1993) and Reeves et al. (2016) 

displayed that some of these functions may be provided by lesser riparian management 

area widths, but providing all of them requires wider riparian management areas. 

Pollock and Kennard (1998) argued that provided shade and microclimate required 

buffer widths greater than 250 feet, while Reeves et al. (2016) argued that most wood 

recruitment occurs from within 100 feet of streams, but that most riparian functions can 

be retained if some management actions occur outside of this zone.

409. Concern Statement: The Forest Service should have a 300-foot buffer for all streams, 

regardless if fish-bearing or seasonally flowing. 

Response: Tang and Montgomery (1995) concluded that 100-meter riparian buffers 

would include 75-95 percent of unstable areas in watersheds on the Olympic Peninsula, 

Washington. Extending riparian management area boundaries to include unstable lands,

as proposed for the revised Forest Plans, would potentially have the same effect, since 

the need for larger buffers is based at least in part on the occurrence of steeper, unstable 

slopes.

410. Concern Statement: The Forest Service should limit ground-disturbing activities, 

including timber harvests, in naturally sensitive riparian areas and detail which uses are 

permitted. The Forest Service should create standards to prohibit landings, skid trails, 

staging and decking in riparian areas to prevent damage to aquatic resources. Riparian 

Management Areas and Riparian Habitat Conservation Areas should have standards that 

emphasize natural processes (like insects, fire, and disease) and snags and downed 

wood. 

Response: As stated in Standard RMA-1, management actions within riparian 

management areas must either maintain riparian conditions, if properly functioning, or 

display progress towards desired conditions, if not properly functioning. Standards and 

guidelines are included in the preferred alternative that limit the location and use of 

roads and landings within riparian management areas.
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411. Concern Statement: The Forest Service should not limit levels of riparian vegetation 

use, as these areas should be open to multiple use. Riparian habitat conservation areas

and riparian management areas should be suitable for timber production. Timber 

removal is needed for ecological health, even within riparian habitat conservation areas 

and riparian management areas, so riparian areas are not overstocked with timber and 

then lost to fires, insects and disease. 

Response: The intent of riparian management areas is that management actions will 

benefit aquatic and riparian-dependent resources. Timber harvest may occur within 

riparian management areas if it results in progress towards desired conditions, such as

the reestablishment of riparian shrubs or hardwoods in areas where they are currently 

excluded by dense, overstocked conifer stands. It is precisely because riparian areas 

perform multiple functions that they are unsuitable for scheduled timber production, but 

may be available for timber harvest if it aids in achieving desired conditions.

412. Concern Statement: The Forest Service should remove standard MA 4B RMA-2 

limiting use of herbicides in riparian areas because it is repetitive of existing regulations. 

Response: The standard is carried forward from PACFISH and reinforces the intent that 

herbicide use will only occur to maintain, enhance, or restore aquatic and riparian 

resources in a manner that does not harm aquatic or riparian resources and this likely 

repeats more than one existing law, including the Clean Water Act.

413. Concern Statement: The Forest Service should ensure that the screens used in standard 

MA 4B RMA-5 to prevent fish entrainment meet State criteria. 

Response: This is standard practice and is specified in Fire Operations Handbooks, 

which recognize and are consistent with, the screening criteria of State agencies in 

Oregon and Washington. By Forest Service regional direction and policy, screens 

deployed to prevent entrainment are consistent with National Marine Fisheries and U.S. 

Fish and Wildlife Service specifications, as agreed through previous Endangered Species 

Act consultations at the national forest level. We believe that these screening 

specifications also meet State criteria.

414. Concern Statement: The Forest Service should allow trail construction (for motor 

vehicle use) as suitable in MA 4B.

Response: We believe allowing motorized trail construction as a suitable use would not 

be consistent with achieving desired conditions for riparian management areas or for 

watershed function, riparian function, or hydrologic function. Suitable uses, along with 

standards and guidelines, were developed to help us move toward desired conditions for 

riparian management areas. We do not have road density standards specific to riparian 

management areas. We do have road density standards that apply to key watersheds.

415. Concern Statement: The Forest Service should not require that side-casting be avoided, 

as stated in standard MA 4B RMA-RD-1 S-49, because exceptions need to be made for 

critical roads like the Dry Creek Road in Wallowa County. Other factors to be 

considered for this and all road-related riparian management area standards and 

guidelines include the added construction and maintenance costs and the need to satisfy 

valid existing rights; therefore, all road-related standards and guidelines in riparian 

management areas need to state “when feasible, considering the associated costs.” 

Response: We believe that methods and practices presently in place allow this standard 

to be met. 
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416. Concern Statement: The Forest Service should broaden its standard MA 4B RMAHYD-1 regarding special uses in riparian areas beyond a hydropower category. 

Response: The wording has been changed in the Forest Plans and Blue Mountains 

ARCS (Appendix A).

417. Concern Statement: The Forest Service should not restore camps, roads and trails 

within MA 4B riparian areas, as listed in MA4B FMA-FIRE-1, if they existed prior to 

firefighting purposes. 

Response: The guideline (now FM-1G) has been edited and states: “If the only suitable 

location for such activities is within a riparian management area, use may be granted 

following review by a resource advisor and discussion with the agency administrator . . 

.” The intent, after they are used for unplanned fire use, is to restore sites to the 

condition they were in before being used as a fire camp or for fire suppression, and can

include decompacting soils, reseeding, removal of noxious weeds, and removing trash, 

among other things.

418. Concern Statement: The Forest Service should not write MA 4B standards and 

guidelines as applicable both “inside and outside” of riparian management areas because 

this inflicts management guidance outside of MA 4B that may or may not be part of the 

management goals, desired conditions or needs of those areas. 

Response: The language only occurs in one standard (RE-4) that specifies hydrologic 

connectivity between roads and streams is minimized. Because source roads often are 

outside of riparian management areas and may be capable of delivering sediment to 

streams that are, by definition, within riparian management areas, the standard is worded 

appropriately.

Watershed: Roads

419. Concern Statement: The Forest Service should explain what type of treatment it 

intends to use on the surface of 30 to 35 miles of roads, in each national forest, in its 1.1 

Watershed Function objective to improve hydrologic function. 

Response: Approaches to road-stream crossings and cross-drain culverts are the two 

most common sources of sediment delivery to streams (Ketcheson and Megahan 1996, 

Burroughs and King 1989). Potential treatment measures for these roads include any 

method that results in dissipating runoff from forest roads. This can include outsloping 

road surfaces, decreasing the spacing between drainage features, adding water bars, 

adding gravel to road surface, or decommissioning roads where road related risks are 

high and road-related runoff cannot otherwise be effectively reduced. Specific measures 

to reduce sediment delivery from forest roads to streams and reduce the hydrological 

effects of roads will be determined during site-specific project planning. Surfacing road 

approaches with crushed rock or gravel and diverting road runoff away from stream 

crossings have been effective methods of reducing sediment. Dissipating the runoff from 

cross drain culverts is also effective.

Watershed-related objectives are intended to be implemented first in priority watersheds. 

Road-related objectives are based on 25 percent of completed road maintenance miles 

for the 3-year period ending in 2012 then adjusting for differences, including budget 

assumptions, between alternatives. Depending on the alternative, 260-800 miles of roads 

are expected to be treated within 10 years, representing 20-50 percent of hydrologically 

connected roads in priority watersheds on the Malheur National Forest, 75-223 percent
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of hydrologically connected roads in priority watersheds on the Umatilla National 

Forest, and 30-92 percent of hydrologically connected roads in priority watersheds on 

the Wallowa-Whitman National Forest. If the objective exceeds the actual number of 

connected roads in priority watersheds, then it is expected that any additional work 

would be conducted in other key watersheds. 

It’s important to note that this is based on studies conducted on several national forests 

that have found that a large percentage of road-related sediment is derived from a small 

percentage of roads and that treating the roads that are found to have the greatest impact 

is a more cost-effective method for reducing road-related sediment delivery to streams 

as well as reducing the hydrologic effects of the existing road network.

420. Concern Statement: The Forest Service should analyze existing road densities at the 

subwatershed scale. Road densities should not exceed 2 miles per square mile in 

subwatersheds or 1 mile per square mile for watersheds containing core and critical 

habitats for listed and at risk species.

Response: Refer to the response to the previous comment. Road densities have been 

computed by watershed and subwatershed across all three National Forests. Road 

density is included in the Matrix of Pathways and Indicators (Blue Mountains ARCS, 

Appendix A), in which subwatersheds with road densities of less than 1 mile per square 

mile are considered functional (in watershed occupied by bull trout) and subwatersheds 

with road densities of less than 2 miles per square mile are considered functional for 

watersheds occupied by steelhead or Chinook salmon. 

Average existing and open road densities on the National Forests are 3.53 existing (2.1 

open) on the Malheur National Forest, 2.1 existing (1.1 open) on the Umatilla National 

Forest, and 3.0 existing (1.5 open) on the Wallowa-Whitman National Forest. Individual 

watersheds may have higher or lower road densities as described in the watershed 

analysis of the Final Environmental Impact Statement. More than 2,200 road miles have 

been decommissioned and more than 9,900 miles of roads have been closed on the three 

National Forests since 1990.

The Forest Plans contain an objective for reducing road-related sediment delivery to 

streams, based on the knowledge that as much as 90 percent of sediment delivery to 

streams comes from as little as 10 percent of the forest road network. Based on this, 

identifying and treating the roads and road segments most responsible for sediment 

delivery to streams (as well as altered hydrology) is more likely to benefit watershed and 

aquatic habitat conditions than a strict adherence to road density standards that may or 

may not address the local effects of specific roads. All this being said, we also recognize 

that not all of the hydrologic effects of roads can be eliminated and roads that are high 

sources of sediment delivery to streams that cannot be effectively treated will remain 

candidates for closure or decommissioning. For key watersheds and watersheds 

containing critical habitat for listed fish species the revised Plans will include a standard 

(KW-1) that requires reductions in road-related risk, depending on watershed conditions.

421. Concern Statement: The Forest Service should determine the hydrologic connectivity 

of roads on a case-by-case basis and remove guideline WR-3, which calls for 

minimization of hydrologic connectivity from roads and trails. In addition, the Forest 

Service should coordinate any actions with the county where such roads are located.

Response: As stated in the Draft Environmental Impact Statement, that is the intent. The 

Draft and Final Environmental Impact Statements used a map-based calculation of roads 
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within 300 feet of streams as an approximation of the miles of hydrologically connected 

roads, following the Forest Service Roads Analysis Guide (USDA-FS 1999). The Draft 

and Final Environmental Impact Statements define hydrologically connected roads as 

roads or road segments that deliver water or sediment directly to streams. 

The roads analysis guide suggested using a fixed buffer as a starting point and gives as 

an example, from the Orleans District of the Six Rivers National Forest, that a fixed 

buffer of 300 feet encompassed 90 percent of roads with inboard ditches. Road crossings 

and cross drain culverts are the two most commonly cited sources of road-related 

sediment to streams, and sediment from culverts draining inside ditches have the longest 

known travel distances. A distance of 300 feet has often been cited as the maximum 

travel distance of road related sediment below culvert outlets, although Megahan and 

Ketcheson (1996) cited a 2 percent probability of travel distances greater than 200 

meters (660 feet). Burroughs and King (1989) noted an average sediment travel distance 

of 127 meters (range 0 to 639 feet) with an 20 percent probability of travel distances 

greater than 200 feet, and also concluded that a slope distance of 175 feet is required to 

prevent 80 percent of cross-drain culverts from contributing sediment to streams. 

Megahan and Ketcheson (1996) and Ketcheson and Megahan (1996) developed a 

predictive equation for the probability of sediment transport distance below the outlets 

of cross drain culverts which predicts a 1 percent probability of transport distance of 232 

meters (760 feet) and a 20 percent probability of transport distances of 92.5 meters (300 

feet).

The distance of 300 feet is used to approximate the numbers of miles of roads that may 

be hydrologically connected. This results in an estimated 51 percent, 37 percent, and 44

percent of existing roads being hydrologically connected on the Malheur, Umatilla, and 

Wallowa-Whitman National Forests, respectively. This compares with 24 to 57 percent 

of roads being connected to streams in studies by Coe (2006), La Marche and 

Lettenmaier (2001), and Wemple et al. (1996). In the example of the Six Rivers National 

Forest, of roads within 100 meters of streams, 30 percent of upper slope roads, 54 

percent of midslope roads, and 72 percent of lower slope roads were found to be 

hydrologically connected to streams.

422. Concern Statement: The Forest Service should include guideline WR-3 in the final 

plan to minimize hydrological connectivity of roads and trails. 

Response: Guideline WR-3 is retained in the preferred alternative as RE-4S. The extent

of hydrologically connected roads is approximated in the Draft and Final Environmental 

Impact Statements but the location of specific connected road segments requires 

identification and inventory using, for example, methods described in Black et al. 

(2012), Cissel et al. (2012), and Nelson et al. (2010). 

All alternatives also include guideline RF-11, which states: “Locate roads to minimize 

delivery of water and sediment from roads to streams. Avoid or minimize disruption of 

hydrologic flow paths, including diversion of streamflow and interception of surface and 

subsurface flow when constructing, reconstructing, and maintaining roads or landings.” 

The objective for reducing road-related sediment delivery to streams applies to all 

alternatives, including the preferred alternative.

423. Concern Statement: The Forest Service should not improve watershed health at the 

expense of motorized recreationists by limiting their road access, particularly to river 

crossing roads like one crossing Dale Creek on the Umatilla National Forest. 
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Response: The authority to close a specific road lies with District Rangers and Forest 

Supervisors and is not a decision that is made in forest plans. The decision to block allterrain vehicle access at the location described would have been a district project-level 

decision. The opportunity for public comment on such proposals is always provided 

before any such action is taken. The Forest Plans describe desired conditions for stream 

channels and for road and trail systems, but do not make decisions on where to 

implement activities that would help to achieve those desired conditions.

Watershed: Use and Rights

424. Concern Statement: The Forest Service should recognize the role of the States to 

regulate water rights and water use, including in-stream flows. Guideline MA 4B RMA4 should remove reference to in-stream flows. 

Response: Forest plans and the direction they provide in the form of desired conditions, 

standards, and guidelines are intended for the management of National Forest System 

lands within the Malheur, Umatilla and Wallowa-Whitman National Forests. We 

recognize that the distribution of land ownerships places limitations on the degree to 

which “connectivity” can be attained, but nothing precludes the Forest Service from 

seeking to provide connectivity within the boundaries of the National Forests. RMA-4 is 

intended to guide the location of water drafting sites within the National Forests so that 

adverse effects to aquatic and riparian resources are avoided. The intent of the guideline 

is specific to avoidance of impacts to surface resources, including instream flows, and is 

unrelated to water rights as managed by the states of Oregon and Washington. 

Management and protection of surface resources within the National Forests are within 

the authority of the Forest Service granted by the Multiple Use and Sustained Yield Act 

of 1960, the National Forest Management Act of 1976, and other federal laws.

425. Concern Statement: The Forest Service should broaden the primary designated 

beneficial use of water on National Forest System lands beyond cold-water fish habitat 

to include human use. Use of water from the Blue Mountains should be for domestic and 

municipal use, irrigation power generation, and recreation. Local residents should not 

have restricted access to water resources.

Response: We recognize the human use of water by acknowledging the multiple sources 

of public and domestic water supplies that originate on the National Forests, many of 

which are designated in the Forest Plans as Management Area 2J – Municipal 

Watersheds. The wording in section 1.11 of the Forest Plans has been modified to 

recognize that the States have designated multiple beneficial uses of water in each 

subbasin, including cold water fish habitat, stock watering, irrigation, hydropower, 

human consumption, contact and non-contact recreation, and public water supplies. It 

remains that most of these uses occur downstream of the National Forests, but that cold 

water fish habitat occurs in nearly every watershed containing National Forest System 

lands. The wording has been changed to remove the word “primary,” but we also point 

out that the Clean Water Act requires protection of the most sensitive use on the 

assumption that water quality for all other uses would then also be protected. Within the 

National Forests, in most cases, the most sensitive designated uses are for aquatic life, 

including cold water fish species. The right to use water, unless related to the purposes 

for which the National Forests were originally reserved, is subject to valid water rights 

granted by the States and regulated by State water rights laws. In practical terms, water 

quality regulations do little to restrict the quantity of water available for domestic, 

municipal, irrigation, power generation, or most forms of recreation.
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Wilderness, Backcountry, and Wild and Scenic Rivers 

Wilderness: Against Designation

426. Concern Statement: The Forest Service should not recommend wilderness areas 

throughout the three Blue Mountains national forests because the 2010 Forest Service 

wilderness evaluation study indicated no more wilderness areas are needed. Wilderness 

use is unlikely to exceed the capacity of the existing wilderness areas and there is 

already a high amount of wilderness land available compared to multiple use lands. 

Response: As stated in the Final Environmental Impact Statement, the “Wilderness 

Need Evaluation for the Malheur, Umatilla, and Wallowa-Whitman National Forests” 

(USDA Forest Service 2010) report findings reveal “that additional wilderness 

designation is not necessary within the Blue Mountain national forests.” The same 

section also states, “However, it is noted that wilderness recommendations may also be 

made based on needs brought forward through public comment. Therefore, the decision 

to propose a wilderness recommendation may be made based on various land 

management strategies and factors, all of which include maintaining biological and 

natural function and diversity within and on the natural landscape.” 

The National Forest Management Act of 1976 (Public Law 94-588) provides for 

multiple use on National Forest System lands. These uses, as outlined in the Act, include 

the coordination of outdoor recreation, range, timber, watershed, wildlife and fish, and 

wilderness. As with all these uses, the Forest Service must seek a balance, where no 

single use predominates over the others, and the Forest Service must also find a balance 

within each single resource use that provides sustainable ecologic, economic, and social 

conditions for current and future generations. 

We developed a range of alternatives allocating varying amounts of preliminary 

administratively recommended wilderness area (Management Area 1B) to different 

alternatives. These allocations provide a range of recommended wilderness that reflect 

different themes embedded within each alternative. For example, Alternative D does not 

allocate any acres to Management Area 1B as the alternative’s theme emphasizes active 

management using mechanical treatments to restore the forested landscape. 

427. Concern Statement: The Forest Service should not recommend 91,000 acres of 

wilderness (preferred Alt E) because wilderness-designated lands restrict multiple-use 

activities, like mineral extraction and mountain biking, and impede the plan's three 

goals: ecological integrity, social well-being, economic well-being. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. Specifically, Alternative D does not allocate any acres to 

Management Area 1B. See our response to the previous comment for more information. 

428. Concern Statement: The Forest Service should not recommend wilderness areas 

throughout the three Blue Mountains national forests because it restricts management 

and results in a decline in forest health through a lack of ability to manage wildfire, 

insects and disease, and noxious weeds. The Forest Service should not recommend areas 

for wilderness that have deteriorating forest conditions, like Aldrich Mountain. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 
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different alternatives. Specifically, Alternative D does not allocate any acres to 

Management Area 1B. As stated in the 1982 Planning Rule (36 CFR 219.17 (a): “Unless 

otherwise provided by law, roadless areas within the National Forest System shall be 

evaluated and considered for recommendation as potential wilderness areas during the 

forest planning process.” 

Designated wilderness does represent more restrictive management compared to other 

management areas. This restriction is statutory and is purposely designed as stated in the 

Wilderness Act (Public Law 88-577). Section 2 (c) of the Wilderness Act states: “An 

area of wilderness is further defined to mean in this Act an area of Undeveloped Federal 

land retaining its primeval character and influence, without permanent improvements or 

human habitation, which is protected and managed so as to preserve its natural 

conditions...” Special Provisions (Section 4 (d) (1) of the Wilderness Act provides for 

specific management actions, stating: “In addition, such measures may be taken as may 

be necessary in the control of fire, insects and diseases, subject to such conditions as the 

Secretary deems desirable.” 

Wilderness use is described in the Final Environmental Impact Statement under Chapter 

3, Issue 5: Preliminary Administratively Recommended Additions to the National 

Wilderness Preservation System. Wilderness designations are not intended to eliminate 

human use, and as stated in Final Environmental Impact Statement: “Section (4)(b) of 

The Wilderness Act states that ‘wilderness areas shall be devoted to the public purposes 

of recreational, scenic, scientific, educational, conservation, and historical use.’ 

Recreation is the most obvious and reported use of wilderness.” 

429. Concern Statement: The Forest Service should not recommend wilderness areas 

throughout the three Blue Mountains national forests because it does not have sufficient 

funding to manage it. 

Response: National Forest System lands allocated to preliminary administratively 

recommended wilderness area (Management Area 1B) will be managed according to 

corresponding desired conditions; and management activities within Management Area 

1B will be implemented using associated standards and guidelines. Budget 

considerations are not specifically integral to the Forest Plan revision process. The 

planning regulations (1982) at 36 CFR 219.10 (e) state: “Subsequent administrative 

activities affecting such lands, including budget proposals, shall be based on the plan.” 

430. Concern Statement: The Forest Service should not recommend additional wilderness 

areas because these lands will be managed for wilderness characteristics, essentially 

creating de facto wilderness that only Congress should designate. For the same 

reasoning, the Forest Service should avoid creating nonmotorized backcountry 

(Management Area 3A) or wilderness study areas (Management Area 1C) because these 

lands will also be managed as de facto wilderness. 

Response: Forest Service regulation requires units to assess and recommend wilderness 

additions during the plan revision process (36 CFR 219.17 (a)), and Forest Service

policy (Forest Service Handbook) directs that any area recommended for wilderness or 

wilderness study is not available for uses or activities that may reduce the wilderness 

potential of an area. The intent is that areas recommended for wilderness retain the 

wilderness characteristics that make them eligible for inclusion in the National 

Wilderness Preservation System as established by the Wilderness Act. The Forest 

Service can only recommend wilderness area allocations; only Congress can designate 

wilderness areas through the legislative process. Recommended Wilderness Areas 
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(Management Area 1B) are therefore managed to preserve wilderness characteristics, but 

they are not designated Wilderness, and therefore are not subject to the statutory 

prohibitions outlined in the Wilderness Act. 

Wilderness study areas (Management Area 1C) are comprised of lands previously 

identified through congressional review processes. These areas are intended for 

additional study to determine their eligibility for inclusion in the National Wilderness

Preservation System. The Homestead Wilderness Study Area, located on the WallowaWhitman National Forest, represents the total area allocated to Management Area 1C. A 

wilderness study completed by the Bureau of Land Management in 1991 included this 

portion of the wilderness study area and did not propose to recommend this area for 

wilderness designation. The study has not yet been accepted by Congress, so these acres 

remain in Management Area 1C. Wilderness values, resources, and characteristics will 

continue to be protected until Congress either designates the area as part of the National 

Wilderness Preservation System or releases the area from consideration. 

The majority of acres allocated to Management Area 3A (Backcountry non-motorized 

vehicle use) overlap with inventoried roadless areas, which are not assigned to their 

own, specific management area. Inventoried roadless areas overlap with multiple 

management areas, with most of the overlap occurring in MA 1B, MA 3A, and MA 3B. 

Other overlap occurs in Special Areas (MA 2 category). Regardless of these overlapping 

management areas, where inventoried roadless areas are present, the prohibitions 

outlined in the 2001 Roadless Area Conservation Rule apply. 

Inventoried roadless areas prohibit timber production and road construction (with some 

exceptions) to maintain and protect social and ecological values and characteristics. 

These areas provide for primitive and semi-primitive nonmotorized use along with semiprimitive motorized classes of dispersed recreation for inventoried roadless areas that 

overlap with Management Area 3B (Backcountry motorized use) (see response below in

Wilderness: For Designation for entire listing of inventoried roadless area benefits). 

431. Concern Statement: The Forest Service should not place buffers around wilderness, 

through recommended wilderness areas and backcountry designations, as the courts 

have ruled there can be no buffers around wilderness. 

Response: We agree that the Forest Service should not establish “buffers zones” 

surrounding designated wilderness, and the revised Forest Plans do not intend to create 

these types of buffers. As stated in the Final Environmental Impacts Statement: “Gorte 

(2011) noted that while the Wilderness Act of 1964 does not speak to the issue of buffer 

zones around wilderness areas, subsequent legislation has prohibited creating buffer 

zones that would ‘restrict . . . uses and activities on federal lands around the wilderness 

area.” The first explicit language was enacted in 1980 in P.L. 96-550; § 105 states: 

“Congress does not intend that the designation of wilderness areas . . . lead to the 

creation of protective perimeters or buffer zones around each wilderness area. The fact 

that nonwilderness activities or uses can be seen or heard from areas within the 

wilderness shall not, of itself, preclude such activities or uses up to the boundary of the 

wilderness area.” 

Nearly identical language has been included in 30 wilderness statutes since 1980 (Gorte 

2011). 

The management area maps for each alternative display the varying allocations for each 

alternative. The maps display a wide range of management areas that adjoin designated 
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wilderness, including: intensively managed areas allocated to Management Area 5 

(Developed Sites and Administrative Areas) and Management Area 4 (General Forest); 

backcountry motorized and nonmotorized areas (Management Areas 3A and 3B) that 

largely overlap Inventoried Roadless Areas; special areas (Management Area 2s) that 

include wild & scenic river allocations, municipal watersheds, and scenic, geological, 

and historic areas; and recommended wilderness areas (Management Area 1B) that 

contain similar characteristics to designated wilderness. This broad range of 

management areas that are immediately adjacent to designated wilderness aligns with 

congressional direction to not create buffer zones surrounding designated wilderness. 

432. Concern Statement: The Forest Service should not designate land as wilderness 

because discrimination occurs against recreationists, specifically motorized 

recreationists, including snowmobilers. Users would not be able to drive within these 

roadless areas. 

Response: As noted in responses above, the Forest Service considers, analyzes, and 

proposes recommended wilderness areas through the plan revision process. Lands 

allocated to Recommended Wilderness Areas (Management Area 1B) are consistent with 

existing regulation and policy. The revised Forest Plans allocate management areas and 

provide suitability ratings for each management area for a range of activities, including 

motor vehicle use for both summer and winter. Suitability ratings align with 

management area desired conditions, and to adhere to existing Forest Service policy, 

motorized use (both summer and winter) are rated as unsuitable in Recommended 

Wilderness (Management Area 1B). The revised Forest Plans do not limit or reduce 

levels of access or propose site-specific changes to the national forest transportation 

system, and reasonable restrictions on motor vehicle use, applied consistently to 

everyone, are not discriminatory. There is no requirement to allow people with 

disabilities to use off-highway vehicles or other motor vehicles on roads, trails, and 

areas that are closed to motor vehicle use. 

The revised Forest Plans establish a range of management areas to reflect multiple uses 

by national forest recreationists. There is a range of recreation opportunities and the 

Forest Service strives to provide a balanced approach whereby motorized users have 

ample opportunity to express their preferred recreational uses; nonmotorized users have 

similar opportunities to express their recreational preferences; and areas where both 

motorized and nonmotorized user groups can enjoy their preferred outdoor recreation 

experiences in combined recreation use settings. 

433. Concern Statement: The Forest Service should not recommend wilderness areas 

throughout the three Blue Mountains national forests because it emphasizes 

opportunities for wilderness recreationists, who are a very small percent of total 

recreationists, and limits opportunities for elderly and handicapped who depend on 

motorized use. 

Response: The Revised Forest Plans align with the National Forest Management Act of 

1976 (Public Law 94-588) and provide for multiple uses of National Forest System 

lands that includes both outdoor recreation and wilderness. The Blue Mountains national 

forests also provide a range of recreation opportunities that accommodate different 

recreational preferences. In some cases, multiple uses create conflicts between resources 

uses, and the Forest Service strives to balance these uses to reduce the amount and 

severity of resource conflict. We recognize that not every single acre of national forest 

lands needs to accommodate every single use of those lands. 
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The revised Forest Plans do not limit or reduce levels of access or propose site-specific 

changes to the national forest transportation system, and reasonable restrictions on 

motor vehicle use are applied consistently to everyone—they are not discriminatory. 

434. Concern Statement: The Forest Service should not recommend additional wilderness 

under the rationale that wilderness will lead to larger wildlife populations, including for 

elk and deer. 

Response: The Revised Forest Plans allocate lands to recommended wilderness areas 

(Management Area 1B) designated for varying reasons, and align with Planning Rule 

regulations (36 CFR 219). The rationale for these allocations may include consideration 

of outdoor recreation, watershed, and fish and wildlife. As stated in the Final 

Environmental Impact Statement under Issue 5: Preliminary Administratively 

Recommended Additions to the National Wilderness Preservation System, “Ecological 

benefits include maintaining species diversity, conserving a ‘reservoir’ of ecological 

processes and a diversity of genetic material, protecting threatened and endangered 

species, protecting watersheds, maintaining large, contiguous, non-fragmented wildlife 

habitats, and serving as a base line for natural conditions to compare with changes in 

other environments (Dawson and Hendee 2009).” These benefits serve multiple species 

and are not solely targeted to increase elk and deer populations, but rather to service 

entire ecological communities that may also include benefits for elk and deer. 

435. Concern Statement: The Forest Service should remove several areas recommended for 

wilderness or wilderness expansion because these areas are not used by the public, not 

managed by the Forest Service, or will not provide significant wilderness benefits. These 

areas include Monument Rock, North Fork John Day, Eagle Cap, Huckleberry Roadless 

Area, Dutch Flat within Twin Mountain, North Fork Umatilla, Hellhole, Greenhorn 

Mountain, Aldrich Mountain, and McClellan Mountain. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. For example, Alternative D 

does not allocate any acres to Management Area 1B as the alternative’s theme 

emphasizes active management using mechanical treatments to restore the forested 

landscape. Alternative C allocates the greatest amount (acres) of land to recommended 

wilderness areas based on its passive restoration theme. The remaining alternatives fall 

in between these two alternatives. 

Individual areas that may be allocated to Recommended Wilderness Areas (Management 

Area 1B) are generally comprised of inventoried roadless areas. These lands are 

generally allocated to three primary management areas including Recommended 

Wilderness Areas (Management Area 1B), Backcountry (nonmotorized use; 

Management Area 3A), and Backcountry (motorized use; Management Area 3B). 

In considering the public comments received, it is important for readers and 

decisionmakers to understand that the comment analysis process does not treat public 

input as if it were a vote. Rather, the content analysis process ensures that every 

comment is considered during the process, regardless of where the commenter resides. 

436. Concern Statement: The Forest Service should not propose lands as wilderness or 

roadless area if they contain routes, visible roads or past timber sales that disqualify 

them, such as the Huckleberry Roadless Area. 
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Response: As noted in responses above, the Forest Service considers, analyzes, and 

proposes recommended wilderness areas through the plan revision process as directed 

by existing regulation and policy. As stated in the 1982 Planning Rule (36 CFR 219.17 

(a): “Unless otherwise provided by law, roadless areas within the National Forest 

System shall be evaluated and considered for recommendation as potential wilderness 

areas during the forest planning process.” 

In contrast, the Forest Service’s 2001 Roadless Area Conservation Rule (36 CFR 294) 

was issued on January 12, 2001, and established a network of Inventoried Roadless 

Areas throughout National Forest System lands. The forest plan revision process does 

not modify, adjust, subtract, or add to the network of inventoried roadless areas. 

The criteria to analyze and propose areas for allocation to Management Area 1B 

(Recommended Wilderness Areas) is outlined in Forest Service policy, specifically 

Forest Service Handbook 1909.12, Chapter 70 – Wilderness Evaluation (2007). This 

policy was used for identifying areas that qualify for a proposed recommended 

wilderness area and to determine each area’s capability, availability, and need. 

437. Concern Statement: The Forest Service should propose small wilderness areas so that 

these can be more easily accessed by families. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. The criteria to analyze and 

propose areas for allocation to Management Area 1B (Recommended Wilderness Areas) 

is outlined in Forest Service policy, specifically Forest Service Handbook 1909.12, 

Chapter 70 – Wilderness Evaluation (2007). This policy was used for identifying areas 

that qualify for a proposed recommended wilderness area and to determine each area’s 

capability, availability, and need. Both the Wilderness Act and Forest Service policy 

establish size criteria when evaluating individual areas. . Additional management areas 

within the Revised Forest Plans provide for nonmotorized, quiet recreation opportunities 

(e.g. Management Area 3A: Backcountry (nonmotorized)), and these areas offer varying 

size ranges and proximity to communities that surround the Blue Mountains national 

forests. 

The Revised Forest Plans allocate acres to Management Area 1B (Recommended 

Wilderness Areas); these recommendations are either contiguous to existing designated 

Wilderness, or in other cases represent recommendations that do not adjoin designated 

Wilderness. These acreages can be considered relatively small compared to the total area 

(acreage) represented in Management Area 1A (Designated Wilderness Area). For 

example, the Eagle Cap Wilderness on the Wallowa-Whitman National Forest is the 

largest designated Wilderness in the State of Oregon and encompasses 350,461 acres. 

The individual areas allocated to Management Area 1B (Preliminary Administratively 

Recommended Wilderness Area) vary in size from less than 500 acres (Wilderness 

additions) to areas greater than 20,000 acres representing relatively larger, discrete areas 

that do not adjoin designated Wilderness areas. The smaller recommended wilderness 

areas represented in the Revised Forest Plans offer wilderness experiences that are easily 

accessed for public use and recreational benefits. 

438. Concern Statement: The Forest Service should not include historical grazing lands, 

such as the Standley Basin area, or current grazing lands as part of potential wilderness 

areas. 
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Response: The Revised Forest Plans do not make site-specific decisions regarding 

grazing. The plans do provide suitability ratings for selected uses and activities on the 

National Forests for each management areas. For all alternatives, grazing (cattle and 

sheep) are rated as suitable in Management Area 1B (Recommended Wilderness Areas). 

If lands allocated to Management Area 1B are further considered and designated by 

Congress as components of the National Wilderness Preservation System, then special 

provisions outlined in the Wilderness Act (Public Law 88-577)) at section 4 (d)(4)(2) 

would apply. Specifically, the Wilderness Act states: “the grazing of livestock, where 

established prior to the effective date of this act, shall be permitted to continue subject to 

reasonable regulations as are deemed necessary by the Secretary of Agriculture.” For 

subsequent legislation that designates wilderness areas, the “effective date of this act” 

language is substituted with the date of the subsequent legislation. 

439. Concern Statement: The Forest Service should not replace the existing scenic area 

designation with recommended wilderness for Vinegar Hill because it would preclude 

use by snowmobilers. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. In many cases, management 

areas can and do overlap one another. For some alternatives, the Vinegar Hill area was 

allocated Management Area 1B creating overlap with the pre-existing Vinegar HillIndian Rock Scenic Area (Management Area 2H). For other alternatives, the Vinegar 

Hill-Indian Rock Scenic Area solely retains the Management Area 2H (Scenic Areas) 

allocation with no overlapping recommended wilderness area to better reflect existing 

uses of this area including winter motorized use and other land use considerations. For 

Alternative E-Modified, the Vinegar Hill Scenic Area was not allocated to Management 

Area 1B (Recommended Wilderness Area). The existing Scenic Area designation allows 

for an adequate range of management options to conserve the area’s unique scenic 

character. 

440. Concern Statement: The Forest Service should remove the Twin Mountain’s Dutch 

Flat Trail proposed wilderness area because it is valuable for low-impact backcountry 

mountain bikers, who have boosted tourism and economic development. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. In many cases, management 

areas can and do overlap one another. For some alternatives, the Twin Mountains area 

was allocated to Management Area 1B, creating overlap with the Dutch Flat Creek, an 

area allocated to Management Area 2A (Wild and Scenic River (includes designated, 

eligible, and suitable rivers)). For other alternatives, Dutch Flat Creek solely retains the 

Management Area 2A (Wild and Scenic Rivers) allocation with no overlapping 

recommended wilderness area to better reflect existing uses of this area including 

mechanical use (bicycle use) and other land use considerations. For Alternative EModified, the Dutch Flat Trail is allocated to Management Area 2A, an allocation that 

will allow continued recreational use including backcountry mountain bike use. The area 

immediately surrounding the Dutch Flat Trail within the MA 2A corridor is allocated to 

Management Area 1B (Recommended Wilderness Area). Both allocations allow for an 
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adequate range of management options to protect and enhance Dutch Flat Creek’s water 

quality and outstandingly remarkable values. 

441. Concern Statement: The Forest Service should remove McClellan Mountain from 

recommended wilderness areas in MA 1B because there is no public access to the north 

side and because it has roads, trails, by-ways, livestock, and forest products. This would 

allow motorized use for hunters, including disabled hunters, to access and retrieve game. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. The criteria to analyze and 

propose areas for allocation to Management Area 1B (Recommended Wilderness Areas) 

is outlined in Forest Service policy, specifically Forest Service Handbook 1909.12, 

Chapter 70 – Wilderness Evaluation (2007). This policy was used for identifying areas 

that qualify for a proposed recommended wilderness area and to determine each area’s 

capability, availability, and need. The revised Forest Plans do not limit or reduce levels 

of access or propose site-specific changes to the forest transportation system, and 

reasonable restrictions on motor vehicle use are applied consistently to everyone—they 

are not discriminatory. 

442. Concern Statement: For every new acre of land set aside as wilderness, the Forest 

Service should transfer an equal number of acres to local counties to sustain economic

development. 

Response: The Forest Service is required to follow all Federal laws, regulations, and 

policies including those that may be enacted during the life of the revised Forest Plans. 

There are no regulation allowing Federal agencies to transfer land to county ownership 

as a result of lands being designated a component of the National Wilderness 

Preservation System. As stated in the revised Forest Plans for Goal 3.2 (Land 

Ownership): “Landownership adjustments should emphasize the following objectives: a) 

acquisition to meet identified resource management needs, b) acquisition contributing to 

consolidation that reduces administrative problems and costs and further enhances 

public use, and c) conveyance of land better suited for non-Federal ownership.” 

Individual land acquisition or conveyance activity would be conducted through a 

separate site-specific analysis and evaluation and would include opportunity for 

additional public involvement and participation. 

443. Concern Statement: The Forest Service should not rely on studies that indicate large 

economic contributions from quiet-use recreationists versus motorized recreationists. 

Response: We agree that studies indicating economic contributions resulting from 

quiet-use recreationists should not be solely relied upon. These studies may provide 

information on broader concepts, but overall these studies are generally inconclusive, 

especially regarding the cause-effect relationships between specially designated lands 

and quiet recreation opportunities and economic outcomes resulting from such 

designations. These studies are not used in the revised Forest Plans and supporting Final 

Environmental Impact Statement to analyze allocating lands to Recommended 

Wilderness Areas (Management Area 1B) or Backcountry (nonmotorized use) 

(Management Area 3A). A range of alternatives was developed allocating varying 

amounts of preliminary administratively recommended wilderness area (Management 

Area 1B) to different alternatives. Similarly, the range of land allocated to Management 

Area 3A (Backcountry (nonmotorized use)) also varies by alternative. These allocations 
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provide a range of recommended wilderness and backcountry nonmotorized use that 

reflect different themes embedded within each alternative. The criteria used to analyze 

and propose areas for allocation to Management Area 1B (Recommended Wilderness 

Areas) is outlined in Forest Service policy, specifically Forest Service Handbook 

1909.12, Chapter 70 – Wilderness Evaluation (2007). 

Wilderness: For Designation

444. Concern Statement: The Forest Service should not rely on the 2010 wilderness needs 

evaluation because it does not capture all of the potential wilderness areas and excludes 

the non-inventoried roadless areas as eligible for wilderness designation. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. The criteria to analyze and 

propose areas for allocation to Management Area 1B (Recommended Wilderness Areas) 

is outlined in Forest Service policy, specifically Forest Service Handbook 1909.12, 

Chapter 70 – Wilderness Evaluation (2007). This policy was used for identifying areas 

that qualify for a proposed recommended wilderness area and to determine each area’s 

capability, availability, and need. 

445. Concern Statement: The Forest Service should recommend more wilderness areas, 

especially in large blocks of intact habitat not subject to outside influences, in order to 

protect keystone species. Listed and at-risk aquatic species, including bull trout and 

other fish, do best in areas with minimal or no roads. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative. The criteria to analyze and 

propose areas for allocation to Management Area 1B (Recommended Wilderness Areas) 

is outlined in Forest Service policy, specifically Forest Service Handbook 1909.12, 

Chapter 70 – Wilderness Evaluation (2007). This policy was used for identifying areas 

that qualify for a proposed recommended wilderness area and to determine each area’s 

capability, availability, and need. 

We agree that areas allocated to recommended wilderness combined with designated 

wilderness provide multiple social and biophysical benefits and values. As stated in 

Final Environmental Impact Statement: “Wilderness provides both social and 

biophysical benefits and values . . . Cole (2005) notes that wilderness experiences 

include recreational and social benefits described as spiritual, educational, 

transcendental, and symbolic. Ecological benefits include maintaining species diversity, 

conserving a ‘reservoir’ of ecological processes and a diversity of genetic material, 

protecting threatened and endangered species, protecting watersheds, maintaining large, 

contiguous, nonfragmented wildlife habitats, and serving as a base line for natural 

conditions to compare with changes in other environments (Dawson and Hendee 2009). 

While these attributes may have overlapping benefits, they represent themes and values 

commonly attached to wilderness.” 

The Forest Service must also strike a balance between often competing multiple uses as 

outlined in the National Forest Management Act of 1976 that includes outdoor 

recreation, range, timber, watershed, wildlife and fish, and wilderness. As with all these 
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uses, the forests must seek a balance, where no single use predominates over the others; 

and the forests must also find a balance within each single resource use that provides 

sustainable ecologic, economic, and social conditions for current and future generations 

446. Concern Statement: The Forest Service should not limit the amount of recommended

wilderness due to the capacity of existing wilderness. The quality of a wilderness area 

and its benefits to the ecosystem and citizens should not be viewed as dependent on the 

number of people using the area. 

Response: We prepared a Wilderness Need Evaluation (2010) that is based on six 

evaluation factors: 

♦ Location, size, type of wilderness; demographics; and accessibility

♦ Use, visitor demographics, and changing patterns of use 

♦ Opportunities for unconfined outdoor recreation experiences 

♦ Refuge for species or protected areas

♦ Capacity of established wilderness to support human use 

♦ Ability to provide for preservation of landform types and ecosystems 

Based on these combined factors—and the evaluation criteria outlined in Forest Service

policy, specifically Forest Service Handbook 1909.12, Chapter 70 – Wilderness 

Evaluation (2007)—areas are allocated to Management Area 1B (Recommended 

Wilderness Area). We developed a range of alternatives allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative.

447. Concern Statement: The Forest Service should propose all wilderness-eligible lands, 

including all undeveloped roadless areas and potential wilderness areas in the 

backcountry, for wilderness designation. More than 5 percent of wild areas, or 91,000 

acres, should be proposed, and the Forest Service should re-examine its capability 

assessment. Areas that should be included as recommended wilderness in the final 

decision include: Boulder Park, Little Eagle Meadows, Lake Fork, Wenatchee Creek, 

Flag Creek, North Fork Malheur, Silver Creek, Fox Creek, Upper Tucannon Roadless 

Area, Joseph Canyon Roadless Area, Hellhole Roadless Area, Murderer’s Creek 

Roadless Area, McClellan Mountain Roadless Area, Five Points Creek on Mt. Emily, 

east face of the Elkhorn, southern edge of the Eagle Cap Wilderness, and Twin Mountain 

Roadless Area. 

Response: A range of alternatives was developed allocating varying amounts of 

preliminary administratively recommended wilderness area (Management Area 1B) to 

different alternatives. These allocations provide a range of recommended wilderness that 

reflect different themes embedded within each alternative.

The majority of areas specifically listed are designated inventoried roadless areas as 

established by the 2000 Roadless Area Conservation Rule. Individual areas that may be 

allocated to Recommended Wilderness Areas (Management Area 1B) are generally 

comprised of Inventoried Roadless Areas (IRAs). These lands are generally allocated to 

three primary management areas including Recommended Wilderness Areas 

(Management Area 1B), Backcountry (nonmotorized use) (Management Area 3A), and 

Backcountry (motorized use) (Management Area 3B). 
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The criteria to analyze and propose areas for allocation to Management Area 1B 

(Recommended Wilderness Areas) is outlined in Forest Service policy, specifically 

Forest Service Handbook 1909.12, Chapter 70 – Wilderness Evaluation (2007). This 

policy was used for identifying areas that qualify for a proposed recommended 

wilderness area and to determine each area’s capability, availability, and need.

Areas not specifically designated as an inventoried roadless area, but listed in the 

concern statement, include the Murderer’s Creek Roadless Area, Five Points Creek on 

Mt. Emily, east face of the Elkhorn, and the southern edge of the Eagle Cap Wilderness. 

Each of these general areas were reviewed and allocated to varying management areas 

for different alternatives as part of the forest plan revision process. Management areas 

broadly describe areas where general management intent is similar and provides 

consistent guidance for areas that express similar landscape characteristics. 

448. Concern Statement: The Forest Service should protect Joseph Canyon Roadless Area 

as a recommended wilderness area to heighten the conservation value of the area. 

Recent motorized use speaks to the need to protect the area for its historic quiet 

recreation. 

Response: A range of alternatives was developed allocating the Joseph Canyon 

Inventoried Roadless Areas to varying management areas; these management areas 

include Recommended Wilderness Area (Management Area 1B), Backcountry 

nonmotorized use (Management Area 3A), and Backcountry motorized use 

(Management Area 3B). The designated Joseph Creek Wild and Scenic River 

(Management Area 2A) does not vary per alternative. Two Research Natural Areas 

(Management Area 2B) are also located within the Joseph Canyon Inventoried Roadless 

Area. For Alternative E-Modified, the Joseph Canyon Inventoried Roadless Area is 

allocated to Management Area 3B (Backcountry motorized use). 

Inventoried roadless areas are not assigned to a specific management area. Inventoried 

roadless areas overlap with multiple management areas, with most of the overlap 

occurring in MA 1B, MA 3A, and MA 3B. Other overlap occurs in Special Areas (MA 2 

category). Regardless of these overlapping management areas, where inventoried 

roadless areas are present, the prohibitions outlined in the 2001 Roadless Area 

Conservation Rule apply. 

Inventoried roadless areas prohibit timber production and road construction (with some 

exceptions) to maintain and protect social and ecological values and characteristics 

including: 

♦ high quality or undisturbed soil, water, and air 

♦ sources of public drinking water 

♦ diversity of plant and animal communities; 

♦ habitat for threatened, endangered, proposed, candidate, and sensitive species and 

for those species dependent on large, undisturbed areas of land 

♦ primitive, semi-primitive nonmotorized, and semi-primitive motorized classes of 

dispersed recreation

♦ reference landscapes

♦ natural appearing landscapes with high scenic quality
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♦ traditional cultural properties and sacred sites

♦ other locally identified unique characteristics

449. Concern Statement: The Forest Service should protect Murderer's Creek Roadless Area 

because it serves as a core habitat for regional species of concern and federal and statelisted species, amongst other reasons. 

Response: There is no official Murderer’s Creek Inventoried Roadless Area, and the 

commenter may be referring to a number of other possible inventoried roadless areas 

within the general vicinity of Murderer’s Creek including Shaketable, Dry Mountain, 

and Aldrich Mountain Inventoried Roadless Areas. The main stem of Murderer’s Creek 

bisects the Shaketable Inventoried Roadless Area, and this area is allocated to varying 

management areas for different alternatives. As with most inventoried roadless areas, 

management area allocation ranges for Shaketable and includes Recommended 

Wilderness Area (Management Area 1B), Backcountry nonmotorized use (Management 

Area 3A), and Backcountry motorized use (Management Area 3B). One Research 

Natural Area (Management Area 2B) is located within the Shaketable Inventoried 

Roadless Area. 

As stated in the previous response, regardless of the management area allocation, the 

prohibitions for inventoried roadless areas apply, and the conservation values inherent in 

inventoried roadless areas are emphasized that includes diversity of plant and animal 

communities; and habitat for threatened, endangered, proposed, candidate, and sensitive 

species and for those species dependent on large, undisturbed areas of land. 

450. Concern Statement: The Forest Service should protect the entire Hellhole Roadless 

Area because its ecological value lets natural systems function, especially in light of 

climate change. 

Response: A range of alternatives was developed allocating the Hellhole Inventoried 

Roadless Areas to varying management areas; these management areas include 

Recommended Wilderness Area (Management Area 1B), Backcountry nonmotorized use 

(Management Area 3A), and Backcountry motorized use (Management Area 3B). One 

research natural area (Management Area 2B) is also located within the Hellhole 

Inventoried Roadless Area. For Alternative E-Modified, the Hellhole Inventoried 

Roadless Area is allocated to each of the above listed management areas (Management 

Areas 1B, 2B, 3A, and 3B). These management areas and associated plan components 

align with the intent expressed in the Roadless Area Conservation Rule and contribute to 

conserving the area’s ecological value, its natural functions, and its role as a reference 

landscape. 

Inventoried roadless areas are not assigned to a specific management area. Inventoried 

roadless areas overlap with multiple management areas, with most of the overlap 

occurring in MA 1B, MA 3A, and MA 3B. Other overlap occurs in Special Areas (MA 2 

category). Regardless of these overlapping management areas, where inventoried 

roadless areas are present, the prohibitions outlined in the 2001 Roadless Area 

Conservation Rule apply. 

Inventoried roadless areas prohibit timber production and road construction (with some 

exceptions) to maintain and protect social and ecological values and characteristics (see 

response to Concern Statement 448 above for complete listing of these values and 

characteristics). 
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451. Concern Statement: The Forest Service should add roadless areas that are contiguous 

with Eagle Cap Wilderness to its recommend wilderness areas. 

Response: A range of alternatives was developed allocating the inventoried roadless 

areas that surround the designated Eagle Cap Wilderness to varying management areas; 

these management areas include Recommended Wilderness Area (Management Area 

1B), Backcountry nonmotorized use (Management Area 3A), and Backcountry 

motorized use (Management Area 3B). Multiple Special Areas (MA 2 category) are 

located within the inventoried roadless areas that are adjacent to the Eagle Cap 

Wilderness. For Alternative E-Modified, the inventoried roadless areas that border the 

Eagle Cap Wilderness are allocated primarily to Management Area 3B (Backcountry 

motorized use) with the exception of the Huckleberry Inventoried Roadless Area that is 

allocated to Management Area 3A (Backcountry nonmotorized use). 

Inventoried roadless areas are not assigned to a specific management area; however, 

they overlap with multiple management areas, with most of the overlap occurring in MA 

1B, MA 3A, and MA 3B. Other overlap occurs in Special Areas (MA 2 category). 

Regardless of these overlapping management areas, where inventoried roadless areas are 

present, the prohibitions outlined in the 2001 Roadless Area Conservation Rule apply. 

Inventoried roadless areas prohibit timber production and road construction (with some 

exceptions) to maintain and protect social and ecological values and characteristics (see 

response to Concern Statement 448 above for complete listing of these values and 

characteristics). 

452. Concern Statement: The Forest Service should extend the Baldy unit of the North Fork 

John Day Wilderness to allow the Elkhorn Crest National Recreation Trail to be 

nonmotorized in the lower portions. 

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. These designations are considered in a separate process that is completed 

under the Travel Management Rule (36 CFR 212). Similarly, the types of use for any 

specific trail are also conducted through site-specific project analysis that includes 

public involvement and participation. 

A range of alternatives was developed allocating the Twin Mountain Inventoried 

Roadless Area, an area that includes the Elkhorn Crest National Recreation Trail, to 

varying management areas; these management areas include Recommended Wilderness 

Area (Management Area 1B), Backcountry nonmotorized use (Management Area 3A), 

and Backcountry motorized use (Management Area 3B). For Alternative E-Modified, 

the portion of the Twin Mountain Inventoried Roadless Area that extends south of the 

Baldy Unit of the North Fork John Day Wilderness is allocated to Management Area 3B 

(Backcountry motorized). The Elkhorn Crest National Recreation Trail is situated within 

this portion of the inventoried roadless area and is rated suitable for motorized use. As 

noted above, the types of use that occur on the Elkhorn Crest Trail are considered 

through project analysis and site-specific decision-making using the National 

Environmental Policy Act process. 

Inventoried roadless areas are not assigned to a specific management area; however, 

they overlap with multiple management areas, with most of the overlap occurring in MA 

1B, MA 3A, and MA 3B. Other overlap occurs in Special Areas (MA 2 category). 

Regardless of these overlapping management areas, where inventoried roadless areas are 

present, the prohibitions outlined in the 2001 Roadless Area Conservation Rule apply. 
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Inventoried roadless areas prohibit timber production and road construction (with some 

exceptions) to maintain and protect social and ecological values and characteristics (see 

response to Concern Statement 448 above for complete listing of these values and 

characteristics). 

453. Concern Statement: The Forest Service should detail which roadless areas were not 

included as recommended wilderness and which specific Forest Service Handbook 

Chapter 70 criteria they failed to meet. In addition, it should not eliminate areas from 

eligibility for wilderness where setbacks or buffers from roads or previous disturbances 

has occurred or where roads are present but not maintained for travel for standard 

passenger vehicles. 

Response: All inventoried roadless areas were evaluated for allocation to 

Recommended Wilderness Areas (Management Area 1B). The criteria to analyze and 

propose areas for allocation to Management Area 1B (Recommended Wilderness Areas) 

is outlined in Forest Service policy, specifically Forest Service Handbook 1909.12, 

Chapter 70 – Wilderness Evaluation (2007). This policy was used for identifying areas 

that qualify for a proposed recommended wilderness area and to determine each area’s 

capability, availability, and need. Some areas in the inventory did not meet the Forest 

Service Handbook criteria for recommended wilderness area due to harvests, roads, road 

buffers, and other developments. 

The criteria used for assessing capability and availability are included in the Final 

Environmental Impact Statement, and ratings are available in the project record. Both 

these criteria, capability and availability, were applied equally to each individual 

potential wilderness area. In contrast, the “need” evaluation was evaluated at the triforest scale. As stated in the “Wilderness Need Evaluation for the Malheur, Umatilla, 

and Wallowa-Whitman National Forests” (USDA Forest Service 2010): 

“The primary function of a Wilderness Need Evaluation is to determine the need for an 

area to be designated as wilderness through an analysis of the degree to which it 

contributes to the overall National Wilderness Preservation System. The evaluation will 

consider the need for wilderness based on current local, regional, and national demands 

and demand trends and the need to protect and preserve a resource, ecosystem, or social 

setting that designation to the National Wilderness Preservation System would provide.” 

As stated in the response above, the “Wilderness Need Evaluation for the Malheur, 

Umatilla, and Wallowa-Whitman National Forests” (USDA Forest Service 2010) report 

findings reveal “that additional wilderness designation is not necessary within the Blue 

Mountain national forests.” The same section also states, “However, it is noted that 

wilderness recommendations may also be made based on needs brought forward through 

public comment. Therefore, the decision to propose a wilderness recommendation may 

be made based on various land management strategies and factors, all of which include 

maintaining biological and natural function and diversity within and on the natural 

landscape.” 

Based on this finding, the Final Environmental Impact Statement includes a range of 

alternatives, each with varying amounts of acreage allocated to Management Area 1B 

(Recommended Wilderness Area). 

454. Concern Statement: The Forest Service should not allow over-the-snow vehicles, such 

as snowmobiles, in MA1B recommended wilderness areas. 
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Response: The revised Forest Plans describe motorized vehicle use (winter) through 

suitability ratings for each management area. The Final Environmental Impact Statement 

includes a range of alternatives where suitability ratings vary by alternative for motor 

vehicle use (winter) in Management Area 1B (Recommended Wilderness Area). 

Alternatives C, E-Modified, and E-Modified Departure each rate motor vehicle use 

(winter) as unsuitable in Management Area 1B. In contrast, Alternatives B, E, and F 

each rate this use as suitable. There is no rating for this use under Alternative D as this 

alternative does not allocate any area to Management Area 1B (Recommended 

Wilderness Area). Analysis in the Final Environmental Impact Statement discusses the 

effects resulting from these varying suitability ratings (see Issue 5, Environmental 

Consequences – Preliminary Administratively Recommended Wilderness Areas).

455. Concern Statement: The Forest Service should be able to update its recommendations 

for wilderness, especially in light of climate change, as the need arises.

Response: The 1982 Planning Rule (36 CFR 219.17 (a) states: “Unless otherwise 

provided by law, roadless areas within the National Forest System shall be evaluated and 

considered for recommendation as potential wilderness areas during the forest planning 

process.” While evaluating areas for wilderness recommendation are inherent in land 

management planning and the forest plan revision process, the Forest Service is not 

precluded from evaluating recommendations outside of the plan revision process, where 

evaluations are based on changing conditions (such as climate change). 

456. Concern Statement: The Forest Service should not allow any recommended wilderness 

to be open to grazing, per the Wilderness Act. 

Response: The Revised Forest Plans do not make site-specific decisions regarding 

grazing. The plans do provide suitability ratings for selected uses and activities on the 

National Forests for each management areas. For all alternatives, grazing (cattle and 

sheep) is rated as suitable for both Management Area 1B (Recommended Wilderness 

Areas) and Management Area 1A (Designated Wilderness). 

If lands allocated to Management Area 1B are further considered and designated by 

Congress as components of the National Wilderness Preservation System, then special 

provisions outlined in the Wilderness Act (Public Law 88-577)) at section 4 (d)(4)(2) 

would apply. Specifically, the Wilderness Act states: “the grazing of livestock, where 

established prior to the effective date of this act, shall be permitted to continue subject to 

reasonable regulations as are deemed necessary by the Secretary of Agriculture.” For 

subsequent legislation that designates wilderness areas, the “effective date of this act” 

language is substituted with the date of the subsequent legislation. 

MA1A and 1B: Standards and Guidelines

457. Concern Statement: The Forest Service should not discourage the use of pack animals 

near waterbodies in wilderness (MA 1A WIL-5) or hitching and tethering of pack 

animals near campsites in wilderness (MA 1A WIL-6), as it is not prohibited in the 

Wilderness Act. 

Response: The Forest Service prepared the Eagle Cap Wilderness Stewardship Plan 

(USDA 1995) to “manage the wilderness under a policy of non-degradation and within 

the standards and guidelines to provide protection and preservation of the wilderness 

resources and outstanding opportunities for primitives and unconfined recreation.” The 

stewardship plan was prepared following regulations conforming to the National 
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Environmental Policy Act. The revised Forest Plans include plan components (standards 

and guidelines) that are included in the Eagle Cap Stewardship Plan to retain 

consistency with this previous planning effort and to reconfirm their status through the 

current planning effort. The Eagle Cap Stewardship Plan also includes a Recreation 

Livestock Monitoring Plan (Appendix F of the Eagle Cap Stewardship Plan) that serves 

to evaluate existing conditions, and to focus inventory and monitoring for condition, 

trend, and utilization at specific camp areas, which are known to have been impacted by 

recreation livestock use. 

458. Concern Statement: The Forest Service should not distance horses and other saddle 

and pack animals 200 feet from any lake in the Eagle Cap Wilderness. Adjust MA 1A 

WAW- WIL-4 to allow for horses within 50 feet of any lake in the Eagle Cap 

Wilderness.

Response: As stated in the previous response, the guidance for recreation livestock use 

activity in the Eagle Cap Wilderness is adapted from the Eagle Cap Stewardship Plan 

(USDA 1995). To retain consistency with this plan, the revised Forest Plans do not alter 

the established standards and guidelines, including distance prohibitions, as outlined in 

the implementation portion of the stewardship plan. 

MA3A and 3B: Backcountry and Roadless Areas

459. Concern Statement: The Forest Service should eliminate MA 3A/B designations, 

including their standards, because they do not protect the resource. The Forest Service 

should reduce the amount of backcountry area and increase the amount of general forest 

so that more area is available for timber production, motorized use, and mining. Some 

commenters ask that exceptions be made to nonmotorized backcountry MA 3A to allow 

motorized use to support grazing and timber harvest. Other commenters ask that no 

motorized use occur in motorized backcountry MA 3B due to the disruption of solitude. 

Response: Inventoried roadless areas, as established in the 2001 Forest Service 

Roadless Area Conservation Rule, are allocated to varying management areas, with the 

majority being allocated to three primary management areas: Recommended Wilderness 

Area (Management Area 1A ), Backcountry nonmotorized (Management Area 3A), and 

Backcountry motorized (Management Area 3B). The desired conditions, suitable use

ratings, and standards and guidelines for these management area designations align with 

the regulations outlined in the Roadless Area Conservation Rule. Prohibitions within 

inventoried roadless areas include road construction and reconstruction, and the cutting, 

sale, or removal of timber (subject to limited exceptions). 

Management Areas 3A and 3B are established as part of the management area spectrum, 

and inventoried roadless areas are not specifically designed to be a management area for 

forest planning purposes. It is common to have management areas overlap with 

inventoried roadless areas, and one important distinction is that inventoried roadless 

areas do not contain desired conditions that evidence management intent. 

A range of alternatives for management areas was developed for the Environmental 

Impact Statements that allocated different amount of acres to different alternatives, 

based in part on the theme of each alternative. For all alternatives, grazing is rates a 

suitable use in Backcountry (Management Areas 3A and 3B); and mining activity is 

subject to existing regulation and existing rights. Backcountry (Management Areas 3A 

and 3B) are separated into motorized and nonmotorized use to (1) allow for different 

recreation opportunities, (2) reflect existing uses on the landscape and, (3) provide for 
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varying desired conditions on the landscape. If users desire a nonmotorized experience, 

it is expected that those users will seek out nonmotorized areas on the landscape 

(Management Areas 1A, 1B, and 3A). 

The draft Forest Plan and Draft Environmental Impact Statement both included the word 

“limited” when describing Backcountry (motorized use), Management Area 3B. 

Editorial efforts were made to eliminate the use of the word “limited,” but not all 

instances where the word was used were corrected. Few or no instances of “limited” (in 

reference to motorized use) are found with the Final Environmental Impact Statement 

and Revised Forest Plans. The use of the word “limited” is unnecessary, as motorized 

use is either considered suitable or unsuitable for any given management area. 

460. Concern Statement: The Forest Service should apply multiple-use management to 

roadless areas.

Response: Inventoried roadless areas as established by the Roadless Area Conservation 

Rule do represent multiple use, and are characterized by “areas that possess social and 

ecological values and characteristics that are becoming scarce in an increasingly 

developed landscape.” Prohibitions within inventoried roadless areas include road 

construction and reconstruction, and the cutting, sale, or removal of timber (subject to 

limited exceptions). While restrictions in these areas prohibit timber production and road 

construction, they do allow for multiple uses as established by the Multiple Use 

Sustained Yield Act including outdoor recreation, range, watershed, and wildlife and fish 

purposes. Specific benefits of inventoried roadless areas are outlined in the Roadless 

Areas Conservation Rule and include: 

♦ high quality or undisturbed soil, water, and air 

♦ sources of public drinking water 

♦ diversity of plant and animal communities; 

♦ habitat for threatened, endangered, proposed, candidate, and sensitive species and 

for those species dependent on large, undisturbed areas of land

♦ primitive, semi-primitive nonmotorized, and semi-primitive motorized classes of 

dispersed recreation

♦ reference landscapes

♦ natural appearing landscapes with high scenic quality

♦ traditional cultural properties and sacred sites

♦ other locally identified unique characteristics

With completion of the Roadless Area Conservation Rule (RACR) in 2001, inventoried 

roadless areas became a designation with fixed boundaries and prohibitions set by that 

rule and Forest Service regulation (36 CFR 294). The revised Forest Plans do not adjust 

the boundaries of inventoried roadless areas, nor do they propose areas for additions to 

or removal from designated inventoried roadless areas. 

461. Concern Statement: The Forest Service should not allow activities in roadless areas 

that impair wilderness character. Roadless areas provide habitat for rare and sensitive 

listed plants and wildlife, support ecological integrity, provide carbon storage, offer 

primitive recreation values, and support indigenous people's treaty rights and use of 

cultural plants. The Forest Service should better analyze cumulative impacts to roadless 
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area characteristics. In addition, the Forest Service should protect roadless and 

backcountry areas to provide for landscape connectivity. 

Response: Inventoried roadless areas, as established in the 2001 Forest Service 

Roadless Area Conservation Rule, are allocated to varying management areas, with the 

majority being allocated to three primary management areas: Recommended Wilderness 

Area (Management Area 1A ), Backcountry nonmotorized (Management Area 3A), and 

Backcountry motorized (Management Area 3B). The desired conditions, suitable use 

ratings, and standards and guidelines for these management area designations align with 

the regulations outlined in the Roadless Area Conservation Rule. Prohibitions within 

inventoried roadless areas include road construction and reconstruction, and the cutting, 

sale, or removal of timber (subject to limited exceptions). We agree that inventoried 

roadless areas maintain and protect social and ecological values and characteristics 

including: 

♦ high quality or undisturbed soil, water, and air 

♦ sources of public drinking water 

♦ diversity of plant and animal communities; 

♦ habitat for threatened, endangered, proposed, candidate, and sensitive species and 

for those species dependent on large, undisturbed areas of land 

♦ primitive, semi-primitive nonmotorized, and semi-primitive motorized classes of 

dispersed recreation

♦ reference landscapes

♦ natural appearing landscapes with high scenic quality 

♦ traditional cultural properties and sacred sites

♦ other locally identified unique characteristics

Standards in the revised Forest Plans that apply to Backcountry (Management Areas 3A 

and 3B) direct national forest staff to manage inventoried roadless areas consistently 

with the guidance in the 2001 Roadless Area Conservation Rule (36 CFR 294). 

462. Concern Statement: The Forest Service should not place road closures on motorized 

backcountry MA 3B motorized backcountry areas either seasonally, by route, or by area, 

because it will limit opportunities for recreation, wood cutting and resource 

development. 

Response: The Forest Plans do not designate routes, trails, or areas open to motorvehicle uses. These designations are considered in a separate process that is completed 

under the Travel Management Rule (36 CFR 212). We agree that motorized access in an 

important component of forest management to meet the needs of many recreating 

publics, and where appropriate, motorized recreation opportunities may be maintained 

or expanded. The forest transportation system may be used to access areas for hunting, 

berry picking, camping, pleasure driving, firewood removal, and to access the trail 

system for off-highway vehicle use, bicycle, hiking, and horseback use. These trails also 

provide access to the backcountry for hunting, fishing, camping, photography, and many 

more recreation and subsistence related activities. As noted above, changes to specific 

routes are not a forest plan decision but an outcome of a site-specific analysis process 

that includes public involvement and participation. 
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MA1C: Wilderness Study Area

463. Concern Statement: The Forest Service should remove the Homestead Wilderness 

Study Area and any other lands from wilderness study areas (Management Area 1C) to 

place those lands in another management area or inventoried roadless areas. 

Response: The lands allocated to Management Area 1C result from congressional 

direction. Those lands remain in that allocation until the study results are complete and 

Congress either includes those lands in the National Wilderness Preservation System; or 

those lands are “released” for other management consideration. Until the congressional 

review process is complete, the Homestead Wilderness Study (Management Area 1C) 

will continue to be managed in such a way as to not reduce or impair the wilderness 

characteristics and qualities for which the area was designated. 

MA3C: Wildlife Corridors

464. Concern Statement: The Forest Service should not create wildlife corridors around 

wilderness areas, as this essentially creates wilderness buffer areas without 

Congressional approval. In addition, it should re-evaluate if these corridors actually 

increase adaptive capacity of terrestrial ecosystems.

Response: A range of alternatives has been developed around the wildlife corridor 

concept, and the current Alternative E-Modified does not contain any lands allocated to 

MA 3C. Management activity allowed in Management Area 3C is not as restrictive as 

designated wilderness and is not intended to create a “buffer” surrounding wilderness. 

For example, activities rated as suitable in Management Area 3C include mechanical 

timber harvest, grazing (and all mechanical and motorized support activities and 

facilities), motor vehicle use (summer and winter), road and trail construction (for 

motorized use), and mechanical fuel treatment. Additionally, structures and permitted 

special uses are considered suitable uses in Wildlife Corridors (Management Area 3C), 

further distinguishing this allocation from congressionally designated wilderness.

465. Concern Statement: The Forest Service should reassess the MA 3C open road density, 

1 mile per square mile in Alternatives C, E and F, because it takes more than a mile of 

road to cross one section due to topography. 

Response: A range of alternatives has been developed around the wildlife corridor 

concept and the current Alternative E-Modified does not contain any lands allocated to 

MA 3C. The road density metric is developed and applied to wildlife corridors, and the 

lower density value serves to maintain habitat linkages, to improve landscape 

connectivity, and to reduce overall human disturbance to wildlife species using these 

areas. As used in the revised Forest Plans and Environmental Impact Statement, road 

density is an indicator of the concentration of roads in an area. In most cases, the area 

being analyzed is not necessarily reduced to one square mile, and likely include larger 

areas that exceed 640 acres. 

466. Concern Statement: The Forest Service should define “landscape connectivity,” 

explain why unconnected landscapes cannot meet targets, and specify how landscape 

connectivity can be enhanced.

Response: Landscape patterns are defined as the number, frequency, size, and 

juxtaposition of landscape elements (stand patches) that are important to the 

determination or interpretation of ecological processes. As noted in the revised Forest 

Plans, landscape patterns contribute to landscape connectivity (how landscapes are 
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connected) and are interrelated with multiple resources and ecological processes. As 

stated in the revised Forest Plans: “Within the patterns of landscapes there is normally a 

predictable range of variation in: (a) stand structure and stand densities, as described in 

Desired Condition 1.6 and 1.8; (b) the number and types of species and their abundance, 

described in Desired Condition 1.7; (c) the ways natural communities form and the ways 

they cycle energy and nutrients through air (Desired Condition 1.9), soil (Desired 

Condition 1.10), and water (Desired Condition 1.11). What remains the same in the 

shifting mosaic of landscape patterns is how natural communities both influence and 

respond to disturbance regimes (Desired Condition 1.4) and the way these dynamics 

create recognizable patterns that repeat across the landscape over time. Terrestrial and 

aquatic species diversity (Desired Condition 1.2) are highly correlated with diversity of 

landscape patterns.” 

Landscape connectivity is also described this way: “cross-connected landscape patches 

provide quality forage, cover, and security as viable species move through porous 

landscapes. Landscape patterns provide a connectivity, allowing animals to move across 

landscapes.” The desired condition for the goals stated above each identify how these 

elements can be enhanced to better achieve improvement for individual resources, and 

when combined are illustrative of how landscape connectivity is improved or enhanced 

through revised Forest Plan implementation. 

467. Concern Statement: The Forest Service should create wildlife corridors to encourage 

genetic diversity and prevent inbreeding of wildlife, which supports Goal 1 “Promote 

Ecological Integrity.” 

Response: A range of alternatives has been developed around the wildlife corridor 

concept and the current Alternative E-Modified does not contain any lands allocated to 

MA 3C. Section 1.12 “Landscape Patterns” provides additional descriptions and desired 

conditions that include providing for genetic diversity, where “cross-connected 

landscape patches provide quality forage, cover, and security as viable species move 

through porous landscapes.” The revised Forest Plans provide direction for managing 

the necessary landscape connectivity at varying scales, and project and site-specific 

planning and analysis will further review landscape connectivity/corridors, and other 

factors including open motor vehicle routes, at the project level. 

468. Concern Statement: The Forest Service should create more wildlife corridors to create

refugia for climate-challenged resources. These areas could protect species movement, 

especially between wilderness and roadless areas and going up and down slopes. 

Animals that would benefit from low road density include gray wolves, elk, lynx, and 

wolverine. 

Response: A range of alternatives has been developed around the wildlife corridor 

concept and the current Alternative E-Modified does not contain any lands allocated to 

MA 3C. Species movement is enhanced through direction and desired conditions 

outlined in section 1.12 “Landscape Patterns.” Designated wilderness and inventoried 

roadless areas also contribute significantly to retaining connectivity, providing refugia 

for varying climate change scenarios, and these landscapes contain historically low road 

densities and will continue to do so into the future. 

MA2A: Wild and Scenic Rivers

469. Concern Statement: The Forest Service should not add any wild and scenic rivers 

because it cannot manage those it has and private land issues can arise. 
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Response: The Forest Plan revision process addresses potential wild and scenic rivers 

as outlined in Forest Service policy (Forest Service Manual 1924.03) and the Wild and 

Scenic Rivers Act (Public Law 90-542), Section 5 (d) (1). As outlined by this Act, the 

Secretary of Agriculture and the Secretary of the Interior administer components of the 

National Wild and Scenic River System, which includes the Federal land management 

agencies within these departments. To comply with section 3 (d)(1) of the Act, a 

comprehensive management plan for designated rivers is developed to provide for the 

protection of river values. The Blue Mountains national forests have developed 

comprehensive management plans for each designated component of the Wild and 

Scenic Rivers System. These plans provide the necessary plan components (standards 

and guidelines) to preserve the rivers’ free-flowing condition, water quality, and 

outstandingly remarkable values. In the case where private lands are concerned, the 

Wild and Scenic Rivers Act provides substantive guidance for land jurisdiction. 

470. Concern Statement: The Forest Service should not designate waterways as wild and 

scenic because more restrictions would not allow for management of insects, disease and 

wildfire, which would burden nearby communities and residents. 

Response: The Forest Plan revision process addresses potential wild and scenic rivers 

as outlined in Forest Service policy (Forest Service Manual 1924.03) and the Wild and 

Scenic Rivers Act (Public Law 90-542), Section 5 (d) (1). Management activity within 

MA 2A would allow for treating insects, disease and wildfire, so long as these 

treatments do not impair water quality or negatively affect the identified outstanding 

remarkable values for a designated, eligible, or suitable river. The background section 

and desired conditions for Goal 1.4 (Disturbance Processes) provides additional 

guidance and information for wildland fire (planned and unplanned ignitions) and 

insects and disease. 

471. Concern Statement: The Forest Service should recommend that additional rivers, 

especially within the Malheur National Forest, be designated as eligible wild and scenic 

rivers through river-related values identified by the public and should explain why some 

rivers are not eligible. 

Response: The revised Forest Plans follow the inventory and evaluation process 

established in the Wild and Scenic Rivers Act (Public Law 90-542) and Forest Service

policy. The planning process for wild and scenic rivers included substantive public 

involvement (three rounds of community collaborative workshops) and coordination 

with other Federal, State, Tribal, and local governments including established watershed 

councils. These efforts informed the identification and inventory processes including 

individual assessments for river eligibility and outstandingly remarkable values. The 

forests documented these assessment findings and they are available in the project 

record and posted on the Forest Plan revision website. The assessment findings were 

prepared by interdisciplinary teams and resource specialists for scenery, recreation, 

wildlife, fisheries, heritage resources, geology, hydrology, botany, ecology, and water 

quality. 

472. Concern Statement: The Forest Service should complete its analysis of wild and scenic 

river status and forward the list of eligible rivers to Congress. 

Response: The revised Forest Plans may include suitability studies, or may be deferred 

to a later time (Forest Service Handbook 1909.12 Chapter 80, Section 81). The 

Wallowa-Whitman National Forest had previously completed suitability studies for 

eligible rivers and included these finding as part of the revised Forest Plans. In contrast, 
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the Malheur and Umatilla National Forests have not completed the suitability studies, 

and will defer this process to a later time outside of the current forest plan revision 

efforts. The process used to recommend suitable rivers for congressional designation is 

outlined in the Forest Service Manual (Chapter 1920, Section 1924.11 (2)). The 

direction states “the Regional Forester shall notify the Chief by letter of the tentative 

preliminary administrative recommendations on rivers evaluated during land 

management planning process.” 

Additional Forest Service Manual direction provides that the decision document for the 

revised forest plans must contain the following statement: “This recommendation is a 

preliminary administrative recommendation that will receive further review and possible 

modification by the Chief of the Forest Service, Secretary of Agriculture, and the 

President of the United States. Congress has reserved the authority to make final 

decisions on designation of rivers as part of the National Wild and Scenic Rivers 

System.” 

473. Concern Statement: The Forest Service should add cultural value as a river-related 

value to its list of outstandingly remarkable values. 

Response: Historic and cultural values are included as part of the eligibility criteria 

assessments. Specifically, Heritage Resources are include in the assessment and included 

the following considerations:

♦ Does the stream corridor contain known occupation sites used by Native Americans 

that are unusual, have exceptional human interest value, have national or regional 

importance for interpreting pre-history, been used for sacred purposes, or listed or 

eligible for listing on the National Register of Historic Places?

♦ Does the stream corridor contain known site(s) or feature(s) associated with a

significant event, important person, or cultural activity from the past that was rare or 

unusual? Of particular importance are sites or features that are listed in, or eligible 

for inclusion in the National Register of Historic Places.

As with other resource areas, the assessment findings were prepared by interdisciplinary 

teams and resource specialists, including heritage resource specialists for each of the 

Blue Mountains national forests. 

474. Concern Statement: The Forest Service should place a higher value on local fisheries 

in its wild and scenic outstandingly remarkable value analysis or eligible rivers. 

Response: The Forest Service uses a standardized approach for evaluating the 

significance of outstanding remarkable values that is based on informed professional 

judgement and interpretation. The standardized process for evaluating these values 

includes: 

♦ The use of an interdisciplinary team approach

♦ Consideration of uniqueness and rarity at a regional and national level 

♦ Values must be river-related in that they owe their existence or contribute to the 

functioning of the river system and its environments

Resource specialists on each ranger district provided current information on river-related 

resources in each river corridor; categories considered include scenery, recreation, 

wildlife, fisheries, heritage resources, geology/hydrology, botany, ecology, and water 

quality. 
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475. Concern Statement: The Forest Service should analyze direct, indirect and cumulative 

impacts of each alternative's actions on designated and eligible wild and scenic rivers. 

Response: Management Area 2A (Designated, Eligible, and Suitable Wild and Scenic 

Rivers) includes desired conditions, standards, guidelines, and established management 

area boundaries. These combined Forest Plan components provided the necessary 

protection for areas (rivers) allocated to Management Area 2A and are designed to 

preserve the rivers’ free-flowing condition, water quality, and outstandingly remarkable 

values. The range of alternatives, and subsequent effects resulting from each, would not 

change or lessen the congressionally mandated guidance or Forest Service policy 

regarding wild and scenic rivers components. Any future project either within or 

adjacent to an area allocated to Management Area 2A is subject to the National 

Environmental Policy Act and its implementing regulations, and such site-specific 

analysis includes additional opportunities for public involvement and participation. 

476. Concern Statement: The Forest Service should tighten the MA 2A WSR-8 guideline so 

as to not impact roads not visible from or outside of the wild and scenic river corridor. 

Response: Based on input received through public comments, public engagement 

sessions, and interdisciplinary team reviews, Guideline MA 2A WSR-8 was not included 

in Alternative E-Modified and Alternative E-Modified Departure. The modified 

alternatives do include a guideline for new road and motorized trail construction (MA 

2A-3G), stating: “New roads and motorized trails should not be constructed within wild 

and scenic classifications of Wild and Scenic River Management allocations unless no 

other feasible alternative exists.” The plan component language indicates that sitespecific analysis, including a range of alternatives, is necessary to authorize such 

construction. This type of project-level planning and analysis is subject to the National 

Environmental Policy Act and its implementing regulations, and such site-specific 

analysis includes additional opportunities for public involvement and participation. 

477. Concern Statement: The Forest Service should adjust MA 2A WSR-3 guideline to 

allow hitching of horses within 50 feet of water areas and change MA 2A WSR-2 

standard so that the use of pack animals is not discouraged.

Response: Wild and scenic river resources and revised Forest Plan components were 

reviewed and refined for the Final Environmental Impact Statement to consider updated 

information and comments received from the public. Two additional action alternatives, 

Alternative E-Modified and Alternative E-Modified Departure, were developed in 

response to multiple resource concerns brought forward through public comment and 

public engagements. The changes made in the addition of those plan revision 

alternatives helped correct minor errors presented in the Draft Environmental Impact 

Statement and reflect public desires and comments. 

We agree that recreation use, including use of pack animals, in wild and scenic river 

corridors is an important part forest recreation, and this specific activity contributes to 

and enhances the outstandingly remarkable values that are commonly associated with 

this unique resource. The MA 2A WSR-3 guideline is not included in the modified 

alternatives. In order to protect water quality and conserve river values, standard MA 2A 

WSR-2 was retained in its entirety and states: “Hitching or tethering of horses or other 

saddle or pack animals to trees, except for loading or unloading, shall not be authorized 

at campsites within wild and scenic river corridors” (MA 2A-2S). The standard is 

intended to conserve river-related resources (vegetation); and alternative means of 
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hitching or tethering horses or other saddle or pack animals is promoted and encouraged 

at campsites within wild and scenic river corridors. 

478. Concern Statement: The Forest Service should adjust the MA 2A WSR-6 guideline to 

make an exception for roads in wild and scenic river corridors in some cases, such as for 

fuel reduction. 

Response: Similar to the previous response, the interdisciplinary team reviewed the 

Draft Revised Forest Plan components, and considered updated information and 

comments received from the public. Based on this review, the MA 2A WSR-6 was not 

included in the current modified alternatives. While this specific guideline in not 

included in Alternative E-Modified, it was necessary to provide specific guidance for 

road and trail construction activities for Management Area 2A in order to protect water 

quality and conserve river related values. Guideline MA 2A-3G was developed and 

included in the modified alternatives, and states: “New roads and motorized trails should 

not be constructed within wild and scenic classifications of wild and scenic river 

management allocations unless no other feasible alternative exists.” As noted in a 

previous response, the plan component language indicates that site-specific analysis, 

including a range of alternatives, is necessary to authorize such activity. This type of 

project-level planning and analysis is subject to the National Environmental Policy Act 

and its implementing regulations, and such site-specific analysis includes additional 

opportunities for public involvement and participation.

479. Concern Statement: The Forest Service should authorize oil and gas leasing in wild 

and scenic river areas if such leases don’t inhibit this management area’s purposes. 

Response: Wild and scenic river resources and revised Forest Plan components were 

reviewed and refined for the Final Environmental Impact Statement to consider updated 

information and comments received from the public. Two additional plan revision 

alternatives, Alternative E-Modified and Alternative E-Modified Departure, were 

developed in response to multiple resource concerns brought forward through public 

comment and public engagements. The changes reflected in the addition of these 

alternatives helped correct minor errors presented in the Draft Environmental Impact 

Statement and reflect public desires and comments.

The Draft Revised Forest Plans included Standard MA 2A WSR-11, stating: “Oil and 

gas leasing shall not be authorized or allowed within 1,320 feet of the high water mark 

in wild river corridors.” This standard was not included in the modified alternatives. 

Removing this standard is based on the foundation that the Forest Service is required to 

follow all Federal laws, regulations, and policies including those that may be enacted 

during the life of this revised Forest Plan. Regulations regarding leasable minerals, 

specifically within wild and scenic rivers, are outlined in the Forest Service Handbook 

(1909.12, Chapter 80), and within section 9 of the Wild and Scenic Rivers Act (Public 

Law 90-542). Additional guidance for minerals, including locatable, leasable, and oil 

and gas resources, may be found in the Code of Federal Regulations, Title 36, Chapter 

II, Part 228. 
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Wildfire

Wildfire: Analysis and Planning

480. Concern Statement: The Forest Service should enhance its description and analysis of 

wildland fire as well as plan components for fire. Analysis should include area burned 

by decade, including on adjacent private lands, and detailed information on current 

conditions and risk. 

Response: Wildland fire is discussed and considered throughout the document and the 

detail sought is included in the specialist reports supporting the overall analysis and is

available as part of the project record. Table 78 in the Wildland Fire and Fuels - Affected 

Environment section (Volume 2) addresses fire occurrence across the planning area from 

1980 to 2017 in comparison to reference conditions. Potential for high severity fires and 

departure in the fire regime condition class address analysis on current conditions and 

risk.

Wildfire: Fuels and Fire Risk

481. Concern Statement: The Forest Service should treat more acres to reduce fuels, 

decrease the potential for severe wildfires, reach desired conditions, better meet the 

needs of communities, prevent fire spread to private lands, and reduce smoke emissions. 

Several commenters suggested treating all lands like the wildland-urban interface. A 

simple indicator of progress should be used rather than condition class departure. 

Response: We have added additional alternatives that consider additional treatments, all 

of which exceed current treatment footprints. Alternatives were added to increase acres 

of fire inside and outside of harvest units or to increase harvest units. Not all acres have 

the same need as those within wildland-urban interface areas. Treatments to protect 

values at risk within wildland-urban interface areas will continue to be a high priority. 

We have tempered these goals based on current and forecast budgets. 

482. Concern Statement: The Forest Service should protect moist forest stands by treating 

fuels in adjacent drier forests. 

Response: We agree that the majority of treatments needed are in the dry forest types. 

Recent research (Johnston 2016) completed on the Malheur National Forest has shown 

that even moist forests have been highly influenced by the frequent fire regimes of the 

dominant dry-forests with fire return intervals no higher than 28 years in studied stands. 

Therefore, to meet the desired goals and provide for overall forest health, we must treat 

stands in moist forests as well as dry. Moist forests currently have fire return intervals 

outside of reference conditions, which show a need for an increase in fire. Studies show 

that forest management practices such as prescribed fire and mechanical fuels removal 

lead to increasing carbon storage. 

483. Concern Statement: The Forest Service shouldn’t manage potential fire severity 

through logging and other restoration work because climate is the main driver of fire 

severity. Treatments may increase fire severity by opening the canopy and allowing for 

regeneration of many young, flammable trees.

Response: While restoration of our forested systems, particularly dry forest types, has 

shown a resultant increase in modeled fire activity, the resistance to control and severity 

of these fires will decrease as it did prior to European settlement. As treatments continue 

across the landscape, the opportunities for characteristically low-severity fire will 
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increase while high severity and high intensity fires will decrease. An increase in fire 

occurrence is needed to address fire return intervals at levels lower than reference 

conditions. 

484. Concern Statement: The Forest Service should create fuelbreaks, such as along major 

roads, and use fire lookouts. 

Response: We regularly treat major roads as a matter of course for visibility and 

maintenance, which aid in making them available for defense corridors. The Malheur, 

Umatilla, and Wallowa-Whitman National Forests completed a strategic roads 

assessment in 2013 to be used as part of project-specific planning as opposed to 

addressing this at the Forest Plan revision level. The Forest Service uses lookouts and 

fire patrols, as well as aerial detection as a regular course of fire management. 

Wildfire: Historical Range of Variability

485. Concern Statement: The Forest Service should document its claim that levels of 

mortality from insects, disease and wildfire are above the historical range and clarify 

where information came from on historical levels of fuel composition, fire frequency, 

fire pattern, and fire regime condition class. 

Response: Fire frequency, pattern and fire regime condition class references are 

included in Table 76 in the Wildland Fire and Fuels Treatments section (Volume 2). 

Local research on fire history is cited in the Wildland Fire Regimes section (Volume 2) 

while the fire regime condition class model is a nationally recognized departure tool 

developed with a number of partners (Barrett et al. 2010).Insect and disease increased 

mortality is addressed in Volume 2 under the section on Insects and Disease.

486. Concern Statement: The Forest Service should reconsider whether or not moist forest 

types are truly departed from historical conditions. In addition, it should reconsider the 

historical extent of high-severity fire in ponderosa pine and dry Douglas-fir as fire scar 

studies bias findings towards documentation of historical low-severity fire regimes.

Response: Recent research (Johnston 2016) completed on the Malheur National Forest 

has shown that even moist forests have been highly influenced by the frequent fire 

regimes of the dominant dry-forests with fire return intervals no higher than 28 years in 

studied stands. Departure of moist forests is discussed in Table 78 in Volume 2 of the 

Final Environmental Impact Statement showing moderate departure of vegetation and 

the fire return interval being 3 to 4 times lower that reference conditions. Table 76 in the 

Wildland Fire and Fuels section (Volume 2) acknowledges that high-severity fire existed 

at 5-15 percent within the dry upland forests. Fire scar studies indicate a lack of record 

for low-severity fire, which burned at intensities that did not leave fire scars. 

Wildfire: Prescribed Fire

487. Concern Statement: The Forest Service should reduce the level of prescribed fire in the 

new plans because of the limited number of days with good burn conditions, State 

regulations, and lack of social agreement. The Forest Service should not replace 

mechanical fuels treatments with prescribed fire. 

Response: The concern about the ability of the Forest Service to increase prescribed 

burning is reasonable considering recent history; this is why mechanical treatments are 

also included in the analysis. Smoke management regulations for both Oregon and 
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Washington are in the process of being updated due to the commenter’s concerns. This 

approach will be assessed as part of required implementation monitoring. 

488. Concern Statement: The Forest Service should use prescribed burning when it is the 

most effective and least expensive management option. 

Response: Prescribed fire is identified as a treatment option in all alternatives. 

Prescribed fire may not be appropriate as a stand-alone treatment but may need to follow 

other mechanical treatments to meet objectives. As stated in Volume 2 of the Final 

Environmental Impact Statement:

“The forests currently use prescribed burns and mechanical treatments in order to 

achieve multiple objectives, including reduction of activity-generated and natural fuels, 

wildlife habitat improvement, ecosystem restoration, and range betterment. While 

management techniques (including mechanical removal) may be used in order to reduce 

heavy fuels, they cannot always completely replace the ecological role that fire plays. 

Fire not only reduces the build-up of dead and downed fuel, it performs many other 

critical ecosystem functions. Fire can recycle nutrients that might otherwise be trapped 

for long periods of time in the dead organic matter that exists in many environments 

with slow rates of decay. It can also stimulate the production of nutrients and provide the 

specific conditions (including seed release, soil, light, and nutrients) that are critical for 

the reproduction of fire-dependent species Long et al. 2008, Thomas and Agee, (1986), 

Fieder (2000), and Fieder et al. (2007).” 

489. Concern Statement: The Forest Service should not use prescribed fire where invasive 

annual grasses are present. 

Response: These concerns will be addressed at the project-specific level. 

Wildfire: Prescribed Fire - Air Quality

490. Concern Statement: The Forest Service should not emphasize prescribed fire in its 

forest plans because it will not be able to meet air quality desired conditions or state and 

federal regulations. 

Response: The Forest Service conducts prescribed fires in accordance with the air 

quality standards established by the Environmental Protection Agency (EPA) and 

Oregon Department of Environmental Quality. This includes burning when smoke 

dispersal conditions are favorable to ensure air quality standards are not violated;

notifying jurisdictional fire authorities and nearby communities of planned prescribed 

burning; and post-burn monitoring and reporting. The EPA and State of Oregon are 

currently reviewing smoke management plans to address restoration burning needs. The 

Blue Mountains national forests are actively engaged in working with partners to 

address social understanding of need for prescribed fire and increased smoke from 

restoration treatments. 

491. Concern Statement: The Forest Service should assess the smoke and carbon impacts 

from anticipated wildfires and should acknowledge that smoke from wildfires is more 

variable than smoke from prescribed fires.

Response: We have updated language throughout the documents to ensure that this is 

clearer. Wildfires fall under the exceptional events rule of the Environmental Protection 

Agency and do not have to comply with those regulations. 
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Wildfire: Standards and Guidelines

492. Concern Statement: The Forest Service should add objectives and guidelines to 

support the use of managed fire.

Response: We have clarified the language to explain that guidelines are developed in 

the National Forest-specific fire management plans to determine where and when 

managed fire is appropriate. This is addressed in the “Wildland Fire and Fuels 

Management” section, Environmental Consequences.

493. Concern Statement: The Forest Service should drop the guideline limiting the 

development of mechanical fireline on slopes over 35 percent. 

Response: We have clarified the language to explain when this type of fireline may be 

used in the standards and guidelines (FIRE-2-G-28).

494. Concern Statement: The Forest Service should drop the guideline limiting the use of 

retardants in riparian areas. 

Response: Analysis at regional and national levels describe the effects to habitat and 

ecosystem health and provide the basis for these limitations, NEPA (USDA Forest 

Service 2012) for the use of retardant was conducted at a national level and is not under 

analysis in this Final Environmental Impact Statement. These limitations are suspended 

when life or property are threatened. 

495. Concern Statement: The Forest Service should not use “Minimum Impact Suppression 

Tactics” (Guideline FIRE-2) because they are too restrictive. 

Response: Minimum Impact Suppression Tactics are used to minimize suppression 

impacts to the greatest extent possible while meeting the overall suppression objective. 

These tactics are primarily used in Wilderness areas to meet wilderness values. 

Wildfire: Suppression and Wildland Fire Use

496. Concern Statement: Managed fire, or wildfire, should be allowed in backcountry, 

roadless, and wilderness areas and in moist/cool and cold forests. Allowing natural fire 

disturbance to occur as much as possible would help restore and maintain historical 

conditions and transitory range and is a less expensive way to achieve desired landscape 

conditions. Wildfire suppression should be reserved for immediate protection of homes. 

Response: We have updated language throughout the documents to ensure that this is 

clearer. Protection of high values at risk will continue to be a priority. Use of managed 

fire is addressed in the “Wildland Fire and Fuels Management” section, Environmental 

Consequences. Fuels reduction activities and suppression of fire are still required due to 

the increase of high severity fire potential. 

497. Concern Statement: The Forest Service should cautiously implement a policy of using 

unplanned ignitions to improve ecosystems. Managed wildfire should not replace other 

management, and social and economic issues should be considered. 

Response: Direction in the revised Forest Plans seeks to balance passive and active 

management. The Forest Service is limited in the amount of active management that is 

possible, given budget levels. Decisions on where wildfire will be managed for resource 

benefit will be based on many things, including potential effects to other resources and 

water quality.
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498. Concern Statement: The Forest Service should suppress 100 percent of all wildfires 

and reinstate its policy of putting out all wildfires by 10am the day after the fire started. 

Response: Direction in the revised Forest Plans seeks to balance passive and active 

management. The Forest Service is limited in the amount of active management that is 

possible, given budget levels. Decisions on where wildfire will be managed for resource 

benefit will be based on many things, including potential effect to other resources and 

water quality. Wildfire suppression has been a major influence on current forest 

conditions leading to missed fire return intervals, heavier fuel, loading, and increased 

fire severity (see the “Wildland Fire Severity” section in the Final Environmental Impact 

Statement). The “Wildland Fire and Fuels Management” Environmental Consequences 

section also addresses the appropriate use of managed fire. The Forest Plans do not set 

policy such as the 10 a.m. rule. 

Wildfire: Wildland Urban Interface

499. Concern Statement: The Forest Service should reconsider how it defines the wildlandurban interface. Commenters suggested both larger WUIs, for example up to 5 miles, 

and smaller wildland-urban interfaces, for example simply the structure ignition zone. 

Response: The definition of wildland-urban interface can be highly varied across the 

country. For the purposes of the Forest Plans, we have relied on community wildfire 

protection plans to address wildland-urban interface needs based on community input as 

well as allow for changes based on local changes. Community wildfire protection plans 

are collaboratively prepared by counties and local communities; as such, the boundaries 

as not determined by the Forest Service. 

Wildlife

Wildlife: Bighorn Sheep - Domestic Grazing

500. Concern Statement: The Forest Service should consider prohibiting sheep grazing 

within 25 to 30 miles of suitable bighorn habitat, including potential habitat that is 

currently unoccupied, in order to allow bighorn populations to recover toward historical 

levels. It was suggested that sheep grazing should be completely eliminated because of 

the disease risk. 

Response: The alternatives are analyzed relative to risks to bighorn sheep from 

domestic sheep grazing allotments through a risk of contact tool. This tool estimates the 

probability of a foraying bighorn sheep contacting a domestic sheep grazing allotment, 

although contact between a bighorn sheep and a domestic sheep grazing allotment does 

not necessarily mean that contact will occur or disease-causing pathogens will be passed 

from domestic sheep to bighorn sheep. The process of modeling risk of contact 

represents the best available science for quantifying the risks posed by foraying bighorn 

sheep coming in contact with domestic sheep allotments. The results are provided in the 

Final Environmental Impact Statement. These results indicate low risks to bighorn sheep 

from current domestic sheep grazing allotments. Domestic sheep grazing allotments 

within 35 kilometers (about 22 miles) of bighorn sheep herds were analyzed using the 

risk of contact tool developed cooperatively by the Forest Service and Bureau of Land 

Management. The process of analyzing risk of contact is explained in O’Brien et al. 

2014. 
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Results of this analysis were compared to a contact rate of 0.08 (or less than 0.8 contacts 

per decade), a threshold suggested by the Wild Sheep Working Group (Forest 

Service/BLM 2015) to limit disease outbreak intervals to a level that would likely result 

in bighorn sheep persistence in the long-term. The highest probability of contact 

between any bighorn sheep and a domestic sheep allotment in this analysis is 0.019, well 

below the 0.080 threshold. Domestic sheep allotments further than 35 kilometers from 

bighorn sheep herds were not analyzed because the extensive telemetry dataset from the 

Hells Canyon bighorn sheep meta-population shows that the large majority of summer 

and winter forays by bighorn rams and ewes are 35 kilometers or less. 

501. Concern Statement: The Forest Service should drop range guideline (RNG-19) which 

entails moving sheep off allotments when bighorn sheep are found within 7 miles. A 

separation distance of 30 meters is effective. 

Response: The Forest Service is required to use the best available data and science to 

inform management decisions. The Forest Service places high value on the 

preponderance of peer-reviewed science that identifies respiratory diseases originating 

from domestic sheep and goats as the most important factor that led to the extirpation of 

wild sheep in most of their range, and continues to suppress population growth. The 

statement that “a separation distance of 30 meters is effective” is not supported by any 

credible research or observations by credible wildlife or veterinary professionals. 

502. Concern Statement: The Forest Service should clarify how it determined the 7-mile 

separation distance between domestic sheep or goats and bighorn sheep. This distance 

should be biologically justified and determined through a quantitative risk assessment. 

High-risk areas should be identified and incorporated into the forest plans. 

Response: Reference to 7 miles in the bighorn sheep management standards does not 

appear in the Final Environmental Impact Statement. The origin of the 7-mile criteria 

comes from former plan revision team member Earl “Duke” Klein regarding a risk 

analysis conducted by the Payette National Forest. Klein suggested that one option for 

the Forest Plan revision is to use the “Payette National Forest information regarding 

‘foray’ distance from core herd ranges and use the 11 kilometer distance or 50 percent

probability of no contact between domestic sheep and wild sheep.” There is no peer 

reviewed literature that uses 7 miles as a component of effective separation between 

domestic sheep and bighorn sheep, but the 11-kilometer distance discussed by Klein is 

equal to approximately 7 miles (11.27 km). 

503. Concern Statement: The Forest Service should create a standard requiring a formal 

response plan for allotments with sheep or goat grazing. Such plans should be 

incorporated into the annual operating instructions and should account for retrieval and 

disposition of stray domestic sheep. 

Response: There is no formal emergency response or action plan specifically required in 

the management direction, but some components that would be expected in such a plan 

are covered in BHSM-3S, BHSM-4S, and BHSM-5S. Additionally, management actions 

that contribute to effective separation are matters of administering the domestic sheep 

grazing permits, and will be addressed in annual operating instructions. 

504. Concern Statement: The Forest Service should change Range Guidelines 13 (trailing of 

domestic sheep or goats) and 19 (separation of domestic and bighorn sheep) to standards 

and require compliance monitoring. The Forest Service should also develop standards to 
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address: (1) diseased domestic sheep, and (2) stocking of domestic sheep and goats on 

allotments where it doesn’t currently occur. 

Response: RNG G-13 and 19 do not appear in the Final Forest Plans; however, the 

concern with trailing domestic sheep near bighorn sheep is addressed in BHSM-1S and 

the intent from RNG G-19 is included in BHSM-5S. The Final Forest Plans contain five 

standards that address bighorn sheep, and no guidelines. The intent was to take the 

multiple standards and guidelines in the Draft Environmental Impact Statement and 

condense them into more concise standards without losing the original intent. There are 

not additional standards that address diseased domestic sheep or stocking of domestic 

sheep or goats, because these are matters of grazing permit administration, and will be 

addressed in annual operating instructions. Regarding “stocking of domestic sheep and 

goats on allotments where it doesn’t currently occur,” the Final Environmental Impact 

Statement identifies the portions of each National Forest that are suitable for domestic 

sheep grazing, and which portions are unsuitable for domestic sheep grazing. 

Additionally, BHSM-1S and BHSM-2S do not allow the authorization of domestic 

sheep or goat grazing where effective separation from bighorn sheep cannot be 

reasonably maintained. 

505. Concern Statement: The Forest Service should allow for grazing by domestic sheep 

and include the opportunity for permittees to relocate to vacant allotments or create 

voluntary exchange opportunities with neighboring allotments. 

Response: Permitted grazing by domestic sheep is continued in the revised Forest 

Plans. Appendix F of the Final Environmental Impact Statement contains the acreages 

for each National Forest that are suitable for grazing by domestic sheep. 

506. Concern Statement: The Forest Service should define “effective separation” in Range 

Standard 9, “source habitat” in Range Standard 10, “adjacent or nearby” in Range 

Standards 11 and 12, “effective monitoring” in Range Standards 12 and 14, “reasonable 

effort” in Range Standard 15, and “at a distance” in Range Standard 17. Typical animal 

identification approaches including ear tags and paint branding should be acceptable for 

identifying animals “at a distance.” 

Response: Some of these terms and phrases are not included in the Final Forest Plans. 

Further explanation of “effective separation” is provided as a footnote to the 

management standards, and is also in the glossary.

507. Concern Statement: The Forest Service should not prohibit grazing by domestic sheep 

or goats if the State fails to effectively monitor for bighorn sheep. 

Response: Standard BHSM-1S prohibits the authorization of domestic sheep or goat 

grazing where effective separation cannot be reasonably maintained. Monitoring can be 

a component of effective separation. There is not a direct connection between whether 

the Forest Service authorizes grazing by domestic sheep and the State’s routine 

monitoring of bighorn sheep populations. The Forest Service and State wildlife agencies 

coordinate on matters that are pertinent to authorized livestock grazing and bighorn 

sheep conservation. 

508. Concern Statement: The Forest Service should require effective monitoring before turn 

out of domestic sheep or goats. In addition, Forest Service staff should count sheep and 

goats rather than the permittee. 
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Response: See the response to the previous comment. In addition, these Forest Plans do 

not require Forest Service staff to count domestic sheep to confirm the number of sheep 

being placed on allotments. 

509. Concern Statement: The Forest Service should consider challenges faced by other 

national forests related to domestic sheep grazing and bighorn recovery. 

Response: Standard BHSM-1S prohibits the authorization of domestic sheep or goat 

grazing where effective separation cannot be reasonably maintained. The management 

direction regarding bighorn sheep was developed from peer-reviewed science and from 

the experiences of other land management agencies throughout the range of bighorn 

sheep. 

510. Concern Statement: The Forest Service should provide maps that delineate all known 

bighorn herds, potential bighorn habitat, areas unsuitable for grazing, and locations of 

domestic sheep allotments, by alternative.

Response: Maps of these landscape features were not in the Draft Environmental 

Impact Statement. Maps of the areas identified as unsuitable for domestic sheep grazing 

are provided in the Final Environmental Impact Statement. Maps of the bighorn sheep 

herds can be found in the Application of the Bighorn Sheep Risk of Contact Model on 

the Blue Mountains National Forests, Final Report (2016). Maps of “potential bighorn 

habitat” are not specifically provided, but “source habitat” is shown. 

Wildlife: Bighorn Sheep - Packgoats

511. Concern Statement: The Forest Service should allow packgoat use by recreationists but 

limit the potential for disease transmission from goats to bighorn sheep. Packgoats allow 

recreationists who can still hike but no longer carry much gear to access remote areas. 

The Forest Service should allow packgoat use by, for example, required tethering or 

penning, “certification,” required permits, or the owner’s presence. 

Response: The revised Forest Plans do not restrict the use of pack goats within the 

planning area, except for those uses requiring a special use permit or other form of 

authorization. Standard RNG-10 S-3 has been removed. Standard BHSM-2S prohibits 

the authorizing of pack goat use where effective separation from bighorn sheep cannot 

be reasonably maintained. Regarding “certified pack goats,” a veterinary test that is 

available, reliable, and affordable does not currently exist. This option will be 

considered as the science develops. 

512. Concern Statement: The best available science should be used to determine what size 

buffer is needed between pack goats and bighorn sheep to prevent disease transmission. 

Response: As mentioned above, the revised Forest Plans do not restrict the use of pack 

goats within the planning area, except for those uses requiring a special use permit or 

other form of authorization. Standard RNG-10 S-3 has been removed. Where 

authorization of pack goat use is involved, effective separation from bighorn sheep will 

be the goal. Effective separation is not limited to a simple avoidance buffer, but 

considers distance, bighorn sheep herd demographic data, permeability of the landscape, 

and other factors that influence how bighorn sheep move within the landscape. Focusing 

on effective separation rather than a buffer is consistent with the best available science. 

513. Concern Statement: The Forest Service should not assume science assessing the 

potential for spread of disease between domestic sheep and bighorn sheep is relevant to 
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goats, and particularly packgoats. Packgoats stay close to owners and are often 

vaccinated. There are very few packgoat users, and many causes have led to the decline 

in the bighorn sheep populations. The Forest Service should indicate the uncertainty in 

its conclusions about the risk of maintaining packgoat access.

Response: As mentioned above, the revised Forest Plans do not restrict the use of pack 

goats within the planning area, except for those uses requiring a special use permit or 

other form of authorization. Standard RNG-10 S-3 has been removed. The Final 

Environmental Impact Statement and management standards acknowledge differences 

between pack goats and domestic goats used for other purposes. There is also 

recognition that pack goats likely represent lesser risks to bighorn sheep than domestic 

sheep or larger herds of goats used for weed control. 

514. Concern Statement: The Forest Service should analyze the social and economic 

impacts of prohibiting packgoat access. 

Response: As mentioned above, the revised forest plans do not restrict the use of pack 

goats within the planning area, except for those uses requiring a special use permit or 

other form of authorization. Standard RNG-10 S-3 has been removed. 

Wildlife: Bighorn Sheep Analysis and Habitat Management

515. Concern Statement: The Forest Service should more completely analyze impacts to 

bighorn sheep populations including those from: bighorn hunting, stress of captivity and 

handling, wolves, invasive weeds, and grazing. The Forest Service should consider 

science that suggests little risk of disease transmission from domestic cattle, sheep and 

goats to bighorn sheep. In addition, the Forest Service should consider disease 

transmission to bighorns from humans, cattle, birds, elk, and other wildlife. 

Response: The state of knowledge on what pathogens are involved in bighorn sheep 

die-offs has advanced well beyond what was understood in 2003 when Weiser et al. 

published the paper “Characterization of Pasteurella multocida Associated with 

Pheumonia in Bighorn Sheep” in the Journal of Wildlife Diseases (39 (3) pages 536-

544). Additionally, Weiser’s paper does not state “a number of animal species, especially 

birds” represent a risk of pathogen transmission to bighorn sheep. Weiser documents the 

bacterial complex that was isolated from bighorn sheep in Hells Canyon. Their focus 

was on the prevalence and variety of Pasteurella multocida subspecies, variants, and 

antigenic variation that were identified in the bighorn sheep sampled. Although 

Mycoplasma ovipneumonia was known when Weiser conducted his work, it had yet to 

be considered an important pre-cursor to other bacteria that can result in sickness and 

mortality in bighorn sheep. Weiser’s paper mentions “mycoplasmal infection” only once 

as one of many factors associated with reduced physical and immunologic defenses in 

bighorn sheep. 

The Wolfe et al. (2010) paper documents several pathogens that were isolated from the 

carcasses of bighorn sheep and syntopic domestic cattle. We have considered the 

findings of this paper. The circumstances documented in the Wolfe paper are 

uncommon, and resulted in cattle and bighorn sheep concentrating together during a 

severe winter period. Another consideration is that the social attraction between these 

two species does not exists as with domestic sheep or goats and bighorn sheep. Although 

our managers will remain vigilant regarding unique circumstances that could 

concentrate cattle and bighorn sheep, Forest Plan direction is not designed to specifically 

address such unique circumstances.
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We have conducted an extensive review of the peer-reviewed literature regarding 

sources of pathogens that are harmful to bighorn sheep. There is little evidence that 

supports the notion that “disease transmission to bighorns from humans, cattle, birds, 

elk, and other wildlife” is worthy of further consideration. The large preponderance of 

scientific literature identifies domestic sheep, and to a lesser extent domestic goats as the 

primary sources of pathogens that are detrimental to bighorn sheep. We will continually 

review and consider research that may implicate other sources of pathogens, and will 

adjust management in response to new, pertinent information. 

516. Concern Statement: The Forest Service should not use data from the Payette National 

Forest for its bighorn analysis. Viability analysis should include information regarding 

the risk of extirpation and should be modeled like all other focal species. 

Response: The bighorn sheep populations within the Blue Mountains Planning Area 

include the Hells Canyon complex, which are the same populations involved in the 

Payette National Forest’s Supplemental Environmental Impact Statement that addresses 

bighorn sheep viability. The bighorn sheep location data for the Hells Canyon complex 

are the same used in the Payette’s analysis and in the Blue Mountains environmental 

analysis. Therefore, it is not only appropriate for the Blue Mountains Forest Plans to use 

these data, but it is required by our mandate to use the best available data and science on 

which to base management decisions. There are no other data that could inform a risk of 

contact analysis except for the location data collected from the Hells Canyon bighorn 

sheep population. One difference between the Payette’s analysis and these revised Forest 

Plans is that the risk of contact analysis conducted for the Blue Mountains Final 

Environmental Impact Statement used a more complete and recent dataset, including 

location data through 2015. 

The Blue Mountains analysis does not rely on or cite the two documents that were the 

focus of the lawsuit by the Idaho Wool Growers Association and North American 

Packgoat Association vs. Thomas Vilsack (Dept. of Agriculture) and Thomas Tidwell 

(US Forest Service), Case No. 1:08-cv-00394-BLW.

517. Concern Statement: The Forest Service should reestablish the Canyon Mountain herd. 

Response: The Forest Service administers habitat for bighorn sheep, and does not 

directly manage populations of bighorn sheep. The Oregon Department of Fish and 

Wildlife has management authority over wildlife populations in the state of Oregon. The 

priorities for the restoration and conservation of bighorn sheep are detailed in “Oregon’s 

Bighorn Sheep and Rocky Mountain Goat Management Plan” (2003). The Oregon 

Department of Fish and Wildlife has determined that Canyon Mountain is too close to 

sources of potential disease that would make bighorn sheep establishment unfeasible. 

An earlier attempt to establish bighorn sheep on Canyon Mountain failed due to disease. 

The potential disease vectors in the vicinity of Canyon Mountain are not associated with 

permitted grazing on National Forest System lands. 

Wildlife: Climate Change

518. Concern Statement: The Forest Service should analyze how anticipated changes in 

climate will impact focal wildlife species and their habitats as well as the combined 

effects of its alternatives and climate change on wildlife.

Response: Climate change and its effect on surrogate (focal) species are discussed 

within the “Surrogate Species” section of the Final Environmental Impact Statement. 
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519. Concern Statement: The Forest Service should incorporate management areas and 

standards to conserve species and habitats threatened by climate change. 

Response: Rather than using management areas and standards to conserve species and 

habitats, the Forest Plans rely on desired conditions for vegetation to guide management 

toward a landscape that will be more resilient in the face of climate change and thus 

provide habitat for species threatened by climate change. 

Wildlife: Coordination with States 

520. Concern Statement: The Forest Service should integrate State wildlife management 

plans and the Oregon Conservation Strategy into the Forest Plans. In addition, the Forest 

Service should consider using Centralized Oregon Mapping Products and Analysis 

Support System (COMPASS) for spatial fish and wildlife data. 

Response: State management plans and the Oregon Conservation Strategy were 

considered where appropriate. Many of the species of conservation concern that were 

considered in the surrogate species viability analysis are also Oregon Strategy species. 

The Forest Service does not use COMPASS at this time.

Wildlife: Deer and Elk Habitat

521. Concern Statement: The Forest Service should create more big game forage habitat, 

including through the use of regeneration harvests. Elk prefer open areas because of the 

growing presence of wolves. The Forest Service should clarify the need for high cover 

and no roads as elk are often found in agricultural areas and other places with roads. 

Response: There is an extensive body of evidence documenting that elk select habitat 

based on a combination of factors including forage, cover, disturbance, and predation 

risk. The Forest Plans do not have standards and guidelines for cover or forage but 

instead rely on the desired conditions for vegetation to provide elk habitat at the 

landscape scale. In addition, fine scale components of elk habitat will be considered at 

the project scale. In response to comments from the public, Tribes, and State agencies, 

the Forest Plans have identified elk priority areas where road-related disturbance will be 

reduced to encourage elk to remain on public, rather than private land. 

522. Concern Statement: The Forest Service should reduce cattle grazing to improve forage 

for elk. 

Response: The level of cattle grazing varies by alternative. Impacts to elk from each 

alternative, including grazing management, are discussed within the “Elk” section of the 

Final Environmental Impact Statement. 

523. Concern Statement: The Forest Service should not use elk as an indicator species and 

should address the potential need to limit elk populations as unrestrained growth can 

damage riparian areas and other habitats. The Forest Service should request that State 

agencies bring elk populations within desired levels where populations exceed them. 

Response: The Forest Service selected elk as a focal species for the new Forest Plans 

due to the economic and cultural significance of this species. Federal land management 

agencies and the State wildlife agencies share legal co-trustee responsibility for the 

management of wildlife. The Forest Service continues to work closely and cooperatively 

with both the Oregon Department of Fish and Wildlife and Washington Department of 

Fish and Wildlife for the management of elk populations and habitat. Elk populations 
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are not in jeopardy of declining in the near future. The primary concern regarding elk is 

poor distribution driven in part by road-related disturbance on public lands that is 

causing elk to shift their habitat use to private lands. 

524. Concern Statement: The Forest Service should not close motor vehicle use in elk 

winter habitat, as proposed in the WLD-HAB-13 guideline, because it would complicate 

timber harvest and winter logging. 

Response: As in the previous Forest Plan, waivers to winter range road closures to 

conduct logging operations would be considered on a site-specific basis in coordination 

with the district wildlife biologist.

525. Concern Statement: The Forest Service should incorporate standards and guidelines to 

support development of habitat for deer and elk, including protection of bitterbrush. 

Response: The desired condition for plant species composition states “the mix of 

species in the grass and shrub layer of forests, as well as shrubland and grassland 

vegetation, contain a diverse array of native species distributed across the landscape 

reflecting historical conditions.” Habitat conditions for deer and elk will benefit from 

achieving the desired conditions for vegetation. Management for specific plant species,

such as bitterbrush, may occur at the project level. 

526. Concern Statement: The Forest Service should leave wildlife management to the State 

agencies who have jurisdiction. 

Response: Federal land management agencies and the state wildlife agencies share legal 

co-trustee responsibility for the protection and management of wildlife. The Forest 

Service continues to work closely and cooperatively with both the Oregon Department 

of Fish and Wildlife (ODFW) and Washington Department of Fish and Wildlife 

(WDFW) for the conservation and management of wildlife resources, including habitat, 

within the Malheur, Umatilla, and Wallowa-Whitman National Forests. In addition, the 

National Forest Management Act and the Forest Service Manual require that the Forests 

manage for viable populations of native species. 

527. Concern Statement: The Forest Service should consider how management activities 

will affect elk and mule deer populations on neighboring lands. 

Response: This has been thoroughly considered and addressed. Please see the “Elk” 

section in the Forest Plans and the Final Environmental Impact Statement. 

Wildlife: Habitat Connectivity

528. Concern Statement: The Forest Service should not include habitat corridors in the 

forest plans as these areas should be managed to reduce fire risk and uncharacteristic 

conditions. Habitat connectivity can be provided in other ways. 

Response: Habitat corridors are not included in the preferred alternative. 

529. Concern Statement: The Forest Service should build wildlife passage over interstates 

and other major roads to facilitate wildlife migration. 

Response: Wildlife passage structures were not considered in the forest plan revision. 

The Forest Plans do not authorize site-specific actions; site-specific proposals require 

project-level analysis that is completed in compliance with the National Environmental 

Policy Act, including opportunities for public participation. 
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The revised Forest Plans do support and promote wildlife habitat, habitat connectivity, 

and wildlife migration through specific plan components. Desired Conditions for Goal 

1.2 – Species Diversity recognizes that species habitat retains adequate quality, 

distribution, and abundance to provide for viable populations including the ability to 

interact, disperse, and find security within habitats in the Planning Area. Additionally, 

Goal 1.12 – Landscape Patterns, emphasizes that landscape patterns provide 

connectivity, facilitating the movement of wildlife across the landscape. 

530. Concern Statement: The Forest Service should evaluate habitat connectivity using 

landscape ecology metrics. 

Response: See the “Wildlife Habitat Connectivity” section in the “Terrestrial Wildlife 

Species” section of the Final Environmental Impact Statement for discussion on 

connectivity.

Wildlife: Management Indicator and Focal Species

531. Concern Statement: The Forest Service should standardize management indicator 

species, analysis methodologies, and metrics across alternatives so the difference in 

effects on wildlife species can be compared. Rather than ranking alternatives, the Forest 

Service should show how much difference there is between alternatives for species 

viability. The Forest Service should improve the cumulative effects analysis for wildlife 

by incorporating an assessment of how each alternative affects regional wildlife 

populations. Inclusion of wildlife population numbers in each management area was 

suggested for comparison reasons. 

Response: Actual population numbers are not available for most species within the 

Planning Area. The surrogate species analysis includes the management indicator and 

focal species with the exception of deer and elk because their populations are controlled 

primarily by hunter harvest. The surrogate species viability analysis does display the 

relative differences in species viability between alternatives. 

532. Concern Statement: The Forest Service should establish population trends and 

objectives for management indicator species per the 1982 Planning Rule requirements in 

36 CFR Section 219.19. 

Response: The Forest Plans have objectives and monitoring for focal species. The focal 

species selected to meet the monitoring requirements of the 2012 Planning Rule are the 

same species that were selected as Management Indicator Species to meet the 

requirements of the 1982 Planning Rule. Population trends are not available for many 

species in the Planning Area so habitat quantity and quality will be monitored as a 

proxy. 

533. Concern Statement: The Forest Service should clarify how focal species and 

management indicator species were selected and how they are used to guide desired 

conditions and management activities. Conservation strategies for focal species should 

be included. 

Response: Surrogate species (which were called focal species in the Draft 

Environmental Impact Statement) were selected based on the methods in Gaines (2017) 

located in the project record and summarized in the Final Environmental Impact 

Statement Surrogate Species section in Volume 2. Management Indicator Species were 

selected because their population changes are believed to indicate the effects of 

management activities. More explanation on the rationale for selecting Management 
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Indicator Species can be found in the project record. The Forest Plans identify habitat 

objectives for Management Indicator Species. 

534. Concern Statement: The Forest Service should not use the concept of focal species 

because it has no scientific validity. Nor should it plan for species of concern as it has no 

authority for this and the category is very broad. 

Response: The National Forest Management Act requires us to manage for viable 

populations of all native wildlife species, including species of concern. Surrogate 

species were referred to as focal species in the draft Plan and Environmental Impact 

Statement. The name was changed to surrogate species to avoid confusion with the 

definition of focal species that is used in the 2012 Planning Rule. Discussion on the 

validity of the surrogate (focal) species concept is located within the Surrogate Species 

section of Volume 2 in the Final Environmental Impact Statement and the planning

record. The use of the surrogate species approach (Lambeck 1997) is a credible and 

scientifically rigorous method to assess ecosystem conditions that contribute to the 

viability of wildlife species. The long-term sustainability of a surrogate species is 

assumed to be representative of a group of species with similar ecological requirements, 

and this group is assumed to respond in a similar manner to environmental change 

(Suring et al. 2011). The final Forest Plans do not use the term species of concern. 

535. Concern Statement: The Forest Service should include a broader range of management 

indicator species. The species selected do not adequately represent all species that may 

be affected by management and are skewed towards species that prefer open areas. 

Recommendations include all management indicator species from the 1990 plans, 

threatened and endangered species, sensitive species, keystone species, and rare species. 

Response: The complete list of species considered and the rationale for those selected 

and not selected is available in the planning record. 

536. Concern Statement: Specific management indicator species recommendations include: 

bighorn sheep, sage grouse, wolf, wolverine, marten, fisher, bald eagle, boreal owl, bats, 

neotropical songbirds, white-headed woodpecker, Lewis' woodpecker, black-backed 

woodpecker, three-toed woodpecker, upland sandpiper, ash-throated flycatcher, pinyon 

jay, northern harrier, short-eared owl, red-naped sapsucker, MacGillivray's or Wilson's 

warbler, black-crowned night heron, greater blue heron, harlequin duck, bufflehead or 

wood duck, Columbia spotted frog, painted turtle, marsh wren, sandhill crane, and 

northern goshawk.

Response: The complete list of species considered and the rationale for those selected 

and not selected is available in the planning record. 

537. Concern Statement: Rocky Mountain elk and mule deer should be designated 

management indicator species. Others suggested elk should not be an indicator because 

of their abundant populations. 

Response: Rocky Mountain elk and mule deer were designated as a focal species 

because they have great cultural and economic significance in the planning area and 

because their distribution is greatly impacted by Forest Service management. The 

primary issue with elk is not low populations, but poor distribution. It is well 

documented that elk spend a disproportionate amount of time on private land in response 

to road-related disturbance on public land. 

538. Concern Statement: The Forest Service should protect more habitat for marten. 
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Response: The American marten is a surrogate species and effects from alternatives are 

discussed within the “Surrogate Species” section of the Final Environmental Impact 

Statement. 

539. Concern Statement: The Forest Service should protect more pileated woodpecker 

habitat and should not reduce habitat below the historic range of variability. 

Response: The pileated woodpecker is a surrogate species and effects from alternatives 

are discussed within the “Surrogate Species” section of the Final Environmental Impact 

Statement. In addition, the pileated woodpecker is a focal species and will be monitored 

throughout the life of the Plans. 

540. Concern Statement: The Forest Service should revisit its assessment for white-headed 

woodpecker as the loss of large trees and snags from logging will likely lead to a 

declining population trend. 

Response: The white-headed woodpecker is a surrogate species and effects from the 

alternatives are discussed within the “Surrogate Species” section of the Final 

Environmental Impact Statement. In addition, the white-headed woodpecker is a focal 

species and will be monitored throughout the life of the plan. 

Wildlife: Monitoring

541. Concern Statement: The Forest Service should incorporate a standard that requires a 

robust monitoring and evaluation plan to counter the loss of standards and guidelines for 

fish and wildlife. 

Response: Focal species and other species with a concern for viability have monitoring 

objectives identified in the monitoring section of the Forest Plans. 

542. Concern Statement: The Forest Service should develop standards related to monitoring 

plans for indicator species. The Forest Service should clarify how it will monitor the 

status and trend of selected focal species. 

Response: Focal species (formerly management indicator species) have monitoring 

objectives that are identified in the monitoring section of the Forest Plans. 

Wildlife: Other Species

543. Concern Statement: The Forest Service should incorporate standards and guidelines to 

prevent impacts to neotropical migratory and sensitive native birds. 

Response: There is a standard that minimizes impacts to all nesting birds (SD-1G): “To 

the extent practical, known cavity or nest trees should be preserved when conducting 

prescribed (planned ignition) burning activities, mechanical fuel treatments, and 

silvicultural treatments to protect the integrity of the nest site.” 

544. Concern Statement: The Forest Service should consider cougar and porcupine habitat 

needs as well as viability of northern goshawk and other forest raptors such as the sharpshinned hawk, peregrine falcon, and flammulated owl. 

Response: The Forest Plans do not analyze impacts to each species that occurs within 

the Blue Mountains but instead rely on a surrogate species approach that analyzes 

impacts to groups of species. See the “Surrogate Species” section of the Final 

Environmental Impact Statement for more information.
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545. Concern Statement: The Forest Service should not support growth of beaver 

populations as beaver are not a viable option for watershed restoration. Others 

recommended clear goals, standards and guidelines and a timeline for beaver 

reintroduction. 

Response: The National Forest Management Act and the Forest Service Manual require 

that the Forest Service manage for viable populations of native species. There are no 

beaver reintroductions proposed in the Forest Plans. Beaver reintroduction would have 

to be coordinated with State wildlife management agencies and would require sitespecific analysis. Managing grazing and riparian management toward desired conditions 

and other plan direction for riparian areas would promote recovery of beaver habitat, 

which would allow beaver to recolonize suitable habitat.

Wildlife: Roads

546. Concern Statement: The Forest Service should have road densities of less than 2 miles 

per square mile in both elk and deer habitat. 

Response: This concern was addressed between the Draft and Final Environmental 

Impact Statements. The Forest Plans have identified elk priority areas. Across 

approximately 30 percent of MA 4, road-related disturbance will be reduced to within 

the desired condition for elk. See the “Elk” section of the Forest Plans for more 

information. 

547. Concern Statement: The Forest Service should not close roads to provide elk security, 

when factors other than roads affect elk populations, including hunting pressures, 

summer forage conditions, and predators. Cross-country travel restrictions in winter 

range, calving and hunting areas may be sufficient. Research from Starkey is flawed and 

should not be used. 

Response: The “Elk” sections within the Forest Plans and the Final Environmental 

Impact Statement discuss the many factors that influence elk populations including 

forage, predators, and hunting pressure. The Forest Service does not manage predator 

populations or hunting pressure, but is responsible for the management of the road 

system on the National Forests. A large body of literature supports the assertion that 

disturbance associated with open roads influences elk distribution. 

548. Concern Statement: The Forest Service should not close roads because this would limit 

access for managers and hunters. Instead, roads could be gated. 

Response: The Forest Plans do not close routes, trails, or areas open to motor-vehicle 

uses. Decisions regarding closing or gating roads will be done at the project level. 

549. Concern Statement: The Forest Service should not have a low road density of 1.5 miles 

per square mile for winter elk habitat because snow naturally limits vehicle use at high 

elevations during the time elk are most vulnerable. 

Response: Standard RME-2G addresses elk winter range. It states that motor vehicle 

use on designated routes and open routes should not be authorized within elk winter 

range between December 1 and April 14. Federal and State highways and major forest 

roads (such as arterials) are exempt to provide reasonable public access. The intent is to 

minimize disturbance to elk while occupying winter range and encourage elk use of 

public land. 
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Wildlife: Sage Grouse Habitat and Management

550. Concern Statement: The Forest Service should manage sage-grouse habitat consistent 

with the BLM’s strategy. 

Response: Much of the sage grouse direction in this Forest Plans is consistent with 

Forest Service sage-grouse plans. The national plans were developed in collaboration 

with the Bureau of Land Management. 

551. Concern Statement: The Forest Service should include standards and guidelines for 

sage-grouse in the forest plans. 

Response: Sage grouse standards and guidelines can be found in Appendix B of the 

Forest Plans. 

552. Concern Statement: The Forest Service should not preferentially rehabilitate sagegrouse habitat after a wildfire and should allow seeding with non-native plant species 

and use of livestock to establish desired species. In addition, the Forest Service should 

modify the guideline making sage grouse habitat a priority for protection from fire 

(FIRE-4) to make human safety and property higher priorities. 

Response: Sage-grouse habitat receives special consideration during fire suppression 

efforts as part of a strategy to maintain a viable population and prevent an endangered 

species listing. Human safety is always the number one priority in fire suppression 

tactics.

553. Concern Statement: The Forest Service should not set policy for managing private 

lands within and adjacent to core sage-grouse habitat. 

Response: The Forest Service does not set policy on private lands.

Wildlife: Species Viability

554. Concern Statement: The Forest Service should not assume that managing for historical 

range of variability assures species viability, as required by the National Forest 

Management Act regulations, and should clarify how it determined that 40 percent of the 

historical level of habitat is acceptable. The Forest Service should protect species 

viability to the greatest extent possible. 

Response: Several general overriding assumptions are used throughout this assessment. 

A key assumption is that managing for the historical range of variability across 

ecosystems will result in a higher likelihood of maintaining viability for most species.If 

management activities can produce conditions close to or within the historical range of 

variability, species that are adapted to these conditions will have a stronger likelihood of 

persistence (Aplet and Keeton 1999, Landres et al. 1999, Swanson et al. 1994). Use of 

historical range of variability relies on two concepts: that past conditions and processes 

provide context and guidance for managing ecological systems today and that 

disturbance-driven spatial and temporal variability is a vital attribute of nearly all 

ecological systems. Approximating historical conditions for source habitats provide a 

management strategy likely to sustain diverse surrogate species, even for those species 

where little information is available (Hunter et al. 1988; Landres et al. 1999; Swanson et 

al. 1994). Similarly, because of limited understanding about ecosystems, approximating 

past conditions offers one of the best means for predicting and reducing impacts to 

current ecosystems (Kaufmann et al. 1994). Therefore, if the amount and structure of 

source habitats are within the historical range of variability, associated wildlife species 
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will have a greater likelihood of sustainability than if the amount and structure of source 

habitats are outside the historical range of variability (Raphael et al. 2001; Spies et al. 

2006). 

Several authors (Rompré et al. 2010, Svancara et al. 2005, With and Crist 1995, Tear et 

al. 2005) have indicated that landscapes containing at least 40 percent of source habitat 

for a species should sustain that species over time. King and Worth (2002) point out that 

dispersal success is usually not a concern when habitat exceeds 40 percent of the 

landscape.

555. Concern Statement: The Forest Service needs population data to assess species 

viability. 

Response: By using a hierarchical evaluation of species, groups, and families, the 

analysis process addresses single- and multi-species needs as well as identifying broadscale patterns of habitat change, as did Wisdom et al. (2000). 

Within the planning area, 175 species were identified as having some level of local 

and/or regional concern. These 175 species were evaluated and 38 species representing 

26 families or groups based on similarity of habitat use were selected for assessment. In 

selecting 38 species for more detailed analysis, the concept of surrogate species 

(Lambeck 1997) was applied and the findings of Wisdom et al. (2000) were consulted. 

Terrestrial species were grouped by habitat associations; risks and threats were identified 

for the group, and a representative species (surrogate species) was selected for the 

group. The groupings are based on the terrestrial families in the Forest Service Pacific 

Northwest Region (Region 6 ) terrestrial assessment (USDA Forest Service 2010). The 

use of terrestrial families may have tenuous value when applied to a small area like a 

subbasin, but when applied to large landscapes it can be an effective analysis tool 

(Raphael et al. 2001, USDA and USDI 2000). 

556. Concern Statement: The Forest Service should not consider species viability or 

prioritize wildlife populations in the Forest Plans. 

Response: The implementing regulations (36 CFR 219.19) for the National Forest 

Management Act of 1976 (NFMA) call for providing viable populations of native and 

desired nonnative wildlife.

557. Concern Statement: The Forest Service should clarify the description of viability 

outcomes, for example by integrating the factor analyses. 

Response: A more detailed description of the viability analysis (Gaines et al. 2017) is in 

the planning record. 

558. Concern Statement: The Forest Service should use more extensive data to assess 

viability for boreal owl, water vole, and Canada lynx. The Forest Service should expand 

monitoring to track Cassin’s finch viability.

Response: Analysis indicates that at the broad scale, habitat for the lynx is being 

maintained or moved towards the historical range of variability. In addition, the Blue 

Mountains are considered unoccupied by resident lynx and a change in suitable habitat 

on the fringe of lynx range would not be expected to have any impact on the lynx 

population. Trends in source habitat for the Boreal Owl and Cassin’s Finch will be 

monitored under the new Forest Plans. 
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The viability modeling indicated that there is a low level of concern for the water vole 

under all alternatives for the life of the plan. The assumption is that those species with a 

moderate or low level of concern have minimal risk of becoming nonviable during the 

life of the plan. A more detailed analysis for these species (Wales et al. 2011) is in the 

planning record. 

559. Concern Statement: The Forest Service should focus more on species that require cool 

and moist forest with large tree structure, decadence, and large blocks of interior forest 

habitat. 

Response: The pileated woodpecker was selected as the surrogate species to represent 

species that use cool moist forest with large trees. Providing adequate amounts and 

distribution of habitat and managing risks for pileated woodpeckers is assumed to 

provide the ecological conditions needed to maintain viability of other species 

associated with cool moist forest with large trees.

560. Concern Statement: The Forest Service should develop plan components including 

goals, objectives, and standards and guidelines to ensure viable populations of native 

wildlife.

Response: A key assumption of the wildlife analysis is that managing for the historical 

range of variability across ecosystems will result in maintaining viability for most 

species.The viability modeling indicated that there is a low level of concern for most 

species that were analyzed. Species for which the viability models predict a high level of 

concern have additional objectives and monitoring to allow for adaptive management 

throughout the life of the plan. Standards and guidelines were developed in cases where 

other plan direction, such as desired conditions, is insufficient to meet the needs of a 

species. 

Wildlife: Standards and Guidelines

561. Concern Statement: The Forest Service should remove standard STA EXP-4 that 

would only allow vehicle access on designated routes in the Starkey Experimental 

Forest and Range. 

Response: Starkey Experimental Forest and Range is a research area and standards and 

guidelines are related to research objectives. 

562. Concern Statement: The Forest Service should dramatically enhance protections for 

wildlife by adopting standards that: 

♦ protect wildlife dispersal (G-1); 

♦ protect late old structure, riparian corridors, and forested habitat corridors within old 

moist and cold forests (G-2, G-3, S-4); 

♦ manage for as much old forest structure as possible (S-5); 

♦ protect goshawk nests (G-10); 

♦ establish goshawk post-fledging family areas (WLD-HAB-8) and home ranges 

management areas (WLD-HAB-9); 

♦ support 3 reproductive pairs of pileated woodpeckers per watershed (WLD-HAB11);
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♦ survey potential bat sites before potentially disturbing activities (WLD-HAB-23); 

and 

♦ survey goshawk habitat (WLD-HAB-24) 

Response: The new forest plans rely primarily on desired conditions to maintain habitat 

for a diversity of species. There are no standards or guidelines pertaining to wildlife 

dispersal or habitat corridors, but see the desired condition for 1.12 Landscape Patterns, 

which discusses providing connectivity to facilitate the movement of wildlife across the 

landscape. There are many standards and guidelines pertaining to old forest and riparian 

areas (see 1.1 Watershed Function and 1.14 Old Forest). Goshawk nests will be 

protected by SD-1G: “To the extent practical, known cavity or nest trees should be 

preserved when conducting prescribed (planned ignition) burning activities, mechanical 

fuel treatments, and silvicultural treatments to protect the integrity of the nest site.” 

There are no standards or guidelines pertaining to goshawk post-fledging areas or 

pileated woodpeckers. There are no requirements to survey for potential bat sites; 

however, there is a standard to protect bat roost and maternity sites. 

563. Concern Statement: The Forest Service should enhance protections for wildlife by 

changing all species diversity guidelines into standards.

Response: In order to provide protection of resources, projects must follow all 

guidelines. Guidelines are an important component of plan direction, allowing some 

flexibility (with proper documentation) while still providing guidance to protect 

resources. Guidelines are commitments that national forest managers will follow during 

plan implementation. The project analysis will document how the project is meeting the 

intent of every guideline. 

564. Concern Statement: The Forest Service should specify whether species diversity 

standards and guidelines apply to utility construction and right-of-way activities. 

Response: The Forest Plans specify whether standards and guidelines apply across the 

national forest or only to specific management areas. 

Wildlife: Threatened, Endangered and Sensitive Species

565. Concern Statement: The Forest Service should have separate standards and guidelines 

for federally listed species and sensitive species. In addition, the Forest Service should 

only include broad statements about complying with the Endangered Species Act rather 

than prescriptive requirements because it is a programmatic document.

Response: The biological assessment presents the species conservation measures used 

to protect listed species and species conservation measures have been incorporated into 

Plan direction. In some cases, a standard or guideline may apply to both listed and 

sensitive species. 

566. Concern Statement: The Forest Service should include standards and guidelines for the 

conservation and recovery of listed species and should incorporate management 

guidance aligned with conservation strategies and recovery plans for listed species. 

Response: The biological assessment presents the species conservation measures used 

to protect listed species. The interdisciplinary team did an additional review between the 

draft and final Plans to verify that the conservation measures are represented within Plan 

direction. During Plan implementation, each project includes a biological assessment 

that addresses how conservation measures are addressed for the specific project. 
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Conservation strategies and recovery plans for listed species were considered during the 

development of the Forest Plans. 

567. Concern Statement: The Forest Service should eliminate the overly broad category of 

sensitive species and focus on managing for resilient habitats. The effect of sensitive 

species designation should be considered. 

Response: The purpose of the sensitive species designation is to prevent a species from 

becoming threatened or endangered. Sensitive species direction is taken directly from

Forest Service Manual Chapter 2670. Sensitive species are selected from (1) Fish and 

Wildlife Service or National Marine Fisheries Service candidates for Federal listing 

(categories 1 and 2) under Federal Register Notice of Review, (2) State lists of 

endangered, threatened, rare, endemic, unique, or vanishing species, especially those 

listed as threatened under State law, or (3) other sources as appropriate in order to focus 

conservation management strategies and to avert the need for Federal or State listing as 

a result of national forest management activities. 

Wildlife: Wolf Management

568. Concern Statement: The Forest Service should correct inaccurate statements in the 

Draft Environmental Impact Statement including that wolves are displaced from habitat 

by humans, challenged by population isolation, require fewer roads, and that most wolf 

mortality in the distinct population segment has been in response to livestock 

depredations. 

Response: Several researchers have documented the effects of roads and other human 

activities on wolves (Thiel 1985, Mech 1989, Carroll 2003, Carroll et al. 2006, Larsen 

and Ripple 2006).

In the time period from 2011-2016 there were 19 wolf mortalities documented by 

Oregon Department of Fish and Wildlife. Of those, one wolf (5 percent) died from 

poison, two (11 percent) died from parvo, five (26 percent) died from poaching, seven 

(37 percent) died from lethal removal in response to livestock depredations, and four (21 

percent) died from unknown causes. 

569. Concern Statement: The Forest Service should not manage for wolves because it’s not 

their job and the wolves are doing fine on their own. Wolves are negatively impacting 

local ranchers, hunting and tourism. 

Response: The National Forest Management Act and the Forest Service Manual require 

that the Forest Service manage for viable populations of native species. 

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Appendix D: Wild and Scenic Rivers

Introduction 

Congress enacted the Wild and Scenic Rivers Act in 1968 to preserve select river’s free-flowing 

condition, water quality and outstandingly remarkable values. The most important provision of 

the Act is protecting rivers from the harmful effects of water resources projects. To protect freeflowing character the Federal Energy Regulatory Commission (which licenses nonfederal 

hydropower projects) is not allowed to license construction of dams, water conduits, reservoirs, 

powerhouses, transmission lines, or other project works on or directly affecting wild and scenic 

rivers. Other Federal agencies may not assist by loan, grant, license, or otherwise any water 

resources project that would have a direct and adverse effect on the values for which a river was 

designated. 

The Wild and Scenic Rivers Act also directs that each river in the National Wild and Scenic 

Rivers System (National System) be administered in a manner to protect and enhance a river’s 

outstanding natural and cultural values. It allows existing uses of a river to continue and future 

uses to be considered, so long as existing or proposed use does not conflict with protecting river 

values. The Act also authorizes managing agencies to build partnerships among landowners, river 

users, tribal nations, and all levels of government. 

Beyond the immediate protection afforded to the eight rivers in the enabling legislation, the Wild 

and Scenic Rivers Act established a process for building a legacy of protected rivers. Rivers may 

be identified for study by an act of Congress under Section 5(a) or through Federal agencyinitiated study under section 5(d)(1). Section 5(d)(1) directs federal agencies to consider the 

potential of wild, scenic and recreational rivers in their planning processes and its application has 

resulted in numerous individual river designations and state and area-specific legislation. 

Both Sections 5(a) and 5(d)(1) studies require determinations to be made regarding a river’s 

eligibility, classification and suitability. Eligibility and classification represent an inventory of 

existing conditions. Eligibility is an evaluation of whether a river is free-flowing and possesses 

one or more outstandingly remarkable values. If found eligible, a river is evaluated to determine 

its current level of development (water resources projects, shoreline development, and 

accessibility) and a recommendation is made that it be placed into one or more of three classes—

wild, scenic or recreational.

The final procedural step, suitability, provides the basis for determining whether to recommend a 

river as part of the National System. A suitability analysis provides information to answer the 

following questions: 

• Should the river’s free-flowing character, water quality, and outstandingly remarkable 

values be protected, or are one or more other uses important enough to warrant doing 

otherwise? 

• Will the river’s free-flowing character, water quality, and outstandingly remarkable 

values be protected through designation? Is it the best method for protecting the river 

corridor? In answering these questions, the benefits and impacts of wild, scenic and 

recreational designation must be evaluated and alternative protection methods considered. 

• Is there a demonstrated commitment to protect the river by any nonfederal entities that 

may be partially responsible for implementing protective management? 
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Rivers authorized for study by Congress are protected under the Wild and Scenic Rivers Act; 

specifically, Sections 7(b)—prevents the harmful effects of water resources projects; 8(b)—

withdraws public lands from disposition under public land laws; 9(b)—withdraws locatable 

minerals from appropriation under mining laws; and 12(a)—directs actions of other federal 

agencies to protect river values. These protections last through the study process, including a 

three-year period following transmittal of the final study report by the President to Congress. The 

integrity of the identified classification must also be maintained during the protection period. 

The identification of a river as eligible through the forest planning process does not confer 

protections under the Wild and Scenic Rivers At. To manage the river for its potential inclusion in 

the National System, other authorities are cited to protect its free-flowing character, water quality, 

outstandingly remarkable values, and recommended classification. 

Past Planning Efforts: Malheur National Forest

In 1994, an appeal decision was reached with American Rivers and the Oregon Rivers Council of 

the existing Forest Plan. As part of the appeal resolution, the Forest was required to further 

document the potential eligibility of 10 rivers. The Malheur National Forest was also required to 

review rivers for eligibility that had been identified in the Pacific Northwest Rivers Study (FSH 

1090.12, chapter 8, Section 8.11, no. 4) and to protect eligible segments of the John Day River, 

Murderer’s Creek, and Little Malheur River, pending analysis of suitability. Forest Service staff 

completed this analysis in 1995. 

Past Planning Efforts: Umatilla National Forest

As a result of an agreement between American Rivers and Oregon Rivers Council, 14 rivers on 

the Umatilla National Forest, including the Tucannon River, were studied for eligibility. Six of the 

rivers were found to be eligible. If a river was eligible, classification determinations were 

completed for those rivers and documented in a resource report that was prepared as a “Working 

Paper” by the Forest. This paper has not been made available for public review; however, the 

Umatilla has provided interim protection and management since that time for the six eligible 

rivers.

Past Planning Efforts: Wallowa-Whitman National Forest

Similar to the Umatilla National Forest, through agreement between American Rivers and Oregon 

Rivers Council, the Forest performed evaluations of eleven rivers on the forest. These rivers were 

studied for their potential eligibility and suitability as wild, scenic and recreational rivers. The 

results have been documented in two final legislative environmental impact statements (FLEIS). 

The FLEIS document the analysis of eligibility and suitability of the rivers for inclusion within 

the National Wild and Scenic River System. Based on the analysis contained in the two FLEIS, 

three rivers are identified as suitable for inclusion in the national system. These recommendations 

have yet to be forwarded to Congress for action. 

Process to Identify 

and Classify Potentially Eligible Wild and Scenic Rivers 

The following describes the multi-step process used for identifying those rivers and streams on 

the Blue Mountains national forests that are potentially eligible for inclusion in the National Wild 

and Scenic River System. Maps of designated and potentially eligible wild, scenic, and 

recreational rivers are also included. 
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In order to identify potentially eligible rivers the Forests followed guidance outlined in the Forest 

Service Handbook 1912.09, chapter 80 for identifying and evaluating potential additions to the 

National Wild and Scenic Rivers System; and used additional guidance found in the Wild and 

Scenic Rivers Guidelines as published in the Federal Register/Vol. 47, No. 173/ September 7, 

1982. 

Step 1 – Evaluate the status of eligible wild and scenic rivers in the forests’ 1990 Forest Plans and 

subsequent settlement agreements. 

The interdisciplinary team reviewed the forest plans and the results from past eligibility studies 

to inform the current forest plan revision process. 

Step 2 – Complete a systematic forest-wide inventory of streams and rivers. 

As directed in the Wild and Scenic Rivers Act at 5(d) (1) and the Forest Service Manual policy 

1924.03 a systematic inventory of named streams and rivers was completed for each of the Blue 

Mountains national forests. The inventory was generated from the Forests’ GIS coverage of 

rivers and streams on the forest and other source material and resulted in identifying candidates 

to consider for edibility. The Forest wide inventory of hundreds of perennial streams and rivers 

on the Blue Mountains national forests resulted in the identification of candidate rivers and 

streams.

Step 3 – Determine which of the candidate named streams and rivers are free-flowing.

Initial assessments were accomplished by interdisciplinary teams representing district and/or 

supervisors office resource specialists that reviewed the listed named rivers and streams; and 

based on their knowledge, identified if the river or stream is free-flowing This determination is 

made by answering the question: 

Is the river segment flowing in a natural condition without impoundment, diversion, 

straightening, rip rapping, or other modification of the waterway? Bridges and culverts 

are allowed and do not affect the segment’s free-flowing nature. 

If the river segment is not free-flowing, the river is not eligible.

Step 4 - Identify potential eligibility by determining which of the candidate named rivers and 

streams are free-flowing, and have a potential “outstandingly remarkable value.” 

To be eligible for designation, a river must be free flowing and possess one or more 

outstandingly remarkable value. Thus, the eligibility analysis consists of an examination of the 

river's hydrology, including any man made alterations; and an assessment of its natural, 

cultural, and recreational resources. The determination that a river area contains outstandingly 

remarkable values is a professional judgment on the part of the interdisciplinary team, based on 

objective, site-specific assessments. 

In order to be assessed as outstandingly remarkable, a river related value must be a unique, rare, 

or exemplary feature that is significant at a comparative regional or national scale. Dictionary 

definitions of the words "unique" and "rare" indicate that such a value would be one that is a 

conspicuous example from among a number of similar values that are themselves uncommon or 

extraordinary. Only one such value is needed for eligibility. 

The area, region or scale of comparison is not fixed, and is defined as that which serves as a 

basis for meaningful comparative analysis; it may vary depending on the value being 

considered. Typically, a "region" is defined on the scale of an administrative unit, a portion of a 
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state, or an appropriately scaled physiographic or hydrologic unit. The comparative scale used 

for this assessment is the Blue Mountains national forests and the larger surround Columbia 

River Basin. That is, the rivers and streams on the Blue Mountains national forests were not 

only compared one to another, but also included a comparison to the broader Columbia Basin 

region for select values. 

While the spectrum of resources that may be considered is broad, all values should be directly 

river related. That is, they should: 

a. Be located in the river or on its immediate shore lands (generally within 1/4 mile on 

either side of the river); 

b. Contribute substantially to the functioning of the river ecosystem; and/or 

c. Owe their location or existence to the presence of the river.

The following criteria were considered in order to establish whether one or more outstandingly 

remarkable values are present. Determining that a river area contains outstandingly remarkable 

values is a professional judgment that is made by an interdisciplinary team of Forest-level 

resource specialists, and is based on existing objective, comparative, scientific information.

Scenery

• Is there a high degree of landscape diversity? 

• Has the landscape been modified? 

• Is the scenic value unique to the region? 

Recreation

• Are the recreation opportunities unique enough to attract visitors from outside the 

geographic region and would visitors be willing to travel long distances to do so? 

• Are interpretive opportunities exceptional?

• Are there opportunities for national or regional competitive events? 

Wildlife

• Does the stream contain nationally or regionally important populations of wildlife 

species?

• Are there known populations of unique or federal- or state-listed wildlife species?

• Are there known populations of candidate, threatened, endangered, and sensitive species? 

• Is the diversity of species unique to the region?

• Does the stream corridor provide exceptionally high quality of unique habitat or a critical 

link in habitat conditions for wildlife of national or regional significance or federal- or 

state-listed or candidate, threatened, endangered, and sensitive species?

• Is the diversity of habitat unique to the region?

Fisheries 

• Is the stream a nationally or regionally important producer of resident and/or anadromous 

fish species?
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• Does the stream contain wild stocks and/or federal- or state-listed threatened, 

endangered, or sensitive species?

• Is the diversity of species or habitat unique to the region?

• Does the stream provide or have the potential to provide exceptionally high quality 

habitat for indigenous fish species? 

Heritage Resources

• Does the stream corridor contain known occupation sites used by Native Americans that 

are unusual, have exceptional human interest value, have national or regional importance 

for interpreting pre-history, been used for sacred purposes, or listed or eligible for listing 

on the National Register of Historic Places?

• Does the stream corridor contain known site(s) or feature(s) associated with a significant 

event, important person, or cultural activity from the past that was rare or unusual? Of 

particular importance are sites or features that are listed in, or eligible for inclusion in the 

National Register of Historic Places.

Geologic/Hydrologic 

• Does the stream contain an example(s) of rare or unusual geologic or hydrologic 

features?

Botany/Ecologic

• Does the stream corridor contain nationally or regionally important populations of 

indigenous plant species that are rare or unique or significant populations of federal- or 

state-listed or candidate threatened, endangered, or sensitive species?

• Is the diversity of plant communities unique?

Water Quality

• Does the stream have exceptionally pure, clear, and/or clean water when compared to 

other similar streams in the basin?

• Is this tributary recognized as providing exceptionally high quality water critical for fish, 

wildlife, recreation, or community uses? 

Assessments were accomplished by interdisciplinary teams with district and/or supervisor office 

resource specialists reviewing the listed named rivers and streams, and based on their knowledge, 

identify whether a potential outstandingly remarkable value exists. In most cases, on-the-ground 

knowledge was used in developing the assessment of outstandingly remarkable values. 

Step 5 - Using the Blue Mountains national forest and the broader Columbia/Snake River Basin 

as comparative scales, review the identified potential outstandingly remarkable values and 

determine whether they meet the criteria of being rare, unique, or exemplary. 

This review was completed by the Forest Plan revision interdisciplinary team along with forest 

specialists. The interdisciplinary teams made preliminary determinations as to whether the 

potential outstandingly remarkable value(s) was unique, rare, or an exemplary feature that is 

significant at the selected comparative scale and meets the other criteria for being directly riverrelated (as described in a, b, c, above). These determinations resulted in the list of eligible 

streams that were brought forward for inclusion in the Environmental Impact Statement for 
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analysis in the action alternatives and include 21 rivers and streams (9 on the Umatilla, 11 on the 

Wallowa-Whitman and 1 on the Malheur National Forests) that are eligible for inclusion in the 

National System.

Narratives were developed for each stream or river system. Some outstandingly remarkable 

values were found to not be rare, unique, or exemplary. Based on the narratives, the 

outstandingly remarkable values were identified and summarized for each eligible stream or 

river system. The final outstandingly remarkable value(s) were determined for the entire river 

system.

Step 6 – Determination preliminary Classification

The potential classification of a river found to be eligible is based on the condition of the river 

and the adjacent lands as they currently exist. Classification identifies the level of human 

alteration and water quality of the river within 1⁄4 mile of the bed and bank. The social and 

physical setting of the river in its current state determined the classification. Classification does 

not need to be consistent for the entire eligible stretch of river. An eligible river can have 

multiple segments each classified differently. Section 2(b) of the Wild and Scenic Rivers Act of 

October 2, 1968 specifies and defines three classification categories for eligible rivers: wild 

rivers, scenic rivers, and recreational rivers.

The USDA and USDI Guidelines for Eligibility, Classification, and Management of River Areas 

dated September 7, 1982 (USDA-USDI Guidelines) provides the following classification criteria 

for wild, scenic, and recreational rivers.

Table D-1. Classification attributes for wild, scenic and recreational river status

Attribute Wild Scenic Recreational

Water 

Resource 

Development

Free of impoundment. Free of impoundment. Some existing impoundment or 

diversion.

The existence of low dams, 

diversions, or other 

modifications of the waterway is 

acceptable, provided the 

waterway remains generally 

natural and riverine in 

appearance.

Shoreline 

Development

Essentially primitive. 

Little or no evidence of 

human activity.

Largely primitive and 

undeveloped. No substantial 

evidence of human activity.

Some development. Substantial 

evidence of human activity.

The presence of a few 

inconspicuous 

structures, particularly 

those of historic or 

cultural value, is 

acceptable.

The presence of small 

communities or dispersed 

dwellings or farm structures 

is acceptable.

The presence of extensive 

residential development and a 

few commercial structures is 

acceptable.

A limited amount of 

domestic livestock 

grazing or hay 

production is 

acceptable.

The presence of grazing, hay 

production, or row crops is 

acceptable.

Lands may have been 

developed for the full range of 

agricultural and forestry uses.

Little or no evidence of 

past timber harvest. No 

ongoing timber harvest.

Evidence of past or ongoing 

timber harvest is acceptable,

provided the forest appears 

natural from the riverbank.

May show evidence of past and 

ongoing timber harvest.
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Attribute Wild Scenic Recreational

Accessibility Generally inaccessible 

except by trail.

Accessible in places by road. Readily accessible by road or 

railroad.

No roads, railroads or 

other provision for 

vehicular travel within 

the river area. A few 

existing roads leading to 

the boundary of the area 

are acceptable.

Roads may occasionally 

reach or bridge the river. The 

existence of short stretches 

of conspicuous or longer 

stretches of inconspicuous 

roads or railroads is 

acceptable.

The existence of parallel roads 

or railroads on one or both 

banks as well as bridge 

crossings and other river 

access points is acceptable.

Water Quality Meets or exceeds 

criteria or federally 

approved state 

standards for aesthetics, 

for propagation of fish 

and wildlife normally 

adapted to the habitat of 

the river, and for primary 

contact recreation 

(swimming) except 

where exceeded by 

natural conditions.

No criteria are prescribed by 

the Wild and Scenic Rivers 

Act. The Federal Water 

Pollution Control Act 

Amendments of 1972 have 

made it a national goal that 

all waters of the United 

States are made fishable and 

swimmable. Therefore, rivers 

will not be precluded from 

scenic or recreational 

classification because of poor 

water quality at the time of 

their study, provided a water 

quality improvement plan 

exists or is being developed 

in compliance with applicable 

federal and state laws.

No criteria are prescribed by the 

Wild and Scenic Rivers Act. The 

Federal Water Pollution Control 

Act Amendments of 1972 have 

made it a national goal that all 

waters of the United States are 

made fishable and swimmable. 

Therefore, rivers will not be 

precluded from scenic or 

recreational classification 

because of poor water quality at 

the time of their study, provided 

a water quality improvement 

plan exists or is being 

developed in compliance with 

applicable federal and state 

laws.

(1) Wild River Areas — The rivers or sections of rivers that are free of impoundments and 

generally inaccessible except by trail, with watersheds or shoreline essentially primitive and 

waters unpolluted. These represent vestiges of primitive America. 

These criteria are interpreted as follows: 

a. "Free of impoundments." Wild river areas shall be free of impoundments. 

b. "Watersheds or shorelines essentially primitive." Wild river areas will show little or 

no evidence of human activity. Shorelines and watersheds within the river area 

should be essentially free of structures including such things as buildings, pipelines, 

power lines, dams, pumps, generators, diversion works, riprap, and other 

modifications of the waterway or adjacent land within the river corridor. The 

existence of a few inconspicuous structures, particularly those of historic or cultural 

value, at the time of study need not bar wild classification. A limited amount of 

domestic livestock grazing or hay production may be considered "essentially 

primitive." There should be no row crops or ongoing timber harvest and the river area 

should show little or no evidence of past logging activities. 

c. "Generally inaccessible except by trail." Wild river areas will not contain roads, 

railroads, or other provisions for vehicular travel within the river area. The existence 

of a few inconspicuous roads leading to the boundary of the river area at the time of 

study will not necessarily bar wild river classification. 

d. "Waters unpolluted." The water quality of a wild river will meet or exceed federal 

criteria or federally approved state standards for aesthetics, for propagation of fish 
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and wildlife normally adapted to the habitat of the stream, and for primary contact 

recreation except where exceeded by natural conditions. 

(2) Scenic River Areas — The rivers, or sections of rivers that are free of impoundments, with 

shorelines or watersheds still largely primitive and shorelines largely undeveloped, but accessible 

in places by roads. 

These criteria are interpreted as follows: 

a. "Free of impoundments." Scenic river areas will be free of impoundments. 

b. "Shorelines or watersheds still largely primitive." To qualify for scenic classification, 

the rivers segment's shorelines and immediate environment should not show 

substantial evidence of human activity. The portion of the watershed within the 

boundary of the scenic river may have some discernible existing development. 

"Largely primitive" means that the shorelines and the immediate river environment 

still present an overall natural character, but that in places land may be developed for 

agricultural purposes. Row crops would be considered as meeting the test of "largely 

primitive," as would timber harvest and other resource use, providing such activity is 

accomplished without a substantial adverse effect on the natural appearance of the 

river or its immediate environment. "Shorelines largely undeveloped," means that any 

structures or concentration of structures must be limited to relatively short reaches of 

the total area under consideration for designation as a scenic river area. 

c. "Accessible in places by road." Means that roads may reach the river area and 

occasionally bridge the river. The presence of short stretches of conspicuous or 

longer stretches of inconspicuous and well-screened roads or railroads will not 

necessarily preclude scenic river designation. In addition to the physical and scenic 

relationship of the free-flowing river area to roads or railroads, consideration should 

be given to the type of use for which such roads or railroads were constructed and the 

type of use which would occur within the proposed scenic river area. 

(3) Recreational River Areas — The 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.

These criteria are interpreted as follows: 

a. "Some impoundment or diversion in the past." There may be some existing 

impoundments, diversions, and other modifications of the waterway having an 

impact on the river area. Existing low dams, diversion works, rip-rap, and other 

minor structures will not bar recreational classification, provided the waterway 

remains generally natural and riverine in appearance. 

b. "Some development along their shorelines." Lands may have been developed for the 

full range of agricultural and forestry uses, may show evidence of past and ongoing 

timber harvest, and may include some residential, commercial, or similar 

development. 

c. “Readily accessible by road or railroad." River areas classified as recreational may 

contain existing parallel roads or railroads in close proximity to one or both banks of 

the river as well as bridge crossings and roads fording or ending at the river.” 

There are several points to keep in mind when reading and applying the classification criteria: 
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381

• It is important to understand each criterion, but it is more important to understand their 

collective intent. Each river segment and its immediate environment should be considered 

as a unit. The basis for classification is the degree of naturalness, or stated negatively, the 

degree of evidence of man's activity in the river area. The most natural rivers will be 

classified wild; those somewhat less natural, scenic, and those least natural, recreational. 

• Generally, only conditions within the river area determine classification; however, 

occasionally conditions outside the river area, such as developments that could impact air 

and water quality, noise levels, or scenic views within the river area, may influence 

classification. 

• For the purpose of classification, a river area may be divided into segments. Each 

segment, considered as a whole, will conform to one of the classifications. In segmenting 

the river, the assessment should take into account the management strategies necessary to 

administer the entire river area and should avoid excessive segmentation. 

• The Wild and Scenic Rivers Act provides no specific guidance on water quality for scenic 

and recreational rivers. However, the Clean Water Act has made it a national goal that all 

waters of the United States be made fishable and swimmable, and provides the legal 

means for upgrading water quality in any river which would otherwise be suitable for 

inclusion in the system. Therefore, rivers will not necessarily be excluded from the 

system because of poor water quality at the time of study, provided a water quality 

improvement plan exists or is being developed in compliance with applicable state and 

federal laws. 

• Although each classification permits certain existing development, the criteria do not 

imply that additional inconsistent development is permitted in the future. 

• The classification criteria provide uniform guidance for professional judgment, but they 

are not absolutes. It is not possible to formulate criteria so as to mechanically or 

automatically classify river areas. Therefore, there may occasionally be exceptions to 

some of the criteria. For example, if the assessment finds that strict application of the 

classification criteria would not provide the most appropriate classification for a specific 

river segment, the recommendation may consider an exception to the classification 

criteria. 

The inventory of perennial streams and rivers on the Blue Mountains national forests resulted in 

the identification of candidate rivers and streams. An eligibility assessment of these candidates 

was conducted to identify any potential outstandingly remarkable values, as directed by the Forest 

Service Manual, and to determine the rivers free-flowing characteristics. Based on this 

assessment 21 rivers and streams (9 on the Umatilla, 11 on the Wallowa-Whitman and 1 on the 

Malheur National Forests) are eligible for inclusion in the National System.

Summary Evaluation Form

The following is an example of the summary evaluation form used by each National Forest to 

evaluate the rivers and streams in the Blue Mountains Plan Area. A report has been completed for 

each eligible river and is contained within the plan revision files at the Wallowa-Whitman Forest 

Headquarters. 

STUDY AREA SUMMARY – Provide locational information and include a map. 

Name of River: xxxx 
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Location: Describe the entire length studied; e.g., from its headwaters to confluence with xx. 

Additionally, describe each segment: 

Segment x – Define termini (including legal description, as necessary). Indicate river miles. 

River Mileage: Indicate the entire miles of river studied and portion determined eligible. 

Studied: xx miles 

Eligible: xx miles 

ELIGIBILITY – Include determination of river’s free-flow and whether it possesses one or more 

outstandingly remarkable values 

Determination of Free-flow: Describe the assessment of the river’s free-flow, by segment, if 

necessary. 

Determination of Outstandingly Remarkable Values: Utilize established guidelines to evaluate 

specific river resource values and determine which are outstandingly remarkable. Include the 

criteria, the description of the particular resource value and a finding. 

Summary of Outstandingly Remarkable Values: Summarize the individual resource findings 

by listing the values identified as outstandingly remarkable with a brief rationale. 

CLASSIFICATION – Details the inventoried classification. Describe the basis for the 

classification of each river segment; i.e., the level of development.

Wild and Scenic Rivers 

Designated Rivers

Across the Blue Mountains national forests, there are 11 rivers designated by Congress as Wild 

and Scenic Rivers. Of those 11 rivers, 145 miles are classified as wild, 58 miles as scenic, and 47 

miles are classified as recreational rivers.

Management areas for each wild and scenic river have been developed for the proposed Revised 

Forest Plan of the Blue Mountains national forests. Those rivers designated by Congress which 

are part of the National Wild and Scenic River System are allocated to Management Area (MA) 

2A – Wild and Scenic River (includes Designated, Eligible, and Suitable rivers). The designated 

rivers of the Malheur, Umatilla, and Wallowa-Whitman National Forests are shown in Table D-2. 
Final Environmental Impact Statement, Volume 4 

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Table D-2. Designated wild and scenic rivers1 for each national forest2

River Name Wild Scenic Recreational Outstandingly Remarkable Values

Malheur

Malheur River 6.7 7.0 0.0 Scenery, geology, wildlife habitat, 

history

North Fork Malheur River 0 25.5 0.0 Scenery, geology, wildlife, fisheries

Totals 6.7 32.5 0.0

Umatilla

Wenaha River 18.7 2.7 0.15 Recreation, scenery, wildlife, fisheries

Grande Ronde River3 17.4 0 1.5 Recreation, fisheries, wildlife

North Fork John Day River3 24.3 10.5 8.9 Scenic, recreation, fisheries, wildlife, 

cultural

Totals 60.4 13.2 10.55

Wallowa-Whitman

Eagle Creek 4.5 6.0 18.4 Fish, recreation, scenery, cultural 

resources, geology/paleontology

Grande Ronde River3 17.4 0.0 1.5 Recreation, fisheries, wildlife

Joseph Creek 8.6 0.0 0.0 Scenic, recreation, geology, fish, water 

quality, wildlife, cultural resources

Imnaha River 15.0 0.0 0.0 Scenic, recreation, fisheries, wildlife, 

historic, botanical, cultural resources

Lostine River 5.0 0.0 11.0 Scenic, recreation, fisheries, wildlife, 

botanical

Minam River 41.9 0.0 0.0 Scenic, recreation, geology, fisheries, 

wildlife

North Fork John Day River3 

Malheur River

3.5 0 6.9 Scenic, recreation, fisheries, wildlife, 

cultural

North Powder River 0.0 6.4 0.0 Recreation, scenery

Totals 95.9 12.4 37.8

1. Mileages in this table are derived from legislative language and/or the most recent figures reported in river plans (or 

“Comprehensive River Management Plans”). 

2. Miles within the Hells Canyon National Recreation Area are not included in this table.

3. The Grande Ronde and North Fork John Day rivers are listed above for both the Umatilla and Wallowa-Whitman National 

Forests as administration is shared. Mileage for the North Fork John Day River is divided within the table to reflect the 

mileage within and administered by each national forest. The Grande Ronde River is part of the administrative boundary 

between the Umatilla and Wallowa-Whitman National Forests, and the mileage is displayed equally for each of the national 

forests and is only counted once in the overall total. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

384

Eligibility Summary

As part of the forest plan revision process, the three Forests reviewed their full documentation 

regarding eligibility and suitability of all perennial streams and rivers located with the planning 

area. Table D-3 lists the eligible wild, scenic, or recreational river, their classification, and 

outstandingly remarkable values for rivers located on each Forest. 

Table D-3. Eligible wild and scenic river list with classification recommendation

River Name Wild Scenic Recreational Outstandingly Remarkable Values

Malheur

Lake Creek 3.3 0.0 0.0 Scenery, geologic, 

vegetation/botanical

Umatilla

Bear Creek 4.6 0.0 0.0 Fisheries

Butte-West Fork Creek 13.9 0.0 0.0 Scenery

Desolation Creek 0.0 0.0 21.5 Recreation, botanical

Lookingglass Creek 0.0 7.9 0.0 Hydrological

North Fork Desolation 

Creek

0.0 0.0 6.8 Botanical

North and South Fork 

Wenaha River

26.3 0.0 0.0 Scenery, fisheries, botanical

Sheep Creek (in 

Washington)

0.0 0.0 0.5 Scenery, botanical

South Fork Desolation 

Creek

0.0 8.9 0.0 Fisheries, botanical

Tucannon River 9.1 4.6 8.7 Recreation, fisheries, cultural, 

botanical

Totals 53.9 21.4 37.5

Wallowa-Whitman

Big Sheep Creek

10.0 39.1 Recreation, fisheries, cultural

Dutch Flat Creek/Van 

Patton Creek*

5.3 0.0 0.0 Scenery, recreation, geological, 

hydrological, botanical

East Eagle Creek* 9.0 0.0 6.6 Scenery, recreation, fisheries, 

geological, cultural

Five Points Creek* 0.0 12.1 0.0 Scenery, fisheries, wildlife

Killamacue/Rock Creek 10.2 8.6 0.0 Scenery, recreation, geologic, 

botanical

North Fork Catherine 

Creek

11.1 0.0 2.6 Scenery, recreation, fisheries, wildlife

Swamp Creek 9.2 0.0 7.6 Fisheries, wildlife, cultural

Upper Grande Ronde 

River

11.7 0.0 18.0 Recreation, fisheries, wildlife, cultural

Totals 66.5 20.7 73.9

Total All 123.7 42.1 111.4

* These rivers have been determined suitable in Dutch Flat Creek, Killamacue Creek and Rock Creek Wild and Scenic 

River Study Report (1996) and Wild and Scenic River Study Report and Final Legislative Environmental Impact 

Statement for Eight Rivers (1997).
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

385

The Malheur National Forest revisited the 1995 river resource evaluation to determine if 

unforeseen or uncontrollable changes had occurred within the watersheds, thus affecting the 

eligibility of the streams for wild, scenic, or recreational river designation. All streams on the 

Forest were affected in some way by either uncontrolled wildland fire or by the listing of 

federally designated anadromous fish species. Fire changed the conditions of many watersheds 

drastically, impacting habitat, scenery, and water quality to a level that affected the significance 

of the resource with the exception of one stream. Also the federal listing of anadromous fish 

species as threatened or endangered was determined to be so regionally broad that the mere 

presence of a species was no longer regionally significant. The populations and habitat were now 

recognized under wild, scenic, or recreational river direction at a lesser level of significance when 

compared within the Columbia/Snake River systems, and thus this singular characteristic did not 

now exceed the threshold of regional significance that is required for outstandingly remarkable 

value status. After the 2005 review, the Malheur National Forest determined that one stream 

located on the Forest met the eligibility criteria. 

The Umatilla National Forest found that some of the study rivers previously identified as eligible 

were not now found to meet the minimum criteria. Clear Creek is not free-flowing. North Fork 

Umatilla River, South Fork Umatilla River, Shimmiehorn Creek, South Fork Cable Creek, North 

Fork Meacham Creek, and South Fork Walla-Walla River are free-flowing but do not have 

outstandingly remarkable values as defined by the criteria outlined in the Wild and Scenic Rivers 

Act. 

All previously identified study rivers on the Wallowa-Whitman met the established Wild and 

Scenic Rivers Act criteria, however new candidate rivers were not identified. 

River evaluation findings are presented in a Summary Information Document for each candidate 

river that provides a synopsis of the information related to eligibility, classification and/or 

suitability (as applicable). All summary information documents are available in the project record.

All Eligible rivers are shown in Table D-3. Maps follow, as well as detailed summaries of the 

eligibility with classification summaries in Table D-4 through Table D-6. 

Table D-4. Eligible wild and scenic river summary with classification recommendation for the 

Malheur National Forest 

Description 

of Segment 

Potential 

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

Lake Creek Wild – 3.3 SCENERY Starting at High Lake the creek is considered a scenic and 

popular destination in the Strawberry Mountain Wilderness featuring 

unique rock escarpments and meadows, creating contrast in landform, 

vegetation, color, climate, and sound. The scenery within view of Lake 

Creek is an outstandingly remarkable value. 

GEOLOGY The creek flows over large slabs of bedrock with several 

high mountain meadows, with high concentrations of springs feeding the 

creek. It is unique geologically: the drops are dramatic with waterfalls 

and slot canyons all through the rock portions. Based on these factors, 

the geology is an outstandingly remarkable value. 

VEGETATION/BOTANICAL High meadow systems have created unique 

features with spruce bogs present along the creek, further influencing 

the creek and meadow systems. The vegetation/botanical resources of 

Lake Creek is an outstandingly remarkable value. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

386

Figure D-1. Lake Creek eligible wild and scenic river, Malheur National Forest

Lake Creek 

Eiligible Wild & Scenic River 

M alheur N ational Forest 

\ 

\ 

\ 

\ ,_ 

' 1 

I 

~ 

/ 

I 

./ 

I' 

\ r:-1 

i I 

/ \ 

\ 

I !.,. · -' I 

r 

15 / 14 

I 

f I 

I 31 

/ Strawberry 

rr<.::. Mountain \ 

\ 

.I 

-vif11Cferness \ 

tJ o 

~ 

<:?! 6 

( 

) 

I 

I 

I 

\ 

" ...__ 

~ 18 17 / 

I r 

""·,/ 

T 

R3

15 

3E 

S 

I 

~ 

22 

() 

1i

!U ' / ~~ g" . 

d -

/ 

. = 

"'-' Wild 

......... Scenic 

"'-' Recreational 

~· / 

\. / 

'3 ( 

'( 

\ 

r ' _,- Perennial Stream/CI-eek 

Intermittent Stream/Creek 

Eligible River Co1Tidor 

L

- J Administrative Forest 

- Bou ndary CJ Wilderness 

T 14$ 

3~ R 34 E 

., 

.,., 

1i 

~ 

§r ...0::; 

) 

l:i 

I 

- ~..i>o. . ~.f 

'· \. 

'· "'-. ...... 11! 

' ' '...._ 

' T 15 S \ 

R34E \ 

Classification (miles): 

W ifd- 3.3 

Scenic- 0 

Recreational- 0 

0.375 0.75 

34 

'·· 

22 

15 M les 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

387

Table D-5. Eligible wild and scenic river summary with classification recommendation for the Umatilla National Forest

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

Bear Creek 

From the headwaters to confluence with 

Tucannon River

Wild – 3 FISHERIES - Bear Creek contains native Chinook, bull trout and steelhead, which are 

federally listed as threatened under the Endangered Species Act. Bull trout populations in 

the Tucannon River are considered isolated and unique. Habitat is limited but pristine. 

The assessment finds the fisheries habitat and populations to be outstandingly 

remarkable values. 

Butte Creek 

From headwaters to confluence with the 

mainstem Wenaha River

Wild – 8 SCENERY - The Wenaha River and surrounding Wenaha -Tucannon Wilderness, 

including Butte Creek, is recognized nationally for its scenic qualities. The mosaic of 

vegetation and stark ruggedness of the landscape contribute to an exceptional scenic 

quality. Scenery qualifies as an outstandingly remarkable value. 

Desolation Creek 

The mainstem of Desolation Creek from the 

confluence of the north and south forks to 

the confluence with the North Fork John 

Day River

Recreational – 21.5 RECREATION - Combined amenities of a large big game population, good roaded 

access to trailhead locations, adjacency to large, remote backcountry areas and desirable 

campsites within the river corridor make this a desirable destination. Conditions of the 

river-related setting make recreation an outstandingly remarkable value. 

BOTANICAL/ECOLOGICAL - Regionally unique and rare plant species have been 

identified in Desolation Meadow. The stream corridor displays a broad range of botanic 

diversity due to its size and broad change in elevation. The ecological diversity is 

exceptional and exhibits outstandingly remarkable values for botany and plant ecology. 

Lookingglass Creek 

From the unnamed tributary in section 3 

near Bald Mountain lookout to the forest 

boundary

Scenic – 7 HYDROLOGIC - The impact that the springs near Summer Creek have on the water 

quantity and quality is rare in the Blue Mountains. The temperature and condition of the 

water that enters the stream course from this source provides the foundation for fisheries 

resources in the creek. Lookingglass Springs is visually impressive with the flow of the 

springs gushing from the bank and streambed growing forty-fold over a distance of a 

couple of hundred yards. The hydrology of Lookingglass is an outstandingly remarkable 

value. 

North Fork Desolation Creek 

Headwaters to confluence with Main 

Desolation Creek

Recreational – 7 BOTANICAL/ECOLOGICAL - Regionally unique and rare plant species have been 

identified in the meadows along the stream corridor, which displays a broad range of 

botanic diversity due to its size and broad change in elevation. The ecological diversity is 

exceptional and exhibits outstandingly remarkable values for botany and plant ecology. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

388

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

North Fork Wenaha and 

South Fork Wenaha River

North Fork Wenaha from headwaters to 

confluence with mainstem Wenaha River, 

and South Fork Wenaha from headwaters 

to confluence with mainstem Wenaha River 

Wild – 26.3 SCENERY - The Wenaha River and surrounding Wenaha -Tucannon Wilderness is 

recognized nationally for its scenic qualities. The mosaic of vegetation and stark 

ruggedness of the landscape contribute to an exceptional scenic quality. Scenery 

qualifies as an outstandingly remarkable value. 

FISHERIES – The Wenaha River system contains native Chinook, bull trout, and 

steelhead, which are listed as threatened under the Endangered Species Act. Bull trout 

populations are considered as one of the healthiest in the Grande Ronde subbasin. The 

habitat is pristine. The assessment finds the fisheries habitat and populations to be 

outstandingly remarkable values.

BOTANICAL/ECOLOGICAL - The large elevational range, little disturbance to bank 

vegetation, and presence of old growth habitat are special attributes. High likelihood of 

sensitive or threatened species located within the corridor. The area contains 

outstandingly remarkable value botanic resources.

Sheep Creek (Washington)

Upstream from the confluence with 

Tucannon River

Recreational – 0.5 SCENERY - Sheep Creek Falls is a scenic location that specifically attracts visitors to this 

area and has been long noted for its unusual vegetation. Flora accompanied by rock 

walls of overhanging moss and spring water creates an aesthetic environment and 

scenery within the corridor is special and unique. Scenery qualifies as an outstandingly 

remarkable value. 

BOTANICAL/ECOLOGICAL - The plant communities are unusually diverse and represent 

some uncommon species. The Sheep Creek Falls refugia is a botanical Special Interest 

Area and is a recreation attraction. The area contains outstandingly remarkable value

botanic resources. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

389

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

South Fork Desolation Creek 

Headwaters to confluence with main 

Desolation Creek

Scenic – 9 FISHERIES - Isolated fish populations in the upper portion have significance as a genetic 

resource and the lower portion provides spawning habitat for steelhead, Chinook, 

redband trout, and Columbia River bull trout. The diversity of habitat is unique to the 

region. The populations and habitat comprise an outstandingly remarkable value of 

fisheries. 

BOTANICAL/ECOLOGICAL - Regionally unique and rare plant species have been 

identified in the high elevation meadows along the stream corridor. The stream corridor 

displays a broad range of botanic diversity due to the fire-dependent ecosystems. The 

ecological diversity is exceptional and exhibits outstandingly remarkable values for botany 

and plant ecology. 

Tucannon River 

From headwaters to the Tucannon Guard 

Station

Wild – 9.1, 

Scenic – 4.6, 

Recreational – 8.6

RECREATION - Because of this river setting, most use originates outside the local area. 

The river-related environment is the focal attraction, particularly attractive to visitors 

seeking sightseeing, camping, fishing, wildlife viewing, photography, hiking, and other 

outdoor activities in a natural appearing landscape. Camp Wooten instills a lifelong 

allegiance to the corridor for many youth. Potential interpretive opportunities are varied 

and could reach a wide audience. Conditions of the river-related setting make recreation 

an outstandingly remarkable value. 

FISHERIES - Each drainage has some distinct genetic traits. Endangered and sensitive 

listed fish are present and the complex habitat is exemplary. The populations along with 

the habitat comprise an outstandingly remarkable value for fisheries.

CULTURAL/HISTORIC - The Tucannon River corridor has a long history of settlement, 

resource use, and recreation and some historic evidence exists. Early maps show 

homesteads, a sawmill, schoolhouse, trail system, roads, telephone lines, camps, and a 

ranger station. Interpretation may enhance the value of recognized heritage resources. 

The presence of old structures, along with the likelihood of other historic finds, make the 

historic resource an outstandingly remarkable value. 

BOTANY/ECOLOGY - The general condition, health, and stability of the riparian 

vegetation is among the highest in the Blue Mountains. The plant community is unusually 

diverse representing some uncommon species. Sheep Creek Falls is the basis for a 

Botanical Special Interest Area. The complex riparian habitat is critical for survival of

endangered and sensitive fish species. The area contains outstandingly remarkable value

botanic resources. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

390

Figure D-2. Bear Creek eligible wild and scenic river, Umatilla National Forest

.Jl 

Bear Creek 

Eligible Wild & Scenic River 

Umatilla National Forest 

j 

,/ 

\ 

~ 

28 

~ 32~ 33 

\ ,~--.. 

( ____ .~' '- ---·= .... '""':r--

W-en a tra- T u cannon 

Wilderness 

2 if7N 

R41 E 

"""' Wild 

Scenic 

~ Recreational 

r··...__, Perennial Stream/Creek 

Intermittent Stream/Creek 

T7N I, 

R42E \ ::. 

Q 

Eligible River Corridor 

1

- I Administrative Forest 

- Boundary 

~Wilderness 

~ I 

27 

34 

) 

ClassifiCation {miles): 

Wild- 4.6 

Scenic- 0 

Recreational- 0 

0 375 0 75 

36 

\\ 

II 

I 

_g 

/ 

II 

II 

\I 

II 

I 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

391

Figure D-3. Butte Creek and West Fork Butte Creek eligible wild and scenic river, Umatilla National Forest

18 

16 

20 21 

Wi d 

Scenic 

~ Recreational 

Eligible Wild & Scenic River 

Umatilla National Forest 

'!:. 

'"" 12 "" ;;" 

"" ~ 

~ 

~ 

0 ~ ~ 

:: \?. <:> 

~ 17 13 t I; 14 .::: 

~ <> ;:: 

~ T7N ~ R41 E 

19 20 

9 12 

T 6N 

R40E 

~ 

0 

... 

I~ ~ 

~ <;; 

13 18 

\ 

\ 22 23 19 20 24 

) 

' 

""-···' Perennial Stream/Creek Eligible River Corridor ClassifiCation (miles): 

Intermittent Stream/Creek ~ Designated Wild & Scenic River Wild- 13.9 

Scenic- 0 

Recreational- 0 l

- I Administrative Forest 

- Boundary 

jg Wilderness 05 

...., 16 1\j 

0 

] 

~ IJ 

21 

16 

15 

2M•les 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

392

Figure D-4. Desolation Creek eligible wild and scenic river, Umatilla National Forest

-I L l 1 I 

4 

j.- ~· I 

Wild 

Scenic 

~ Recreational 

, Desolation Creek 

l 

,..~.'---' Perennial Stream/Creek Eligible River CorTidor 

·, lntennittent Stream/Creek ~ Designated Wild & Seen ic River 

l

- I Administrative Forest 

- Boundary 

[t"!J:i] Wilderness 

Eligible Wild & Scenic River 

Umatilla National Forest 

.., . 

i 

0 

.,. 

"' ~ I 

if 8 S y . 

,R 33. E 

Classification (miles): 

Wild- 0 

Scenic- 0 

Recreation ol- 2 1.5 

0 75 1 5 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

393

Figure D-5. Lookingglass Creek eligible wild and scenic river, Umatilla National Forest

'- ..... 

Lookingglass Creek 

Eligible Wild & Scenic River 

Umatilla National Forest 

34 

11 

Wild 

~Scenic 

_...-., _ ·' Perennial Stream/Creek 

-'" '· Intermittent Stream/Creek 

~ Recreational 

13 

'2 

' !:'ag7e Creek ~ / -

13 

Eligible River Corridor 

l

- 1 Administrative Forest 

- Boundary 

[tL -j) Wilderness 

Ia 

31 

16 

17 

T3N 

Classifrcation (miles): 

Wild-0 

Scenic- 7.9 

Recreational- 0 

0475 0 9S 

34 

f; 15 

I 

34 

1 9MI!e.s 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

394

Figure D-6. North Fork Desolation Creek eligible wild and scenic river, Umatilla National Forest

JS 

TSS 

R 33 E 1 

I 

/ai 

/ 

T9S 

R 33 E 

13 

'\ 

Malheu

"'-->r --- --.. ., 

National )i<; 

Fo res t Q 

24 \-

23 

- -1 

I 

I 

I 

I 

I 

I 

~ I 

\ 

31 

' 

7 \ ' 

19 

\ 

\ 

32 

\ 

'\ >:;". 

~ \ 0 

~ ..,. 

\.u mat i II a 

i\Ja ti on a l 

Forest 

'\ 

/~ .... 

.( 8 I /:, 

\, 

Wild 

.......... Sceni~ 

r--, _ _.. Perennia I Stream/Creek Eligible River Corridor 

~ Recreationa l 

Intermittent Stream/Creek l- I Administrative Forest 

_ - 6<1Yndary 

18 

North F/o r k 

John Day 

Wilderness 

/ 

\ 

\ 

--~~ 

I 

I 

II 

rr . 

I I 

I ~ ' 

/:ort,{~o;: _j 

John Day 

2a W i lqerness 

>, 

Classification (miles): 

Wild- 0 

Scenic- 0 

Recreational- 6.8 

03 06 1 2 Mtles 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

395

Figure D-7. North and South Fork Wenaha River eligible wild and scenic river, Umatilla National Forest

~-

\ ' 

\/ ........ J.' , __ 

) 

_. 

/ 

~~ 

f--

' I ) 

/ 

I ,~ 

~-_) 

,..., __ , Perennial Stream/Creek 

North and South Fork Wen aha River : 

Eligible Wild & Scenic River 

Umatilla National Forest 

Eligible River Corridor 

~ 'IUt:. 

/ 

I 

T6N 

~O E 

ClassifiCation (miles): 

T6N 

R 41 E 

""""' Wild 

Scenic Intermittent Stream/Creek ~ Designated Wild & Scenic River Wild- 26.3 

Scenic- 0 

~ Recreational- 0 Recreational L - I Administrative Forest 

- Boundary 

0 75 15 Miles 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

396

Figure D-8. Sheep Creek eligible wild and scenic river, Umatilla National Forest (in Washington)

~ 

1\ 

Sheep Creek 

Eligible Wild & Scenic River 

Umatilla National Forest 

11 10 

/ 

/ 

12 

Wenaha-Tucannon 

,Wilderness 

15 

Wild 

.....__.Scenic 

I 

:r:,0l ' 

r.J" .: 

14 

'· 

' 

,...,'-" Perennial Stream/Creek 

lntennittent Stream/Creek 

........... Recreational 

// 

i 

Eligible River Corridor 

l

- I Administrative Forest 

- Soundary 

W ilderness 

,..-· 

./ 

/ 

/' \ 

,..-- ......._ 

( 

' / 

I 

/ 

/ 

/ 

I 

/ 

I 

I 

/ 

I 

I 

/ 

I 

I 

I 

/ ... raN 

/ R42E 

I 

) 

18 

/ 

/ 

/ 

./ 

/ 

ClassifiCation (miles): 

Wi/d- 0 

Scenic- 0 

Recreational- 0.5 

0 175 0 35 

/ / 

-···- / 

/ 

07Mites 

/ 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

397

Figure D-9. South Fork Desolation Creek eligible wild and scenic river, Umatilla National Forest

South Fork Desolation Creek 

Eligible Wild & Scenic River 

Umatilla National Forest 

--li,: 0 1:3 61 

I 

tr / 

\ 

.... 

' v' / 

/ 

-I' 

I 

\ 

' ./-

' ' 

21 

\ \ 

'l~ .. 

\ 

\ \ 

\ 

'·-, 12 

\ 

-,-

! < 

/ / 

; 

11 

( 

-~ 

I 

--

23 I 

35 

I 

\ ., 

10 45 0 11 

,.. ··, _, Perennial Stream/Creek 

/ 

'··. ' \ 

\ 

"'W Eligible River Corridor ild 

~Scenic Intermittent Stream/Creek l- I Administrative Forest 

- Boundary 

.-....., Recreational Wilderness 

\ 

\ 

\ / ..... . \ 

,( 8 

( ·, 

~-

/; --· 

( ~01 \ I 27 

' 

-

' ( N o r t h. F o r k 

• Joh-n Day 

\ Wi ( derness 

4 

9 

\ 

' ·· - - >· 1o 

Classiftcotion (miles): 

Wild-0 

Scenic- 8.9 

Recreation ol- 0 

0 425 0 85 17 Miles 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

398

Figure D-10. Tucannon River eligible wild and scenic river, Umatilla National Forest

\ 

33 34 

/ ' 

r ~ \ 

I 16 

,I \ "TBN ./ ,, ...., 20 , .. _ -- J- R 41 ,-E I 

' \ / 

/ ?1 I '\· ~2 ' 23 . I . , -

We·{' a ha-l'uca n non 

Wilderness 

\ 

h&-." 26 

1 i\ 27 

1 29 / 

I 35 I 

) 34 

13 

\ 

\. 

I 

- ·l\1 0 N ....? ! ! • I / (""')_,. ""' .Q...,_ ~-~ (';1 35 

3( R J 2 E''Sz ~~ 1i ......_¢-"'~ Tucannon River 

! Eligible Wild & Scenic River 

' Umatilla National Forest ~ / 

lh ' ' 

~) 

18 

6' ./ ., I 

/ ~ i 

' j 

I IZ 

/ 

10 11 

i ./i . ./(21}· 13 

25 

;----'"" ~ d 3o 

121

· 

33 ~ 

~" 

1..~ 

'---'-- ---

ld 

Scenic 

~ Recreational 

T7N ~~ 

R 41 E 4 0 ¢'~ 

~ 

'"' .. / Perennia I Stream/Creek 

,-' . Intermittent Stream/Creek 

6 

Eligible River Corridor 

l

- 1 Administrative Forest 

- Boundary 

~Wil derness 

~ .... 

ClassifiCation (miles): 

Wild- 9.1 

Scenic- 4.6 

Recreational- 8. 7 

0 75 1.5 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

399

Table D-6. Eligible wild and scenic river summary with classification recommendation for the Wallowa-Whitman National Forest1

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

Big Sheep Creek

From the headwaters (and including) the 

North Fork, Middle Fork and South Fork to 

the Imnaha WSR boundary. 

Wild – 9.5 

Recreational – 38.5

RECREATION - The quality, variety, and year-round recreation opportunities available 

along middle and upper Big Sheep Creek make it a popular area with local and regional 

visitors. The stream corridor is an excellent area for viewing wildlife. Conditions of the 

river-related setting make recreation an outstandingly remarkable value upstream from 

Carrol Creek. 

FISHERIES – Populations of Chinook salmon; steelhead; native rainbow trout; and 

established bull trout are present. Big Sheep Creek supports populations of fish species 

that are regionally and nationally important, and has a great potential for high-quality 

fisheries habitat for indigenous stocks. The populations along with the habitat comprise an 

outstandingly remarkable value fisheries value.

CULTURAL/PREHISTORIC – There are known sites that are either named to the National 

Register of Historic Places or are eligible and the stream corridor contains a unique 

concentration of prehistoric sites. The presence of old structures and historical human 

interest make the historic resource an outstandingly remarkable value. 

Dutch Flat/ Van Patton Creek2

From the Headwaters of Dutch Flat Creek 

to the forest boundary including Van Patton 

Creek from Van Patton Lake to its 

confluence with Dutch Flat Creek. 

Wild – 9.1 SCENERY - Plant diversity, mountain meadows, and mountain vistas of rugged Elkhorn 

Ridge provide year long, high-quality scenic values in the stream corridor. Natural patterns 

created by topography and natural processes such as lightning fires, avalanches, and rock 

slides, dominate the landscape character. The scenic diversity in landform, color, and

vegetation qualifies as an outstandingly remarkable value. 

RECREATION - The Dutch Flat Creek system offers a diversity of remote, semi-primitive 

recreation opportunities including hunting, fishing, hiking, mountain biking, sightseeing and 

horseback riding. The variety and remoteness of opportunities in the corridor provide an 

outstandingly remarkable value for recreation.

GEOLOGIC - Excellent examples of glacial plucking, striation, and polish, and exfoliation 

features that in some locations rival features preserved in Yosemite National Park. Dutch 

Flat Creek and Van Patton Creek are determined to contain outstandingly remarkable 

value for geologic features.

HYDROLOGY - The high gradient reaches below Dutch Flat Lake are characterized by 

steep riffles and water cascading over boulders. Dutch Flat Creek provides excellent 

examples of several distinct types of distinctive stream channels not represented by other 

established northeastern Oregon Wild and Scenic Rivers. The hydrology of Dutch Flat 

Creek was considered to be outstandingly remarkable value from its confluence with Van 

Patton Creek to its headwaters.

BOTANICAL/ECOLOGICAL – Sensitive plants species occur in the upper reaches of 

Dutch Flat Creek including Allium madidum and Lycopodium annotinum. The ecological 

diversity is exceptional and exhibits outstandingly remarkable value for botany and plant 

ecology in the upper reaches of Dutch Flat Creek. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

400

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

East Eagle Creek2

Headwaters in the Eagle Cap Wilderness to 

the confluence of Eagle and East Eagle 

Creeks.

Wild – 9.0 

Recreational – 6.5

SCENERY - Attractions that combine to create East Eagle Creek’s scenic beauty are the 

glaciated landscape; the steep, forested canyon with numerous waterfalls, rapids, and 

deep pools; and the views of Granite Cliff and Krag Peak. Vegetation diversity includes 

lush meadows; subalpine fir and spruce; larch, fir, and ponderosa pine forests; and grassy 

openings. East Eagle Creek has been a focus of human interest since the turn of the 

century, however visual impacts remain relatively minor and the drainage presents an 

overall natural landscape. The scenic diversity in landform, water, color, and vegetation 

qualifies as an outstandingly remarkable value. 

RECREATION - The quality and diversity of dispersed recreation opportunities available 

along the East Eagle Creek make it a popular area almost year-round. There are 

exceptional opportunities to develop interpretive sites or tours to explain the area's unique 

natural and cultural history. Interpretation of the area’s gold mining history could be 

developed to complement the other nearby historic sites such as the Oregon Trail 

Interpretive Center, potentially attracting visitors from outside the geographic region.

Conditions of the river-related setting make recreation an outstandingly remarkable value. 

FISHERIES - East Eagle Creek is known for its excellent trout fishing and supports 

significant fishing activity throughout the season. The importance of the existing good-tohigh-quality habitat which supports native trout, possibly including bull trout is notable. The 

populations along with the habitat comprise an outstandingly remarkable value for 

fisheries.

GEOLOGIC - The variety of rare and exemplary geologic features in the corridor, 

particularly in the middle and lower reaches of East Eagle Creek merit the recognition. The 

quality, variety, and importance of the geology qualify as an outstandingly remarkable 

value. 

CULTURAL/HISTORIC - The settlement of northeast Oregon is tied to the discovery of 

gold and East Eagle Creek still has much evidence of this history. Outstanding 

opportunities exist to interpret a number of features located in fairly close proximity within 

the corridor. The presence of old structures and historical human interest make the historic 

resource an outstandingly remarkable value. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

401

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

Five Points Creek2

Headwaters north of the confluence with the 

Middle Fork of Five Points Creek to the NF 

boundary about 1⁄4-mile southwest of 

Blacksmith Canyon.

Scenic – 12 SCENERY - The combination of distinctive landscape elements, lack of cultural 

modifications, and the primitive and undisturbed nature of the view shed are notable. 

Scenery qualifies as an outstandingly remarkable value. 

FISHERIES - The presence of summer steelhead and native rainbow trout populations and 

the existing “high quality” of fisheries habitat (specifically water quality, low temperatures, 

low turbidity) for indigenous stocks and for spring/summer Chinook salmon in the Grande 

Ronde River. The populations along with the habitat comprise an outstandingly remarkable 

value for fisheries.

WILDLIFE – The existing habitat is significant and the presence of wildlife species of 

interest, including the bald eagle and a significant population of elk are notable. The 

quality, variety, and importance of existing wildlife habitat, comprise an outstandingly 

remarkable value for wildlife. 

Killamacue/ Rock Creek

Killamacue Creek from its headwaters to 

the diversion ditch near the confluence with 

Rock Creek, and Rock Creek from below 

the outlet of Rock Creek Dam to the NF 

boundary including North Fork and South 

Fork Rock Creek. 

Wild – 11.9 

Scenic – 7.0

SCENERY - High-quality scenic values include plant diversity, mountain meadows, and 

mountain vistas of the Elkhorns, a rocky and rugged range with aspen groves scattered 

among granite outcroppings. Other outstanding scenery associated with rock forms, timber 

stands and open alpine and subalpine vistas exhibit an overall natural and undeveloped 

character. Scenery in these drainages qualifies as an outstandingly remarkable value. 

RECREATION - The Rock Creek corridor offers a unique opportunity in northeast Oregon 

to access a relatively primitive setting by four-wheel drive vehicle. The amount of semiprimitive roads in an area this large makes it unique to the region and important for semiprimitive motorized travel recreational opportunities with easy access from Interstate 84 

and the Baker Valley. The Killamacue and Rock Creek system offer a diversity of semiprimitive recreation opportunities in a remote relatively primitive setting with low use. The 

variety and remoteness of recreation opportunities in the corridor provide an outstandingly 

remarkable value for recreation.

GEOLOGIC - The upper drainages of the North Fork of Rock Creek and of Killamacue 

Creek contain exposures of a rare rock type called lamprophyre. Study of these rocks will 

provide outstanding and critical contributions to understanding the tectonic history of 

northeast Oregon. Killamacue Creek drainage contains a narrow glacial hanging valley 

and the polished outcrops and rounded glacial forms are easily visible, easy to access, 

and major in scope. The quality, variety, and importance of the geology qualify as an 

outstandingly remarkable value. 

BOTANICAL/ECOLOGICAL - Killamacue Creek has nine different wetland types along the 

relatively short study reach and the number and diversity of wetland types is unique in 

such a small area. Because the plants, meadows, riparian areas, and plant associations 

are common in northeast Oregon, Rock Creek does not contain ecological/botanical 

outstandingly remarkable value values, although some sensitive plant species are present. 

Killamacue Creek exhibits outstandingly remarkable values for ecological and botanical 

values. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

402

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

North Fork Catherine Creek

From its headwaters in the Eagle Cap 

Wilderness to the National Forest boundary 

near its confluence with South Fork 

Catherine Creek.

Wild- 10.5 (from 

headwaters to 

Catherine Creek 

Campground) 

Recreation – 2.5 

(from Catherine 

creek campground to 

NF boundary) 

SCENERY - The North Fork Catherine Creek drainage possesses scenic features notable 

in the geographic region. Some of the attributes that contribute to the scenic value of the 

area include the diversity of landforms from the glaciated headwaters to the dissected 

basalt uplands found lower in the corridor, the free-flowing river, and the diversity of 

vegetation. The scenery of the area qualifies as an outstandingly remarkable value. 

RECREATION - The quality and diversity of recreational opportunities available in the 

North Fork Catherine Creek corridor makes it a popular area with local residents and 

draws a substantial number of visitors from outside the region. Conditions of the riverrelated setting make recreation an outstandingly remarkable value. 

FISHERIES - The presence of stable habitat supporting four salmonid species, including 

three federally listed species, is highly significant regionally. Critical spring/summer 

Chinook salmon spawning habitat is found in this portion of the river. The populations 

along with the habitat comprise an outstandingly remarkable value for fisheries.

WILDLIFE - The presence of high-quality wildlife habitat; the number of kinds of habitat; 

the presence of unique habitat; the juxtapositions of habitats; the contiguous nature of 

riparian corridors; all contribute to an ecosystem component unmatched in diversity. The 

diversity of vegetation, number of natural edges utilized by big game and nongame 

species, and presence of old-growth mixed conifer stands in the corridor, provide important 

habitat for a variety of wildlife species. The diversity of habitat found in the corridor 

supports a finding of outstandingly remarkable value. 

Swamp Creek

From the National Forest boundary to the 

WSR boundary.

Wild – 8.5 

Recreational – 9.5

FISHERIES - In addition, Swamp Creek supports a wild summer steelhead population that 

is regionally important, and has potential for high-quality fisheries habitat for indigenous 

stocks including native rainbow trout populations. The populations along with the habitat 

comprise an outstandingly remarkable value for fisheries 

WILDLIFE - The inaccessibility, diversity, and significance of the wildlife populations in 

Swamp Creek along with the presence of bald eagles and the large stretch of riparian 

habitat make the area important. The quality, variety, and importance of existing wildlife 

habitat, comprise outstandingly remarkable value for wildlife. 

CULTURAL/HISTORIC - The Swamp Creek stream corridor plays a vital role in Nez Perce 

tribal history. Most important is the proximity to the gathering place for Chief Joseph and 

his band at the confluence of the Grande Ronde River and Joseph Creek. In addition, the 

old homesteads and evidence of railroad logging add to the interpretive potential of the 

area. Important cultural resources along with the presence of old structures and historical 

human interest make the cultural and historic resource an outstandingly remarkable value. 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

403

Description of Segment Potential

Potential 

Classification 

(miles)

Summary of Outstandingly Remarkable Values

Upper Grand Ronde River

Headwaters to the National Forest 

boundary near the mouth of Fly Creek

Wild – 11 

Recreational – 19

RECREATION - The quality and variety of recreation opportunities available along the 

Upper Grande Ronde River make it a popular area with local and regional visitors. The 

river corridor is an excellent area for viewing wildlife and is one of the most heavily used 

areas in the state during the fall big game hunting seasons. Conditions of the river-related 

setting make recreation an outstandingly remarkable value. 

FISHERIES - This river provides critical spring and summer spawning habitat for Chinook 

salmon, steelhead, and bull trout species. The fish populations along with the habitat 

comprise an outstandingly remarkable value for fisheries. 

WILDLIFE - The presence of suitable habitat for bald eagles and their use of the river 

corridor; high quality and quantity of wildlife habitat; the presence of unique habitat; the 

juxtapositions of habitats and contiguous nature of riparian corridors, all contribute to an 

uncommon ecosystem. The quality, variety, and importance of existing wildlife habitat, 

comprise an outstandingly remarkable value for wildlife. 

CULTURAL/HISTORIC - There are several features of historical human interest in the 

corridor. The splash dam in Vey Meadows is a relatively unique feature for northeast 

Oregon as well as the Camp Carson historic mining district, which is potentially eligible for 

the National Register of Historic Places. Interpretive opportunities are excellent. The 

presence of old structures and historical human interest make the historic resource an 

outstandingly remarkable value. 

1. For Alternatives D, E, E-Modified, E-Modified Departure, and F, the eight rivers identified as not suitable for National Wild and Scenic River System designation would be considered 

ineligible. This finding is documented in the Wild and Scenic River Study Report and Final Legislative Environmental Impact Statement. Maps for rivers determined not suitable are 

not presented below. Please refer the management area maps for the locations of MA 2A for each of the alternatives, available from the plan revision website: 

http://www.fs.usda.gov/goto/BlueMtnsPlanRevision. 

2. These rivers have been determined suitable in Dutch Flat Creek, Killamacue Creek and Rock Creek Wild and Scenic River Study Report (1996) and Wild and Scenic River Study 

Report and Final Legislative Environmental Impact Statement for Eight Rivers (1997).
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

404

Suitability Summary

The final phase of study addresses the suitability of a river for inclusion in the National Wild and Scenic 

Rivers System. The Wallowa-Whitman National Forest prepared suitability studies for eleven rivers 

determined eligible on that national forest. The eleven rivers studied are all or portions of the Big Sheep 

Creek, Dutch Flat- Van Patton Creek, East Eagle Creek, Five Points Creek, Killamacue/ Rock Creek, 

Granite Creek, North Fork Catherine Creek, Sheep Creek, Swamp Creek, Upper Grande Ronde River and 

the Snake River. Of these, three were found to be suitable for inclusion within the Wild and Scenic Rivers 

System (Table D-7). These recommendations have yet to be forwarded to Congress for action.

Table D-7. Suitable wild and scenic river list with classification recommendation

River Name Wild Scenic Recreational Outstandingly Remarkable Values

Dutch Flat Creek 5.3 0.0 0.0 Scenery, recreation, geological, 

hydrological, botanical

East Eagle Creek 9.0 0.0 6.6 Scenery, recreation, fisheries, 

geological, cultural

Five Points Creek 0.0 12.1 0.0 Scenery, fisheries, wildlife

Totals 14.3 12.1 6.6

A description of the alternatives, including river classification and miles recommended, can be found in 

The Dutch Flat Creek, Killamacue Creek, and Rock Creek Wild and Scenic River Study Report and EIS 

(1996) and the Wild and Scenic River Study Report and Final Legislative Environmental Impact 

Statement for Eight Rivers Administered by the Wallowa-Whitman National Forest (1996). 

The suitability study phase will be initiated at a later date for the 10 eligible rivers on the Umatilla and 

Malheur National Forests. However, the forest plan will provide management direction to protect the freeflowing character, potential classification, and outstandingly remarkable values of eligible rivers until a 

suitability study is completed and final recommendation to Congress regarding river designation is made.
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

405

Figure D-11. Dutch Flat Creek suitable wild and scenic river, Wallowa-Whitman National Forest

s II 

%! Dutch Flat Creek 

Suitable Wild & Scenic River 

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Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

406

Figure D-12. East Eagle Creek suitable wild and scenic river, Wallowa-Whitman National Forest

.J "" .• 

East Eagle Creek 32 33 

Suitable Wild & Scenic River 

Wallowa-Whitman NationaJ Forest 

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3 M11es 
Final Environmental Impact Statement, Volume 4 

Appendix D:Wild and Scenic Rivers

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

407

Figure D-13. Five Points Creek suitable wild and scenic river, Wallowa-Whitman National Forest

~ 1 Five Points Creek 

""' Wild 

..... Scenic 

.-...., Recreational 

,...,, _., Perennial Stream/Creek Suitable River Corridor 

Intermittent Stream/Creek l- I Administrative Forest 

- Boundary 

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Wild- 0 

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2 Mifes 

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

409

Appendix E: Wilderness Evaluation

Introduction 

When revising a Forest Plan, the national forests are required by the National Forest Management 

Act (NFMA) to evaluate potential wilderness areas and to determine whether these areas should 

be recommended to Congress for wilderness designation. This document describes the process 

used to evaluate the wilderness potential of 76 areas within the Blue Mountains forests plan 

revision area. 

The forest plan revision team determined suitability of potential wilderness areas for Wilderness 

designation by evaluating capability, availability and need. There were are 76 potential wilderness 

areas identified within the Blue Mountains national forests, and each was evaluated for these 

attributes. The Wilderness Need Evaluation (March 25, 2010) was completed for the entire Blue 

Mountains forests plan revision area and many of these areas were determined to have capacity 

and availability for wilderness designation; however, a need was not identified to be present. 

While an area may not ‘need’ to be formally designated to protect resources, there may be other 

reasons for proposing designation. Political and social factors also play a part in deciding whether 

to propose areas for inclusion in the wilderness system; these factors are not addressed in this 

evaluation. 

The following documents are available in the project record and provide more detailed 

information on the wilderness evaluation:

• Wilderness Area Need Evaluation (March 2010)

• Malheur National Forest Review of Areas with Wilderness Potential (March 2010)

• Umatilla National Forest Review of Areas with Wilderness Potential (March 2010)

• Wallowa-Whitman National Forest Review of Areas with Wilderness Potential (March 

2010) 

Potential Wilderness Areas

The analysis first examined the current inventoried roadless areas (areas identified in Appendix C, 

Inventoried Roadless Areas, of each national forest’s 1990 Land and Resource Management Plan 

Final Environmental Impact Statement ) to determine if these areas met the criteria for potential 

wilderness areas. Some areas in the inventory did not meet the criteria for wilderness designation. 

In addition, the remaining forest system lands in the three forests were examined to see if there 

are other areas with wilderness potential. Several areas were found that met the wilderness 

criteria stipulated in Forest Service Handbook (FSH) 1909.12 71.1 – Inventory Criteria. Both 

these efforts followed direction outlined in the implementing regulations for the National Forest 

Management Act (36 CFR 219.18) and Forest Service Handbook (FSH 1909.12, Chapter 70) 

which states: “Areas qualify for placement on the potential wilderness inventory if they meet the 

statutory definition of wilderness. Include areas that meet either criteria 1 and 3, or criteria 2 and 

3 below. 

1. Areas contain 5,000 acres or more. 

2. Areas contain less than 5,000 acres, but can meet one or more of the following criteria: 

• Areas can be preserved due to physical terrain and natural conditions; 
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

410

• Areas are self-contained ecosystems, such as an island, that can be effectively managed 

as a separate unit of the National Wilderness Preservation System; and 

• Areas are contiguous to existing wilderness, primitive areas, administration-endorsed 

wilderness, or potential wilderness in other Federal ownership, regardless of their size.

3. Areas do not contain forest roads (36 CFR 212.1) or other permanently authorized roads, 

except as permitted in areas east of the 100th meridian (sec. 71.12).” 

All areas meeting the criteria for wilderness designation were considered potential wilderness 

areas and evaluated as possible recommendations for designation as wilderness. 

Through this process, 76 potential wilderness areas were identified within the Blue Mountains 

national forests. These areas cover 705,310 acres or 13 percent of the National Forest System 

lands. Refer to individual forests Review of Areas with Wilderness Potential for a complete list of 

each of the 76 areas by national forest. 

Suitability Analysis

Three tests—capability, availability, and need—were used to determine suitability as described in 

Forest Service Handbook 1909.12, chapter 70. In addition to the inherent wilderness qualities an 

area might possess, the area must provide opportunities and experiences that are dependent on 

and enhanced by a wilderness environment. The area and boundaries must allow the area to be 

managed as wilderness.

• Capability is the degree to which the area contains the basic characteristics that make it 

suitable for wilderness recommendation without regard to its availability for or need as 

wilderness. All areas that are determined to be capable are evaluated for availability. 

(FSH 1909.12 Chapter 70 subpart 72.1) 

• Availability of the area for wilderness designation is conditioned by the value of and need 

for wilderness resource compared to the value of and need for other resources. (FSH 

1909.12 Chapter 70, subpart 72.2) 

• Need for wilderness designation is determined through an analysis of the degree to which 

an area contributes to the National Wilderness Preservation System based on several 

factors on both a regional and a local basis. (FSH 1909.12 Chapter 70 subpart 72.3) 

Capability and Availability Evaluation 

Capability

Determining the capability of an area to provide a wilderness experience considers elements, 

activities, or features that describe the basic characteristics of wilderness. Criteria were 

established to consider existing as well as future conditions within and adjacent to the inventoried 

roadless area. 

The five basic characteristics identified in FSH 1909.12, Chapter 70 to evaluate the capability of 

an area are natural, undeveloped, outstanding opportunities for solitude or primitive and 

unconfined recreation, special features and values, and manageability.

The environment provides the person the opportunity to feel or experience solitude and serenity, a 

spirit of adventure and awareness, and a sense of self-reliance. The area should appear natural and 

free from disturbance and where the normal activities and life cycles of biotic species take place. 
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

411

A range of geological, biological, and ecological variability exists and is identified. Any 

scientific, educational, or historical values are identified and considered. Social and economic 

factors must blend with the environment and natural features to make the area desirable and 

manageable as wilderness.

Outdoor recreation opportunities that are primitive and unconfined include hiking, backpacking, 

stock riding, hunting, fishing, skiing, snowshoeing, and rafting. These may or may not currently 

exist within an individual area. Other outdoor recreational activities may currently exist but are 

not compatible with a wilderness setting or other wilderness characteristics.

Special features recognize scientific, educational, historical, and scenic values found in the area. 

The abundance and variety of wildlife and fish, including threaten and endangered species, will 

be considered. Other special features that are unique or are outstanding will be identified.

Manageability considers the ability to manage the area as wilderness as required by the 1964 

Wilderness Act. Such factors as size, shape, and juxtaposition to external situations are 

considered. Boundary location and the ability to easily identify the boundary on the ground are 

critical in meeting this characteristic.

There are many combinations of basic natural characteristics, and no two areas possess any of 

these characteristics in the same measure. The process, then, is to analyze the quality and quantity 

of these characteristics and determine if they can be provided by establishing management, 

protective, mitigation, or enhancement measures.

To evaluate each of the five basic characteristics, individual elements, activities, or features were 

developed that are descriptive of these characteristics and provide a basis for rating. Criteria were 

established to consider existing as well as future conditions both inside and adjacent to the area, 

and are rated as high, medium, or low depending on how well the criterion is or can be met in the 

area. 

Availability

Availability of an area for wilderness management must be evaluated against other resource 

needs, demands, and uses of the area. To be available for wilderness, the wilderness value, both 

tangible and intangible, should offset the value of the other resources. The predominant value 

does not necessarily reflect the use or combination of uses that would yield the greatest dollar 

return or the greatest unit output. In evaluating other resources, current uses, trends, and potential 

future uses and outputs need to be considered. 

Constraints and encumbrances on lands may also govern the availability of lands for wilderness. 

Forest Service control over the surface and subsurface of the area is a consideration regarding 

availability. The Forest Service should have sufficient control to prevent development of 

irresolvable, incompatible uses that would negatively affect wilderness characteristics and 

potential. 

Other resources evaluated are determined from resource specialists’ knowledge of the areas and 

public comments. Once the resources were identified, criteria were established for evaluation. 

Forest and district resource specialists rated the criteria as high, medium, or low. Forest program 

managers and plan revision interdisciplinary team members then evaluated each area’s 

availability for wilderness designation.
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

412

Need

Evaluation of need determines the degree to which an area can contribute to the overall National 

Wilderness Preservation System. There should be evidence of current or future public need for 

additional designated wilderness in the general vicinity of the area being considered. Need 

analysis uses such factors as the geographic distribution of areas, representations of landforms 

and ecosystems, and the presence of wildlife expected to be present in a wilderness environment. 

Evaluation Findings 

Potential wilderness is based on the inherent wilderness quality determined in the capability, 

availability, and needs assessment. In addition to the inherent wilderness quality an area might 

possess, the area should provide opportunities and experiences one would expect to find in a 

wilderness environment. Potential wilderness management considers establishing boundaries that 

are easy to define and locate on the ground. Forest land managers reviewed the evaluation and 

determined which areas to recommend for wilderness designation. 

Potential wilderness boundaries and mapping was completed following the guidelines in FSH 

1909.12, Chapter 70 for each area recommended for wilderness designation. Boundaries should 

be easy to define, locatable on the ground, and be manageable. Determination of a recommended 

wilderness boundary uses the following guidelines (in descending order of desirability). 

1. Use natural features locatable on both a map and on the ground, such as a ridge top, 

mountain peak, or lake shore; 

2. Use semi-permanent human-made features such as roads and power lines. The 

boundary may be set back a given distance from these features;

3. Use previously surveyed lines or legally determined lines such as section and 

township lines, property lines, or state boundaries 

4. Use a straight line from one locatable, visible point to another, such as between two 

mountain peaks; and 

5. Use a series of bearings and distances between locatable points that are not visible.

Evaluation of the 76 areas for potential wilderness and recommendation was based on the 

methodology established above 

Capability Process 

Capability analysis consisted of completing rating for elements, activities, or features that 

describe the five basic characteristics outlined in FSH 1909.12, Chapter 70 (1982). Forest plan 

revision interdisciplinary team members, recreation program managers, environmental analysis 

specialists, and forest planners prepared the ratings. 

The five basic characteristics were broken down into 18 elements, activities, or features. Further 

criteria were used to help inform the rating responses for each of the 18 broader elements. 

Generally, the criteria are listed in order of priority for each element, activity, or feature. Criteria 

were established to consider existing as well as future conditions both inside and adjacent to an 

area. 

Evaluation of the criteria was performed by district recreation managers, Forest Service fish and 

wildlife biologists, and hydrologists. Each criterion was rated as high, medium, or low. For areas 
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

413

that crossed national forest boundaries, the evaluation was conducted on each individual national 

forest.

Forest Service wilderness program managers and district personnel rated the 19 elements, 

activities, or features. Areas were rated as high, medium, or low in capability. Table E-1 shows 

the 18 elements, activities and features and the criteria used to rate the areas.

Table E-1. Area capability assessment criteria

High Moderate Low

Environmental Elements

Opportunity for Solitude

• Feeling of being alone or 

remote from civilization. 

• The possibility of meeting 

another party is remote. 

• Recreation use is light.

• Feeling of being alone is 

possible but signs of 

civilization are likely. 

• The possibility of meeting or 

not meeting another party is 

about equal. 

• Recreation use is moderate.

• Little opportunity of feeling 

alone.

• It would be rare NOT to meet 

another party.

• Recreation use is high.

Natural Integrity of the Area

• Free of human disturbance, or 

appears to be natural.

• Area visible (outside of the 

area) human disturbances do 

not dominate the view.

• Only minor improvements 

such as a trail.

• Noxious weeds not evident

• Mostly free of human 

disturbance, Natural 

Disturbance evident but does 

not dominate the area.

• Area visible (outside of the 

area) has signs of human 

activities such as roads or 

structures. 

• Several minor improvements.

• Noxious weeds evident in 

isolated spots

• Signs of human disturbances, 

natural disturbance dominates 

the landscape, such as a 

stand replacing wildfire. 

• Area visible in surrounding 

foreground shows obvious 

human activity such as 

clearcuts or a town. 

• Major improvements such as 

a powerline, dam or road. 

• Noxious weeds common or 

scattered throughout the area

Provides Challenge and Adventure

• Terrain generally rugged.

• Requires above average 

physical ability, knowledge, or 

skill to recreate safely in the 

area.

• Terrain typical for general 

forest area.

• Requires similar physical 

ability, knowledge, or skill as 

the general forested area.

• Terrain more gentle and 

rolling.

• Area easily accessible; 

requires average physical 

ability, limited knowledge and 

skill as compared to the 

abilities required in the 

general forested area.

Primitive Outdoor Recreation Opportunities

Hiking Opportunities

• Two or more trails, class 3 or 

higher, routinely maintained.

• Terrain is gentle and 

vegetation open to allow easy 

cross-country travel.

• At least one trail, class 2 or 

higher, routinely maintained.

• Terrain that is moderate or 

vegetation brushy that 

impedes cross-country travel.

• No system trails that are 

maintained.

• Terrain is steep or vegetation 

too dense that cross-country 

travel is difficult.
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

414

High Moderate Low

Backpacking Opportunities

• Two or more trails, class 3 or 

higher, routinely maintained.

• Area has several dispersed 

campsites that are routinely 

used.

• At least one trail, class 2 or 

higher, routinely maintained.

• Area has at least one 

dispersed campsite that is 

occasionally used.

• No system trails that are 

maintained.

• Area does not have dispersed 

campsites, but progressive 

camping may occur.

Horseback Riding/Saddle Stock

• At least one trail, class 3 or 

higher, designed for saddle 

stock and routinely 

maintained.

• Trailhead with stock facilities, 

such as unloading ramp.

• At least one trail, class 2 or 

higher, suitable for saddle 

stock and routinely 

maintained.

• Trailhead has room to turn 

around stock truck or stock 

trailer.

• No system trails that are 

maintained.

• Trailhead does not support 

use of stock.

Hunting

• Good populations of the big 

game animals or fair 

population of permitted 

animals such as bighorn 

sheep or mountain goats.

• Terrain is gentle and 

vegetation open to allow easy 

hunting access off trails and 

ridges.

• Fair populations of game 

animals.

• Terrain is moderately steep or 

vegetation brushy that limits 

hunting on much of the area.

• Has scattered small herds of 

big game animals.

• Terrain is steep or vegetation 

too dense that hunting is 

limited to trails or ridges.

Fishing

• Good populations of native 

game fish.

• Stream bottoms are generally 

gentle with minor brush 

allowing access to water.

• Fair populations of native 

game fish.

• Stream channel has enough 

brush to limit access; channel 

bottom or side slopes not 

overly steep.

• Low populations of native 

game fish.

• Stream channel steep, or 

steep rocky side slopes, or 

brush along channel makes 

access difficult.

Cross-country Skiing/Snowshoeing

• Terrain is gentle and 

vegetation open to allow easy 

cross-country travel.

• Area is easily accessible in 

winter by motorized wheeled 

vehicles.

• Terrain is moderate or 

vegetation brushy that 

impedes cross-country travel.

• Snow keeps wheeled vehicles 

several miles from area but 

access is possible by 

snowmobile.

• Terrain is steep, or vegetation 

too dense that cross-country 

travel is difficult.

• Area difficult or rarely 

accessed by snowmobile

Special Features

Unique Fish, Wildlife, Plants and/or Plant Associations

• Diverse community of native 

mammals, birds and fish.

• There is a known high variety 

of threatened, endangered 

and sensitive species within 

the area.

• Overall habitat integrity rating 

of high. 

• Provides critical linkage 

between wildlife areas or 

habitats.

• Moderate variety of native 

mammals, birds and fish.

• There is a known moderate 

variety of threatened, 

endangered and sensitive 

species within the area.

• Overall habitat integrity rating 

of moderate.

• Provides linkage between 

wildlife areas or habitats.

• Community of native 

mammals, birds and fish is not 

diverse.

• There is a known low variety 

of threatened, endangered 

and sensitive species within 

the area.

• Overall habitat integrity rating 

of low. 

• Does not provide linkage 

between wildlife areas or 

habitats.
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

415

High Moderate Low

Potential or Existing Research Natural Area

• Area contains an established 

special area such as a 

research natural area.

• Area contains a candidate or 

eligible research natural area. 

• Area does not contain 

potential or eligible area for 

research natural area.

Scenic Features

• Area has peaks or rocky 

formations considered 

spectacular from the rest of 

the Forest and/or special 

vegetative features that are 

considered very scenic.

• Area has a peak or formation 

that stands out from 

surrounding terrain and/or 

vegetative features 

considered scenic.

• Terrain is typical of the forest 

or surrounding area and the 

vegetation is common to the 

surrounding area.

Significant Cultural Resources

• IRA contains several historic 

or prehistoric areas or sites 

such as those eligible as 

National Register Historic 

Sites. 

• Identified values are unique to 

the Blue Mountain area.

• IRA contains at least one 

historic or prehistoric area or 

site such as those eligible as 

National Register Historic 

Sites. 

• Identified values are common 

in Northwestern U.S., but are 

uncommon in the Blue 

Mountain area.

• IRA contains no historic or 

prehistoric areas or sites such 

as those eligible as National 

Register Historic Sites.

• Identified values are common 

to the northwest U.S. and to 

the Blue Mountain area.

Manageable Boundaries

Recognizable Boundaries or 

conform to terrain

• Vast majority of boundary

follows features that can be 

identified on the ground such 

as dominant ridge, creek, road 

or trail.

• Boundary can be easily 

adjusted to follow locatable 

and identifiable features 

without significantly modifying 

the area boundaries.

• More than half of the 

boundary follows a feature 

that can be easily found on 

the ground.

• Boundary can be adjusted to 

follow locatable and 

identifiable features but will 

modify the general size and 

shape of the IRA. Boundary 

may be identified with minimal 

signing.

• Boundary generally lies 

across the hillside and can 

rarely be located without 

equipment, such as GPS unit.

• Boundary cannot be adjusted 

to follow locatable and 

identifiable features, or 

requires extensive signing.

Boundary isolates area from Influence by outside activities

• Area accessed by trail or 

closed and revegetated road; 

adjacent area has natural 

setting.

• No active disturbance near 

boundary.

• Natural processes take place 

undisturbed and 

unmanipulated. 

• May be accessed by narrow 

or two track open road that is 

lightly traveled; minimal 

human presence is evident.

• May have disturbance near 

boundary, but it is short term 

such as a logging operation.

• Minimal disturbance of natural 

processes.

• Boundary adjacent to heavily 

used road or along area 

showing high human 

presence, such as private 

lands with structures or 

cultivated land.

• Boundary adjacent to longterm disturbance like farmland 

or mining operations.

• Natural processes cannot 

occur without human 

intervention.
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

416

High Moderate Low

Boundaries are Manageable

• Boundary total on National 

Forest and not adjacent to 

private lands. 

• No inholdings.

• Boundary follows property line 

forming irregular shape. 

• Few small inholdings may be 

present. 

• Boundary crosses private 

property so there are 

inholdings along the 

boundary. 

• Several small or large 

inholdings.

Boundaries are a barrier to prohibited uses

• Topographic features provide 

a natural barrier, such as 

major stream of steep hillside.

• Human improvement is 

significant to physically 

provide a barrier, such as a 

road cut slope.

• Topography generally makes 

it difficult to participate in 

prohibited uses.

• Human improvement places 

user on notice of prohibited 

use, such as a sign.

• Topography not a deterrent to 

prohibited uses.

• Human improvement not a 

deterrent; may provide a point 

of access of prohibited uses.

Capability Results

Using these criteria, the capability assessment for the Blue Mountains national forests are 

displayed in the following tables. Capability ratings are informed and supplemented by narratives 

that provide additional detail for each area including an area overview and area characteristics 

(see Malheur National Forest Review of Areas with Wilderness Potential, 2010; Umatilla 

National Forest Review of Areas with Wilderness Potential, 2010; and Wallowa-Whitman 

National Forest Review of Areas with Wilderness Potential, 2010). Narratives are available in the 

project record and on the Blue Mountains plan revision website.
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

417

Table E-2. Area capability assessment criteria for the Malheur National Forest (Aldrich Mountain, Baldy Mountain, Cedar Grove, Dixie Butte, Dry Cabin, 

Glacier Mountain) 

Evaluation Criteria/Area Name Aldrich 

Mountain

Baldy 

Mountain Cedar Grove Dixie Butte Dry Cabin Glacier 

Mountain

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

High High Moderate Moderate High High

Natural integrity, area is free from disturbance High High High Low High Moderate

Overall High High High Moderate High High

Challenge 

Provides outstanding opportunities for challenge and 

adventure

High Moderate Low Moderate High Low

Outdoor Recreation Opportunity*

Hiking Low Low High High Low High

Backpacking Low Low Low High Low Moderate

Horseback riding/saddle stock Low Low Low Moderate Low Moderate

Fishing Moderate Moderate Low Moderate Moderate Low

Hunting Moderate Moderate Low High High Moderate

Cross-country skiing/Snowshoeing N/A N/A Low Moderate N/A Moderate

Overall Low Low Low Moderate Moderate Moderate

Special Features

Unique fish and wildlife species Low High Low Low High Moderate

Unique plants or plant communities Low Low High Moderate Moderate Low

Potential or existing Research Natural Areas N/A N/A N/A High N/A N/A

Outstanding landscape features High Moderate Low Low Moderate Low

Significant cultural resource sites Low Low Low Low Moderate Low

Overall Low Low Low Low Moderate Low

Manageability

Boundaries are recognizable/conform with terrain High High Low Low High Moderate

Boundary isolates area from Influence by outside activities Moderate High Moderate Low High Moderate

Boundaries are manageable Moderate Moderate Moderate Moderate Moderate Low

Boundaries constitute a barrier to prohibited use Moderate Moderate Low Low Moderate Low

Overall Moderate Moderate Low Low High Moderate

CAPABILITY RATING OVERALL Moderate Moderate Low M/L M/H Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

418

Table E-3. Area capability assessment criteria for the Malheur National Forest (Greenhorn Mountain, Jumpoff Joe, Malheur River, McClellan Mountain, 

Myrtle Silvies, Nipple Butte)

Evaluation Criteria/Area Name Greenhorn 

Mountain. Jumpoff Joe Malheur River McClellan Mtn. Myrtle Silvies Nipple Butte

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Moderate Low Moderate Moderate Moderate Moderate

Natural integrity, area is free from disturbance Moderate Low High High Moderate High

Overall Moderate Low Moderate High Moderate Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low Low High Moderate Moderate Low

Outdoor Recreation Opportunity*

Hiking Moderate High High High High Moderate

Backpacking Low High High High High Moderate

Horseback riding/saddle stock Low High High High High Low

Fishing Moderate High High High Moderate Moderate

Hunting Moderate High High High High High

Cross-country skiing/Snowshoeing High High N/A Moderate N/A N/A

Overall Moderate High High High High Moderate

Special Features

Unique fish and wildlife species High Low High Low Moderate Low

Unique plants or plant communities High Moderate High Moderate Low Low

Potential or existing Research Natural Areas Moderate N/A N/A High N/A Low

Outstanding landscape features High Moderate High Moderate Low Low

Significant cultural resource sites Moderate Low High Moderate Low Low

Overall High Low High Moderate Low Low

Manageability

Boundaries are recognizable/conform with terrain Moderate Moderate Low Low Low Moderate

Boundary isolates area from Influence by outside activities Moderate Low Low Moderate Low Moderate

Boundaries are manageable Low Low Moderate Moderate Low Low

Boundaries constitute a barrier to prohibited use Low Low Low Low Low Low

Overall Low Low Low Low Low Low

CAPABILITY RATING OVERALL Mod./Low Moderate Moderate Moderate Low Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

419

Table E-4. Area capability assessment criteria for the Malheur National Forest (Pine Creek, Shake Table, Strawberry Mtn. Additions, Utley Butte)

Evaluation Criteria/Area Name Pine Creek Shaketable Strawberry Mountain 

Additions Utley Butte

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

High Low Moderate Moderate

Natural integrity, area is free from disturbance Moderate Low High Moderate

Overall High Low M/H Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low Moderate High Moderate

Outdoor Recreation Opportunity*

Hiking Moderate Moderate Low Low

Backpacking Low Low Low Low

Horseback riding/saddle stock Low Low Low Low

Fishing Moderate Low Low Moderate

Hunting Moderate Moderate High Moderate

Cross-country skiing/Snowshoeing N/A N/A Low N/A

Overall Moderate Low Low Low

Special Features

Unique fish and wildlife species Low Moderate Low Moderate

Unique plants or plant communities Low Moderate Low Moderate

Potential or existing Research Natural Areas Low High Low Low

Outstanding landscape features Low Low Moderate Low

Significant cultural resource sites Low Low Low Low

Overall Low Moderate Low Low

Manageability

Boundaries are recognizable/conform with terrain Low Moderate Low High

Boundary isolates area from Influence by outside activities Low Moderate Low Low

Boundaries are manageable Low Moderate Low Low

Boundaries constitute a barrier to prohibited use Low Low Moderate Low

Overall Low Moderate Low Low

CAPABILITY RATING OVERALL Low Moderate Moderate Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

420

Table E-5. Area capability assessment criteria for the Umatilla National Forest (Asotin Creek, Grande Ronde, Greenhorn Mountain, Hellhole, Horseshoe 

Ridge, Jumpoff Joe)

Evaluation Criteria/Area Name Asotin Creek Grande Ronde Greenhorn 

Mtn. Hellhole Horseshoe Ridge Jumpoff Joe

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Moderate Moderate Moderate Moderate Moderate Low

Natural integrity, area is free from disturbance High High Moderate High High Low

Overall High High Moderate High High Low

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Moderate Low High Low Low

Outdoor Recreation Opportunity*

Hiking Moderate Low Moderate Moderate Low High

Backpacking Low Low Low Moderate Low High

Horseback riding/saddle stock Low Low Low Moderate Low High

Fishing Low High Moderate Moderate Low High

Hunting Moderate Low Moderate Moderate Moderate High

Cross-country skiing/Snowshoeing N/A N/A High N/A Low High

Overall Moderate Low Moderate Moderate Low High

Special Features

Unique fish and wildlife species Moderate High High Moderate Low Low

Unique plants or plant communities Moderate Moderate High Moderate Low Moderate

Potential or existing Research Natural Areas Low Low Moderate Low Low Low

Outstanding landscape features Moderate High High Low Low Moderate

Significant cultural resource sites Low Low Moderate Low Moderate Low

Overall Moderate Moderate High Moderate Low Low

Manageability

Boundaries are recognizable/conform with terrain High High Moderate High High Moderate

Boundary isolates area from Influence by outside activities High High Moderate High Low Low

Boundaries are manageable High High Low High Moderate Low

Boundaries constitute a barrier to prohibited use High High Low High High Low

Overall High High Low High Moderate Low

CAPABILITY RATING OVERALL Moderate Moderate M/L High M/L Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

421

Table E-6. Area capability assessment criteria for the Umatilla National Forest (Lookingglass, Meadow Creek, Mill Creek, North Fork John Day 

Additions, North Fork Umatilla Additions, North Mt. Emily)

Evaluation Criteria/Area Name

Lookingglass Meadow Creek Mill Creek North Fork 

John Day 

Additions

NF Umatilla 

Additions

North Mt. 

Emily

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Moderate Low High Low Moderate Low

Natural integrity, area is free from disturbance Moderate Moderate High High Moderate Moderate

Overall Moderate Low High Moderate Moderate Low

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Low High Low Moderate Low

Outdoor Recreation Opportunity*

Hiking High Moderate Low Low Moderate Low

Backpacking High Moderate Low Low Low Low

Horseback riding/saddle stock High Moderate Low Low Low Low

Fishing High High Low Low Low Low

Hunting High High High High High Moderate

Cross-country skiing/Snowshoeing High Low N/A Low N/A Moderate

Overall High Moderate Low Low Moderate Low

Special Features

Unique fish and wildlife species Moderate Moderate Low Low Low Low

Unique plants or plant communities Moderate Moderate Moderate Low Low Low

Potential or existing Research Natural Areas Low Low Moderate Low Low Low

Outstanding landscape features Low Low Low Low Low Moderate

Significant cultural resource sites Low Low Low Low Low Low

Overall Low Low Low Low Low Low

Manageability

Boundaries are recognizable/conform with terrain Moderate Moderate High High Moderate High

Boundary isolates area from Influence by outside activities Low Low High Moderate Moderate Low

Boundaries are manageable Moderate Moderate High High Moderate High

Boundaries constitute a barrier to prohibited use Low Low High Moderate Moderate Low

Overall Low Low High High Moderate Moderate

CAPABILITY RATING OVERALL Moderate Low Moderate Moderate Moderate Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

422

Table E-7. Area capability assessment criteria for the Umatilla National Forest (Owsley, Potamus, Skookum, South Fork/Tower, Spangler, Squaw/Little Fly)

Evaluation Criteria/Area Name Owsley Potamus Skookum South 

Fork/Tower Spangler Squaw/ Little Fly

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Moderate Moderate Low Low Moderate Low

Natural integrity, area is free from disturbance Moderate Low Moderate Low Moderate Low

Overall Moderate Moderate Moderate Low Moderate Low

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Low Low Low Low Low

Outdoor Recreation Opportunity*

Hiking Low Low Low Low Low High

Backpacking Low Low Low Low Low Moderate

Horseback riding/saddle stock Low Low Low Low Low Moderate

Fishing Moderate low Low Low Moderate Low

Hunting Low Moderate Moderate High Moderate High

Cross-country skiing/Snowshoeing Low Low Low Low Moderate N/A

Overall Low Low Low Low Moderate Moderate

Special Features

Unique fish and wildlife species Moderate Moderate Moderate Moderate Moderate Low

Unique plants or plant communities Low Low Low Low Low Low

Potential or existing Research Natural Areas Low Low Low Low Low Low

Outstanding landscape features Low Moderate Low Low Low Low

Significant cultural resource sites Low Moderate Low Low Low Low

Overall Low Moderate Low Low Low Low

Manageability

Boundaries are recognizable/conform with terrain High High High Moderate High Low

Boundary isolates area from Influence by outside activities High Low Low Low Low Low

Boundaries are manageable High Moderate Moderate Moderate Moderate Low

Boundaries constitute a barrier to prohibited use Low Low Low Low Low Low

Overall High Moderate Moderate Low Moderate Low

CAPABILITY RATING OVERALL Moderate Moderate Low Low Moderate Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

423

Table E-8. Area capability assessment criteria for the Umatilla National Forest (Texas Butte, Tiger Creek, Upper Tucannon, W-T Three)

Evaluation Criteria/Area Name Texas Butte Tiger Creek Upper Tucannon W-T Three

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low Moderate Moderate Moderate

Natural integrity, area is free from disturbance Moderate Moderate Moderate Moderate

Overall Moderate Moderate Moderate Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low High Moderate Moderate

Outdoor Recreation Opportunity*

Hiking High High High High

Backpacking High Moderate High High

Horseback riding/saddle stock High Moderate High High

Fishing High Low Low High

Hunting High High High High

Cross-country skiing/Snowshoeing N/A N/A N/A N/A

Overall High Moderate High High

Special Features

Unique fish and wildlife species Moderate Moderate High High

Unique plants or plant communities Low Low High Low

Potential or existing Research Natural Areas Low Low High Low

Outstanding landscape features Moderate Low High High

Significant cultural resource sites Low Low Moderate Low

Overall Moderate Low High Moderate

Manageability

Boundaries are recognizable/conform with terrain High Moderate High High

Boundary isolates area from Influence by outside activities Low Moderate Moderate High

Boundaries are manageable Moderate High High High

Boundaries constitute a barrier to prohibited use Low Moderate Moderate High

Overall Moderate Moderate Moderate High

CAPABILITY RATING OVERALL Moderate Moderate Moderate High
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

424

Table E-9. Area capability assessment criteria for the Umatilla National Forest (Walla Walla River, Wenatchee Creek, Willow Springs)

Evaluation Criteria/Area Name Walla Walla River Wenatchee Creek Willow Springs

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low High Low

Natural integrity, area is free from disturbance High High Moderate

Overall Moderate High Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate High Moderate

Outdoor Recreation Opportunity*

Hiking High High High

Backpacking High High High

Horseback riding/saddle stock High High High

Fishing High High Low

Hunting High High High

Cross-country skiing/Snowshoeing N/A N/A N/A

Overall High High High

Special Features

Unique fish and wildlife species High Moderate Moderate

Unique plants or plant communities Moderate Moderate Low

Potential or existing Research Natural Areas Low Low Low

Outstanding landscape features Low Low Low

Significant cultural resource sites Low Low Low

Overall Moderate/Low Moderate Low

Manageability

Boundaries are recognizable/conform with terrain High High Moderate

Boundary isolates area from Influence by outside activities Low High Low

Boundaries are manageable High High Moderate

Boundaries constitute a barrier to prohibited use Low High Low

Overall Moderate High Low

CAPABILITY RATING OVERALL Moderate High Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

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Table E-10. Area capability assessment criteria for the Wallowa-Whitman National Forest (Beaver Creek, Big Canyon, Boulder Park/Little Eagle Meadows, 

Buckhorn, Castle Ridge, Cook Ridge)

Evaluation Criteria/Area Name Beaver Creek Big Canyon

Boulder 

Park/Little Eagle 

Meadows

Buckhorn Castle Ridge Cook Ridge

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

High Low Moderate Low Moderate High

Natural integrity, area is free from disturbance High Low Low Moderate Low High

Overall High Low Moderate Moderate Moderate High

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low High Moderate Low Moderate High

Outdoor Recreation Opportunity*

Hiking Moderate Low High High High Low

Backpacking Low Low High High Low Low

Horseback riding/saddle stock Moderate Low High High Low Low

Fishing Moderate Low Low Low Low Low

Hunting High High High High High Moderate

Cross-country skiing/Snowshoeing N/A N/A Moderate Low Moderate N/A

Overall Moderate Low Moderate High Moderate Low

Special Features

Unique fish and wildlife species Low Low Moderate Moderate Moderate Low

Unique plants or plant communities Low Moderate Low Low Moderate Low

Potential or existing Research Natural Areas Low Low Low Low High Low

Outstanding landscape features Low High High High Moderate Moderate

Significant cultural resource sites Low Moderate Moderate High Low Moderate

Overall Low Moderate Moderate Moderate Moderate Low

Manageability

Boundaries are recognizable/conform with terrain High High Moderate Low Moderate High

Boundary isolates area from Influence by outside activities Moderate High Low Low Low High

Boundaries are manageable High High Moderate Low Moderate High

Boundaries constitute a barrier to prohibited use Moderate Low Low Low Low High

Overall High High Moderate Low Moderate High

CAPABILITY RATING OVERALL Moderate Moderate Moderate Moderate Moderate Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

426

Table E-11. Area capability assessment criteria for the Wallowa-Whitman National Forest (Deadhorse, Dunns Bluff, Grande Ronde, Greenhorn Mountain, 

Hellhole, Homestead)

Evaluation Criteria/Area Name Deadhorse Dunns Bluff Grande Ronde Greenhorn 

Mountain Hellhole Homestead

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low Moderate Moderate Moderate Moderate Low

Natural integrity, area is free from disturbance Low Low High Moderate High Low

Overall Low Moderate High Moderate High Low

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Low Moderate Low High Moderate

Outdoor Recreation Opportunity*

Hiking Low Low Low Moderate Moderate Low

Backpacking Low Low Low Low Moderate Low

Horseback riding/saddle stock Low Low Low Low Moderate Low

Fishing Low Low High Moderate Moderate Low

Hunting Moderate Moderate Low Moderate Moderate Moderate

Cross-country skiing/Snowshoeing N/A N/A N/A High N/A N/A

Overall Low Low Low Moderate Moderate Low

Special Features

Unique fish and wildlife species Low Low High High Moderate Low

Unique plants or plant communities Low Low Moderate High Moderate Low

Potential or existing Research Natural Areas Low Low Low Moderate Low Low

Outstanding landscape features Low Low High High Low Low

Significant cultural resource sites Low Low Low Moderate Low Low

Overall Low Low Moderate High Moderate Low

Manageability

Boundaries are recognizable/conform with terrain Low Moderate High Moderate High Low

Boundary isolates area from Influence by outside activities Low Low High Moderate High Low

Boundaries are manageable Low Moderate High Low High Low

Boundaries constitute a barrier to prohibited use Low Low High Low High Low

Overall Low Moderate High Low High Low

CAPABILITY RATING OVERALL Low Low Moderate M/L High Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

427

Table E-12. Area capability assessment criteria for the Wallowa-Whitman National Forest (Huckleberry, Hurricane Creek, Imnaha Face, Joseph Canyon, 

Klopton-Corral Creek, Lake Fork)

Evaluation Criteria/Area Name Huckleberry Hurricane 

Creek Imnaha Face Joseph Canyon

KloptonCorral Creek Lake Fork

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

High Low Moderate Moderate Low Low

Natural integrity, area is free from disturbance High Low Moderate Moderate Low Low

Overall High Low Moderate Moderate Low Low

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Low Moderate Moderate High Low

Outdoor Recreation Opportunity*

Hiking High Low High High Low High

Backpacking High Low High High Low High

Horseback riding/saddle stock High Low High High Low High

Fishing Low Low Moderate Moderate Low High

Hunting High Low High High High High

Cross-country skiing/Snowshoeing Moderate Moderate Moderate Moderate N/A High

Overall Moderate Low High High Low High

Special Features

Unique fish and wildlife species Low Moderate Low High Low Moderate

Unique plants or plant communities Low Low Moderate Moderate Moderate High

Potential or existing Research Natural Areas Low Low Low Low Low High

Outstanding landscape features Low Low High High High Moderate

Significant cultural resource sites Low Low Low High Low Low

Overall Low Low Moderate High Moderate Moderate

Manageability

Boundaries are recognizable/conform with terrain Moderate Low Moderate Low High Moderate

Boundary isolates area from Influence by outside activities Low Low Low Moderate High Low

Boundaries are manageable Moderate Low Low Low High Moderate

Boundaries constitute a barrier to prohibited use Low Low Moderate Low Low Low

Overall Moderate Low Moderate Low High Low

CAPABILITY RATING OVERALL Moderate Low Moderate Moderate Moderate Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

428

Table E-13. Area capability assessment criteria for the Wallowa-Whitman National Forest (Lick Creek, Little Creek, Little Eagle Meadows, Little Sheep, 

Lord-Flat-Sommers Point, Marble Point)

Evaluation Criteria/Area Name Lick Creek Little Creek Little Eagle 

Meadows Little Sheep Lord FlatSommers Point Marble Point

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Moderate Moderate Moderate Low Moderate Moderate

Natural integrity, area is free from disturbance Moderate Moderate Low Low High Moderate

Overall Moderate Moderate Moderate Low High Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Moderate Moderate Low Moderate Moderate

Outdoor Recreation Opportunity*

Hiking High High High High High High

Backpacking High High High High High High

Horseback riding/saddle stock High High High High High High

Fishing Moderate Low Low Moderate Moderate Low

Hunting High High High High High High

Cross-country skiing/Snowshoeing Moderate Moderate Moderate High N/A N/A

Overall High High Moderate High High High

Special Features

Unique fish and wildlife species High Low Moderate Low Moderate High

Unique plants or plant communities Moderate Moderate Low Low Low Low

Potential or existing Research Natural Areas High Low Low Low Low Low

Outstanding landscape features High Low High Low High Moderate

Significant cultural resource sites High Low Moderate Low Low Moderate

Overall High Low Moderate Low Low Moderate

Manageability

Boundaries are recognizable/conform with terrain High Moderate Moderate Low Moderate High

Boundary isolates area from Influence by outside activities High Moderate Low Low Low High

Boundaries are manageable High Moderate Moderate Low Moderate High

Boundaries constitute a barrier to prohibited use Low Moderate Low Low Low Low

Overall High Moderate Moderate Low Low High

CAPABILITY RATING OVERALL High Moderate Moderate Low Moderate Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

429

Table E-14. Area capability assessment criteria for the Wallowa-Whitman National Forest (Monument Rock, Mountain Sheep, Mount Emily, North Mound 

Emily, Reservoir, Sheep Divide)

Evaluation Criteria/Area Name Monument 

Rock

Mountain 

Sheep Mount Emily North Mount Emily Reservoir Sheep Divide

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low Low Moderate Low Low Moderate

Natural integrity, area is free from disturbance Low High Moderate Moderate Low Moderate

Overall Low Moderate Moderate Low Low Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low High Moderate Low Low Low

Outdoor Recreation Opportunity*

Hiking High High High Low High Low

Backpacking High Low Low Low High Low

Horseback riding/saddle stock High Low Low Low High Low

Fishing Low Low Low Low Low Low

Hunting High Moderate Moderate Moderate High Moderate

Cross-country skiing/Snowshoeing N/A N/A Low Moderate High Low

Overall High Low Low Low High Low

Special Features

Unique fish and wildlife species Low Moderate Low Low Low Moderate

Unique plants or plant communities Low Low Low Low Low Low

Potential or existing Research Natural Areas Low Low Low Low Low Low

Outstanding landscape features Low Moderate Low Moderate High Low

Significant cultural resource sites Low Moderate Low Low Low Low

Overall Low Moderate Low Low Low Low

Manageability

Boundaries are recognizable/conform with terrain High Moderate Moderate High Moderate Low

Boundary isolates area from Influence by outside activities Low Moderate Low Low Low Low

Boundaries are manageable Moderate Moderate Moderate High Low Low

Boundaries constitute a barrier to prohibited use Low Low Low Low Low Low

Overall Low Moderate Low Moderate Low Low

CAPABILITY RATING OVERALL Low Moderate Low Low Low Low
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

430

Table E-15. Area capability assessment criteria for the Wallowa-Whitman National Forest (Snake River, Squaw/Little Fly, Tope Creek, South Fork/Tower, 

Upper Catherine Creek)

Evaluation Criteria/Area Name Snake River Squaw 

(Little Fly) Tope Creek South Fork/Tower Twin Mountain Upper Catherine Creek

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low Low Low Low Moderate Moderate

Natural integrity, area is free from disturbance Low Low Low Low Moderate Moderate

Overall Low Low Low Low Moderate Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Low Low Low Low Low Moderate

Outdoor Recreation Opportunity*

Hiking Low High Low Low High High

Backpacking Low Moderate Low Low High High

Horseback riding/saddle stock Low Moderate Low Low High High

Fishing Low Low Low Low Low Low

Hunting High High Moderate High High High

Cross-country skiing/Snowshoeing N/A N/A Low Low High Moderate

Overall Low Moderate Low Low High High

Special Features

Unique fish and wildlife species Moderate Low Low Moderate High Low

Unique plants or plant communities Low Low Low Low Low Moderate

Potential or existing Research Natural Areas Low Low Low Low Low Low

Outstanding landscape features High Low High Low High Low

Significant cultural resource sites Low Low Low Low High Low

Overall Low Low Low Low Moderate Low

Manageability

Boundaries are recognizable/conform with terrain Moderate Low Low Moderate Low Moderate

Boundary isolates area from Influence by outside activities Low Low Low Low Low Moderate

Boundaries are manageable Moderate Low Low Moderate Moderate Moderate

Boundaries constitute a barrier to prohibited use Low Low Low Low Low Moderate

Overall Low Low Low Low Low Moderate

CAPABILITY RATING OVERALL Moderate Low Low Low Moderate Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

431

Table E-16. Area capability assessment criteria for the Wallowa-Whitman National Forest (Upper Grande Ronde, Wildhorse)

Evaluation Criteria/Area Name Upper Grande Ronde Wildhorse

Environmental

Opportunity for solitude, isolation from sights, sounds, and 

presence of others (size, screening, distance from impacts, 

degree of permanent intrusions)

Low Low

Natural integrity, area is free from disturbance Low High

Overall Low Moderate

Challenge 

Provides outstanding opportunities for challenge and 

adventure

Moderate Moderate

Outdoor Recreation Opportunity*

Hiking Low Low

Backpacking Low Low

Horseback riding/saddle stock Low Low

Fishing Low Low

Hunting Moderate Moderate

Cross-country skiing/Snowshoeing Low N/A

Overall Low Low

Special Features

Unique fish and wildlife species High Moderate

Unique plants or plant communities Low Low

Potential or existing Research Natural Areas Low Low

Outstanding landscape features High High

Significant cultural resource sites High Moderate

Overall Moderate Moderate

Manageability

Boundaries are recognizable/conform with terrain Moderate Moderate

Boundary isolates area from Influence by outside activities Moderate Moderate

Boundaries are manageable Moderate Moderate

Boundaries constitute a barrier to prohibited use Low Low

Overall Moderate Moderate

CAPABILITY RATING OVERALL Moderate Moderate
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

432

Availability Process 

While capability evaluated the wilderness characteristics of an area, 

availability considers other resources. Direction from FSH 1909.12, 

Chapter 70 (1982) and internal and external comments were used to 

identify other resources for evaluation and establish the rating 

process. The Forest identified eight resource categories, and selected 

resource specialists from the Forest rated the resource categories 

using a high, moderate, or low rating system. Specialists included 

recreation managers, wildlife and fishery biologists, hydrologists, 

ecologists, geologists, fuels and wildfire specialists, land specialists 

(special use permits), and silviculturists.

Individual Forest Service specialists’ ratings are determined for each 

area. An overall availability rating was then determined by the 

wilderness program manager. 

The following tables list the eight resource categories evaluated and 

their ratings for each area. The availability of an area for potential 

wilderness designation is the opposite of the rating for other resource 

requirements. For example, a rating of high mineral value will mean 

a low rating for availability.

Availability ratings are informed and supplemented by narratives that 

provide additional detail for each area including an area overview 

and area characteristics (see Malheur National Forest Review of 

Areas with Wilderness Potential, 2010; Umatilla National Forest 

Review of Areas with Wilderness Potential, 2010; and WallowaWhitman National Forest Review of Areas with Wilderness 

Potential, 2010). Narratives are available in the project record and on 

the Blue Mountain national forest plan revision website. 
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

433 

Table E-17. Area availability assessment criteria for the Malheur National Forest (Aldrich Mountain, Baldy Mountain, Cedar Gove, Dixie Butte, Dry Cabin, 

Glacier Mountain) 

Evaluation Criteria/Area Name Aldrich 

Mountain Baldy Mtn. Cedar Grove Dixie Butte Dry Cabin Glacier 

Mountain

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

N/A N/A No N/A No No

Would wilderness designation seriously restrict 

needed fish management activities?

Yes Yes No N/A No No

Does the area have high level of strategic or 

economic mineral development potential?

No No No No No No

Is the land needed to meet clearly 

documented resource demands such as for 

timber, minerals, or developed recreation sites 

including winter sports?

No No No No No No

Are there existing contractual or other 

significant obligations on the area not in 

concert with wilderness designation? Includes 

SUPs and MOAs 

No No No Yes No No

Presence of Inholdings (private property) Yes No No No No No

Is the land needed to meet clearly 

documented resource demands such as for 

fuels treatment?

N/A N/A No N/A N/A N/A

AVAILABILITY RATING OVERALL Available Available Available Not Available Available Available

N/A = not applicable
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

434

Table E-18. Area availability assessment criteria for the Malheur National Forest (Greenhorn Mtn, Jumpoff Joe, Malheur River, McClellan Mtn, Myrtle 

Silvies, Nipple Butte) 

Evaluation Criteria/Area Name Greenhorn 

Mtn. Jumpoff Joe Malheur River McClellan Mtn. Myrtle Silvies Nipple Butte

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No Yes Yes No

Would wilderness designation seriously restrict 

needed fish management activities?

Yes No Yes Yes Yes No

Does the area have high level of strategic or 

economic mineral development potential?

Yes No No No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No No No No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

Yes No No No Yes Yes

Presence of Inholdings (private property) No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

N/A N/A N/A N/A N/A N/A

AVAILABILITY RATING OVERALL Not Available Available Available Available Not Available Available

N/A = not applicable
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

435

Table E-19. Area availability assessment criteria for the Malheur National Forest (Pine Creek, Shaketable, Strawberry Mtn Additions, Utley Butte)

Evaluation Criteria/Area Name Pine Creek Shaketable Strawberry Mtn. 

Additions Utley Butte

Availability Determination

Is the area vitally needed for increased water production and 

storage?

No No No No

Would wilderness designation seriously restrict needed wildlife 

management activities?

No No No Yes

Would wilderness designation seriously restrict needed fish 

management activities?

No No No No

Does the area have high level of strategic or economic mineral 

development potential?

No No No No

Is the land needed to meet clearly documented resource 

demands such as for timber, minerals, or developed recreation 

sites including winter sports?

No No No No

Are there existing contractual or other significant obligations on 

the area not in concert with wilderness designation? Includes 

SUP's and MOA's

No No No No

Presence of Inholdings (private property) No No No No

Is the land needed to meet clearly documented resource 

demands such as for fuels treatment?

N/A N/A N/A N/A

AVAILABILITY RATING OVERALL Available Available Available Available

N/A = not applicable
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

436

Table E-20. Area availability assessment criteria for the Umatilla National Forest (Asotin Creek, Grande Ronde, Greenhorn Mtn, Hellhole, Horseshoe 

Ridge, Jumpoff Joe)

Evaluation Criteria/Area Name Asotin Creek Grande Ronde Greenhorn 

Mtn. Hellhole Horseshoe Ridge Jumpoff Joe

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No Yes No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No Yes No No No

Does the area have high level of strategic or 

economic mineral development potential?

No No Yes No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

N/A No No N/A No No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

No No Yes Yes No No

Presence of Inholdings (private property) Yes No No Yes No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

N/A N/A N/A N/A N/A N/A

AVAILABILITY RATING OVERALL Available Available Not Available Not Available Available Available

N/A = not applicable
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

437

Table E-21. Area availability assessment criteria for the Umatilla National Forest (Lookingglass, Meadow Creek, Mill Creek, North Fork John Day 

Additions, North Fork Umatilla Additions, North Mt. Emily)

Evaluation Criteria/Area Name Lookingglass Meadow Creek Mill Creek

North Fork 

John Day 

Additions

NF Umatilla 

Additions

North Mt. 

Emily 

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No Yes No No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No xx No No No

Would wilderness designation seriously restrict 

needed fish management activities?

Yes No xx No No No

Does the area have high level of strategic or 

economic mineral development potential?

No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No No No No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

No Yes Yes No No No

Presence of Inholdings (private property) No No Yes No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

Yes Yes Yes No Yes Yes

AVAILABILITY RATING OVERALL Not Available Not Available Not Available Available Not Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

438

Table E-22. Area availability assessment criteria for the Umatilla National Forest (Owsley, Potamus, Skookum, South Fork/Tower, Spangler, 

Squaw/Little Fly)

Evaluation Criteria/Area Name Owsley Potamus Skookum South 

Fork/Tower Spangler Squaw/ Little fly 

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No Yes Yes No No No

Would wilderness designation seriously restrict 

needed fish management activities?

Yes No No Yes No No

Does the area have high level of strategic or 

economic mineral development potential?

No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No Yes Yes Yes

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

No No No Yes Yes Yes

Presence of Inholdings (private property) No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

Yes No No No No No

AVAILABILITY RATING OVERALL Not Available Available Available Not Available Not Available Not Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

439

Table E-23. Area availability assessment criteria for the Umatilla National Forest (Texas Butte, Tiger Creek, Upper Tucannon, W-T Three)

Evaluation Criteria/Area Name Texas Butte Tiger Creek Upper Tucannon W-T Three

Availability Determination

Is the area vitally needed for increased water production and 

storage?

No No No No

Would wilderness designation seriously restrict needed wildlife 

management activities?

Yes No No No

Would wilderness designation seriously restrict needed fish 

management activities?

No No No No

Does the area have high level of strategic or economic mineral 

development potential?

No No No No

Is the land needed to meet clearly documented resource 

demands such as for timber, minerals, or developed recreation 

sites including winter sports?

Yes No No No

Are there existing contractual or other significant obligations on 

the area not in concert with wilderness designation? Includes 

SUP's and MOA's

No No No No

Presence of Inholdings (private property) No No No No

Is the land needed to meet clearly documented resource 

demands such as for fuels treatment?

No No No No

AVAILABILITY RATING OVERALL Not Available Available Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

440

Table E-24. Area availability assessment criteria for the Umatilla National Forest (Walla Walla River, Wenatchee Creek, Willow Springs

Evaluation Criteria/Area Name Walla Walla River Wenatchee Creek Willow Springs

Availability Determination

Is the area vitally needed for increased water production and 

storage?

Yes No No

Would wilderness designation seriously restrict needed wildlife 

management activities?

No No No

Would wilderness designation seriously restrict needed fish 

management activities?

No No No

Does the area have high level of strategic or economic mineral 

development potential?

No No No

Is the land needed to meet clearly documented resource 

demands such as for timber, minerals, or developed recreation 

sites including winter sports?

No No No

Are there existing contractual or other significant obligations on 

the area not in concert with wilderness designation? Includes 

SUP's and MOA's

No No No

Presence of Inholdings (private property) No No No

Is the land needed to meet clearly documented resource 

demands such as for fuels treatment?

No No No

AVAILABILITY RATING OVERALL Available Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

441

Table E-25. Area availability assessment criteria for the Wallowa-Whitman National Forest (Beaver Creek, Big Canyon, Boulder Park/Little Eagle 

Meadows, Buckhorn, Castle Ridge, Cook Ridge)

Evaluation Criteria/Area Name Beaver Creek Big Canyon 

(ID)

Boulder 

Park/Little 

Eagle Meadows

Buckhorn Castle Ridge Cook Ridge

Availability Determination

Is the area vitally needed for increased water 

production and storage?

Yes No No No No No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No No No No

Does the area have high level of strategic or 

economic mineral development potential?

No No Yes No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No No Yes No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

Yes No Yes No Yes No

Presence of Inholdings (private property) No No No Yes No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

Yes No No No Yes No

AVAILABILITY RATING OVERALL Not Available Available Available Available Not Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

442

Table E-26. Area availability assessment criteria for the Wallowa-Whitman National Forest (Deadhorse, Dunns Bluff, Grande Ronde, Greenhorn 

Mountain, Hellhole, Homestead)

Evaluation Criteria/Area Name Deadhorse Dunns Bluff Grande Ronde Greenhorn 

Mountain Hellhole Homestead

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No Yes No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No N/A No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No Yes N/A No

Does the area have high level of strategic or 

economic mineral development potential?

No No No Yes No Yes

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No No No No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's

and MOA's

No No No Yes Yes Yes

Presence of Inholdings (private property) No No No No Yes No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

No No N/A N/A N/A No

AVAILABILITY RATING OVERALL Available Available Available Not Available Not Available Available

N/A = not applicable
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

443

Table E-27. Area availability assessment criteria for the Wallowa-Whitman National Forest (Huckleberry, Hurricane Creek, Imnaha Face, Joseph 

Canyon, Klopton-Corral Creek, Lake Fork)

Evaluation Criteria/Area Name Huckleberry Hurricane 

Creek Imnaha Face Joseph Canyon

Klopton-Corral 

Creek Lake Fork

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No No Yes

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No No No No

Does the area have high level of strategic or 

economic mineral development potential?

No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No Yes No Yes

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

No No No No No Yes

Presence of Inholdings (private property) No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

No No No No No No

AVAILABILITY RATING OVERALL Available Available Available Available Available Not Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

444

Table E-28. Area availability assessment criteria for the Wallowa-Whitman National Forest (Lick Creek, Little Creek, Little Eagle Meadows, Little Sheep, 

Lord Flat-Sommers Point, Marble Point)

Evaluation Criteria/Area Name Lick Creek Little Creek Little Eagle 

Meadows Little Sheep Lord FlatSommers Point Marble Point

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No Yes No No No Yes

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No No No No

Does the area have high level of strategic or 

economic mineral development potential?

No No Yes No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

Yes No No Yes No No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

Yes Yes Yes Yes Yes Yes

Presence of Inholdings (private property) No No No No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

No Yes No No No Yes

AVAILABILITY RATING OVERALL Not Available Not Available Available Not Available Available Not Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

445

Table E-29. Area availability assessment criteria for the Wallowa-Whitman National Forest (Monument Rock, Mountain Sheep, Mount Emily, North 

Mount Emily, Reservoir, Sheep Divide)

Evaluation Criteria/Area Name Monument 

Rock

Mountain 

Sheep Mount Emily North Mount Emily Reservoir Sheep Divide

Availability Determination

Is the area vitally needed for increased water 

production and storage?

Yes No No No Yes No

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No No No No

Does the area have high level of strategic or 

economic mineral development potential?

No ? No No No No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No No No No Yes No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

No No No No Yes No

Presence of Inholdings (private property) No Yes No No No No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

No No Yes Yes No No

AVAILABILITY RATING OVERALL Available Not Available Not Available Available Not Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

446

Table E-30. Area availability assessment criteria for the Wallowa-Whitman National Forest (Snake River, Squaw/Little Fly, Tope Creek, South 

Fork/Tower, Twin Mountain, Upper Catherine Creek) 

Evaluation Criteria/Area Name Snake River Squaw 

(Little Fly) Tope Creek South 

Fork/Tower Twin Mountain

Upper 

Catherine 

Creek

Availability Determination

Is the area vitally needed for increased water 

production and storage?

No No No No Yes Yes

Would wilderness designation seriously restrict 

needed wildlife management activities?

No No No No No No

Would wilderness designation seriously restrict 

needed fish management activities?

No No No Yes No No

Does the area have high level of strategic or 

economic mineral development potential?

No No No No Yes No

Is the land needed to meet clearly documented 

resource demands such as for timber, minerals, 

or developed recreation sites including winter 

sports?

No Yes No Yes Yes No

Are there existing contractual or other 

significant obligations on the area not in concert 

with wilderness designation? Includes SUP's 

and MOA's

Yes Yes No Yes Yes Yes

Presence of Inholdings (private property) No No No No Yes No

Is the land needed to meet clearly documented 

resource demands such as for fuels treatment?

No No No No Yes Yes

AVAILABILITY RATING OVERALL Available Not Available Available Not Available Not Available Not Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

447

Table E-31. Area availability assessment criteria for the Wallowa-Whitman National Forest (Upper 

Grande Ronde, Wildhorse)

Evaluation Criteria/Area Name Upper Grande Ronde Wildhorse

Availability Determination

Is the area vitally needed for 

increased water production and 

storage?

No No

Would wilderness designation 

seriously restrict needed wildlife 

management activities?

No No

Would wilderness designation 

seriously restrict needed fish 

management activities?

No No

Does the area have high level of 

strategic or economic mineral 

development potential?

No No

Is the land needed to meet clearly 

documented resource demands such 

as for timber, minerals, or developed 

recreation sites including winter 

sports?

Yes No

Are there existing contractual or other 

significant obligations on the area not 

in concert with wilderness 

designation? Includes SUP's and 

MOA's

No No

Presence of Inholdings (private 

property)

No No

Is the land needed to meet clearly 

documented resource demands such 

as for fuels treatment?

No No

AVAILABILITY RATING OVERALL Available Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

448

Table E-32. Area capability and availability summary for the Malheur National Forest

Malheur National Forest Areas Capability Rating Availability Rating

Aldrich Mountain Moderate Available

Baldy Mountain Moderate Available

Cedar Grove Low Available

Dixie Butte Moderate/Low Not Available

Dry Cabin Moderate/High Available

Flag Creek N/A N/A

Fox Creek N/A N/A

Glacier Mountain Moderate Available

Greenhorn Mountain Moderate/Low Not Available

Jumpoff Joe Moderate Available

Malheur River Moderate Available

McClellan Mountain Moderate Available

Myrtle-Silvies Low Not Available

Nipple Butte Low Available

North Fork Malheur River N/A N/A

Pine Creek Low Available

Shaketable Moderate Available

Silver Creek N/A N/A

Strawberry Mountain Additions Moderate Available

Utley Butte Low Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

449

Table E-33. Area capability and availability summary for the Umatilla National Forest

Umatilla National Forest Areas Capability Rating Availability Rating

Asotin Creek Moderate Available

Grande Ronde Moderate Available

Greenhorn Mountain Moderate/Low Not Available

Hellhole High Not Available

Horseshoe Ridge Moderate/Low Available

Jaussaud Corral Low Not Available

Jumpoff Joe Moderate Available

Lookingglass Moderate Not Available

Meadow Creek Low Not Available

Mill Creek Watershed Moderate Not Available

North Fork John Day Additions Unknown Unknown

North Fork Umatilla Additions Moderate Not Available

North Mount Emily Low Available

Owsley Moderate Not Available

Potamus Moderate Available

Skookum Low Available

South Fork - Tower Low Not Available

Spangler Moderate Not Available

Squaw (Little Fly) Low Not Available

Texas Butte Moderate Not Available

Tiger Creek Moderate Available

Upper Tucannon Moderate Available

W - T Three High Available

Walla Walla River Moderate Available

Wenatchee Creek High Available

Willow Springs Moderate Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

450

Table E-34. Area capability and availability summary for the Wallowa-Whitman National Forest

Wallow-Whitman National 

Forest Areas

Capability Rating Availability Rating

Beaver Creek Moderate Not Available

Big Canyon Id Moderate Available

Boulder Park Moderate Available

Buckhorn Moderate Available

Castle Ridge Moderate Not Available

Cook Ridge Moderate Available

Deadhorse Low Available

Dunns Bluff Low Available

Grande Ronde Moderate Available

Greenhorn Mountain Moderate/Low Not Available

Hellhole High Not Available

Homestead Low Available

Huckleberry Moderate Available

Hurricane Creek Low Available

Imnaha Face Moderate Available

Joseph Canyon Moderate Available

Klopton-Corral Creek Moderate Available

Lake Fork Moderate Not Available

Lick Creek Moderate Not Available

Little Creek High Not Available

Little Eagle Meadows Moderate Available

Little Sheep Low Not Available

Lord Flat Somers Point Moderate Available

Marble Point Moderate Not Available

Monument Rock Low Available

Mountain Sheep Moderate Not Available

Mt. Emily Low Not Available

North Mount Emily Low Available

Reservoir Low Not Available

Sheep Divide Low Available

Snake River Moderate Available

Squaw Low Not Available

Tope Creek Low Available

South Fork/Tower Low Not Available

Twin Mountain Moderate Not Available

Upper Catherine Creek Moderate Not Available

Upper Grande Ronde Moderate Available

Wildhorse Moderate Available
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

451

Need Evaluation

A Wilderness Needs Assessment was completed in 2010 by the forest plan interdisciplinary team. 

This evaluation determined the need to include these areas as part of the overall National 

Wilderness Preservation System. This assessment covered the Blue Mountains national forests 

planning area as whole, not individual potential wilderness areas. The need for additional 

wilderness in the Blue Mountains was assessed using the following factors from the Forest 

Service Handbook (FSH 1902.12, Chapter 70 Subpart 72.31): 

1. The location, size, and type of other wilderness areas in the general vicinity and their 

distance from the proposed area. Considering accessibility of areas to population 

centers and user groups. Public demand for wilderness may increase with proximity 

to growing population centers. 

2. Present visitor pressure on other wilderness areas, the trends in use, changing patterns 

of use, population expansion factors, and trends and changes in transportation. 

3. The extent to which nonwilderness lands on the national forests or other federal lands 

are likely to provide opportunities for unconfined outdoor recreation experiences. 

4. The need to provide a refuge for those species that have demonstrated an inability to 

survive in less than primitive surroundings or the need for a protected area for other 

unique scientific values or phenomena. 

5. Within social and biological limits, management may increase the capacity of 

established wildernesses to support human use without unacceptable depreciation of 

the wilderness resource. 

6. An area’s ability to provide for preservation of identifiable landform types and 

ecosystems. Consideration of this factor may include utilization of Edwin A. 

Hammond‟s subdivision of landform types and the Bailey-Kuchler ecosystem 

classification. This approach is helpful from the standpoint of round out the National 

Wilderness Preservation System and may be further subdivided to suit local, 

subregional, and regional needs.

The evaluation provides decisionmakers with information on the resources and uses of each area, 

and a regional context for making wilderness designation proposals. Proposing wilderness 

through the Wilderness Evaluations and the completed revised Forest Plan is not the only route 

for making wilderness proposals. A wilderness recommendation may also be made based on 

needs brought forward through public comment. Therefore, the decision to propose a wilderness 

recommendation is not entirely based on need, but may be made based on various land 

management strategies and factors, which include maintaining biological and natural function and 

diversity within and on the natural landscape. The following is a summary of the findings from 

the need evaluation.

Factor 1 – Location, Size, Type of Wilderness; Demographics; and Accessibility 

Designated wilderness areas in the Blue Mountains are more remote and less accessible to major 

population centers than other wilderness areas in the general vicinity. While the current 

designated wilderness areas offer opportunities for solitude, the time and expense needed to visit 

the Blue Mountains limits the number of out-of-area visitors that utilize current wilderness. Only 

a small percentage of the use in current wilderness occurs by other than local residents. Given the 

expected population growth in the general vicinity over the next 15 years, this is not expected to 

change. 
Final Environmental Impact Statement, Volume 4 

Appendix E: Wilderness Evaluation

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

452

Factor 2 – Use, Visitors, and Changing Patterns of Use 

Currently, use of the Blue Mountains wilderness areas account for only a small part (8 percent) of 

the overall use on the Blue Mountains and even a smaller proportion (4 percent) of the use of 

national forest lands in the general vicinity. Use trend data suggests 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 over the next 15 years. This increase will primarily be in day 

uses from non-wilderness areas. Current wilderness areas in the Blue Mountains reach capacity 

only in specific areas during brief, high use periods. 

Factor 3 - Opportunities for Unconfined Outdoor Recreation Experiences 

The Blue Mountains provide high potential opportunities for unconfined recreation experiences 

and solitude, regionally and locally. The social demand for these unconfined experiences is 

related to general dispersed settings, not specifically wilderness areas that provide both motorized 

and nonmotorized activities. 

Factor 4 – Refuge for Species or Protected Areas 

The draft revised land management plan will identify a variety of plan components (existing 

designated wilderness, management areas, desired conditions, objectives, guidelines, and 

monitoring). The arrangement of these areas on the landscape and the objectives and guidelines 

through which they are managed will set the stage for the Malheur, Umatilla and WallowaWhitman National Forests contribution to the diversity of native plant, animal, and fish species. 

Based on this conclusion, no recommendations for additional designated wilderness are needed to 

provide refuge for native species. 

Factor 5 – Capacity of Established Wildernesses to Support Human Use 

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, except in site-specific locations on limited occasions. Alternative sites exist 

within and adjacent to these areas and within other wilderness areas in the Blue Mountains to 

accommodate visitor responses to these instances. Based on current uses, trends, primary market 

zones, demographic changes, crowding levels, visitor pressures, projected uses, existing 

opportunities for unconfined recreation, and social values. 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. 

Factor 6 – Ability to Provide for Preservation of Landform Types and Ecosystems 

Desired conditions, objectives for treatments, and guidelines for management in the draft revised 

land management plan insure that natural process will predominate and that ecosystems will be 

preserved across the landscape. While there are opportunities to increase representation of underrepresented vegetation types in the wilderness system, given the management direction outlined 

in the draft revised land management plan, wilderness designation is not needed for “preservation 

of landform types and ecosystems.” 
Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

453

Appendix F: Suitable Acres

within Range Allotments for Each Alternative

The following tables display the total acres suitable for cattle or 

sheep grazing in each allotment. Suitability and capability for 

grazing within allotments is determined by factors that include 

canopy closure, steepness of slopes, plant production level, and soil 

condition (land type associations). 

Suitability by alternative varies with proximity to bighorn sheep, 

proximity to federally listed and species at risk plants, riparian 

management areas, research natural areas, botanical areas, grazing 

after wildfire, greater sage grouse habitat, wild and scenic river 

corridors, and proximity of grazing to federally listed fish. 

Acres listed in the following tables were generated using geographic 

information systems data for comparison purposes between 

alternatives. The Forest Service cannot assure the reliability or 

suitability of this information for another purpose. 

Table F-1. Suitable acres for cattle grazing in active and vacant cattle allotments for each alternative on the Malheur National Forest

Allotment Alt. A Alt. B Alt. C Alt. D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt. F 

Total Acres 

Within the 

Allotment

Aldrich 8,237 8,858 1,315 8,237 8,237 8,237 8,237 20,351

Alkali 24,844 24,815 20,464 24,844 24,844 24,844 24,844 26,397

Allison 19,671 19,775 15,997 19,671 19,671 19,671 19,671 21,077

Antelope (Silvies) 26,131 26,238 22,500 26,131 26,131 26,131 26,131 28,194

Antelope (Upper Malheur) 4,297 4,299 3,777 4,297 4,297 4,297 4,297 4,519

Balance Creek 122 124 0 122 122 122 122 150

Bear Creek 1,271 1,274 0 1,271 1,271 1,271 1,271 1,477

Beech Creek 1,290 1,273 60 1,290 1,290 1,290 1,290 1,632

Big Sagehen 20,327 20,177 17,686 20,327 20,327 20,327 20,327 21,373

Blue Creek 15,953 15,849 13,278 15,953 15,953 15,953 15,953 17,422

Blue Mountain (vacant) 0 18,748 0 18,746 0 18,794 0 22,683

Bluebucket 17,611 18,218 5,190 17,611 17,611 17,611 17,611 23,500

Bridge Creek 7,247 7,231 6,300 7,247 7,247 7,247 7,247 7,621

Buck Mountain 40,236 40,215 33,224 40,236 40,236 40,236 40,236 41,478

Calamity 18,691 18,660 15,306 18,691 18,691 18,691 18,691 22,412

Camp Creek (Silvies) 12,192 12,164 10,239 12,192 12,192 12,192 12,192 13,684
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

454

Allotment Alt. A Alt. B Alt. C Alt. D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt. F

Total Acres 

Within the 

Allotment

Central Malheur 9,125 9,484 579 9,125 9,125 9,125 9,125 10,727

County Road 127 129 127 127 127 127 127 135

Crooked Creek 4,931 4,924 4,212 4,931 4,931 4,931 4,931 5,076

Dark Canyon 26,272 26,318 9,687 26,272 26,272 26,272 26,272 31,733

Deadhorse 8,246 8,038 912 8,246 8,246 8,246 8,246 15,507

Deardorff 5,686 5,639 0 5,686 5,686 5,686 5,686 10,984

Deer Creek 1,806 1,797 38 1,806 1,806 1,806 1,806 2,177

Devine 23,602 23,594 18,835 23,602 23,602 23,602 23,602 25,010

Dixie 9,661 9,538 1 9,661 9,661 9,661 9,661 16,824

Dollar Basin 14,133 14,101 205 14,133 14,133 14,133 14,133 16,395

Donaldson 6,034 6,010 911 6,034 6,034 6,034 6,034 7,809

Fawn Spring 5,775 5,781 0 5,775 5,775 5,775 5,775 6,289

Ferg 81 82 81 81 81 81 81 108

Fields Peak 18,198 18,104 46 18,198 18,198 18,198 18,198 30,451

Flag Prairie 24,101 24,820 11,535 24,101 24,101 24,101 24,101 28,746

Flagtail 13,768 13,742 11,008 13,768 13,768 13,768 13,768 14,890

Fox 18,007 17,912 1,456 18,007 18,007 18,007 18,007 26,125

Frenchy 484 486 355 484 484 484 484 500

Green Butte 42,851 44,200 34,201 42,851 42,851 42,851 42,851 45,155

Hanscomb 7,385 7,320 3,392 7,385 7,385 7,385 7,385 9,233

Herberger (combined) 0 0 0 0 0 129 0 167

Highway 705 705 40 705 705 705 705 784

Hot Springs 1,343 1,332 2 1,343 1,343 1,343 1,343 2,283

House Creek 2,824 2,819 2,507 2,824 2,824 2,824 2,824 3,252

Hughet Valley 1,820 1,798 1,412 1,820 1,820 1,820 1,820 1,877

Hunter Cabin 13,117 13,120 6,004 13,117 13,117 13,117 13,117 15,599

Indian Creek 951 1,206 344 951 951 951 951 1,285

Izee 15,369 15,262 12,264 15,369 15,369 15,369 15,369 18,434

Jack Creek 9,376 9,345 7,407 9,376 9,376 9,376 9,376 9,802
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

455

Allotment Alt. A Alt. B Alt. C Alt. D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt. F

Total Acres 

Within the 

Allotment

Joaquin 19 17 0 19 19 19 19 35

Justice 422 422 20 422 422 422 422 499

Keeney Meadows 220 219 0 220 220 220 220 295

Koehler 90 88 47 90 90 90 90 115

Lewis Creek 365 361 198 365 365 365 365 392

Little Mowich 286 289 274 286 286 286 286 317

Lake Creek (vacant) 0 0 0 0 0 9,799 0 10,196

Logan Valley 3,706 3,685 0 3,706 3,706 3,706 3,706 3,762

Lonesome 29,560 29,532 24,888 29,560 29,560 29,560 29,560 31,875

Long Creek 35,272 35,228 0 35,272 35,272 35,272 35,272 49,472

Lower Middle Fork 37,754 37,995 0 37,754 37,754 37,754 37,754 57,426

Lower Nicoll 3,928 3,928 3,142 3,928 3,928 3,928 3,928 3,966

Mcclellan 412 366 0 412 412 412 412 2,808

Mccoy Creek 978 956 0 978 978 978 978 980

McCullough 0 0 0 0 0 397 0 626

Mt. Vernon/John Day 34,196 33,753 7,839 34,196 34,196 34,196 34,196 45,941

Muddy 5,927 5,899 4,940 5,927 5,927 5,927 5,927 6,552

Murderers Creek 52,575 52,948 1,241 52,575 52,575 52,575 52,575 73,518

Myrtle 24,416 24,311 20,700 24,416 24,416 24,416 24,416 29,313

North Fork 23,280 25,315 14,843 23,280 23,280 23,280 23,280 31,036

Ott 26,234 26,265 14,725 26,234 26,234 26,234 26,234 29,868

Pearson 59 60 43 59 59 59 59 65

Pine Creek 35,053 35,697 29,260 35,053 35,053 35,053 35,053 39,663

Poison 57 57 14 57 57 57 57 74

Rail Creek 9,341 9,276 334 9,341 9,341 9,341 9,341 17,022

Rainbow 24,569 24,552 19,681 24,569 24,569 24,569 24,569 26,277

Reynolds Creek 11,680 10,778 0 11,680 11,680 11,680 11,680 21,608

Rosebud 4,462 4,420 3,622 4,462 4,462 4,462 4,462 6,370

Roundtop 10,653 10,644 0 10,653 10,653 10,653 10,653 13,212
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

456

Allotment Alt. A Alt. B Alt. C Alt. D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt. F

Total Acres 

Within the 

Allotment

Sawmill 20,848 20,834 16,849 20,848 20,848 20,848 20,848 21,461

Sawtooth 14,971 15,000 11,682 14,971 14,971 14,971 14,971 16,682

Scatfield 626 612 585 626 626 626 626 684

Scotty Creek 32,027 32,026 26,511 32,027 32,027 32,027 32,027 35,482

Seneca 7,184 7,127 3,457 7,184 7,184 7,184 7,184 10,027

Silver Creek 30,038 32,026 24,084 30,038 30,038 30,038 30,038 34,727

Silvies 7,748 7,732 6,900 7,748 7,748 7,748 7,748 8,621

Slide Creek 19,249 19,463 1,226 19,249 19,249 19,249 19,249 24,595

Smoky 8,040 8,014 6,492 8,040 8,040 8,040 8,040 9,043

Snow Mountain 10,701 10,709 8,449 10,701 10,701 10,701 10,701 12,362

Snowshoe 5,385 5,334 3,891 5,385 5,385 5,385 5,385 6,383

Spring Creek* 44,890 45,157 7,065 44,890 44,890 44,890 44,890 57,748

Star Glade 1,036 1,033 0 1,036 1,036 1,036 1,036 1,117

Story-Fry 487 485 434 487 487 487 487 540

Sullens (vacant) 0 0 0 0 0 30,155 0 46,426

Summit Prairie 22,328 22,249 15,784 22,328 22,328 22,328 22,328 25,327

Upper Middle Fork 35,299 36,668 2 35,299 35,299 35,299 35,299 54,285

Van 5,168 5,533 4,450 5,168 5,168 5,168 5,168 6,669

War Canyon 509 511 344 509 509 509 509 534

West Malheur 17,897 18,787 15,827 17,897 17,897 17,897 17,897 22,908

West Myrtle 8,152 8,151 6,831 8,152 8,152 8,152 8,152 8,540

Williams Pasture 234 231 0 234 234 234 234 294

Windy Point (combined) 141 335

Wolf Mountain 24,225 24,637 20,559 24,225 24,225 24,225 24,225 31,607

York 503 501 0 503 503 503 503 519

*Spring creek allotment runs both sheep and cattle on an annual basis 
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

457

Table F-2. Suitable acres for sheep grazing within active sheep allotments for each alternative on the Malheur National Forest

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Donnelly 54,716 54,490 54,490 54,490 54,490 54,490 54,490 56,054

Spring Creek* 47,080 46,856 0 46,856 46,856 46,856 46,856 57,748

*Spring creek allotment runs both sheep and cattle on an annual basis 

Table F-3. Suitable acres for cattle grazing in active cattle allotments for each alternative on the Umatilla National Forest

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Asotin 6,836 10,510 3,059 6,836 6,836 6,836 6,836 39,022

Brock 130 379 25 130 130 130 130 964

Central Desolation 6,956 7,069 2,236 6,956 6,956 6,956 6,956 13,934

Coalmine 608 608 271 608 608 608 608 1,097

Collins Butte 7,356 7,875 1,650 7,356 7,356 7,356 7,356 16,916

Cooper Creek 894 894 678 894 894 894 894 1,284

Ditch Creek 16,467 16,559 1,258 16,467 16,467 16,467 16,467 37,150

Eden 11,130 15,807 0 11,130 11,130 11,130 11,130 34,113

F.G. Whitney 26,908 26,908 2,866 26,908 26,908 26,908 26,908 49,932

Hardman 12,211 12,462 0 12,211 12,211 12,211 12,211 20,913

Hidaway 16,543 16,566 0 16,543 16,543 16,543 16,543 37,142

Hutchison 167 167 83 167 167 167 167 208

Indian Creek 34,989 29,446 2,896 34,989 34,989 34,989 34,989 76,163

Jim Creek 0 17 0 70 0 70 0 106

Klondike 11,648 11,831 104 11,648 11,648 11,648 11,648 24,624

Little Wall 23,488 24,384 858 23,488 23,488 23,488 23,488 37,169

Lucky Strike 7,046 7,006 1,117 7,046 7,046 7,046 7,046 16,973

Matlock 5,751 5,882 288 5,751 5,751 5,751 5,751 10,697

Mcdonald Spring 48 48 24 48 48 48 48 48

Monument 10,107 10,120 1,084 10,107 10,107 10,107 10,107 18,568
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

458

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Peola 13,726 15,978 3,108 13,726 13,726 13,726 13,726 43,736

Stonehill 0 0 0 228 0 228 0 255

Swale Creek 14,176 14,792 809 14,176 14,176 14,176 14,176 27,051

Tamarack 7,896 8,228 438 7,896 7,896 7,896 7,896 19,397

Texas Bar 28,124 28,655 2,555 28,124 28,124 28,124 28,124 41,889

Thompson Flat 4,119 4,201 21 4,119 4,119 4,119 4,119 6,535

Wenatchee 1,933 2,203 992 1,933 1,933 1,933 1,933 6,252

Western Desolation 8,591 8,591 3,077 8,591 8,591 8,591 8,591 13,459

Winlock 2,940 4,116 432 2,940 2,940 2,940 2,940 5,166

Yellowjacket 3,330 3,380 431 3,330 3,330 3,330 3,330 7,577

Table F-4. Suitable acres for sheep grazing within active sheep allotments for each alternative on the Umatilla National Forest

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Butcher Creek 2,902 2,902 2,902 2,902 2,902 2,902 2,902 10,890

Central Desolation 11,292 11,292 1,652 11,292 11,292 11,292 11,292 13,934

Cunningham 11,314 11,314 1,659 11,314 11,314 11,314 11,314 19,135

North End 37,535 5,455 24 19,308 19,308 19,308 19,308 126,923

Spring Mountain 8,499 8,499 8,399 8,499 8,499 8,499 8,499 35,509

Table F-5. Suitable acres for cattle grazing in active and vacant cattle allotments for each alternative on the Wallowa-Whitman National Forest

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Al-Cunningham 321 475 0 321 321 321 321 1,296

Alder Springs 13,446 13,446 8,167 13,446 13,446 13,446 13,446 21,712

Auburn 8,434 8,392 6,925 8,434 8,434 8,434 8,434 15,076

Balm Creek 262 259 139 262 262 262 262 1,643
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

459

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Bear Gulch 509 2,234 0 509 509 509 509 8,964

Big Creek 21,738 21,239 8,915 21,738 21,738 21,738 21,738 44,744

Big Sheep 760 2,826 0 760 760 760 760 18,780

Black Mountain 2,894 2,894 2,261 2,894 2,894 2,894 2,894 4,694

Blue Canyon 6,379 6,379 4,127 6,379 6,379 6,379 6,379 8,463

Boulder Creek 2,240 4,399 1,069 2,240 2,240 2,240 2,240 11,532

Bourne 3,939 4,546 321 3,939 3,939 3,939 3,939 15,995

Bridgeport 3,022 3,081 2,410 3,022 3,022 3,022 3,022 4,438

Buck Creek 11,709 12,321 0 11,709 11,709 11,709 11,709 19,544

Bullrun 12,370 12,370 10,372 12,370 12,370 12,370 12,370 30,116

Camp Creek 0 0 0 10,732 0 10,732 0 23,076

Carrol Creek 55 116 0 55 55 55 55 1,100

Catherine Creek 5,632 5,844 1,952 5,632 5,632 5,632 5,632 20,944

Chalk Creek 43 50 0 43 43 43 43 276

Chesnimnus 10,848 10,909 9 10,848 10,848 10,848 10,848 30,057

Chicken Hill 

(vacant)

0 0 0 0 0 8,773 0 15,573

China Creek 3,253 3,253 2,760 3,253 3,253 3,253 3,253 7,367

Clark Mountain 156 156 58 156 156 156 156 319

Cold Springs 247 247 0 247 247 247 247 555

Cougar Creek 8,498 8,609 0 8,498 8,498 8,498 8,498 18,331

Cree 121 121 99 121 121 121 121 188

Crow Creek 557 557 0 557 557 557 557 1,206

Dark-Ensign 14,241 14,241 2,467 14,241 14,241 14,241 14,241 25,825

Davis Creek 3,393 3,393 0 3,393 3,393 3,393 3,393 5,640

Day Ridge 346 468 98 346 346 346 346 2,626

Dean-Huck 10,292 10,292 7,334 10,292 10,292 10,292 10,292 15,955

Denney Creek 295 295 172 295 295 295 295 760
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

460

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Divide 7,939 8,602 0 7,939 7,939 7,939 7,939 14,745

Dobbins 140 140 0 140 140 140 140 282

Dodson-Haas 4 11 0 4 4 4 4 19

Doe Creek 6,036 6,162 0 6,036 6,036 6,036 6,036 14,940

Eagle Valley 15,489 15,717 10,333 15,489 15,489 15,489 15,489 32,589

East Pine Valley 15,319 15,485 3,029 15,319 15,319 15,319 15,319 33,085

Elk Mountain 206 206 0 206 206 206 206 207

Elmwood 121 121 90 121 121 121 121 162

Fine 581 581 0 581 581 581 581 1,513

Five Points 7,084 7,523 1 7,084 7,084 7,084 7,084 20,263

Frazier Mountain 1,629 1,629 550 1,629 1,629 1,629 1,629 2,617

Fruit Springs 190 190 106 190 190 190 190 253

Ghostbull 396 673 289 396 396 396 396 2,311

Gilkison 953 953 434 953 953 953 953 1,796

Goose Creek 15,262 15,274 9,854 15,262 15,262 15,262 15,262 27,323

Grouseline 217 514 0 217 217 217 217 2,742

Hale 249 249 197 249 249 249 249 458

Haney Gulch

(vacant)

0 0 0 207 0 213 0 893

Hawley Gulch 2,273 2,273 1,207 2,273 2,273 2,273 2,273 2,584

Hooker Flat 60 60 46 60 60 60 60 76

Hootin Rock 118 155 68 118 118 118 118 353

Hunting Camp 2,816 2,960 0 2,816 2,816 2,816 2,816 10,236

Indian Crane 

(vacant)

0 0 0 0 0 22,050 0 43,014

Indian Creek 2,650 0 124 2,650 2,650 2,650 2,650 7,496

Ironside 9,323 9,465 8,100 9,323 9,323 9,323 9,323 16,985

Joseph Creek 55 120 0 55 55 55 55 1,003
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

461

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Jordan Creek 

(vacant)

0 0 0 0 0 6,582 0 10,011

Limber Jim 

(vacant)

0 0 0 0 0 15,570 0 24,932

Little Bald 

Mountain

483 483 383 483 483 483 483 836

Lobo 9,374 9,374 30 9,374 9,374 9,374 9,374 15,655

Lockhart 4,921 4,989 3,943 4,921 4,921 4,921 4,921 10,108

Marr Flat 10,571 11,426 0 10,571 10,571 10,571 10,571 42,932

Middle Point 234 240 4 234 234 234 234 1,396

Mill Creek (vacant) 0 0 0 2,964 0 2,976 0 8,585

Mink 78 91 0 78 78 78 78 268

North Burnt River 9,186 9,186 6,982 9,186 9,186 9,186 9,186 18,906

North Fork Burnt 

River

37 37 37 37 37 37 37 46

North Powwatka 356 560 0 356 356 356 356 4,506

Pole Creek 3,669 3,790 0 3,669 3,669 3,669 3,669 11,213

Powell Gulch 246 246 189 246 246 246 246 365

Schleur 56 73 0 56 56 56 56 712

Sheep Ranch 22,600 22,600 0 22,600 22,600 22,600 22,600 32,335

Sheep Rock 0 0 0 0 0 4,761 0 19,646

Snow Creek 7,376 8,216 5,997 7,376 7,376 7,376 7,376 15,994

South Burnt River 12,818 11,249 12,818 12,818 12,818 12,818 32,566

South Powwatka 5,658 5,868 99 5,658 5,658 5,658 5,658 10,993

Sparks (vacant) 0 0 0 0 0 1 0 1,213

Special #2 42 84 0 42 42 42 42 108

Spring Creek 0 53 0 0 0 53 0 20,951

Starkey 14,338 14,361 0 14,338 14,338 14,338 14,338 30,381

Stovepipe 11,155 11,155 2,812 11,155 11,155 11,155 11,155 21,142
Final Environmental Impact Statement, Volume 4 

Appendix F: Suitable Acres within Range Allotments for Each Alternative

Land Management Plans for the Malheur, Umatilla, and Wallowa-Whitman National Forests

462

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Swamp Creek 10,644 13,143 0 10,644 10,644 10,644 10,644 33,458

Table Mountain 3,621 4,448 0 3,621 3,621 3,621 3,621 14,604

Tater Knob 

(vacant)

0 0 0 0 0 109 0 359

Teepee Elk 1,368 1,368 0 1,368 1,368 1,368 1,368 4,385

Tie Creek 96 0 0 96 96 96 96 311

Tin Trough 3,180 3,299 0 3,180 3,180 3,180 3,180 4,454

Tope Creek 2,203 2,317 0 2,203 2,203 2,203 2,203 7,372

Trouble Gulch 72 136 41 72 72 72 72 1,139

Upper Clover 

Creek

16 16 0 16 16 16 16 16

Vigne 705 705 0 705 705 705 705 1,285

Warm Springs 9 9 0 9 9 9 9 297

West Burnt River 7,107 7,107 5,681 7,107 7,107 7,107 7,107 13,315

West Minam 6,129 4,418 0 6,129 6,129 6,129 6,129 13,682

West Pine Valley 14,432 14,742 926 14,432 14,432 14,432 14,432 34,939

Whipple Gulch 3,163 3,162 2,598 3,163 3,163 3,163 3,163 5,028

Whitehorse 6,600 6,600 0 6,600 6,600 6,600 6,600 13,798

Whitney 220 220 169 220 220 220 220 478

Table F-6. Suitable acres for sheep grazing within active and vacant sheep allotments for each alternative on the Wallowa-Whitman National Forest

Allotment Alt. A Alt. B Alt. C Alt D Alt. E

Alt. E-Modified 

and E-Modified 

Departure Alt F

Total Acres 

Within the 

Allotment

Cunningham 18,147 18,147 3,576 18,147 18,147 18,147 18,147 25,203

McCarty 9,837 9,837 9,814 9,837 9,837 9,837 9,837 17,923

Mud Creek 3,710 0 0 3,437 3,437 3,437 3,437 8,090

Spring Creek 11,864 11,864 11,864 11,864 11,864 11,864 11,864 20,951
Appendix G: Maps

Malheur National Forest

The following maps are displayed in an 11-inch by 17-inch format. 

• Management Areas for Alternative A

• Management Areas for Alternative B

• Management Areas for Alternative C

• Management Areas for Alternative D

• Management Areas for Alternatives E and F

• Management Areas for Alternatives E-Modified and E-Modified Departure 
395

26

395

26

19

7

Fox

Izee

Dale

Unity

Ukiah

Galena

Austin

Seneca

Hardman

Monument Granite

John Day

Dayville

Long Creek

Canyon City

Prairie City

Mount Vernon

Lehman Springs

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternative A

Umatilla

National Forest

Wallowa-Whitman

National Forest

Umatilla

National Forest

20

78

205

Riley

Lawen Crane

Hines

Burns

Drewsey

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

2A Designated Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

National Forest Administrative Boundary

5 Developed Site & Administrative Area

4B Riparian Management Area

4C Old Forest

4D Big Game Winter/Summer Range

4E Wildlife/Fish Emphasis

4F Visuals

3B Backcountry (motorized use)

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.
395

26

395

20

26

19

7

78

205

Burns

Canyon

City

Dayville

Granite

Hines

John Day

Long

Creek

Monument

Mount

Vernon

Prairie

City

Seneca

Sumpter

Ukiah

Unity

Lehman

Springs

Hardman

Kimberly

Fox

Austin

Galena

Dale

Drewsey

Lawen

Crane

Riley

Izee

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternative B

Umatilla

National Forest

Wallowa-Whitman

National Forest

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)

2G Nationally Designated Trail
395

26

395

20

26

19

7

78

205

Burns

Canyon

City

Dayville

Granite

Hines

John Day

Long

Creek

Monument

Mount

Vernon

Prairie

City

Seneca

Sumpter

Ukiah

Unity

Lehman

Springs

Hardman

Kimberly

Fox

Austin

Galena

Dale

Drewsey

Lawen

Crane

Riley

Izee

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternative C

Umatilla

National Forest

Wallowa-Whitman

National Forest

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

3C Wildlife Corridor

4C Old Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
395

26

395

20

26

19

7

78

205

Burns

Canyon

City

Dayville

Granite

Hines

John Day

Long

Creek

Monument

Mount

Vernon

Prairie

City

Seneca

Sumpter

Ukiah

Unity

Lehman

Springs

Hardman

Kimberly

Fox

Austin

Galena

Dale

Drewsey

Lawen

Crane

Riley

Izee

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternative D

Umatilla

National Forest

Wallowa-Whitman

National Forest

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail 3B Backcountry (motorized use)
395

26

395

20

26

19

7

78

205

Burns

Canyon

City

Dayville

Granite

Hines

John Day

Long

Creek

Monument

Mount

Vernon

Prairie

City

Seneca

Sumpter

Ukiah

Unity

Lehman

Springs

Hardman

Kimberly

Fox

Austin

Galena

Dale

Drewsey

Lawen

Crane

Riley

Izee

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternatives E and F

Umatilla

National Forest

Wallowa-Whitman

National Forest

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

3B Backcountry (motorized use) This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
395

26

395

20

26

19

7

78

205

Burns

Canyon

City

Dayville

Granite

Hines

John Day

Long

Creek

Monument

Mount

Vernon

Prairie

City

Seneca

Sumpter

Ukiah

Unity

Lehman

Springs

Hardman

Kimberly

Fox

Austin

Galena

Dale

Drewsey

Lawen

Crane

Riley

Izee

Blue Mountains Forest Plan Revision FEIS (2018)

Malheur National Forest

Management Areas for Alternatives E-Modified and E-Modified Departure

Umatilla

National Forest

Wallowa-Whitman

National Forest

0 1.75 3.5 7 10.5 14

Miles

Malheur

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2C Botanical Area

2D Geologic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

3B Backcountry (motorized use) This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Malheur National Forest at 541-575-3000

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
Appendix G: Maps

Umatilla National Forest

The following maps are displayed in an 11-inch by 17-inch format. 

• Management Areas for Alternative A

• Management Areas for Alternative B

• Management Areas for Alternative C

• Management Areas for Alternative D

• Management Areas for Alternatives E and F

• Management Areas for Alternatives E-Modified and E-Modified Departure
395

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enterprise

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternative A

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

1A Designated Wilderness Area

Legend

2A Designated Wild & Scenic River

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use) 5 Developed Site & Administrative Area

National Forest Administrative Boundary

Wallowa-Whitman

National Forest

4B Riparian Management Area

4A General Forest

4C Old Forest

4D Big Game Winter/Summer Range

4E Wildlife/Fish Emphasis

4F Visuals

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)
395

84

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enter

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternative B

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

Legend

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

Wallowa-Whitman

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)

2G Nationally Designated Trail
395

84

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enter

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternative C

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

Legend

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

3C Wildlife Corridor

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

Wallowa-Whitman

National Forest

4C Old Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
395

84

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enter

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternative D

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

1A Designated Wilderness Area

Legend

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

Wallowa-Whitman

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)

2G Nationally Designated Trail
395

84

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enter

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternatives E and F

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

Legend

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

3C Wildlife Corridor

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

Wallowa-Whitman

National Forest

3B Backcountry (motorized use)

2G Nationally Designated Trail
395

84

395

12

26

207

7

74

11

244

204

19

82

Baker

City

Enter

Heppner

John Day

La Grande

Pendleton

Prairie

City

Pomeroy

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Umatilla National Forest

Management Areas for Alternatives E-Modified and E-Modified Departure

Malheur

National Forest

Wallowa-Whitman

National Forest

0 3 6 12 18 24

Miles

Umatilla

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Umatilla National Forest at 541-278-3716

The USDA is an equal opportunity provider and employer.

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

Legend

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2C Botanical Area

2D Geologic Area

2B Research Natural Area

2E Historic Area

2H Scenic Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

Wallowa-Whitman

National Forest

3B Backcountry (motorized use)

2G Nationally Designated Trail
Appendix G: Maps

Wallowa-Whitman National Forest

The following maps are displayed in an 11-inch by 17-inch format. 

• Management Areas for Alternative A

• Management Areas for Alternative B

• Management Areas for Alternative C

• Management Areas for Alternative D

• Management Areas for Alternatives E and F

• Management Areas for Alternatives E-Modified and E-Modified Departure
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternative A

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh

oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

2A Designated Wild & Scenic River

2B Research Natural Area

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

1C Wilderness Study Area

2I Starkey Experimental Forest and Range

4C Old Forest

4D Big Game Winter/Summer Range

4E Wildlife/Fish Emphasis

4F Visuals

Hells Canyon

National Recreation Area

Malheur

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternative B

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh

oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2J Municipal Watershed

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

1C Wilderness Study Area 2F Scenic Byway & All-American Road

2I Starkey Experimental Forest and Range

Hells Canyon

National Recreation Area

Malheur

National Forest

3B Backcountry (motorized use)

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternative C

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh

oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Eligible Wild & Scenic River

2B Research Natural Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

1C Wilderness Study Area 2F Scenic Byway & All-American Road

2I Starkey Experimental Forest and Range

3C Wildlife Corridor

Hells Canyon

National Recreation Area

4C Old Forest

Malheur

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternative D

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh

oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

2A Designated Wild & Scenic River

2A Suitable Wild & Scenic River

2B Research Natural Area

2J Municipal Watershed

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

1C Wilderness Study Area

2I Starkey Experimental Forest and Range

Hells Canyon

National Recreation Area

Malheur

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use)

2G Nationally Designated Trail
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternatives E and F

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh

oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Suitable Wild & Scenic River

2B Research Natural Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

1C Wilderness Study Area 2F Scenic Byway & All-American Road

2I Starkey Experimental Forest and Range

3C Wildlife Corridor

Hells Canyon

National Recreation Area

Malheur

National Forest

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

The USDA is an equal opportunity provider and employer.

3B Backcountry (motorized use) 2G Nationally Designated Trail
237

124

245

7

62

71

129

82

125

86

220

11

331

335

3

201

204

52

128

203

72

244

95

12

30

26

20/26

20

84

Baker

City

Enterprise

La Grande

Prairie

City

Walla

Walla

Malheur

National Forest

Umatilla

National Forest

0 2.5 5 10 15 20

Miles

Wallowa-Whitman

National Forest

 O r e g o n

 I d a h o

 W a s h i n g t o n

W a s h i n g t o n W a s h i n g t o n

O r e g o n O r e g o n

O r e g o n O r e g o n

I d a h o I d a h o

WW aa

ss

hh ii nn

gg tt oo

nn

II dd

aa

hh oo

Umatilla

National Forest

Legend

1A Designated Wilderness Area

1B

Preliminary Administratively Recommended

Wilderness Area

2A Designated Wild & Scenic River

2A Suitable Wild & Scenic River

2B Research Natural Area

2J Municipal Watershed

3A Backcountry (non-motorized use)

4A General Forest

5 Developed Site & Administrative Area

National Forest Administrative Boundary

2F Scenic Byway & All-American Road

1C Wilderness Study Area

2I Starkey Experimental Forest and Range

Hells Canyon

National Recreation Area

Malheur

National Forest

3B Backcountry (motorized use)

Blue Mountains Forest Plan Revision FEIS (2018)

Wallowa-Whitman National Forest

Management Areas for Alternatives E-Modified and E-Modified Departure

This product is produced from information prepared by the USDA, 

Forest Service, or from other suppliers. The Forest Service cannot 

assure the reliability or suitability of this information for a particular 

purpose. The data and product accuracy may vary due to

compilation from various sources, including modeling and 

interpretation, and may not meet National Map Accuracy Standards. 

This information may be updated, corrected, or otherwise modified

without notification. 

For more information please contact:

Wallowa-Whitman National Forest at 541-523-6391

2C Botanical Area The USDA is an equal opportunity provider and employer.

2G Nationally Designated Trail

Utility Corridor

Utility Corridor