u.s. forest service south fork management unit...

—Decision Notice —

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Final Decision Notice Westside Plantation Project

U.S. Forest Service

South Fork Management Unit

Shasta-Trinity National Forest

Trinity County, California

Decision Based upon my review of the Westside Plantation Project Final Environmental Assessment (Final EA)

(USDA 2014) dated September 2014, public comments, and the project record, it is my decision to

implement Alternative 2.

The selection of Alternative 2 authorizes thinning plantations on approximately 5,533 acres.

Approximately 3,294 acres would be thinned by mastication or by hand work (chainsaw felling, hand pile

and burn, and/or jackpot burn1), and approximately 2,239 acres would be commercially thinned. All

commercially thinned units would be whole-tree yarded2 to a landing. Additional fuels treatments may

occur within the commercially thinned units, including mastication, machine piling or hand work.

Connected actions include road maintenance and reconstruction, temporary road use and use and creation

of landings. Water drafting may occur as part of the road maintenance and reconstruction.

Alternative 2 is detailed in the Final EA starting on page 12 in the Alternatives, Including the Proposed

Action section. The Final EA was modified compared to the July 2014 EA in the following ways:

The land allocation discussion was moved from the Alternatives section to the Background

section and information on the Late Successional Reserve Assessment, Shasta-Trinity National

Forest Land and Resource Management Plan (Forest Plan) Management Areas, and the Aquatic

Conservation Strategy were added to the discussion;

The description of the watersheds the project occurs within was refined;

The number of new landings required to implement Alternative 2 was updated (from 80 to 35) in

the description of Alternative 2 in the Alternatives, Including the Proposed Action section;

The description of the hand treatments in Riparian Reserve Equipment Exclusion Zones was

clarified in the Resource Protection Measures section;

1 Hand burning of a large pocket of downed natural wood, brush, or activity fuels without first creating a pile. 2 The entire tree, including most branches, would be transported to the landing for processing. This method cuts down on the

amount of activity fuels left in units.


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The description of treatment of hazard trees was clarified in the Resource Protection Measures

section;

The description of treatments within active landslides was clarified in the Resource Protection

Measures section;

The Fuels analysis summary in the Environmental Consequences section was clarified to better

describe the differences in fuels treatment results between the two action alternatives;

The hydrology cumulative effects analysis description was clarified in the Hydrology analysis

summary in the Environmental Consequences section;

A description of the Public Comment period was added to the Public Involvement section; and,

Appendix A in the July 2014 EA (Response to Scoping Comments) was replaced with the 218

Comment Period Analysis/Response.

The Final Decision Notice was modified compared to the Draft Decision Notice in the following ways:

The date of the National Marine Fisheries Service Letter of Concurrence was added.

A statement of consistency with the northern spotted owl recovery plan was added to the National

Forest Management Act consistency section.

A description of the objection process was added.

An errata list for the September EA was added as an appendix (Appendix A).

Decision Rationale My decision to implement Alternative 2 is based on thorough review of all the alternatives and the

environmental consequences presented in the Final EA and project record.

The purpose and need of the project is to develop and maintain vigorous and healthy forest stands within

existing plantations that will be resilient to natural disturbances. Within the project area, there is a need to

improve forest health, habitat conditions and tree growth in the plantations, while providing some

economic benefit.

I based my decision to implement Alternative 2 on careful consideration of analyses in the Final EA,

public comments, and responsiveness of the alternatives to public comments while meeting the purpose

and need. I considered public issues and concerns from the scoping period and the alternatives developed

from those issues. I also considered public comments on the July 2014 EA.

Three alternatives were considered in detail. I selected Alternative 2 because it best meets the purpose and

need. Alternative 2 opens up the stands in all of the plantations thereby improving overall stand health

(Final EA pages 62-63, Silvicultural Report page 10) and future habitat conditions for northern spotted

owl (Final EA page 83, Wildlife Biological Assessment page 9, Letter of Concurrence page 4). The

reduction in fuel loading and continuity of fuels increases the resiliency of plantations to natural

disturbance (Final EA pages 48-50, Fuels report pages 13-16) and reduces the potential for high severity

fire behavior. Commercial treatments fulfill this aspect of the purpose and need to the greatest extent by

removing fuel from the stands (through whole-tree yarding); non-commercial treatments would leave all

fuels in the stands and would simply rearrange them through mastication or hand treatments with chain

saws to reduce fuel ladders (Final EA pages 49-50, Fuels Report pages 14-16). Some non-commercial

treatments may have follow-up fuel reduction treatments including piling and burning, and burning of


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concentrations of fuels (Final EA pages 16-19). Thinning plantations by hand (as proposed to a great

extent in Alternative 3) leaves many more logs on the ground in the stands due to the limitations of hand

treatments. The higher density of logs could create hotter burn conditions than stands with fewer logs

(Final EA page 175-176, Fuels Report page 16-17). Given that commercial treatments go the farthest in

terms of reducing fuel levels in the stands, Alternative 2 would meet this aspect of the purpose and need

to a greater extent than Alternative 3 because more plantations would be commercially thinned under

Alternative 2 (Final EA page 51-53, Fuels Report page 16-19). The greater amount of commercial

treatments in Alternative 2 also contributes more raw materials toward the existing forest products

infrastructure than Alternative 3. The differences in environmental impacts to water resource, soils,

botany and wildlife between the two action alternatives are so small as to be inconsequential; therefore,

no substantial environmental benefit would be gained by selecting Alternative 3. I have included all of the

project Resource Protection Measures that I believe are necessary to avoid or minimize impacts on the

resources potentially affected (Final EA pages 23-37).

The selected alternative supports the Forest Plan (USDA 1995) goals for the Hayfork, Indian

Valley/Rattlesnake, and South Fork Mountain Management Areas (Final EA page 4). It is compatible

with the Late-Successional Reserve, Riparian Reserve (including the Aquatic Conservation Strategy),

Adaptive Management Area and Matrix land allocation standards and guidelines in the Forest Plan, and is

consistent with the Shasta-Trinity National Forest, Forest Wide Late Successional Reserve Assessment

(USDA 1999; pages 162-163 and page 169; Final EA page 4).

Alternatives Considered The Final EA analyzed and reviewed two action alternatives, a no action alternative, and three

alternatives that were eliminated from detailed study. A more detailed discussion can be found in Chapter

2 of the Final EA (pages 12-23).

Alternative 1, the no action alternative, was not chosen because it would not meet the purpose and need to

develop and maintain vigorous and healthy forest stands within existing plantations that will be resilient

to natural disturbances. Forest conditions would continue to trend in the direction described in the

Purpose and Need and Affected Environment sections of the Final EA. Currently forest conditions in

treatment units are overly dense, leading to increased mortality due to competition, lack of water and

resources for all trees, and decreased ability of trees to survive droughts, insect and disease. With current

trends, mortality levels would increase, leading to heavier fuel loading in the plantation units.

Alternative 3 was developed in response to public scoping comment concerns that the proposed action

would have negative impacts on the watershed due to the use of temporary roads and the amount of

mechanical treatments proposed, especially mechanical treatments in Riparian Reserves. Alternative 3

would treat the same plantations as Alternative 2, but would not treat as many acres commercially (those

units that are in Riparian Reserve land allocation and those that would require temporary roads to treat)

and would not include any mastication. Alternative 3 was not chosen because, while it would meet the

purpose and need to some degree, it would not meet the purpose and need to the extent that Alternative 2

would. Alternative 3 would contribute less raw material to the existing forest products infrastructure, and

would be much more costly for the Forest Service to implement, which would result in a much slower

implementation timeline. Alternative 3 also would reduce fuels within many units to a lesser extent than

Alternative 2, due to the fewer commercial treatments (commercial treatments remove fuels while hand


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treatments only rearrange them). Additionally, the differences in negative impacts on the environment

between Alternative 2 and 3 are so small as to be insignificant; therefore, the benefits to the environment

were not large enough to outweigh the less effective treatments.

Three other alternatives were considered but not in detail. The Original Project Proposal considered

treatment of all plantations in the specific age range considered on the west side of the Forest. This

alternative was dropped from detailed consideration to be responsive to internal and external scoping

comments over concerns about the potential unknown impacts of a project of that scale (33,000 acres).

During scoping, an alternative was proposed by several individuals and groups to treat these plantations

by retaining a higher stand density. The alternative is referred to as the 60-85 Percent Canopy Cover

Alternative in the EA. This alternative was considered but eliminated from detailed study for several

reasons. The existing canopy cover for these stands for layers of all trees (with no treatment) averages 50

to75 percent. If canopy cover is measured based upon trees that exceed 40 feet in height the range drops

down to 10 to 65 percent. Northern spotted owl habitat requires canopy produced by trees that are 40 feet

in height or taller. These plantations are young, even-aged and overstocked, and provide no habitat for

late seral dependent wildlife species such as the northern spotted owl. The plantation stands that do have

high percentages of canopy cover (greater than 60 percent) are at higher risk for insect and disease

outbreaks (Negron 1998, Negron and Popp 2004, Oliver 1997, Chojnacky et al. 2000, Fettig et al. 2007).

As a result, the considered 60-85 percent Canopy Cover alternative would not provide the canopy cover

necessary to provide suitable habitat for dispersing NSO nor would it optimally free up the site resources

from density dependent competition to help accelerate stand development to suitable NSO habitat

conditions.

In addition, treatments in young plantations at the levels proposed in Alternatives 2 and 3 would meet the

management intent of the Forest Plan, which is to protect forest resources from loss to wildfire, pathogens

and insects (Limited Roaded Motorized Recreation prescription); maintain healthy and vigorous

ecosystems (Roaded Recreation and Wildlife Habitat Management prescriptions); accelerate development

of late-successional conditions while making the future stand less susceptible to natural disturbances, and

minimize the number of future entries (Late-Successional Reserve prescription); manage to control

competition (release and weeding), obtain stocking control (thinning), and minimize mortality (pest

management: Commercial Wood Projects prescription); and, control stocking, reestablish and manage

stand, and acquire desired vegetation characteristics needed to attain the Aquatic Conservation Strategy

objectives (Riparian Reserves prescription).

3 For these reasons, this alternative did not meet the purpose

and need for the project.

The third alternative that was considered but eliminated from detailed study was the Diameter Limit of 21

inches dbh Alternative. This alternative was developed based on several public comments that expressed

the need to limit the size of trees that may be removed by this project. Another commenter submitted that

a diameter limit would not be appropriate for the project. Due to the young age of these plantations and

the silvicultural prescriptions proposed, a 21 inch diameter limit does not result in a meaningful reduction

3 Forest Plan, pages 4-37, 4-46, 4-47, 4-64., 4-66, 4-67, 4-53, 4-54, 4-59.


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in the number or size of trees removed. Trees over 21 inches will be mostly retained as the tallest, best

growing codominant and dominant individuals in the stand. On particularly productive sites, plantations

may be almost entirely comprised of trees of this size or close to this size; if a dbh limit was imposed on

these units, it would prevent meaningful thinning of these stands leaving them susceptible to higher

mortality rates. In other productive sites, several trees in this size class may be spaced closely together. In

some cases, it may be appropriate to leave this denser area as a skipped area,4 but in some cases if these

dense patches are left, crowns of the leave trees will be severely competition-limited, impacting the

resilience of the trees (see the Silvicultural Prescription in the project record). In these situations, trees

over 21 inches will be removed to improve the health and growth of the leave trees. The total number of

trees over 21 inches removed in this project will be fairly low. The ability to thin trees of this size class is

central to the purpose and need of the project because this thinning would maintain and improve forest

health and resiliency. As such, an alternative that includes a 21 inch diameter limit does not meet the

purpose and need of the project.

The Westside Plantation Project Final EA documents the environmental analysis and conclusions upon

which this decision is based.

Public Involvement The Forest first listed the Westside Plantation Project in the July 2008 Schedule of Proposed Actions

(SOPA). Starting on September 23, 2008 the project preliminary purpose and need, original proposed

action, and maps of the original proposed action were posted to the Shasta-Trinity web page.

On September 23, 2008, 248 postcards were mailed to potentially interested participants. The postcards

requested public comment on the project and described how to receive additional information on the

project, and listed the web address where the original proposed action and maps could be found. Thirty-

five scoping letters and maps describing the proposed action were sent to interested and affected citizens,

agencies and tribes on September 24, 2008, or within the scoping period. A legal notice describing the

public scoping comment process for this project was published in the Record Searchlight on September

24, 2008. The notice requested public comments from September 24 to October 24, 2008. Public

comments received were reviewed by the project interdisciplinary team and evaluated for issues that

would create a need for changes to the proposed action and/or development of additional alternatives or

environmental analysis. Responses to the public comments are available in Appendix A of the draft EA.

The Forest received comment letters from 8 individuals and groups. In addition, the Forest received

comments from Maggie E. Robinson of California Regional Quality Control Board, dated December 15,

2008.

A legal notice for comment on the July 2014 EA was published in the Redding Record Searchlight on

August 6, 2014, with a 30-day comment period that ended on September 5, 2014. Letters were mailed to

13 individuals and groups that had expressed interest in the project or provided comments during the

4 Untreated area left to retain some complexity in the stand.


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public scoping period. The July 2014 EA and resource specialist reports were published on the Forest’s

website. A notice was also published in the Redding Record Searchlight on August 6, 2014. The public

comments from this comment period and project interdisciplinary team responses to them can be found in

the Final EA in Appendix A.

The major themes of the scoping comments and comments on the July 2014 EA are summarized below:

A diameter limit should be established to ensure the largest trees remain along with any legacy

trees. An alternative was developed in response to this issue, but was eliminated from detailed

study.

Hardwoods should not be cut to avoid resprout. Resource protection measures were developed in

response to this issue. Healthy, dominant and codominant hardwoods would be retained in all

units. In addition, intermediate hardwoods would be retained in Riparian Reserves.

Variable density thinning should be used to benefit the development of wildlife habitat. The

silvicultural prescription for all units is based on variable density thinning, with skips and gaps.5

Temporary road use could have negative impacts on the environment. Resource protection

measures have been developed for Alternative 2 to minimize impacts from temporary roads to the

extent possible. Additionally, Alternative 3 includes no temporary road use.

Treatments in Riparian Reserves could have negative impacts on riparian habitat and on

streams; only hand work should be allowed in Riparian Reserves. Alternative 3 was developed in

response to this issue. Only hand treatments with no commercial removal would be allowed in

Riparian Reserves under Alternative 3.

Large amounts of mechanical treatments could have negative environmental impacts. Alternative

3 was developed in response to this issue. No mastication would occur in non-commercial units

under Alternative 3.

The proposed tree spacing, and resulting canopy cover, is too sparse and will result in rapid re-

growth of brush, and hotter, dryer conditions in the plantations. An alternative was developed in

response to this issue, but was eliminated from detailed study.

Due to small tree size and distance to processing facilities, many of the units are not

economically viable. The Forest Service recognizes that economic viability is of concern when

treating young plantations. Economic viability was considered in the development of the project

when deciding which units would be commercially treated and which would be non-

commercially treated. Additionally, an economic analysis was completed and analysis is

summarized in the EA. The implementation of the project would be accomplished with a

combination of commercial and non-commercial contracts.

5 Skips are areas left untreated to provide denser areas. Gaps are openings created in the stand (no larger than ¼ acre). Skips and

gaps would be used to provide complexity within the stand structure.


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In order to provide stand health, diseased old or large legacy trees should be removed. The

proposed action was modified in response to this issue. Diseased legacy trees would be removed

in matrix land allocations; healthy legacy trees would still be retained. Diseased or dying large

legacy trees would be retained in Riparian Reserves and Late-Successional Reserves, unless they

pose a hazard to workers.

The size of the project makes site specific analysis difficult, if not impossible. The original

proposed action (33,000 acres) was eliminated from detailed study, and the new proposed action

was developed at a reduced scale (5,533 acres) in response to this issue.

The project is uneconomical as currently designed. The Forest Service understands that

appropriated Forest Service dollars must be used to implement the project. Where there is

commercial value, that value will offset the cost of implementation to the extent possible.

Impacts to northern spotted owls and other threatened, endangered and sensitive species were

inadequately addressed in the EA analysis. Concerns were expressed that the project activities

will negatively affect northern spotted owls and their habitat/designated Critical Habitat. A

Wildlife Biological Assessment (BA) was prepared for the project to evaluate the direct, indirect,

and cumulative effects of the project on northern spotted owl and their habitat and Critical

Habitat. Consultation was initiated with the U.S. Fish and Wildlife Service, Yreka field office on

August 13, 2014. The analysis in the BA determined that Alternative 2 may affect, but is not

likely to adversely affect, the northern spotted owl or its designated Critical Habitat. The U.S.

Fish and Wildlife Service concurred with this determination in its letter dated September 2, 2014.

No northern spotted owl suitable habitat will be affected by the project; however, because some

suitable habitat is within ¼ mile of the project units, some noise disturbance could occur. Limited

operating periods were incorporated into the project design as a Resource Protection Measure to

prevent noise disturbance during the breeding and nesting period.

Concerns were expressed that the project activities will negatively affect the federally threatened

Southern Oregon Northern California Coasts (SONCC) coho salmon (Oncorhynchus kisutch) and

its designated Critical Habitat (CH). A Fish Biological Assessment (BA) was prepared for the

project to evaluate the direct, indirect, and cumulative effects of the project. Consultation was

initiated with the National Marine Fisheries Service, Arcata field office on September 9, 2014.

The analysis in the BA determined that Alternative 2 may affect, but is not likely to adversely

affect, the SONCC coho salmon or its designated Critical Habitat. A Letter of Concurrence was

received from National Marine Fisheries Service on September 29, 2014.

Impacts to Forest Service Sensitive species were analyzed and disclosed in the EA. No Sensitive

species would be impacted by the project activities to the extent that would lead to a trend

towards listing under the Endangered Species Act. Resource Protection Measures have been

incorporated to protect Sensitive botanical, fish, and wildlife species, including Limited

Operating Periods for wildlife and fish, and flag and avoid for botanical species.

The Pacific Fisher is addressed in the Wildlife Biological Evaluation as a Sensitive species and

the proposed listing of the Pacific fisher under the Endangered Species Act is addressed in the

Wildlife Report Supplement. The determination that potential impacts of project actions on


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population demography of the Pacific fisher are limited and insignificant, eliminates the

possibility of jeopardy. Given this determination, the Forest Service is not compelled to

conference with the U.S. Fish and Wildlife Service concerning the Pacific fisher. If the U.S. Fish

and Wildlife Service list the Pacific fisher under the Endangered Species Act, we will evaluate

the need for consultation at that time.

This proposed decision was subject to objection pursuant to 36 CFR §218, Subparts A and B. Objections

were accepted from those who submitted project-specific written comments during scoping or another

designated comment period. The Forest received one objection from Conservation Congress. An

Objection Review Team was convened by the Forest Service Region 5 Regional Office during the week

of December 8, 2014. An objection resolution meeting was held by conference call with Conservation

Congress on December 16, 2014. The objection points were all related to impacts to northern spotted

owls, suitable habitat for the northern spotted owl, and Critical Habitat for the northern spotted owl. The

reviewing officer responded in writing to all pending objections on January 30, 2013, and all concerns

and instructions identified by the reviewing officer in the objection response have been addressed (36

CFR §218.12) in the Supplement to the Wildlife Report (available in the project record) and the errata

contained in Appendix A of this document. Implementation can begin immediately after this Decision

Notice is signed but is subject to all resource protection measures listed in the EA, including limited

operating periods.

Finding of No Significant Impact As the responsible official, I am responsible for evaluating the effects of the project relative to the

definition of significance established by the Council of Environmental Quality (CEQ) Regulations (40

CFR §1508.27). I have reviewed and considered the Final EA and documentation included in the project

record, and I have determined that Alternatives 2 and 3 would not have a significant effect on the quality

of the human environment. Alternative 2 is of limited scope and duration and would improve forest health

and fuels conditions within young plantations through a combination of thinning of plantations by

commercial harvest, mastication, and hand work. Alternative 3 would not pose significant short- or long-

term adverse effects as described in Environmental Consequences section (starting on page 41 of the

Final EA). Resource Protection Measures minimize or avoid adverse impacts to the extent that any

impacts are within accepted levels. As a result, no environmental impact statement will be prepared. My

rationale for this finding is as follows, organized by sub-section of the CEQ definition of significance

cited above.

Context For the Proposed Action and alternatives, the context of the environmental effects is based on the

environmental analysis in the Final EA.

The Westside Plantation project area is approximately 65,000 acres in size. However, about 8.5 percent of

the project area will reflect the physical footprint where proposed plantation thinning actions will occur.

More importantly, the actions will have a localized effect on reducing fuels and improving forest health.

The fuel reduction activities would reduce the intensity of fire that occurs in the treated areas. Resource


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protection measures minimize or avoid adverse impacts to the extent that any impacts are within generally

accepted levels.

Intensity Intensity is a measure of the severity, extent, or quantity of effects, and is based on information from the

effects analysis of this EA and the references in the project record. The effects of this project have been

appropriately and thoroughly considered with an analysis that is responsive to concerns and issues raised

by the public. The agency has taken a hard look at the environmental effects using relevant scientific

information and knowledge of site-specific conditions gained from field visits and a thorough review of

the intensity of the effects through the lens of the ten criteria identified in 40 CFR §1508.27(b).

My finding of no significant impact is based on both the context of the project and intensity of effects as

noted above.

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

Federal agency believes that on balance the effect will be beneficial.

Consideration of the intensity of environmental effects is not biased by beneficial effects of the

alternatives. For some resources both beneficial and adverse effects were identified. No adverse effects

were determined to be significant and none are expected to be long term. No adverse effects exceed the

thresholds set by the Forest Plan or other laws and regulations. Long term beneficial effects of the

Proposed Action include increased forest health and reduced fuels and associated fire behavior in the

plantations treated. Beneficial effects were not used to offset or compensate for potential adverse effects.

Some actions may have short term effects, including commercial tractor skidding, machine piling, pile

burning, mastication, temporary road use and landing use. These short term effects will be minimized by

implementing Resource Protection Measures, and are not considered significant, because thresholds of

concern and soil quality standards will not be exceeded. Long term effects will be beneficial by reducing

fire intensity. Road maintenance activities and temporary roadbed rehabilitation will reduce potential

negative road related effects (Final EA Geology section page 130, Hydrology section page 122).

The project may result in localized brief periods of increased erosion, turbidity, and sediment delivery

associated with the temporary road-stream crossings and reconstruction or maintenance of stream

crossings on National Forest Transportation System roads. These short-term effects are not considered to

be significant because they would be localized in extent and low in severity. Refer to hydrology analysis

in Final EA page 121-122.

Project actions also occur in areas with serpentine that could potentially contain naturally occurring

asbestos. These sites have the potential to produce asbestos bearing dust during tractor work in the units

and road maintenance; however these areas will be subject to Resource Protection Measures that will

minimize dust exposure to an insignificant level.

The potential adverse effects of plantation thinning actions on the northern spotted owl are restricted to

potential noise disturbance; however, Resource Protection Measures include a Limited Operating Period

(LOP) in the project design in any areas within 0.25 miles of suitable nesting habitat that would prevent

implementation noise from disturbing owls during the sensitive breeding and nesting period. No northern

spotted owl suitable habitat would be directly affected by project implementation (Final EA pages 82-85).


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The only potential project related effect to SONCC coho salmon habitat would be water drafting. National

Marine Fisheries Service water drafting standards and guidelines are included in the Resource Protection

Measures to prevent negative impacts to coho salmon. All plantation thinning activities would be

upstream of SONCC coho habitat.

2. The degree to which the proposed action affects public health or safety.

The action alternatives would not pose a significant risk to public health and safety. The action

alternatives incorporate public health and safety in the following:

The action alternatives include road maintenance and reconstruction activities that will result in increased

opportunities for safe public access (Final EA page 18).

The action also reduces fuels and associated fire effects within plantations in 2,855 acres of Wildland

Urban Interface (WUI) (Final EA pages 44).

The action includes Resource Protection Measures to protect Forest Service and contract workers from

exposure to naturally occurring asbestos fibers when working in areas with ultramafic soils (Final EA

page 34-35).

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

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

ecologically critical areas.

Project actions do not significantly affect the unique characteristics of the geographic area because the

project is designed to avoid these features.

Sensitive and endemic plants – Unique vegetative patterns are found within the project boundary and

are associated with serpentine soils. Many sensitive and endemic plants are associated with fens,

meadows, seeps and streambanks. The vegetative patterns are unique features within the context of the

analysis area and the action alternatives are designed to protect these features by flagging and avoiding

known locations (Final EA pages 25-26). Additional Resource Protection Measures are included for

implementation during project activities (Final EA 25-26).

Wild and Scenic River Corridor – Plantations within the Wild and Scenic River corridor in the project

area are not proposed for treatment in this project (Final EA page 3).

Historical and Cultural Resources – Historic and cultural resource locations will be flagged and

avoided during project implementation (Final EA Resource Protection Measures pages 35-36). The

proposed action will have no impact on historical or cultural resources (Final EA page 142-143).

Northern spotted owl Critical Habitat – No suitable northern spotted owl habitat within Critical Habitat

would be affected. The plantations proposed for treatment within Critical Habitat do not provide suitable

habitat for the northern spotted owl. The plantation thinning treatments would accelerate the development

of late successional stand characteristics, leading to development of suitable northern spotted owl habitat

more quickly than the no action alternative (Final EA pages 83).

No prime farmlands or parklands occur within the project area. Some small wetlands (springs or seeps)

are known to occur within project units. Known wetlands, and any additional wetlands found within units


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during project implementation, will be protected by BMPs and Resource Protection Measures including

Riparian Reserve buffer areas that would be flagged for avoidance.

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

highly controversial.

The effects of the Proposed Action on the quality of the human environment are not likely to be highly

controversial among professional experts. Similar plantation thinning actions have been undertaken in

many areas throughout the Shasta-Trinity National Forest. There is widespread agreement at a national

level that thinning of plantations can improve forest health and reduce fuel levels, reducing the likelihood

of high severity fire within the plantations (Final EA pages 45, 56, 59, 61-63). The Westside Plantation

project incorporates practices and technical procedures accepted by experts and common practices to

protect the human environment as well as natural resources (See Resource Protection Measures, Final EA

pages 23-37).

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

or involve unique or unknown risks.

Implementing the proposed action would not pose unique or unknown risks or result in highly uncertain

effects on the human environment. The proposed plantation thinning proposed by the Forest Service for

achieving the desired conditions for the area are not unusual or unique. The existing conditions have been

well documented, and the likely effects of implementation on the environment are well understood and

described in the Environmental Consequences section of the Final EA (starting on Final EA page 41). No

unique risks were identified and no unknown or undocumented risks are likely.

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

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

Implementation of the actions would not establish a precedent for future actions. The project does not

imply approval of other future projects. Future proposals will be evaluated for effects to the environment

prior to approval and implementation.

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

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

cumulatively significant impact on the environment. Significance cannot be avoided by

terming an action temporary or by breaking it down into smaller component parts.

According to the Council on Environmental Quality (NEPA) regulations “cumulative impact” is the

impact on the environment which results from the incremental impact of the action when added to other

past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-

Federal) or person undertakes such actions (40 CFR §1508.7).

The relevant boundaries (time and distance) and projects assessed for cumulative effects vary by resource

based upon the area over which that resource may be affected by this project. Each resource cumulative

effect area can be different and possibly larger or smaller. Relevant cumulative effects are discussed for

each resource in the individual resource reports and the Environmental Consequences section of the EA

(starting on Final EA page 41). The cumulative effects analysis for each environmental component or

resource area is guided by and consistent with the Council on Environmental Quality letter “Guidance on

the Consideration of Past Actions in Cumulative Effects Analysis” of June 24, 2005. A listing of relevant


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related past, present and future management activities in the assessment area is provided in Appendix D

of the Final EA. No cumulatively significant effects were identified for any resource.

The proposed action would either meet or not prevent the attainment of each Aquatic Conservation

Strategy objective at the project and watershed scale (Fish Biological Assessment Appendix D). The

cumulative watershed effects analysis showed the action alternatives will not significantly impact water

quality and aquatic/riparian habitats located at the local HUC 8 and larger HUC 5 scales. The project

would not exceed thresholds at the relevant HUC 5 analysis level (See Cumulative Effects, Final EA

pages 123-126).

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

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

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

Neither of the action alternatives analyzed in detail would cause the loss or destruction of significant

scientific, cultural, or historical resources. Clearance for Section 106 of the National Historic Preservation

Act has been accomplished under the Regional Programmatic Agreement (USDA 2013). The project area

has been surveyed in the past for cultural and historical resources and sites have been identified in and

adjacent to treatment areas. The proposed action has been designed to avoid or protect areas containing

resources or sites. (Refer to the Environmental Consequences section, Cultural Resources, Final EA pages

142-143).

Resource Protection Measures (Final EA pages 23-37) would be implemented to protect heritage

resources. Project activities would not be permitted within site boundaries.

Archaeological sites, or buried cultural materials not evident on the surface may be discovered during

project operations. If this occurs, all work must cease immediately and the appropriate unit archaeologist

consulted before project activities resume. No significant effects to heritage or cultural resources are

expected from project implementation.

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

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

Effects to Threatened and Endangered wildlife species are discussed starting on Final EA page 82. A

Biological Assessment (BA; Goldsmith 2014) for the project was prepared to evaluate any threatened or

endangered wildlife species that may be affected by this project. A Final BA was submitted and informal

consultation was initiated with the U.S. Fish and Wildlife Service, Yreka field office on August 13, 2014.

The wildlife BA addressed only the species and designated critical habitat known to occur and/or have

suitable habitat in the area: the northern spotted owl and its designated Critical Habitat. The analysis in

the BA of direct, indirect and cumulative effects of the Westside Plantation project on the northern

spotted owl, and its designated Critical Habitat, yielded a determination that Alternative 2 (the Proposed

Action) may affect, but is not likely to adversely affect, the northern spotted owl or designated Critical

Habitat for the northern spotted owl. The U.S. Fish and Wildlife Service provided a Letter of Concurrence

for this determination on September 2, 2014.

Effects to Threatened and Endangered fish species are discussed starting on Final EA page 124. A BA

(Brock 2014) for the project was prepared to evaluate any threatened or endangered fish species that may

be affected by this project. A Final BA was submitted and informal consultation was initiated with the


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National Marine Fisheries Service, Arcata field office on September 9, 2014. The fish BA addressed only

the species and designated Critical Habitat known to occur and/or have suitable habitat in the area: the

SONCC coho salmon (Oncorhynchus kisutch) and its designated Critical Habitat. The analysis in the BA

of direct, indirect and cumulative effects of the Westside Plantation project on the coho salmon, and its

designated Critical Habitat, yielded a determination that Alternative 2 (the Proposed Action) may affect,

but is not likely to adversely affect, the SONCC coho salmon or designated Critical Habitat for the

SONCC coho salmon. A Letter of Concurrence was received from the National Marine Fisheries Service

on September 29, 2014.

10. Whether the action threatens a violation of Federal, State, or local law or requirements

imposed for the protection of the environment.

The Proposed Action is consistent with all Federal, State and local laws or requirements imposed for

protection of the environment as discussed here and earlier in this document. The appropriate agencies

have been consulted for this project. Alternatives 2 and 3 are consistent with the Forest Plan, and were

specifically developed to comply with the following laws, regulations and executive orders:

National Forest Management Act (NFMA) - Forest Plans are developed in compliance with statutory

and regulatory direction including NFMA. Projects must be consistent with Forest Plans (36 CFR

§219.1).

The Westside Plantation Project Final EA and the project record document the interdisciplinary review

process. Consistency with the Forest Plan is documented in the following ways:

Desired conditions and objectives - Desired conditions and project objectives are described in the

Final EA Purpose and Need for Action section, starting on page 7.

Forest Plan standards and guidelines– Forest Plan standards and guidelines are adhered to through

project design and Resource Protection Measures. The project would not retard or prevent

attainment of any Aquatic Conservation Strategy objectives (Final EA page 4, Fish Specialist

Report Appendix D). The project is in compliance with the list of Survey and Manage species in

the 2001 Survey and Manage Record of Decision (see Survey and Manage Species discussion,

starting on Final EA page 98). The Forest Plan management indicator monitoring requirement has

been met and implementation of the Proposed Action is not likely to result in any meaningful

change to population trends and habitat availability for the assemblages involved (Management

Indicator Assemblages discussion, starting on Final EA page 93).

Watershed - Soil, slope, or other watershed conditions would not be irreversibly damaged.

Hydrologic function, water quality and fish habitat will not be adversely affected. The project will

not result in detrimental changes in water temperatures, or blockages of water courses. See

Resource Protection Measures starting on Final EA page 23, and the Soils, Hydrology, and Fish

sections of the Final EA starting on pages 91, 112, and 131. Protection is provided for streams,

streambanks, fish habitat, wetlands and other bodies of water from detrimental changes in water

temperatures and deposits of sediment. Riparian Reserves are protected by Resource Protection

Measures. Hydrologic function and water quality will not be adversely affected (see Final EA

starting on page 120).


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Late Successional Reserves – The Shasta-Trinity National Forest, Forest-Wide Late Successional

Reserve Assessment (LSRA) was prepared as directed in the Forest Plan (Forest Plan page 4-37)

to provide guidance for managing Late-Successional Reserves (LSRs). The project activities are

consistent with the LSRA (Final EA page 4; LSRA pages 162-163 and page 169).

Consistency with Threatened and Endangered Species Recovery Plans – The Forest Plan

Standards and Guidelines for threatened, endangered and sensitive wildlife species states

“Maintain and/or enhance habitat for TE&S species consistent with individual species recovery

plans” (Forest Plan page 4-30). The proposed activities are consistent with the NSO Revised

Recovery Plan (USDI Fish and Wildlife Service 2011) (Wildlife Report Supplement pages 2-3).

Clean Water Act - Pursuant to Section 208 of the Clean Water Act, all agencies responsible for carrying

out any portion of a State Water Quality Management Plan must be designated as a Water Quality

Management Agency. The State Water Resources Control Board designated the Forest Service as a Water

Quality Management Agency. The Forest Service employs Best Management Practices as the primary

tool for managing water quality on NFS lands. Applicable Best Management Practices were considered

and used to develop Resource Protection Measures to ensure that potential impacts to water quality would

be prevented or effectively mitigated. Refer to Resource Protection Measures starting on Final EA page

23.

Federal Clean Air Act, As Amended, State Clean Air Act and other Air Quality Regulations -

Naturally occurring asbestos is present in the assessment area. Resource Protection Measures were

developed to prevent and/or reduce dust production during implementation and provide for safe working

conditions (see Resource Protection Measures on Final EA pages 23-37, and the Soils Report (Rust

2014)).

The Forest Service voluntarily follows the guidelines assigned by the California Air Resource Board to

limit state-wide exposure on a cumulative basis, in compliance with the Clean Air Act. All pile burning

under Alternatives 2 and 3 will be consistent with the provisions of the North Coast Unified Air Quality

Management District rules and regulations through the permit process.

National Historic Preservation Act Section 106 (including the Region 5 Heritage Programmatic

Agreement) - Refer to Cultural Resources starting on Final EA page 140. The requirements of Section

106 of NHPA have been met; no consultation with the State Historic Preservation Office was required

because the project would have no effect on heritage resources. The Westside Plantation project would

have no adverse effect on unevaluated or National Register eligible historic properties, is in full

compliance with Section 106 of the NHPA, and meets the requirements of the Regional Programmatic

Agreement. There are no federally recognized tribes in the South Fork Management area requiring direct

consultation. However, in this area there are two non-federally-recognized Native American groups: the

Nor-Rel-Muk Wintu and the Tsnungwe. They were contacted as part of normal section 106 consultations

for this project as an interested party (see Final EA page 152).

Migratory Bird Treaty Act - The project is compliant with the Migratory Bird Treaty Act. Refer to

migratory birds, starting on Final EA page 99. Opportunities to promote conservation of migratory birds

and their habitats in the project area were considered during development and design of the Westside

Plantation project. Resource Protection Measures were included to minimize impacts on migratory birds.

mailto:[email protected]

http://www.fs.usda.gov/project/?project=25380


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Works Cited Boucher, K. and J. Gonzalez. 2014. Westside Plantation Project Fuels Report. USDA,Forest Service,

Shasta-Trinity National Forest. Available online at the project website:

http://www.fs.usda.gov/project/?project=25380.

Brock, W. 2014a. Westside Plantation Project Fish Biological Assessment / Biological Evaluation. USDA

Forest Service, Shasta-Trinity National Forest. Available online at the project website:


Brock, W. 2014b. Westside Plantation Project Fish Report. USDA Forest Service, Shasta-Trinity National

Forest. Available online at the project website: http://www.fs.usda.gov/project/?project=25380.

Chojnacky, D.C., B.J. Bentz, and J.A. Logan. 2000. Mountain pine beetle attack in ponderosa pine:

Comparing methods for rating susceptibility. USDA Forest Service, Rocky Mountain Research Station.

Research Paper RMRS-RP-26. Available at:

http://www.fs.fed.us/rm/publications/titles/rmrs_research_papers.html

Fettig, C.J., K.D. Klepzig, R.F. Billings, A.S. Munson, T.E. Nebeker, J.F. Negrón and J.T. Nowak. 2007.

The effectiveness of vegetation management practices for prevention and control of bark beetle outbreaks

in coniferous forests of the western and southern United States. Forest Ecology Management.

Goldsmith, M. 2014. Westside Plantation Project Wildlife PIF-Biological Assessment. USDA, Forest

Service, Shasta-Trinity National Forest. Available online at the project website:


Goldsmith, M. 2014. Westside Plantation Project Wildife Report. USDA, Forest Service, Shasta-Trinity

National Forest. Available online at the project website: http://www.fs.usda.gov/project/?project=25380.

Negron J.F., 1998. Probability of infestation and extent of mortality associated with the Douglas-fir beetle

in the Colorado Front Range. Forest Ecology and Management 107: 71–85.

Negrón and J.B. Popp 2004. Probability of ponderosa pine infestation by mountain pine beetle in the

Colorado Front Range, Forest Ecology and Management 19: 17–27.

Oliver, W. W. 1997. Twenty-five-year growth and mortality of planted ponderosa pine repeatedly thinned

to different stand densities in northern California. Western Journal of Applied Forestry 12.4: 122-130.

Paris, R. 2014. Westside Plantation Project Silviculture Report and Prescription. USDA, Forest Service,

Shasta-Trinity National Forest. Available online at the project website:


Rust, B. 2014. Westside Plantation Project Soils Report. USDA,Forest Service, Shasta-Trinity National

Forest. Available online at the project website: http://www.fs.usda.gov/project/?project=25380.

USDA. 2014. Final EA for the Westside Plantation Project. USDA Forest Service, Shasta-Trinity

National Forest, Hayfork Ranger District. Available online at the project website:


USDA. 2014. Letter initiating consultation with NMFS for the Westside Plantation Project. USDA Forest

Service, Shasta-Trinity National Forest. September 9, 2014.










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USDA. 2014. Letter Initiating Consultation with USFWS for the Westside Plantation Project. USDA

Forest Service, Shasta-Trinity National Forest. August 13, 2014.

USDI. 2014. Letter of Concurrence for the Determination that the Westside Plantation Project is Not

Likely To Adversely Affect the Northern Spotted Owl. U.S. Fish and Wildlife Service. September 2,

2014.

USDA. 2013. Processes for Compliance with Section 106 of the National Historic Preservation Act for

Management of Historic Properties by The National Forests of the Pacific Southwest. USDA Forest

Service, Pacific Southwest Region. Regional Programmatic Agreement.

USDA. 1999a. Forest-wide Late-Successional Reserve Assessment. Forest Service, Shasta-Trinity

National Forest. Redding, CA. Available online at:

http://www.fs.usda.gov/main/stnf/landmanagement/planning.

USDA. 1995. Shasta-Trinity National Forests Land and Resource Managment Plan. Forest Service,

Pacific Southwest Region, Shasta-Trinity National Forest. Available online at:

http://www.fs.usda.gov/detailfull/stnf/landmanagement/planning/?cid=stelprdb5108815&width=full.

http://www.fs.usda.gov/main/stnf/landmanagement/planning

http://www.fs.usda.gov/detailfull/stnf/landmanagement/planning/?cid=stelprdb5108815&width=full


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Appendix A – Errata list for the September 2014 Westside Plantation

Project Environmental Assessment

The following items were found to be in error in the Westside Plantation Environmental Assessment (EA)

and related specialist reports and are corrected here.

With respect to northern spotted owl dispersal habitat, page 75 of the EA states that “Some dispersal

habitat occurs within project units (approximately 553 acres)”. This statement is incorrect. The 553 acres

are acres of plantations that will provide dispersal habitat after treatment, but do not currently provide

habitat due to the dense condition of the stands and the many dead branches in the understory that would

currently restrict flight through the stand. The treatments would reduce density and remove many of the

dead branches in the understory, allowing northern spotted owls to utilize the stands as dispersal habitat.

With respect to proposed temporary road use under Alternative 2 related to northern spotted owl habitat,

page 83 of the EA states that “A total of four acres of temporary roads (not counting areas already inside

the thinning units) will be used. No suitable northern spotted owl habitat will be affected. Approximately

3.7 acres are within northern spotted owl home ranges, and 0.9 of these acres are within northern spotted

owl core areas.” The acreages listed in this statement were preliminary acreages that were subsequently

revised in the Wildlife Project Information Form/Biological Assessment. The corrected statement for the

EA is “A total of 12.9 acres of temporary roads (not counting areas already inside the thinning units) will

be used. No suitable NSO habitat will be affected. Approximately 10.7 acres are within NSO home

ranges, and 1.4 of these acres are within NSO core areas.”

With respect to Critical Habitat, the EA (page 75) and the Wildlife Report (page 3) cite the 2008 Critical

Habitat Rule (USDI 2008) instead of the 2012 Revised Critical Habitat rule. The correct citation is USDI

2012, which refers to the Designation of Revised Critical Habitat for the Northern Spotted Owl, Final

Rule. U.S. Department of the Interior, Fish and Wildlife Service. Washington, DC, Federal Register Vol.

77: 43 pp. All information related to Critical Habitat in that paragraph is correct.

A supplement to the Wildlife Report was produced and is available in the project record. It addresses

dispersal habitat, Critical Habitat, barred owls, the NSO Revised Recovery Plan, and the proposed listing

of the Pacific fisher in more detail than is included in the Wildlife Report. None of the determinations

were changed in this supplement.

u.s. forest service south fork management unit...

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