United States Department of Agriculture Forest Service Silver Creek Thin Environmental Assessment

Cowlitz Valley Ranger District, Gifford Pinchot National Forest, Lewis County, January 2017

Responsible Official: Gar Abbas, Cowlitz Valley District Ranger Gifford Pinchot National Forest

For More Information Contact: Elizabeth Robinson Cowlitz Valley Ranger District PO Box 670, 10024 US Highway 12 Randle, WA 98377 Phone: 360-497-1136 Email: [email protected] Fax: 360-497-1102

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i Silver Creek Thin Environmental Assessment January 2017

Contents Introduction ...... 1 Location ...... 1 Purpose and Need for the Proposal ...... 3 Management Direction, Goals, and Objectives ...... 4 Public Involvement ...... 7 Proposed Action and Alternatives...... 8 Proposed Action ...... 8 Commercial thinning to manage forest density ...... 8 Access for efficient management of vegetation ...... 9 Closure and Stabilization of Roads ...... 12 Other restoration activities within the project area ...... 13 Project Design Criteria and Mitigation Measures ...... 19 Alternative- No Action ...... 41 Alternatives Considered, but Eliminated from Detailed Study ...... 41 Alternative to Reconstruct FR 47 Crossing at East Fork Silver Creek ...... 41 Alternative to Harvest Timber without Restoration Projects ...... 41 Alternative to Daylight Roads...... 41 Alternative to Conduct Proposed Action without any Construction or Reconstruction of Non-system (temporary) Roads ...... 42 Environmental Impacts of the Proposed Action and Alternative ...... 43 General Comments Regarding Cumulative Effects ...... 43 Setting ...... 44 Physical ...... 44 Disturbance Regimes ...... 46 Landscape Pattern ...... 46 Plant Communities ...... 47 Soil Resources ...... 48 Existing Condition ...... 48 Effects ...... 58 Vegetation ...... 66 Existing Condition ...... 66 Desired Future Condition ...... 69 Vegetation Proposal Objectives ...... 69 Effects ...... 72 Fire Ecology ...... 81 Existing Condition ...... 81 Desired Future Condition ...... 83 Effects ...... 83 Botanical Resources ...... 84 Analysis Methods ...... 84 Existing Condition ...... 85 Effects ...... 89 Noxious Weeds and Invasive Plants ...... 91 Existing Condition ...... 91 Effects ...... 92 Wildlife ...... 97 Analysis Issues and Indicators ...... 97 Threatened, Endangered, and Proposed Species ...... 98

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Silver Creek Thin Environmental Assessment December 2016

Sensitive Species ...... 121 Sensitive and Survey and Manage Species ...... 125 Management Indicator Species ...... 131 Neotropical Migratory Birds ...... 142 Hydrology and Water Quality ...... 148 Resource Indicators and Measures ...... 148 Methods...... 148 Existing Condition ...... 151 Effects ...... 154 Fisheries ...... 166 Resource Indicators and Measures ...... 166 Methods...... 167 Existing Condition ...... 167 Effects ...... 172 Heritage Resources ...... 189 Existing Condition ...... 189 Effects ...... 189 Recreation and Visual Quality ...... 190 Existing Condition ...... 190 Desired Condition ...... 194 Effects ...... 195 Economics ...... 201 Existing Condition ...... 201 Effects ...... 205 Climate Change ...... 206 Existing Condition ...... 206 Effects ...... 208 Other Environmental Consequences and Required Disclosures ...... 209 Conflicts with other Plans, Policies, or Other Jurisdictions ...... 209 Environmental Justice ...... 209 Treaty Resources and Reserved Indian Rights ...... 209 Wetlands and Floodplains ...... 209 Unique Characteristics of the Area ...... 209 Air Quality and Sensitive Airsheds ...... 209 Potential or Unusual Expenditures of Energy ...... 210 Irreversible and Irretrievable Commitments of Resources ...... 210 Agencies, Tribes, and other Entities Consulted ...... 211 Indian Tribes ...... 211 Washington State Historic Preservation Office ...... 211 US Fish and Wildlife Service ...... 211 National Marine Fisheries Service...... 211 References ...... 213 Appendix A: Issues Raised During Scoping ...... 222 Appendix B: Interdisciplinary Team Members...... 233 Appendix C: Transportation System Report ...... 234 Introduction ...... 234 Existing Condition ...... 234 Transportation System ...... 234 Road Reconstruction and Maintenance ...... 236 Appendix D: East Fork Silver Crossing Economic Analysis...... 246 Appendix E: Landscape Analysis ...... 248

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Summary of Landscape Year of Origin ...... 249 Summary of Seral Stage Analysis and Deviation from Historic Reference ...... 250 Appendix F: Response to Comments Received on the Preliminary EA ...... 256 Appendix G...... 294

Tables Table 1: Silver Creek Thin Proposed Vegetation Management ...... 8 Table 2: Temporary and non-system roads associated with Silver Creek Thin ...... 11 Table 3: Silver Creek Thin Project Proposed Road Closure and Stabilization ...... 12 Table 4: Actions Considered in Cumulative Effects Analysis ...... 43 Table 5: Silver Creek Thin treatment unit physical setting...... 45 Table 6. Plant Associations of the Silver Creek Project (Topik et al. 1986 and Brockway et al. 1983) ..... 47 Table 7: Summary of soil characteristics in Silver Creek Thin project area (Wade, et al. 1992) ...... 48 Table 8: Extent of detrimental soil conditions (as approximate percent of units) ...... 51 Table 9: Unstable Soils Buffers, Design Features, and Mitigation Measures ...... 55 Table 10. Summary of Soil Productivity Loss by Alternative ...... 60 Table 11. Summary of New Detrimental Soil Conditions in Silver Creek Thin ...... 61 Table 12. Silver Creek Thin Stand Attributes Generated from FVS ...... 67 Table 13. Available Harvest Volume by Unit ...... 71 Table 14. Average Projected Change in Treatment Unit Attributes with No Action ...... 73 Table 15. Unit Attributes after Proposed Action Compared with No Action ...... 76 Table 16. Total Stand Volumes Present and at Culmination of Mean Annual Increment (CMAI) ...... 77 Table 17. Change in Project Area Structural Stage as Affected by Proposed Action ...... 79 Table 18. Comparison of Alternatives by Purpose and Need Category...... 80 Table 19. Federally Endangered (E), Threatened (T), and RFSSSL (S/Str), and other Rare and Uncommon (RU) Botanical Species Documented or Suspected to Occur on the Gifford Pinchot National Forest, with an Estimate of Likelihood of Occurrence within the Silver Creek Thin Timber Sale Planning Area. RFSSSL Iteration December 2011 ...... 86 Table 20. Sensitive and other Rare and Uncommon Botanical Species Occurrences within Silver Creek Thin Proposed Timber Sale Units ...... 88 Table 21. Noxious and significant invasive plant taxa expected within the Silver Creek Thin project area ...... 92 Table 22. Summary of Effects of Silver Creek Thin Proposed Action on Invasive Species ...... 92 Table 23. Potential Effects of Silver Creek Thin Restoration Projects on Weeds ...... 94 Table 24. Risk for Spread of Noxious Weeds in Silver Creek Thin ...... 96 Table 25. Summary of Status and Effects to Threatened, Endangered, Candidate, Sensitive and Survey and Manage, and Management Indicator Species in the Silver Creek Thin Project Area ...... 98 Table 26. Approximate Acres NRF Habitat within NSO Historic Activity sites and in Silver Creek Thin ...... 101 Table 27. Summary of NSO Critical Habitat (CH) subunits and baseline habitat conditions in Silver Creek area ...... 108 Table 28. Pre-treatment and post-treatment habitat acres in CH in Silver Creek Thin ...... 109 Table 29. Estimated meters of old growth (OG) edge adjacent to Silver Creek Thin Units ...... 114 Table 30. Survey and Manage Mollusks on the Cowlitz Valley Ranger District ...... 129 Table 31. Summary of Hydrology and Water Quality Indicators and Measures for Analysis ...... 148 Table 32. Summary of Hydrologic Indicators and Existing Condition ...... 151 Table 33. Silver Creek Thin Project Effects to Hydrologic Indicators ...... 155 Table 34. ARP Values in Silver Creek Subwatershed by Catchment ID ...... 158

iv Silver Creek Thin Environmental Assessment December 2016

Table 35. No-harvest buffer acres (total 1299 acres) in all Riparian Reserves in Silver Creek Thin Project ...... 160 Table 36. Thinned Acres in Outer Riparian Reserves under Silver Creek Thin Proposed Action ...... 160 Table 37. Activities considered in cumulative effects analysis for hydrologic resources and effects ...... 162 Table 38. Fish affected resource summary and evaluation criteria and measures for Silver Creek Thin. 167 Table 39. TES Fish Species Presence within the Silver Creek Project Area ...... 168 Table 40. Typical freshwater life history of native salmonids fish found in the Silver Creek Thin analysis area...... 168 Table 41. Riparian seral stages in the Silver Creek planning area ...... 169 Table 42. Channel stability risk index for channels inventoried in the Silver Creek Thin project area (modified from Pfankuch 1975) ...... 170 Table 43. Species listing status according to Federal Endangered Species Act status and Washington State listing status as per Priority Habitat and Species List (PHS) (WDFW 2012)...... 171 Table 44. Proposed harvest units in proximity (< .75 mi) to Listed Fish Habitat (LFH) in Silver Creek Thin project area ...... 176 Table 45. Silver Creek Thin Restoration Projects Effect to Fish and Fish Habitat ...... 178 Table 46. Past, Present, and Reasonably Foreseeable Future Activities and Cumulative Effects of Silver Creek Thin for Middle Cowlitz Watershed Analysis Area ...... 180 Table 47. Summary of Cumulative Effects for Silver Creek Thin...... 183 Table 48. Project Effects Determination Key, Silver Creek Thin...... 184 Table 49. Summary of effects determination for ESA listed species in the Silver Creek Thin analysis area...... 185 Table 50. ACS Consistency Summary for Silver Creek Thin...... 188 Table 51. Projected Increase in People Participating in Different Recreation Activities from 2013 and 2023...... 192 Table 52. Percent People Participating in Various Recreational Activities in Washington in 2013 ...... 193 Table 53. Crosswalk from Forest Plan Visual Management System to Scenery Management System ... 197 Table 54. Silver Creek Timber Sale Revenue and Costs ...... 205 Table 55. Summary of Existing Roads and Management Level Status in Silver Creek Thin Project Area ...... 235 Table 56. Pre- and Post-harvest Road Reconstruction and Maintenance Summary for Silver Creek Thin ...... 238

Figures Figure 1. Silver Creek Thin Vicinity Map ...... 2 Figure 2. Silver Creek Thin Planning Area Land and Management Allocations ...... 6 Figure 3. Silver Creek Planning Area Map #1 ...... 14 Figure 4. Silver Creek Planning Area Map #2 ...... 15 Figure 5. Silver Creek Planning Area Map #3 ...... 16 Figure 6. Silver Creek Planning Area Map #4 ...... 17 Figure 7. Silver Creek Planning Area Map #5 ...... 18 Figure 8. Aerial view of Silver Creek Thin Unit 30, June 2006 (top) and June 2009 (bottom) ...... 53 Figure 9. Slope stability - Landslides and Potential Landslide Zones (in Riparian No-Cut Buffer) in Silver Creek Thin Project ...... 65 Figure 10. Projected Relative Density for No Action and Proposed Action Alternative for All Commercial Treatments in Matrix Lands ...... 74 Figure 11. Projected Average Diameter for No Action and Proposed Action for All Commercial Treatments in LSR Stands...... 75 Figure 12. Upper Silver Creek showing highly fragmented late-successional forest ...... 97

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Figure 13. Silver Creek Thin Marbled Murrelet Habitat ...... 113 Figure 14. Distribution of Small Snags in WLCH Forest in Silver Creek Project Area ...... 135 Figure 15. Wildlife tolerance levels for snags >=19.7” dbh percentage of westside lowland conifer- hardwood forest in the Silver Creek Thin project area that provides habitat for species based on GNN 2006 data...... 136 Figure 16. Wildlife tolerance levels for snags >= 9.8” dbh percentage of westside lowland conifer- hardwood forest in the Silver Creek Thin project area that provide habitat for species based on GNN 2006 data...... 136 Figure 17. Silver Creek Seral Stages; A=early seral, B=mid-seral closed, C=mid-seral open, D= late seral open, E=late seral closed...... 139 Figure 18. Westside Elk Habitat Model for Silver Creek Thin Project Area...... 140 Figure 19. North American Bird Conservation Regions ...... 144 Figure 20. Catchments within the Silver Creek subwatershed. Labels correspond to labels on ARP map in Middle Cowlitz Watershed Analysis (1997)...... 153 Figure 21. Qualitative comparison of the rate of recovery for watersheds with and without watershed restoration. FEMAT 1993 ...... 174 Figure 22: Percent of total land area in Federal ownership in Silver Creek Thin vicinity ...... 201 Figure 23. Commodity Sectors as Percent of Total Employment in Silver Creek Thin vicinity ...... 202 Figure 24. Industries including travel and tourism in Silver Creek Thin vicinity ...... 203 Figure 25. Non-labor income as percent of total personal income in Silver Creek Thin vicinity ...... 203 Figure 26. Services as percent of private employment in Silver Creek Thin vicinity ...... 204 Figure 27. Government employment as percent of total in Silver Creek Thin vicinity ...... 204 Figure 28. Year of origin (age class) for stands in the Silver Creek planning area. All stands proposed for harvest are shown as less than 80 years old except stands 9038 (dropped from proposed action) and 9053...... 248 Figure 29. Seral stages in the Silver Creek planning area. A= early seral; B=mid seral closed; c= mid seral open; D= late seral open; E= late seral closed...... 251 Figure 30. Relative amounts of seral stages present in the Silver Creek planning area ...... 252

vi Silver Creek Thin Environmental Assessment January 2017

Introduction The Silver Creek Thin project is located within the Silver Creek subwatershed of the Middle Cowlitz River watershed on the Cowlitz Valley Ranger District of the Gifford Pinchot National Forest (Figure 1). The project area includes approximately 3,302 gross acres of proposed timber thinning, road maintenance and reconstruction to support efficient haul of timber, 10.2 miles of road closure and stabilization, and a suite of other restoration projects located in the same area. Thinning of overstocked timber plantations, road, and other restoration treatments proposed to enhance or restore ecological condition, function, and processes, while providing economic benefit to the community.

This environmental assessment (EA) was prepared to determine whether implementation of commercial thinning, road closure and stabilization, and other restoration projects might significantly affect the quality of the human environment and thereby require the preparation of an environmental impact statement. By preparing this EA, we are fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA). Location The Silver Creek Thin project is located in the Silver Creek subwatershed of the Middle Cowlitz River watershed in Township 14N Range 7E, Sections 29, 31, 32, and 34; Township 13N Range 7E, Sections 2, 10, 12-15, 22, 23, 26-28, 33, and 34; Township 12N Range 7E Sections 3, and 4; Township13N Range 8E, Sections 4, 9, and 16, Willamette Meridian, Lewis County, Washington (Fig. 1). Elevations range from 1,900 feet half a mile north of Kehoe Mountain to 4,500 feet a mile west of Cougar Gap.

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Cowlitz Valley Ranger District

Figure 1. Silver Creek Thin Vicinity Map

2 Silver Creek Thin Environmental Assessment January 2017

Purpose and Need for the Proposal The purpose of the proposed action is to manipulate the existing vegetation, riparian communities and transportation network to more closely resemble desired future conditions of the Management Area Categories of the Land and Resource Management Plan (LRMP) as amended by the Northwest Forest Plan (NWFP) to the extent where there is a need to:

• Produce commercial yields of wood and optimization of timber in Matrix lands (NWFP ROD, p.B-5). Commercial thinning of vigorous, well-stocked young stands should receive the highest priority of intermediate cutting (LRMP, p. IV-87). • Actively manage and restore Riparian Reserves in the Lynx Creek and Silver Creek drainages to promote large tree structure and riparian vegetation development using commercial and non- commercial variable density thinning techniques (Middle Cowlitz Watershed Analysis, pp. 6-2 to 6-4). This will help control stocking and acquire vegetation characteristics needed to attain Aquatic Conservation Strategy objectives (NWFP ROD, pp. B-11, C-31 and C-32). • Close and stabilize roads, and restore stream channels and crossings in the Silver Creek subwatershed (Middle Cowlitz Watershed Analysis, pp. 6-4, 6-12, 6-15 to 6-17). This will enable riparian connectivity, wildlife habitat security and support floodplain function and integrity. • Use commercial thinning and create snags and down wood in Late Successional Reserves to accelerate development of old-growth forest characteristics including snags, down logs, large trees, multiple tree layers and species diversity to maintain a functional and interacting late successional and old-growth forest ecosystem (NWFP ROD, pp.C-11 and C-12). • Stand improvement cutting in young plantations to reduce tree competition and increase vigor and species diversity. • Create a sustainable supply of timber and other forest products that will help maintain the stability of local and regional economies (NWFP FEIS, p.S-4). The need for action came about from an assessment of the following circumstances: • Older, managed plantations in Matrix lands in the planning area are overstocked and are beginning to, or will soon, decline in growth and overall health and vigor. • Similar stands in Late Successional Reserves have limited diversity and late successional forest characteristics such as multi-layered canopies of varying tree sizes, species diversity and well- distributed coarse woody debris. • Lack of early seral wildlife habitat, particularly deer and elk forage, in the planning area. • Riparian Reserves, due to intense past timber harvest, also lack these same late successional characteristics. • None of the stream reaches in the planning area has adequate Large Woody Debris (LWD) resulting in poor habitat complexity, sediment storage and bank protection (Middle Cowlitz Watershed Analysis, p. 4-9). • High amounts of Riparian Reserves in the Lake Creek, Lynx Creek and Willie Creek drainages are in dense pole and small tree structural stages with slow tree growth and little existing potential for LWD recruitment (Middle Cowlitz Watershed Analysis, p. 4-9). • The planning area has high riparian fragmentation from existing roads that may be contributing sediment and increased flow to streams (Middle Cowlitz Watershed Analysis, pp. 4-7 to 4-9). • Local communities are dependent upon a continual supply of wood products.

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Management Direction, Goals, and Objectives This EA is tiered to the Gifford Pinchot National Forest Land and Resource Management Plan Final Environmental Impact Statement and Record of Decision (1990) and incorporates by reference the accompanying Forest Plan. The Forest Plan guides all natural resource management activities and establishes management standards and guidelines for the Forest. It describes resource management practices, levels of resource production, and availability and suitability of lands for resource management. Goals, objectives, and desired future conditions of the management areas within the project area are discussed in the description of land allocations below. In addition, management direction for the area is provided in three major Forest Plan amendments:

• Northwest Forest Plan - Record of Decision for Amendments to Forest Service and Bureau of Land Management Planning Documents Within the Range of the Northern Spotted Owl (USDA and USDI 1994);

• Survey and Manage - Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines (2001); and,

• Invasive Species - Invasive Plant Program Preventing and Managing Invasive Plants Record of Decision (2005) and Record of Decision and Final Environmental Impact Statement and Forest Plan Amendment #20, Gifford Pinchot National Forest and Columbia River Gorge National Scenic Area (Washington portion): Site-specific Invasive Plant Treatment Project and Forest Plan Amendment (2008).

Treatment units affected by the Silver Creek Thin project lie within Late Successional Reserve (LSR), Matrix, and Riparian Reserves land allocations as defined in the Northwest Forest Plan. According to the NWFP, Matrix objectives for silviculture should include: (1) production of commercial yields of wood, including those species such as Pacific yew and western redcedar that require extended rotations, (2) retention of moderate levels of ecologically valuable old-growth components such as snags, logs and relatively large green trees and (3) increasing ecological diversity by providing early-successional habitat (USDA 1994).

Late Successional Reserve direction is to protect and enhance conditions of late successional and old growth forest ecosystems, which serve as habitat for old-growth related species including the northern spotted owl (Forest Plan Management Area Category LS). The LSR is designed to maintain a functional and interacting late successional and old-growth forest ecosystem. Objectives are to accelerate development of late successional conditions in relatively young (39-67 year old) plantation stands while making future stands less susceptible to natural disturbances (USDA 1994).

The Forest Plan Management Area Categories for Matrix are Timber Production (TS), and Deer and Elk Winter Range (EM, ES) (USDA 1990). The goal of the Timber Production allocation is to optimize timber production, the utilization of wood fiber and other commodities in a manner that assures the future productivity of the land. Satisfactory tree growth should be maintained and stands should be protected from insects, disease and damage (USDA 1990). The goal of Deer and Elk Winter Range is to provide a mix of forage and cover that, over time maintains the carrying capacity for deer and elk.

Riparian Reserves as defined by the NWFP are portions of watersheds where riparian-dependent resources receive primary emphasis. Standards and guidelines prohibit and regulate activities in Riparian Reserves that retard or prevent attainment of the Aquatic Conservation Strategy objectives. The Aquatic Conservation Strategy objectives are to maintain and restore ecosystem health at watershed and landscape

4 Silver Creek Thin Environmental Assessment December 2016 scales to protect habitat for fish and other riparian-dependent species and resources and to restore currently degraded habitats (USDA 1994). The Riparian Reserves allocation overlays and supersedes all management direction for Late Successional Reserve and Matrix lands.

The Gifford Pinchot National Forest Forestwide late successional Reserve Assessment describes the conditions and functions of each LSR and explains the ecological framework within which projects will be designed to ensure they will meet LSR standards and guidelines and further LSR objectives. This assessment reports the following findings for the Nisqually LSR, which encompasses the LSR land allocation within the Silver Creek subwatershed:

• Due to the higher elevation of the Nisqually LSR, progress toward late successional conditions will be at a slower rate than others on the Forest. • The Nisqually LSR contains very little large tree, large patch habitat. The LSR has a relatively large expanse of younger habitat in the small-tree structural stage located in the interior. • Connectivity between LSRs in the north part of the Forest is weak. An east-west linkage between the Nisqually and Packwood LSRs through the Tatoosh Wilderness is unlikely to be used by less mobile species because of the barrier formed by the Tatoosh Range. • Major forest roads in the Nisqually LSR as well as state highways create barriers to movement not only within the LSR but between other LSRs and Mount Rainier National Park. • There have been no large, stand-replacement fires in the Nisqually LSR for over 200 years. This circumstance, coupled with adjacency to wilderness areas poses a greater risk of wildfire.

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Figure 2. Silver Creek Thin Planning Area Land and Management Allocations

6 Silver Creek Thin Environmental Assessment December 2016

Public Involvement Informal public involvement for the Silver Creek Thin project began with a field trip to the project area in August of 2013. The field trip was hosted by the Pinchot Partners collaborative group and facilitated by Forest Service staff, and was open to the public. The interdisciplinary team led the field trip to several sites identified for potential thinning and restoration treatments and welcomed open discussion with the partners and public of different ideas and concerns.

Another field trip was held in August of 2014 as field surveys were underway, advertised through local news outlets, via the Pinchot Partners contact list, and through the Gifford Pinchot National Forest public affairs office via Facebook and through a press release to area news outlets.

The Forest Service and the Pinchot Partners co-hosted a public meeting at Randle Fire Hall in November of 2014, providing information and maps about the preliminary proposal. Concerns of the public were captured and considered in further refining the project description. The initial proposed action was provided for public scoping through a legal notice on December 11, 2014 and listed in the Gifford Pinchot National Forest Schedule of Proposed Actions (SOPA). The Forest Service received seven responses following public notification of the proposed action, reflecting a diversity of views and interests about the project. Topics and issues raised during the scoping period are summarized, along with interdisciplinary discussion for each topic in Appendix A.

The Silver Creek Thin Preliminary EA was released for a 30-day public comment period commencing on December 1, 2015 through publication of a legal notice in the newspaper of record (The Chronicle, Centralia, WA). Comments received and the responses of the interdisciplinary team are found in Appendix F. Minor changes were made to the Preliminary EA to clarify and correct items raised during the comment period, resulting in this EA. Individuals and entities who submitted specific written comments at this stage are eligible to object according to 36 CFR 218. This rule provides an opportunity for the public to comment and express concerns on projects before a decision is made, rather than having to appeal a signed decision. The Forest Service believes this aligns with our collaborative approach to forest management and increases the likelihood of resolving those concerns, resulting in better, more informed decisions.

This EA, which was updated, based on comments received, and a draft Decision Notice with Finding of No Significant Impact will be released for a 45-day review and objection period through a legal notice in The Chronicle. Issues raised in objection must be based on previously submitted written comments specific to the proposed project or activity unless the objection concerns an issue that arose after the opportunities to comment. For more information on 36 CFR Part 218, see the Federal Register, Volume 78, No. 59, March 27, 2013.

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Proposed Action and Alternatives Proposed Action In order to manipulate the existing vegetation, riparian communities and transportation network to more closely resemble desired future conditions as described in the Purpose of and Need for Action, the Forest Service proposes the following actions in the project area (depicted in Figures 3 – 8):

Commercial thinning to manage forest density • Approximately 3,302 gross acres of thinning in 38 units utilizing ground-based, skyline, and helicopter logging systems (Table 1). These units are young, dense stands (managed plantations) regenerated through timber harvest between 1955 and 1975, broadcast burned, and subsequently planted. No Harvest “Skip” acres are areas excluded from commercial logging, specifically streamside areas, wetlands, unstable and potentially unstable slopes, and debris flows.

• Approximately 146 acres of early seral successional stage creation utilizing light forest retention techniques for wildlife winter forage. These units are young, dense stands (managed plantations) with the exception of one stand that naturally regenerated in 1930.

• Hazardous fuels treatment where units are adjacent to major roads.

Modifications to this alternative were made during the Objection Resolution meeting; the treatment of Unit 29 is described in detail under Table 1 on page 6 of this document.

Table 1: Silver Creek Thin Proposed Vegetation Management Unit Total No Harvest Early Seral Ground- Skyline Helicopter Target Residual Number Acres “Skip” Wildlife based Harvest Harvest Relative Percent (Stand ID) Acres Habitat Harvest Acres Acres Density Canopy Acres Acres (Curtis) Cover

1 (522) 26 3 ------3 15 5 35 50-60 2 (9108) 103 11 ------20 72 ------35 50-60 3 (33) 8 1 ------1 6 ------35 50-60 4 (9040) 69 41 ------2 26 ------35 50-60 5 (9041) 20 1 ------19 ------35 50-60 6 (9029) 90 35 ------2 53 ------35 50-60 7 (35) 31 8 ------23 ------35 50-60 8 (1453) 33 18 ------12 3 30 40-45 9 (323) 23 0 ------23 ------30 45-50 10 (9570) 43 10 ------33 ------35 50-60 11 (9594) 574 243 ------53 264 14 35 50-60 12 (9581) 22 8 ------11 3 30 45-50 13 (9579) 20 2 ------18 ------25 40-45 14 (9593) 260 133 ------1 126 ------35 50-60 15 (31) 267 111 ------35 116 5 35 50-60 16 (9626) 22 4 ------7 11 ------30 45-50 17 (9592) 389 204 42* 60 125 ------35 50-60 18 (9561) 98 13 ------10 75 ------35 50-60 19 (9584) 30 13 ------17 ------35 50-60

8 Silver Creek Thin Environmental Assessment December 2016

Unit Total No Harvest Early Seral Ground- Skyline Helicopter Target Residual Number Acres “Skip” Wildlife based Harvest Harvest Relative Percent (Stand ID) Acres Habitat Harvest Acres Acres Density Canopy Acres Acres (Curtis) Cover

20 (9625) 113 20 ------13 75 5 35 50-60 21 (9558) 56 0 14* 30 21 5 35 50-60 22 (9559) 8 0 ------8 ------35 50-60 23 (9585) 5 0 ------5 ------35 50-60 24 (9586) 51 13 ------15 23 ------25 40-45 25 (9588) 23 5 ------2 16 ------25 40-45 26 (41) 38 21 ------4 13 ------35 50-60 27 (43) 101 42 8* 8 51 ------35 50-60 28 (9541) 255 48 59* 80 127 ------35 50-60 29 (9053) 50 37 0 ------13 ------35 50-60 30 (9545) 38 15 ------23 ------35 50-60 31 (18) 134 67 ------12 49 6 35 50-60 32 (9051) 33 7 ------26 ------35 50-60 33 (9620) 6 0 ------6 ------35 50-60 34 (9534) 29 18 ------1 10 ------35 50-60 35 (9533) 93 48 ------2 43 ------35 50-60 36 (9540) 23 5 ------4 14 ------35 50-60 37 (9591) 286 122 18* 28 111 25 35 50-60 38 (9524) 8 2 2* 2 4 ------35 50-60 Total 3,478 1,329 143 426 1,652 71

*Wildlife forage opening acreage is a subset of treatment acres. Target relative density is 5 to 10 percent and residual canopy cover is approximately 18 percent for these acres. These acres are non-contiguous, but are dispersed within the applicable unit.

♦ The modified decision eliminates treatment of the stand east of Forest Road 47 in Unit 29 (see Figure 3). The little finger of land west of the FR47 that is the northern portion of Unit 29 will be changed. The new prescription for the little finger would be thinned as will the rest of the unit west of the road.

Access for efficient management of vegetation 1. Reconstruct shoulder and replace culvert of Forest Road (FR) 8500000 at milepost 13.0.

2. Reclaim asphalt from mileposts 0 to 6.5 of Forest Road 8500000 and from mileposts 10.3 to 17.1 of Forest Road 4700000.

3. Blasting and crushing of rock at St. Regis (FR 7500000) and Boundary (FR 4740015) quarries for road fill and surfacing.

4. Replace washed-out culverts at mileposts 0.00, 0.48, 0.77 and 1.52 of FR 4700174.

5. Install temporary bridge where FR 4778043 crosses Willie Creek at milepost 0.2, repair washout with culvert at milepost 0.3 and unbury culvert at milepost 2.2. Reconstruct road junction with FR 4778042 for bridge delivery and installation.

6. Repair washout with culvert at milepost 0.15 of FR 4778045.

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7. Repair washouts with culverts on FR 4778046.

8. Repair embankment at milepost 0.48 of FR 7500064, remove slide, unbury culvert at milepost 0.97, and unbury culvert at milepost 1.09.

9. Install culverts at mileposts 0.01, 0.45, 0.87 and 1.3 of FR 8522000.

10. Remove slough at milepost 4.7 of FR 4700000.

11. Deep patch repair between mileposts 10.58 and 16.12 of FR 4700000.

12. Realignment at milepost 16.12 and 16.2 with embankment repair at milepost 16.15 of FR 4700000.

13. Reconstruct length of FR 4700135 including ditch, shoulder, surface, embankment repair and blasting near terminus.

14. Reconstruct length of FR 4700184 including ditch, shoulder, surface and embankment repair.

15. Reconstruct FR 4745000 between mileposts 0 and 1.2 including ditch, shoulder, surface and embankment repair.

16. Reconstruct FR 4773000 at milepost 0.1 including ditch, shoulder, surface and embankment repair.

17. Reconstruct length of FR 4740015 including ditch, shoulder, and surface and cross drain installation.

18. Reconstruct FR 4778000 including ditch, shoulder and surface repair between milepost 0.08 and 0.91.

19. Repair washouts and replace culverts at milepost 0.39, 0.42, 0.46, 0.87 and 0.91 of FR 4778000.

20. Reconstruct length of FR 4778011 including ditch, shoulder and surface repair and culvert replacement at mileposts 0.56 and 0.6.

21. Reconstruct length of FR 6300000 including ditch, shoulder, surface repair and culvert replacement.

22. Repair washouts and replace culverts at mileposts 4.8 and 5.5 of FR 7500000. Reconstruct roadway at MP 1.8 and 2.3 including ditch, shoulder, surface and embankment repair.

23. Unbury culvert at milepost 1.08 and repair washouts and replace culverts at mileposts 1.25 and 1.3 of FR 7561000.

24. Reconstruct FR 8511000 including ditch, shoulder, surface and embankment repair.

25. Construct approximately 7.41 miles of new, temporary road and re-open approximately 7.43 miles of existing, non-system road (Table 2). All temporary roads will be closed and returned to a more natural state after all harvest activities have been completed.

26. Maintain about 85 miles of system road, which includes ditch line and drainage structure cleaning, brushing, blading and shaping the roadway, as well as adding some additional surfacing rock and clearing logs and danger trees from the roads where necessary.

10 Silver Creek Thin Environmental Assessment January 2017

Table 2: Temporary and non-system roads associated with Silver Creek Thin Unit Number New Temporary Road Miles Existing Non-system Road Miles

1 .43 .15 2 .19 .40 3 ------4 ------.04 5 .13 .11 6 ------7 .23 ------8 .19 .20 9 ------10 .09 ------11 1.32 .37 12 ------13 ------.11 14 .22 .11 15 .43 1.19 16 .15 .16 17 .72 1.20 18 .28 ------19 ------20 .36 .07 21 .32 ------22 .07 ------23 ------24 .22 .18 25 ------26 .14 .14 27 .19 1.07 28 .69 .64 29 é 0.00 ------30 ------31 .02 .07 32 ------33 .13 ------34 ------.24 35 .04 .45 36 .21 .27 37 .21 .26 38 .07 ------Total 7.05 Miles 7.43 Miles

é Because the portion of Unit 29 east of FR47 has been removed from treatment, the temporary road accessing Unit 29 is no longer needed, and has been removed from this table.

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Cowlitz Valley Ranger District

Closure and Stabilization of Roads Table 3 details the roads proposed for closure and stabilization with ratings for access need and aquatic and terrestrial risk as identified from by the Silver Creek Thin interdisciplinary team and informed by the 2002 Gifford Pinchot National Forest Roads Analysis.

Table 3: Silver Creek Thin Project Proposed Road Closure and Stabilization

Road Miles Justification Location Access Aquatic Terrestrial Number Need Risk Risk 7561018 1.01 High aquatic risk From the Moderate High Low junction of FR 7561 to its terminus 4778011 0.70 Wildlife habitat security From the Low High High junction of FR 4700 to the junction of FR 4778 4700213 0.78 Wildlife habitat security From the Moderate Moderate High junction of FR 4700 to its terminus 7500065 0.10 High terrestrial risk From milepost Low Moderate High 1.10 miles to its terminus

4778000 3.23 High aquatic risk From the Low High High junction of FR 4700 to the junction of FR 4778042 7500047, 2.20 High terrestrial risk; in From the High Moderate High

7500048, conjunction with junction of FR 7500049, restoration project #3 7500 to their 7500602 below termini 8500108 0.8 Moderate aquatic risk From the High Moderate Low junction of FR 8500 to its terminus

4700000 1.4 High aquatic risk From milepost Low High Moderate 16.6 to East Fork crossing

Total 10.22

12 Silver Creek Thin Environmental Assessment January 2017

Other restoration activities within the project area

Forest Health 1. 583 acres of pre-commercial thinning across 19 units to reduce inter-tree competition maintain health and vigor and promote species and forest structural diversity. Residual tree density by stand will range from 90 to 300 trees per acre.

Wildlife 2. Create snags from trees 20 to 30 inches in diameter at breast height (DBH) in stands adjacent to treatment units to improve foraging for species dependent upon late successional habitat.

Aquatic and Hydrologic Function 3. Removal of improperly functioning culvert to re-establish natural flow and water levels between wetland and Hampton Creek

4. Large woody debris recruitment, riparian planting and bank stabilization to restore water quality and fish habitat along 3.8 miles of Silver Creek.

5. Clean drainage structures and re-establish natural flow lines of stream channels along Forest Road 4700000 in Unit 11 and along Forest Road 4745000.

6. Remove abandoned, non-functional stream crossings on existing, non-system roads to restore natural streamflow, channel habitat, vegetative cover and substrate while improving natural sediment regime and transport where these sites occur within proposed treatment units.

7. Non-commercial felling and leaving of 16-30 trees per acre with average diameter of 14 inches across approximately 600 acres of No Harvest “Skip” Riparian Reserves expected to contribute to aquatic system stability and complexity along Silver Creek, East Fork of Silver Creek, Lake Creek and Willie Creek.

8. Replacement of undersized culvert at milepost 0.1 of Forest Road 4773000 near junction of Forest Road 4700000 junction.

9. Close and stabilize approximately 1.4 miles of FR 4700000 in proximity of East Fork of Silver Creek to include the removal of culverts, asphalt, and any protective road railings. Allow natural revegetation and growth over former road and/or seed and mulch and apply other applicable Best Management Practices.

10. Upgrade culverts at stream crossings to improve fish passage on North Fork Willame Creek at Forest Road (FR) 4700 (milepost 4.0) and unnamed tributary to Willame Creek at FR 4715 (milepost 1.0), West Fork Willame Creek on FR 4725 (milepost 0.48), and unnamed tributary to Muddy Fork Cowlitz on FR 5290 (milepost 4.8).

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Cowlitz Valley Ranger District

Figure 3. Silver Creek Planning Area Map #1

14 Silver Creek Thin Environmental Assessment December 2016

Figure 4. Silver Creek Planning Area Map #2

15 Cowlitz Valley Ranger District

Figure 5. Silver Creek Planning Area Map #3

16 Silver Creek Thin Environmental Assessment December 2016

Figure 6. Silver Creek Planning Area Map #4

17 Cowlitz Valley Ranger District

Figure 7. Silver Creek Planning Area Map #5

18 Silver Creek Thin EA January 2017 Project Design Criteria and Mitigation Measures NEPA defines “mitigation” as avoiding, minimizing, rectifying, reducing, eliminating, or compensating project impacts. The following design criteria and mitigation measures are an integral part of this project and would be carried out if the project were implemented under the Proposed Action. The analysis and disclosure of effects assumes implementation of these measures.

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

1 Silvicultural Prescription and Layout Considerations

1.1 Minimize bole scarring of residual stand. Minimize tree bole scarring by restricting operations during the high sap- Units 10-12, 14-35, and 37-38. Note: Early flow period of March 1 through May 31. Sap-flow operation restrictions seral forage opening subunits do not have may be waived by the sale administrator (after documenting consultation a sap-flow period restriction with the District or Forest Silviculturist) if it can be clearly demonstrated that operations can be conducted without unacceptable damage to leave trees.

1.2 Minimize bole scarring of residual stand. Minimize tree bole scarring by restricting operations during the high sap- Units 1-9, 13, and 36 flow period of March 1 through July 31. Sap-flow operation restrictions may be waived (in consultation with the District or Forest Silviculturist) if it can be clearly demonstrated that operations can be conducted without unacceptable damage to leave trees.

1.3 Protect genetic resource trees. Protect genetic resource select trees by 1) showing their locations on Units 4, 15, 17, 21, 30, 37 as follows: Unit the sale area map; 2) ensure they are not used as guy trees or tailholds 4: Black Cottonwood # 036; Unit 15: Black and protected from skylines; 3) directionally fall take trees away from Cottonwood # 040; Unit 17: Western them; and 4) protected during post-sale slash disposal and erosion Hemlock # 006, Black Cottonwood # control work. 010; Unit 21: Black Cottonwood # 046; Unit # 30: Douglas-fir # 267; and Unit 37: Black Cottonwood # 008.

1.4 Promote species diversity and resilience Unless more site-specific field review indicates otherwise, target All units with the following exceptions: to root disease. Douglas-fir, western hemlock, Pacific silver fir and red alder for harvest. Units 7, and 25 where Douglas-fir is a Designate all other species as minor and retain regardless of size and minor species, Units 1-4, 6-16, 19, 21, 23, condition for diversity and impeding root disease. 26, 29, and 35-37 where western hemlock is a minor species, Units 7, and 8 where noble fir is not a minor specie and Units 12, 21, and 26-28 where red alder and black cottonwood is not a minor species.

19 Cowlitz Valley Ranger District

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

1.5 Maintain optimal stand growth and Target post-treatment relative densities of approximately 35% in Matrix Matrix units except those identified for promote stand resilience in Matrix stands. objectives besides timber production (early stands seral wildlife habitat openings). See detailed post-treatment stand density table in Vegetation section of EA.

1.6 Provide spatial heterogeneity and Approximately 10% of the cutting units located in Late Successional LSR Units: 8, 9, 12, 13, 24, 25 resilience to root disease in treated Reserve will be openings (gaps) that are 1/10 to ¼ acre in size. The stands. openings will be multi-purpose and located where possible root disease occurs to slow its damage and small-scale canopy disturbance provides spatial heterogeneity. Gaps will not be located within 100 feet of any unit boundary adjacent to old growth (see Wildlife measures below).

1.7 Allow for natural suppression mortality, Approximately 10% of the cutting units located in Late Successional LSR Units: 8, 9, 12, 13, 24, 25 spatial variation, and protection of Reserve will be left in unthinned “skips” between 1/10 and 1/3 acre in unique areas of biological diversity and size to Inner riparian reserves will count toward skip acreage. legacy features such as live and standing dead trees and down woody debris.

1.8 Provide early seral forest openings for Create all openings at least 5 acres in size with larger openings Units 17E, 21E, 27E, 28E, 29E, 37E, and wildlife in Deer and Elk winter range preferred. 38E through Light Forest Retention harvest. All merchantable sized trees, outside of aggregated retention areas and not designated for single-tree retention, would be felled and removed.

1.9 Limit size of and connectivity between Light Forest Retention units shall not exceed 40 net acres excluding any Units 17E, 21E, 27E, 28E, 29E, 37E, and Light Forest Retention units to ensure group retention, aggregated retention, visual buffers or Riparian 38E compliance with NFMA and other Reserves. Adjacent stands of Light Forest Retention may be combined considerations provided this size limitation is met (relevant in units 17E, 21E, 27E and 28E). Light Forest Retention units shall be separated by blocks of land generally not classified as regeneration harvest but containing logical harvest units.

1.10 Retain 15% of stands harvested through Single tree or group retention: A portion of the total stand retention will Units 17E, 21E, 27E, 28E, 29E, 37E, and Light Forest Retention in no-cut be of live trees left singly or in groups of a ¼ acre. These trees will 38E aggregates and single trees to promote comprise 5% of the stand’s area, plus an additional nine trees per acre ecological complexity such as future to supplement future and down log levels. These retention trees snags and down logs. should be the largest, oldest, most decadent and leaning trees. Aggregated Retention: Most of the stand retention will be in areas of aggregated retention (aka big skips) and have no timber cutting.

20 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.) Aggregated retention would comprise 10-11% of the stand area. These leave areas should be at least 2.5 acres in size or larger to provide some interior forest conditions, though aggregates down to ½ acre are permissible. Riparian Reserves: There would be no commercial tree harvest within Riparian Reserves surrounding aquatic features. Riparian Reserves may be incorporated into the stands’ aggregated retention areas.

1.11 Ensure minimum tree regeneration in Plant seedlings in Early Seral Wildlife Habitat openings to augment Units 17E, 21E, 27E, 28E, 29E, 37E, and early seral wildlife habitat openings natural regeneration in order to meet minimum stocking of 125 trees per 38E acre within 5 years.

1.12 Preserve pocket of Pacific Yew Install an aggregated retention skip of no less than one acre in size in Unit 17 the vicinity of GPS UTM coordinates 10T 0584455, 5160974

1.13 Protect potential habitat for Marbled No gaps will be created within 100 feet of an edge bordering old growth, Units 4-9, 11, 13-18, 20, 21, 24-26, 29, Murrelet or adjacent stand with large tree structure that could potentially be 30, 34-38 marbled murrelet nesting habitat. Forage openings will not be created within 110 yards of suitable nesting stands.

1.14 Limit microclimatic effects and retain Retain a minimum buffer of two tree crown-widths (intermingled canopy) Units 4-9, 11, 13-18, 20, 21, 24-26, 29, cover for potential marbled murrelet where treatment unit abuts an old growth or large tree structure edge 30, 34-38 nesting habitat

1.15 Promote variability within stands and All of the units will have a maximum tree diameter limit for harvest. This All retain legacy trees is determined for each unit prior to harvest but, in general, will not exceed 40 inches Diameter Stump Height

1.16 Restore or not prevent attainment of The outer riparian reserves will follow a prescription consistent with the All units. Note that maps shown in EA ACS objectives upland (treatment unit) silvicultural prescription. Exclude inner reserves depict unit boundaries after already from commercial harvest as defined here: excluding riparian reserves.

Stream Class I (fish bearing) 300 ft.

Stream Class II (fish bearing) 300 ft.

Stream Class III (perennial non-fish bearing) 150 ft.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

Stream Class IV (intermittent) 100 ft.

Geologic Hazard (mapped active slide or mass movement) 180 ft.

Wetlands < 1 ac 60 ft.

Wetlands > 1 ac 120 ft.

1.17 Protect sensitive and Survey and Implement buffer appropriate for protection of any S&M species found in Units 11, 14, 15,16, 17, 20, 21, 32 Manage botanical and wildlife species treatment units as specified in Botany and Wildlife sections of EA. (botanical); Unit 29 (mollusks)

2 Wildlife Limited Operating Periods (LOPs)

2.1 Limit potential noise disturbance to The early NSO nesting season LOP of March 1 to July 15 will apply to Units 4-9, 11, 13-18, 20, 21, 24-26, 29, 30, Northern Spotted Owl during nesting all timber harvest, road reconstruction and closure/stabilization work, 34-38 season. pre-commercial thinning, and other noise-generating work (over approximately 90 dB, includes chainsaw use, heavy equipment, helicopters) within 110 yards of unsurveyed suitable NSO nesting habitat.

2.2 Limit potential noise disturbance to No harvest activity or other noise-generating work (same activities as in Units 4-9, 11, 13-18, 20, 21, 24-26, 29, 30, Marbled Murrelet during nesting NSO LOP above) will occur in the 2 hours after sunrise and the 2 hours 34-38 season. before sunset for units bordering potential MAMU nest stands between April 1 and September 23.

2.3 Limit potential disturbance to Marbled Prior to inclusion of Unit 29 in a timber sale contract, surveys according Unit 29 Murrelet. to protocol (12 visits during the nesting season for 2 seasons) will be conducted for marbled murrelets to determine occupancy in the stand. If occupancy is detected a ½ mile radius LSR will be designated to protect the nest stand.

2.4 Limit potential disturbance to deer and No harvest activity or other project related work will occur between Units 17, 21, 22, 27-32, 37, 38 elk while in winter range areas December 1 and April 1 in units in deer and elk winter range

3 Hazardous Fuels

3.1 Reduce loading of fine slash to an Residual loading of woody fuels less than 4 inches diameter should not All units acceptable level that mitigates fire risk. exceed 25 tons/acre.

22 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

3.2 Provide greater slash load reduction Residual loading of woody fuels less than 4 inches diameter should not (Forage): units 17, 21, 27, 28, 29, 37, 38; along major travel routes to mitigate fire exceed 15 tons/acre in forage units and within 50 feet of FR 47, FR 75, (FR 47): units 11, 17, 18, 19, 20, 21, 22, risk and allow for quicker regeneration FR 7561, and FR 85. 27, 28, 29, 30; (FR 75): 32, 33, 34, 35, and of shrub and herb components 37; (FR 7561): unit 33, 36, and 37; (FR preferred by wildlife in the forage units. 85): units 11, 12, 15, 16, 17.

3.3 Reduce slash depth to an acceptable Average residual fuel depth should not exceed 24 inches immediately All units level that mitigates fire risk. post -harvest.

3.4 To address smoke emissions and other An approved burn plan will accompany any prescribed fire activities. All units. hazards to firefighter and public safety.

4 Recreation and Visual Quality

4.1 Protect Visual Quality Objective of Ground disturbance by any activity should be rehabilitated within one Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and year to natural appearance. Timber slash and debris should be treated Middleground units. within one year. (e.g. piling and burning, whole tree skidding, chipping)

4.2 Protect Visual Quality Objective of Stumps resulting from any activity should be flush cut (6" maximum Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and height) where they are visible within 100 feet of Forest Roads 47, 84, Middleground units. and 85. Topography may require flush cutting for shorter or distances greater than 100’ in order to conceal stumps from designated visual corridor travel routes.

4.3 Protect Visual Quality Objective of A fully stocked timber harvest area will no longer be considered an Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and opening when average tree height is in excess of 20’. Middleground units.

4.4 Protect Visual Quality Objective of Harvest units may not dominate natural form, line, color, and texture. Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and Unit boundary and wildlife opening edges should blend with the natural Middleground units. landscape. Edges should not be straight lines, but should mimic natural appearing edges that are commonly found in the surrounding landscape, i.e., leave a variable 50' transitional thin along contrasting edges of unit. Thinning should include elements that promote spatial variability (e.g. diameter limits, species limits, skips, and gaps). Leave trees and boundaries should not be visibly marked from designated visual corridor travel routes.

4.5 Protect Visual Quality Objective of Retain diversity in undergrowth. Thinning should include elements that Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and promote spatial variability (e.g. diameter limits, species limits, skips, and Middleground units. gaps).

23 Cowlitz Valley Ranger District

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

4.6 Protect Visual Quality Objective of Maintain diversity of species and/or age classes. The proposed action Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and would accomplish this, as it would speed the development of these Middleground units. characteristics in what are currently even-aged stands.

4.7 Protect Visual Quality Objective of All quarry/stockpile sites should be located out of sight or rehabilitated. Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and Middleground units.

4.8 Protect Visual Quality Objective of Roads may not dominate the natural form, line, color, and texture. Re- Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and vegetation for visual quality and erosion control should be completed Middleground units. within one season after construction.

4.9 Protect Visual Quality Objective of Machine slash piles should not be visible from roads and trails in Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and foreground areas. Slash piles visible from roads and trails in foreground Middleground units. areas (except those remaining for wildlife purposes) should be burned within one year following treatment or when burning requirements are met (smoke permits, weather conditions and available resources).

4.10 Protect Visual Quality Objective of Landings and/or log decks, and equipment staging areas should not be Units 8, 9, 12, 13, 16, 23 - 25 "Retention" in Foreground and visible, or camouflaged to the extent possible as viewed from FRs 47, Middleground units. 84, 85, and Hwy 12 and all trails within and/or adjacent to the treatment areas.

4.11 Protect Visual Quality Objective of A fully stocked timber harvest area will no longer be considered an Units 1-7, 10, 11, 14, 15, 17-22, 26-38 Modification opening when average tree height is in excess of 4 ½’.

4.12 Protect Visual Quality Objective of Harvest units may dominate natural form, line, color, and texture, but Units 1-7, 10, 11, 14, 15, 17-22, 26 -38 Modification must blend with the natural character of the land. Unit boundary and wildlife opening edges should blend with the natural landscape. Edges should not be straight lines, but should mimic natural appearing edges that are commonly found in the surrounding landscape, i.e., leave a variable 50' transitional thin along contrasting edges of unit.

4.13 Protect visual quality by avoiding Skyline corridors should be as narrow as possible and logs should be All units where skyline corridors/cable disturbance to the soil and resultant line suspended as high above the corridor as possible (when safe for yarding will occur. contrast. operator and not causing damage to residual trees) when cable yarding to landings.

24 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

4.14 Protect visual quality along major travel In treatment areas where leave trees are marked w/ tree marking paint, Units 1, 2, 4, 7, 8, 11, 12, 15-22, 28-30 corridors. marking paint should occur on the backside of trees if the trees are visible from Forest Roads 47, 84, 85, US Highway 12, and all trails within and/or adjacent to the treatment area.

4.15 Restore visual quality following harvest. Temporary access roads and/or skid roads should be re-contoured, All units seeded, and restored to a natural grade and closed to travel as soon as possible. Re-vegetation for visual quality and erosion control should be completed within one season after construction.

4.16 Protect public safety at trailheads During active logging, close and post signage on FR 8511, as this is the Unit 2 access point for Greenwood Lake Trail #253 and Allen Mountain Trail #269. Notify District Recreation Specialist to notify the public and post appropriate signage at trailheads.

5 Invasive Weeds Management

5.1 Mitigate potential for invasive plant During the field season before the ground-disturbing phase of project Specific locations may be found in Botany establishment and spread from known implementation begins, treat the following occurrences, using a Forest Report in Project Record weed sites due to Silver Creek timber s approved method. In all cases, control should occur before set seed for and associated activities the year (May or June in most units). The Sale Administrator shall inform the Gifford Pinchot North Zone Botanist at least one month prior to when ground disturbing work is scheduled to commence, so that weed control activities may be scheduled. 1) Lesser burdock occurrences within planning area (Map A) 2) Diffuse knapweed occurrences within planning area (Map B) 3) Spotted knapweed occurrences within the planning area (Map C) 4) Scotch broom occurrences within planning area (Map D) 5) Herb Robert occurrences within planning area (Map E) 6) Meadow hawkweed occurrences within planning area (Map F) 7) Tall Hawkweed occurrences within planning area (Map G) 8) English holly occurrences within planning area (Map H)

25 Cowlitz Valley Ranger District

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.) 9) Perennial pea occurrences within planning area (Map I) 10) Stinking Willie occurrences within planning area (Map J)

5.2 Mitigate potential for invasive plant For two field seasons following project completion, re-occurrences of Specific locations may be found in Botany establishment and spread from known the species listed in PDC #5.1 should be controlled as specified above. Report in Project Record weed sites due to Silver Creek timber s In addition, harvest units should be surveyed for invasive plant and associated activities establishment and/or encroachment. If new invasive plant populations are located within harvested units, population data shall be collected for entry into the NRIS database, and a treatment plan should be developed.

5.3 Avoid introduction of weeds to project To the extent possible, all off-road equipment are to be thoroughly All areas with desired vegetation, and help cleaned prior to entering National Forest System lands. An on-site prevent the further spread of weeds inspection will be conducted to ensure that equipment is clean before already established in the project area. work can begin. (PNW Region Invasive Plant Program FEIS ROD 2005). In addition, the USDA Forest Service Guide to noxious weed prevention practices mandates the use of the equipment cleaning contract clause WO-C/CT 6.36. In order to simplify requirements for purchasers, the following modified form of this standard is recommended: Purchaser must clean off-road equipment prior to moving between cutting units on this timber sale. This requirement could be waived by the sale administrator, at the request of the purchaser, with consultation with the district botanist, in specific situations where the recorded weed lists are the same between two units.

5.4 Avoid introduction of weeds to project Use weed-free straw and mulch for all projects, conducted or authorized All areas with desired vegetation, and help by the Forest Service, on national forest system lands. If certified straw prevent the further spread of weeds and/or mulch is not available, individual forests should require sources already established in the project area. certified to be weed free using the North American Weed Fee Forage Program standards or a similar certification process (Standard 3, R6 Weed EIS).

5.5 Avoid introduction of weeds to project Inspect active gravel, fill, sand stockpiles, quarry sites, and borrow All areas with desired vegetation, and help material for invasive plants before use and transport. Treat or require prevent the further spread of weeds treatment of infested sources before any use of pit material. Use only already established in the project area. gravel, fill, sand, and rock that is judged weed free by district or forest weed specialists (Standard 7, R6 Weed EIS).

26 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

5.6 Encourage revegetation by native plant Native plant materials are the first choice in revegetation for restoration Areas where revegetation is needed or species and protect National Forest and rehabilitation where timely natural regeneration of the native plant prescribed consistent with (Standard 13, System lands from invasion by non- community is not likely to occur. Non-native, non-invasive plant species R6 Weed EIS). As presented in the Gifford native weeds may be used in limited situations (see Botanical Resources report in Pinchot N.F. forest plan IV-66, Road, Silver Creek Thin project record or discuss with District Botanist). Under Bridge, and Culvert Construction and no circumstances will non-native invasive plant species be used for reconstruction revegetation. Following construction work, erosion control and restoration should be completed during the same season or as soon as practicable with a native seed mix and application prescription developed by the Forest. Consult Gifford Pinchot N.F. North Zone botanist at the time revegetation is needed for recommendations on seed mixes and fertilization.

5.7 The purpose of this mitigation is Minimize road maintenance clearing zones as much as safety Project-related roads maintain shady conditions that help regulations will allow. (Prevention Guide, Goal 5, p.7) minimize invasive plant population expansion

5.8 The purpose of this mitigation is to During the period of project implementation, conduct any road brushing Project-related roads reduce the risk of release of viable activities prior to seed maturity of weedy species. seeds that could be dispersed along hauling corridors by vehicles, and/or when wind-borne seeds could disperse into newly harvested units.

5.9 Limit spread of new invasives in project Depending on available funding, control specified invasive plants at Project-related disturbance areas area. landings, culvert replacement sites, and along access roads for 1/4 mile preceding areas of ground disturbance (i.e. staging areas, and harvest units adjacent to roads), to 1/4 mile following area of ground disturbance, and within timber harvest units, as specified in Botanical Resources Specialist Report (Silver Creek Thin Project Record)

6 Soil, Water, and Aquatic Resources - Vegetation Management Activities

6.1 The objective is to limit the degree of Ground-based machinery will not be operated where soil water content Units: 1 (522), 11 (9594), 13 (9579), 14 detrimental soil rutting and puddling as is high enough to cause detrimental puddling, defined as when the depth (9593), 15 (31), 16 (9626), 17 (9592), 18 well as reduce the potential for of ruts or imprints is six inches or deeper, for 10 feet or longer. (9561), 2 (9108), 20 (9625), 21 (9558), 22 sediment delivery to streams. (9559), 23 (9585), 24 (9586), 26 (41), 27 (43), 28 (9541), 3 (33), 31 (18), 34 (9534), 35 (9533), 36 (9540), 37 (9591), 38 (9524), 4 (9040), 6 (9029), 25 (9588)

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.2 The objective is to prevent soil Mechanical harvesters, when traveling away from approved skid trails or All compaction and displacement and roads will operate on ground cover as thick and continuous as practical protect topsoil for vegetative growth. that protects the soil, such as slash, existing vegetation, downed saplings, or broken limbs. This equipment shall not travel while bearing weight of trees (i.e., skidding), except minimal amounts at ends of skid trails to reduce soil disturbance by skidders.

6.3 The objective is to prevent surface soil Areas of gouging or soil displacement resulting from logging systems All erosion resulting from ground will be treated to prevent rill and gully erosion and potential sediment disturbance. delivery to stream courses. Off road trails used for equipment fueling and servicing will be rehabilitated post use by moving soil back to natural hillslope contour (re-contour) and placing slash or vegetation on exposed mineral soils. Erosion control treatment may include, but is not limited to, repositioning displaced soil to restore the hillslope contour of disturbed sites, creating small ditches or diversions to redirect surface water movement, and scattering slash material to create flow disruption and surface soil stability. Erosion control measures will be implemented 15 days prior to the close of the timber sale in normal operating seasons, or as soon as practicable outside the season.

6.4 The objective is to prevent surface soil Forest Service will approve landings, skid trails, and skyline corridors All erosion resulting from ground prior to timber felling. Skid trails must be located outside of all no harvest disturbance. buffers, unless otherwise specified in unit specific project design features, where resource specialists have approved and marked a crossing. Skid trails will be spaced an average of 150 feet apart. Skid trails will be re-established at previous road or trail locations, except where existing trails from prior entry would cause detrimental soil or hydrologic conditions that could be further avoided with alternative skid trail location. Skid trails will be decompacted after use where compaction related to the project remains, with exceptions identified by the Forest Service. De-compaction of the soil profile will shattered the entire depth of soil compaction and available logging slash will be placed across the decompacted surface. This measure will be accomplished 15 days prior to the close of the timber sale in Normal Operating Season, or soon as practicable after October 1.

28 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.5 The objective is to promote well- Temporary roads will be located where past logging roads were located. All loosened substrate for vegetative If a new location would cause less resource effects than using an growth and water infiltration following existing temporary road, then the newer road with less resource effects logging and harvest activities. will be used to harvest the unit with line officer approval in coordination with an aquatics or soils resource specialist. Rock will be applied only where needed to reduce erosion, puddling, and compaction. Rock will be removed and road will be de-compacted following harvest activities (see mitigation measure below which requires de-compaction).

6.6 The objective is to promote well- Landings will be located where past landings were located, unless a new All loosened substrate for vegetative location would cause less resource effects, or where no past landings growth and water infiltration following were used to harvest the unit. New landings will be located outside of all logging and harvest activities. no harvest buffers. Landings will be limited to the area needed for safe and efficient yarding and loading operations and have proper drainage. Certified weed free erosion control catchments or silt fences will be used to avert sediment transport in road ditches and streams. The catchments will be located to intercept runoff from the landing prior to reaching any stream.

6.7 The objective is to rehabilitate areas Temporary roads and landings will be closed and restored after harvest All compacted during management and related activities are complete. Temporary roads and landings that activities, accelerate recovery of were established for the timber sale will be de-compacted to the entire compacted soils, and facilitate water depth of compaction, for an uneven, rough surface without furrows, and infiltration and re-vegetation disturbed be accomplished immediately following logging activities. De- areas. These measures will also provide compaction will encompass the entire landing and the sight distance (to ground cover for exposed soils in order discourage a bypass) from the beginning of the road, no less than 200 to reduce the potential for offsite erosion feet. The rest of the road will have drainage reestablished. Available and maintain soil organic matter to logging slash will be placed across the de-compacted surface. No prevent nutrient and carbon cycle ground-based equipment will be operated on de-compacted portions of deficits. roads and landings completed to prevent re-compacting them. Post- harvest motorized access to temporary roads will be prevented. Closure to vehicles will prevent restored areas from being re-compacted, allow vegetation to develop, and curb erosion and sediment delivery.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.8 The objective is to minimize erosion and Forest Service will periodically inspect ground-based operations to All potential sediment delivery to streams prevent or rectify resource damage that may occur. Resource damage and provide data for BMP monitoring. includes ponding, ruts, rills, culvert blockages, stream channel instability, and the occurrence of scour or sediment transport and deposition downstream of cross drains. Project activities will be suspended and corrective action taken before work resumes if resource damage is occurring. Written records will be made available of all significant day-to- day Sale Administration occurrences that involve acceptance of completed work, purchaser’s deficiencies, and the need for follow-up action on the part of either party. For every site visit and contact between Forest Service and Purchaser’s Representative, records will include a rating of “satisfactory,” “needs attention,” or “unsatisfactory” for: a. Resource protection measures related to erosion control, wet weather operations, damage to forest soils, stream protection, road maintenance, pollution prevention (soils, air, and water); b. Approval of skid trails, temporary roads, haul routes, camp sites, and location and size of landings; and c. Comments on performance, mutual agreements, approvals, acceptance of work, or noncompliance under the timber sale contract.

6.9 The objective is to limit soil compaction Mechanical harvesters and feller bunchers shall be allowed on slopes up All and displacement, to protect the topsoil to 35 percent, and approved on a unit-by-unit basis, on slopes up to 45 for vegetative growth, and provide water percent prior to start of operation. Mechanical cutting and harvesting infiltration machines will not operate over erosive soils on slopes greater than 35%, as shown on soils maps Mechanical cutting and harvesting machines shall: a) Not exceed limits on slope steepness, measured by percent slope (not grade of a trail/road). Slope maximum limit for harvesters is 45 percent, when approved on a unit-by-unit basis, including short steep pitches. b) avoid uphill travel on forest soils greater than 30% slope. Only travel downhill on steep slopes, when traveling off approved skid trails or roads, and reduce or eliminate turning and traveling across the slope to minimize soil gouging. c) Operate on a slash mat of ground cover or limbs and tops as thick and continuous as practical. d) Avoid carrying logs (skidding) as described above, if traveling on forest soils greater than 30% slope. e) Not enter into riparian no harvest buffers and unstable slopes.

30 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.10 The objective is to identify and avoid Temporary road construction will avoid unstable slopes shown on All units. Note that unstable areas have high risk unstable areas and implement Unstable Soil maps (USDA2015c), unless otherwise specified in unit already been excluded from treatment unit timber harvesting techniques least specific project design features. Consultation with a soil scientist or boundaries shown in EA. damaging to natural slope stability geologist will allow some timber harvest in low to moderate risk areas using sale design, light to regular thin prescriptions that retain greater than 50% canopy cover, and careful road location. No-cut buffers encompassing the entire NW Forest Plan Riparian Reserves will exclude highest risk areas from road building and vegetation management.

6.11 The objective of this measure is to Harvested trees will be felled away from streams, wetlands or other All prevent damage to riparian vegetation riparian reserve features. Exceptions would be trees which are leaning and soils within Riparian Reserves. towards the creek, or when conditions would not allow safe felling. Any portion of a felled tree that lands in the no cut buffer will be left on the ground. Trees accidentally felled onto stream channels whether across it fully or partially shall be left alone. Applicable BMPs: T-6 - Protection of unstable lands; T-13 - Erosion prevention and control measures during timber sale operations, T-17 - Meadow protection during timber harvesting.

6.12 The objective of this measure is to One end log suspension will be required for ground-based and cable- All minimize erosion and potential yarding systems except during winching or lateral yarding. No yarding is sedimentation. permitted over class I, II, III, or IV streams. This will reduce the risk of soil displacement and gullies from dragging entire logs along the ground. Applicable BMP: T-13 - Erosion prevention and control measures during timber sale

6.13 The objective of this measure is to Ground based equipment, unless designed and approved for off-road Units: 1 (522), 11 (9594), 13 (9579), 14 minimize the extent and the degree of use, will be confined to roads, skid trails and landings during yarding and (9593), 15 (31), 16(9626), 17 (9592), 18 soil disturbance from ground based brush disposal operations. Roads will not be constructed within the inner (9561), 2 (9108), 20 (9625), 21 (9558), 22 equipment in riparian buffers. riparian buffer, and only pre-approved skid trails will be used in the outer (9559), 23 (9585), 24 (9586), 26 (41), 27 riparian buffer. Skid trails must be located at least 300 feet from class I- (43), 28 (9541), 3 (33), 31 (18), 34 (9534), II, 150 feet from class III, and 100 feet from class IV streams and 35 (9533). 36 (9540), 37 (9591), 38 wetlands greater than one acre, and at least 60 feet on wet areas less (9524), 4 (9040), 6 (9029), 25 (9588) than one acre. Applicable BMP: T-11. Tractor Skid Trail Location and Design.

6.14 The objective of this measure is to limit Designated non-system roads and skid trails will not be permitted on All the amount of erosion, soil compaction slopes greater than 30 percent. Proposed exceptions to this restriction and displacement associated with use must be pre-approved by the sale administrator and must be of equipment on steep slopes. documented in project file.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.15 The objective of this measure is to Upon completion of harvest, non-system roads will be treated with All facilitate water movement on those cross-drains (also called water bars), constructed to drain every 150 feet disturbed areas. or more frequently where slopes exceed 5%, every 100 feet when slopes exceed 15%. Applicable BMP: T-13. Erosion Prevention and control measures during timber sale operations; T-14 - Revegetation of area disturbed by harvesting activities; T-16. Erosion control on skid trails.

6.16 The objective of this measure is to All road drainage structures (e.g. culverts) installed will be designed to All ensure channel transport function and accommodate bankfull flow flood events if left in place into the wet channel longitudinal connectivity. season (October 1 - June 30), consistent with Gifford Pinchot Land Resource Management Plan Standards and Guidelines (USDA 1995) and Memorandum of Understanding between Washington Department of Fish and Wildlife and USDA-Forest Service Region 6 (WDFW, USDA 2005). Non-system drainage structures will be designed to meet the base flow condition if utilized only during the dry season (June 1July 1 - Sept 30) and removed prior to the fall wet season. If new structures are to weather through fall and winter (October 1 – June 30), they must comply with standards and guidelines as if a permanent structure. Applicable BMP: T-13. Erosion prevention and control measures during timber sale operations.

6.17 The objective of this measure is to All currently closed system roads used by the Project will be closed and All prevent chronic drainage problems, stabilized or decommissioned after sale activities have been completed. reduce compaction, minimize negative These roads will be left in a self-maintaining condition with features such impacts of mass wasting, and help as follows: place a barrier at the junction with the existing road system restore hydrologic and biological adequate to prevent vehicle use, construct cross ditching on steep- process. gradient sections and at culverts or other drainage locations. Applicable BMPs: T-13 - Erosion prevention and control measures during timber sale operations; T-14 - Revegetation of area disturbed by harvesting activities.

6.18 The objective of this measure is to Timing of erosion control treatment shall be prior to the wet season All reduce risk of soil displacement through (October 1 to June 30) for cross drains and grade breaks on all non- rill, gully, and splash erosion processes. system roads, skid trails, landings, and skyline corridors. Applicable BMP: T-13 - Erosion prevention and control measures during timber sale operations.

32 Silver Creek Thin EA January 2017

# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

6.19 Protect water quality. Spill containment and prevention will follow specified timber sale All contract language in GT.3.4 Sanitation and Servicing, GT.3.4.1 Prevention of Oil Spills, Applicable BMPs: T-4 - Use of sale area maps for designating water quality protection needs; T-7 - Streamside management unit designation; T-17. Meadow protection during timber harvesting; T-22 - Modification of the Timber Sale Contract (TSC); R-12 - Control of construction in streamside management units.

6.20 Objective is to prevent erosion and During extended periods of dry weather between the dates of All potential sediment delivery to streams September 30 to July 1October 1 – June 30, logging operations may during off-season logging operations. proceed only with written approval of the sale administrator and providing there is regular monitoring to evaluate implementation and effectiveness of prescribed BMP for project activities as follows:

Log haul and road maintenance operations shall be limited to weather and ground conditions using these indicators.

1. Current daily precipitation remains below the average daily maximum precipitation for the July 1 through September 30 period as calculated from historical records of a nearby precipitation gauge; District Hydrologist will designate the gauge of record for this evaluation. AND

Current two-week cumulative total precipitation remains less than the average maximum two-week precipitation during the July through September period as calculated from historical records of a nearby precipitation gauge. AND

Snow levels and conditions, prescribed by the hydrologist using nearby SNOTEL data, show low risk of a rain-on- snow event.

2. OR, in cases of winter operations: Previous and predicted cold air temperature histories indicate exposed road surface is frozen to a depth of 6 inches (to prevent rutting and triggering erosion and sediment delivery).

Ground-based logging operations, to include temporary road and landing construction, maintenance, and use, shall be limited to two of the following three indicators:

1. Current daily precipitation remains below the average daily maximum precipitation for the July 1 through September 30 period as calculated from historical records of a nearby precipitation gauge; District Hydrologist will designate the gauge of record for this evaluation.

2. Current two-week cumulative total precipitation remains less than the average maximum two-week precipitation during the July through September period as calculated from historical records of a nearby precipitation gauge.

3. Soil moisture is field measured at 20% of optimal compaction and soil displacement potential is low.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

During cold weather (winter) logging operations, ground-based equipment shall operate on either snow that is at least 2 feet deep OR a combination of 3 to 4 inches of compacted snow and soil frozen to at least 6 inches in depth.

Operations shall not continue where snow does not provide protection from soil compaction or rutting. For example, if it rains heavily and the soil and snow become saturated. As an indicator, overnight temperatures should be less than 25 degrees F; afternoon daytime temperatures should not exceed 32 degrees F.

6.21 Objective is to prevent erosion and Project activities occurring during the Period of October 1 to June 30 will All potential sediment delivery to streams be curtailed and corrective action taken when any forms of sediment during off-season logging operations. delivery or erosional features are encountered or expected. These conditions require immediate mitigation to remedy resource damage:

System Roads Operation and Maintenance (BMP Road-4 Road Operation and Maintenance. FSH 7709.59)

i. Scour or sediment deposition evident and extending more than 10 feet below outlet of cross drain.

ii. Ponding present on road surface or road fill that may be causing fill subsidence or otherwise threatening integrity of fill.

iii. Rills (greater than 2” deep and 10’ in length) or sediment deposition has extended more than 10 feet off the road prism.

iv. Ruts formed that can channel water past erosion control structures (drain dips, water bars, cross drains).

v. Turbidity visible in ditch lines leading to stream courses

Culverts or drainage structure conditions (BMP Road-7 Stream Crossings FSM 7722 and FSH 7709.56b)

i. Any drainage features are obstructed or not properly functioning as designed

ii. Any culverts not aligned with the elevation of the streambed to avoid erosion below the outlet

Skid Trails, Temporary Roads, and Harvest Areas (BMP Veg-4. Ground based Skidding and Yarding. FSH 2409.15)

i. Rills or gullies present that are over 2 inches deep and more than 10 feet in length (6 inches deep, over 5 feet length)

ii. Rills, gullies or sediment deposition extends more than 10 feet below waterbar or cross drains outlets on temporary roads.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

iii. Drainage control structures are not functional on temporary roads

iv. Visible turbid water flowing from skid trail and temporary roads

v. Soil displacement (puddling), defined as ruts six inches deep or more, for 5 feet or longer.

Landings (BMP Veg-6. Landings. FSH 2409.15)

i. Rills (greater than 2” deep and 10’ in length) or sediment deposition has extended more than 10 feet beyond the landing.

ii. Functioning erosion control structures which are bypassed by any overland flow

7 Road Repair, Stream Crossings, and Aquatic Organism Passage Projects

7.1 The objective is to restore natural Road segments treated within riparian areas the topography should be See specific road segments of concern in channel function and process. recontoured to mimic natural floodplain contours and gradient to the Aquatic Biological Assessment greatest degree possible.

7.2 The objective is to reduce road related For those road segments immediately adjacent to the stream or where “ sediment sources to live streams. the road fill is near the wetted perimeter or active channel, install sediment control barriers between the project and the stream. Examples include straw bales or erosion control matting, or silt fencing.

7.3 The objective is to reduce road related Drainage features (drain dips) should be spaced to hydrologically “ sediment sources to live streams. disconnect road surface runoff from stream channels (USDI 2013). Project design should be reviewed with an aquatic specialist.

7.4 The objective is to reduce source of Dispose of excavated waste material in stable sites out of the flood “ sediment delivery. prone area. Waste material other than hardened surface material may be used to restore natural or near-natural contours.

7.5 The objective is to reduce sediment Minimize disturbance of existing vegetation in ditches and at stream “ delivery. crossings to the greatest extent possible.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

7.6 The objective is to protect fish including Conduct activities during dry-field conditions – low to moderate soil See Table in Fisheries Biological TES species. moisture levels. For the Silver Creek drainage the allowable work period Assessment in or near fish-bearing waters is August 1 to August 15 (Table 2). If a non-fish bearing stream is less than 0.25 miles from a fish-bearing stream, the allowable work period is July 1 to September 30. Non-fish bearing streams more than 0.25 miles from fish-bearing waters are not required to adhere to these work periods unless a WDFW or USFS fish biologist determines they are likely to adversely affect aquatic life, channel processes or function. High Risk Stability and Geo Hazards sites are included in this normal operating seasonal provision.

7.7 The objective is to maintain channel Evaluate channel incision risk (e.g. headcutting) and construct in- connectivity, reduce sediment loads by channel grade control structures in accordance with ARBO II and State reducing the risk of unwanted MOU (USDA, WA State 2012). headcutting upstream of roadwork.

7.8 Reduce risk of sediment delivery due to Road repairs associated with high risk stability stream segments which See Table in Fisheries Biological instability are within proximity to fish bearing streams should use special Assessment for road segments with provisions to reduce risk of future failure including: headcut, debris slide, special provisions surface erosion or mass movement. Of particular concern are road repairs with substantial quantities of fill replacement listed in Table 3. Road repair design should incorporate Geo Technical solutions and Aquatic resources special provisions to reduce risk of sediment delivery. Special Provisions should include but not limited to one or more of the following: Grade Control (GC), Toe Slope Stabilization (TS) or Surface Drainage (SD). High-risk road segments should receive a Level I Stability Assessment (LISA) or similar site stability assessment as per Gifford Pinchot Nation Forest Cumulative Effects Protocol (USDA 1988).

7.9 The objective is to protect fish including When working in fish bearing streams the project should follow the Fish “ TES species. Isolation Plan (WDFW MOU).

7.10 The objective is to promote fish habitat The Silver Thin stream crossing projects should restore natural drainage All stream crossings affected by Proposed including critical habitat for TES patterns (e.g. channel geometry, substrate and flow) and when possible Action species. promote passage of all fish species and life stages present in the area.

7.11 The objective is to protect waterways All applicable Forest Plan standards and guidelines will be followed, as General guideline and aquatic organisms. well as applicable administrative unit Best Management Practices and WA state findings and recommendations (Washington State Hydraulic Codes).

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

7.12 The objective is to maintain channel Road stabilization will retain Large Woody Material (LWM) typically All road segments proposed for Closure function and process. accumulated on culvert structures and channel margins. Material should and Stabilization in Proposed Action “ be repositioned on-site or integrated into stream restoration projects as identified by a Forest Service Fish Biologist to the benefit of aquatic species.

7.13 The objective is to maintain natural Remove rip-rap or other hard structures currently used in culvert “ channel function and process. protection (e.g. rock armoring at the inlet and outlet of the culvert) on decommissioning and close / stabilize crossings.

7.14 The objective is to maintain natural Any streambank stabilization deemed necessary following culvert “ channel function and process. removal shall use bioengineered solutions (such as root wads, log toes, coir logs, woody and herbaceous plantings).

7.15 The objective is to maintain water Use effective and appropriate erosion controls as necessary to ensure All sediment-generating activities quality and aquatic habitat. that the likelihood of sediment delivery to streams or other water bodies is negligible (See BMPs).

7.16 The objective is to maintain water Develop and carry an approved spill containment plan that includes All activities where fuel and other quality and aquatic habitat. having spill containment kit on-site and previously identified containment substances that may harm water quality locations. are needed for implementation.

8 Riparian Reserve Down Wood and Non-Commercial Thinning Projects

8.1 Provide instream sediment filtration Downed large woody debris should be evenly dispersed in the flood prone area in numbers consistent with the Late Seral Reserve (LSR) standards and guidelines (USDA 1997) at 240 linear feet per acre. Large wood will serve to moderate high flows and provide source of instream wood. Fell and retain whole tree down wood (>15 inches dbh) to provide adequate sediment filtration. All Riparian Down Wood and Riparian Non-Commercial Thinning units identified in Proposed Action

8.2 Integrate resource objectives An experienced silviculturist, botanist, ecologist, biologist or associated technician, shall be involved in designing vegetation treatments.

8.3 Minimize ground disturbance No roads or landings will be constructed or reconstructed. The objective is to minimize ground disturbance.

8.4 Promote structural diversity in stands Thin conifers to accelerate attainment of late-seral conditions within riparian areas in competitive exclusion developmental stages within plantations (i.e. where even-aged stands are growing because of previous silvicultural prescriptions).

8.5 Promote structural diversity in stands Thin dense understories resulting in even age plantation management to select for and promote survival of late-seral trees.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

8.6 Promote structural diversity in stands Trees felled within riparian area will be used to restore instream aquatic habitat and/or riparian l habitat by returning volume of large and coarse woody debris levels to within the range of natural variability.

8.7 Reduce disturbance to aquatic The treatment area is located outside of the bankfull channel and includes a twenty-foot no-cut buffer, which will leave ecosystems the trees immediately adjacent to the aquatic feature (wetland, stream) unaffected.

8.8 Promote structural development of trees Select leave trees to be released with diameter class in the top 10 % of stand average dbh or largest available trees. inside the riparian reserve.

8.9 The objective is to maximize down Select drop trees (down wood) with a minimum diameter of 12 inches dbh. When conditions permit trees up to 28 wood function. inches may be selected for down wood recruitment.

8.10 The objective is to maximize species Retain all minor species including western red cedar (), Alaskan yellow cedar (Callitropsis nootkatensis), diversity and promote ecological pacific yew (Taxus brevifolia), big leaf maple (Acer macrophyllum) red alder (Alnus rubra), spruce (Picea engelmannii), diversity. and black cottonwood (Populus trichocarpa).

8.11 Minimize ground disturbance and All felled trees within the riparian reserve will be left on site. Trees shall be dropped whole with tops intact. promote ecosystem diversity

8.12 The objective is to avoid incidental and Felled trees should be selected in areas inaccessible from roads (> 100 ft.) unless otherwise stated. unwanted harvest (e.g. firewood) where possible.

8.13 The objective is to avoid ground Work will be accomplished with hand tools (i.e. chainsaw), no heavy equipment allowed. disturbing activities and reduce the risk of sediment delivery.

8.14 The objective is to avoid ground The project will comply with limited operating period described by PDC 6.20 and 6.21 where relevant activities are disturbance during the rainy season and prescribed. reduce the risk of sediment delivery to water bodies.

8.15 The objective is to determine Conduct a post-project monitoring regime. effectiveness, evaluate additional treatment and ensure design goals and objectives have been met

9 Instream Habitat Restoration Projects

9.1 The objective is to promote channel Excavated material removed from the instream projects will be spread cross the adjacent floodplain in a manner that connectivity. does not restrict floodplain capacity.

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

9.2 The objective is to promote off channel Design project to naturally maintain inlet and outlet connections with the mainstream channel. habitat and relief channel function.

9.3 The objective is to reduce disturbance Should fish rescue occur, use fish handling criteria specified in the Aquatic Restoration Biological Opinion (ARBO II) to aquatic species. (USDI 2013).

9.4 The objective is to prioritize efforts and Bank restoration work will optimize effectiveness by concentrating effort on eroding stream banks, primarily the achieve restoration goals and outside edge of meander bends or areas deficient of large wood as per desired future condition (USDI 2013). objectives.

9.5 The objective is to effectively and Bank restoration projects will emulate the natural conditions to the extent possible and describe a reference channel efficiently restore channel form and conditions (width: depth ratio, radius of curvature, etc.). As possible, bank-stabilizing materials will emulate naturally function. occurring material found at that site (such as LW, woody and herbaceous plantings, native sedge and rush mats, or native rock).

9.6 Prevent erosion and limit potential for Jute matting or other biodegradable used in conjunction with plantings to help prevent erosion of affected banks waste in streams material should not contain mesh material that may function as a gill net if liberated into the channel.

9.7 The objective is to avoid ground The project will comply with limited operating period described by PDC 6.20 and 6.21 where relevant activities are disturbance during the rainy season and prescribed. reduce the risk of sediment delivery to water bodies.

9.8 The objective is to determine Conduct a post-project monitoring regime. effectiveness, evaluate additional treatment and ensure design goals and objectives have been met.

10 Pre-Commercial “Young Stand” Thinning Projects

10.1 Treat young stands with prescription - From healthy undamaged conifers to achieve the required average spacing of 12 ft. x 12 ft. to 18 ft. x 18 ft. Spacing and spacing guidelines to achieve will depend on management objectives such as timber or wildlife management and huckleberry regeneration; management objectives for site - If no healthy undamaged trees exist at the required spacing interval, leave a tree with minor damage; - If no healthy tree exists, leave the healthiest tree present, within spacing limits, regardless of species; - Trees will be selected in the following order for leave trees: a. White Pine; b. Alaska cedar; c. Noble Fir; d. Douglas- fir; e. Hardwoods; f. Western Hemlock; g. Other coniferous species

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# Objective Project Design Criteria or Mitigation Location (Road, treatment unit, etc.)

10.2 Protect water quality Refuel equipment (including chain saws and other hand power tools) at a location remote from water bodies (at least 100 feet distant) or use absorbent pads for immobile equipment to prevent direct delivery of contaminants into a water body. Set back as far as possible from the water body where local site conditions do not allow a 100-foot setback. Develop and implement an approved spill containment plan that includes having a spill containment kit on-site and previously identified containment locations. - A spill containment kit will be located where equipment is stored. Any accidental spills of a hazardous material (e.g. oil, fuel, transmission fluid) from any operating equipment or in place of storage on land or in water must be reported to the Gifford Pinchot National Forest. - Hydraulic/oil/fuel leaks will be repaired prior to operating on National Forest System lands. Truck equipment will be checked daily for leaks and any necessary repairs shall be completed prior to commencing work activities in or near stream channels. - Equipment storage locations will need to be away from any live streams by at least 100 feet. Equipment will not be stored adjacent to or in stream channels when not in use to avoid/minimize any potential effects of vandals, accidents, or natural disasters. - Motorized equipment such as 4-wheel ATV’s will not be permitted off existing transportation system roads.

10.3 Protect streams and water quality. Maintain a minimum 25-foot untreated buffer on ephemeral, intermittent, and perennial streams.

10.4 Limit wildlife disturbance • No chain saw or helicopter use will occur within the noise disturbance threshold distances from potential suitable marbled murrelet nesting habitat from March 1 to September 23. The distance disturbance thresholds that apply will be 65 yards for chain saw use and one mile for helicopter. • No project activities will occur from March 1 to July 15 to protect breeding migratory birds. Project activities will not occur in units above 4000 feet in elevation from March 1 to July 31 due to later nesting season at higher elevations. • There will be no project activity that includes the use of chain saws and helicopters from November 1 until July 15 in stands within mountain goat winter range. • No project activities that cause disturbance above ambient levels will occur from December 1 to April 1 in stands in deer and elk biological winter range (below 2200 to 2400 feet). • No project activities that produce noise above ambient levels will occur in stands adjacent to known active northern spotted owl pair activity sites from March 1 to August 31 or in stands adjacent to suitable northern spotted owl habitat from March 1 to July 15.

10.5 Protect wildlife habitat • Retain important hardwood species such as bigleaf maple and use thinning to “release” bigleaf maple where possible to promote growth. • Retain 1 or 2 clumps per acre of unthinned trees totaling approximately 1/10th acre within stands to provide habitat diversity and big game cover. (untreated riparian buffer areas are counted toward the 1/10th untreated acre per acre target)

40 Silver Creek Thin EA January 2017

Alternative- No Action Under the No Action alternative, no timber harvest, associated activities, or restoration projects would occur to accomplish project or Forest Plan goals within the Silver Creek subwatershed. Without action, stands may be expected to expand in tree size and density, although with reduced vigor and increased susceptibility to insects, disease, and other natural disturbance. In addition, wood products would not be provided and revenue would not be generated through timber or restoration projects associated with the Silver Creek Thin. Stands in Riparian Reserves would not be treated to improve quality and quantity of down wood and accelerate development of the remaining forest. In addition, the No Action alternative would not repair any roads beyond those prioritized and funded otherwise for minimal maintenance. No reconstruction, and no closure or stabilization would occur except as might happen “naturally” through lack of maintenance or use. Current use of the transportation network in the planning area would not change intentionally; although over the long-term public use of this system could decline due to decreased navigability over time. Alternatives Considered, but Eliminated from Detailed Study Federal agencies are required by NEPA to explore and objectively evaluate all reasonable alternatives and to discuss the reasons for eliminating any alternatives not developed in detail (40 CFR 1502.14). Public comments received, as well as preliminary effects analysis conducted by the interdisciplinary team suggested alternative methods for achieving the purpose and need. Some alternatives were outside the scope of this analysis, did not meet the purpose and need for action, were not reasonably feasible or viable, were duplicative of alternatives considered in detail, or were determined to cause unnecessary environmental harm.

Alternative to Reconstruct FR 47 Crossing at East Fork Silver Creek An alternative that included reconstruction of a stream crossing over the East Fork of Silver Creek on Forest Road 47 was not pursued due to preliminary analyses indicating that such a crossing, even if constructed to minimum specifications purely for temporary use during timber hauling, would not be economically viable. A permanent crossing constructed to modern engineering standards would be even more costly, exceeding anticipated road budget allocations and/or the ability for a timber sale or stewardship sale to afford. In addition, any crossing at that location would be subject to continued instability and damage or catastrophic failure in the event that heavy debris upstream dislodged during a major flood event.

Alternative to Harvest Timber without Restoration Projects An alternative to conduct only vegetation thinning without aquatic restoration projects was not evaluated because the prevailing direction for the project area supports a comprehensive range of vegetation and restoration activities to benefit terrestrial and aquatic ecosystems in addition to promoting the local economy. Numerous other restoration activities were proposed to benefit ecosystems in the project area, but were not analyzed due to practical considerations.

Alternative to Daylight Roads An alternative that included “daylighting” or the clearing of timber within a 20-foot swath on either side of timber haul roads was considered, in order to reduce subsequent road maintenance costs by allowing the road to dry more quickly and reducing buildup of debris in ditch lines and culverts. Daylighting would also stimulate growth of early seral vegetation, including

41 Cowlitz Valley Ranger District

huckleberries in some areas, meeting a variety of public interests such as berry picking and hunting. This alternative was not carried into full analysis because daylight treatments would only be permitted outside of riparian reserves in order to reduce potential adverse effects to habitat and water quality; however, by eliminating reserves from daylighting, the potential benefits to road maintenance cost would be marginal. In addition, there was not determined to be sufficient timber volume on haul routes to make the activity commercially viable for a timber purchaser to complete.

Alternative to Conduct Proposed Action without any Construction or Reconstruction of Non-system (temporary) Roads The interdisciplinary team endeavored to minimize the need for temporary roads in the Proposed Action while still meeting the purpose and need to provide a sustainable supply of timber to the local and regional economy. However, to provide access to sufficient timber volume from the project area to meet this need it was necessary to include some temporary roads in the Proposed Action. Where site- and road-specific resource concerns were raised through internal or external scoping and review, the team was able to resolve them by revising silvicultural prescriptions, requiring project design criteria, or by dropping units or portions of units, resulting in a single proposed action rather than multiple alternatives to meet the purpose and need of this project.

Finally, there are many more restoration activities that would benefit ecosystems in the project area, but they were not analyzed due to practical considerations.

42 Silver Creek Thin EA January 2017

Environmental Impacts of the Proposed Action and Alternative This section summarizes the potential impacts of the Proposed Action and No Action alternatives for each impacted resource. Each resource area discloses the direct, indirect, and cumulative effects of the Proposed Action, providing the existing condition and desired future condition as reference points.

The Environmental Assessment hereby incorporates by reference the project record (40 CFR 1502.21). The project record contains specialist reports, biological evaluations, biological assessments, and other technical documentation used to support the analyses and conclusions in this EA. The record includes specialist reports for vegetation resources, road conditions, geology and soils, hydrology and water quality, fisheries, wildlife, botany and invasive plants, recreation, visual quality, fuels, and heritage resources. Full versions of these reports and supplemental data are stored electronically and hard copy at the Cowlitz Valley Ranger District office in Randle, Washington. General Comments Regarding Cumulative Effects Each resource section that follows discusses cumulative effects to evaluate measurable effects from the action alternative combined with past, present and future actions that overlap in space and time. In order to understand the contribution of past actions to the cumulative effects of the Proposed Action and No Action alternatives, this analysis relies heavily on current environmental conditions as a proxy for the impacts of past actions. This is because existing conditions reflect the aggregate impact of all prior human actions and natural events that have affected the environment and might contribute to cumulative effects.

Activities considered in the cumulative effects analysis are shown below (Table 4). Note that the past, present, and reasonably foreseeable future activities relevant to each resource may differ, because the appropriate scale for evaluating effects varies for each resource.

Table 4: Actions Considered in Cumulative Effects Analysis

Action Description Date

PAST

Timber harvest within Managed stands were clear-cut harvest, followed by planting. 1940s onward and adjacent to the units

System and non- Roads constructed for previous logging and other land-management 1940s onward system road activities. System roads have undergone varying levels of construction maintenance depending on forest priorities and funding. Non-system roads are generally naturally recovering to native vegetation, but may contain crossing and culverts, and be subject to unauthorized use.

PRESENT

National Forest Maintenance and management of system roads on lands within the Ongoing System roads listed subwatersheds. Roads exist at relatively high density and are maintained as priorities and funding allow.

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Action Description Date

Special forest products Commercial harvest, sale, and free use of forest products create soil Seasonal harvest disturbances away from system roads and may introduce contaminants and invasive species. Relatively low extent and effect in this watershed.

Forest Trails, Management of forest trails including erosion work, route signing, Ongoing unauthorized trails and maintenance. User-created trails and dispersed recreation disturbs soils and reduce soil quality. There are relatively few trails in this subwatershed.

FUTURE

Road closure and Forest Service road system that is feasible to maintain will likely 2015 and decommissioning decline with budget. Ongoing Forest-wide travel analysis will result beyond in prioritization process to include assessment of risk to public safety, aquatic and terrestrial resources, and the need to maintain access for resource management and public access.

Timber harvest outside State and private lands adjacent to National Forest boundary within Unknown National Forest the Silver Creek watershed may be harvested for timber. System lands

Global climate change Significant changes to atmospheric conditions that could affect Ongoing and vegetation, soil temperature, and moisture regimes. Increased uncertain temperatures, more extreme precipitation events, and lower through and snowpack with altered timing of snowmelt are likely. beyond 21st century

Setting Physical Silver Creek Thin planning area is located within the Silver Creek subwatershed in the north part of the Middle Cowlitz Watershed. The planning area is within National Forest, however approximately 10,000 acres of private and state land occur within the National Forest boundary.

Elevations range from 1900 feet (Unit 38) half a mile north of Kehoe Mountain to 4,500 feet (Unit 7) a mile west of Cougar Gap.

Almost all stands proposed for thinning are young, dense stands (managed plantations) regenerated through timber harvest, broadcast burning and subsequent planting between 1955 and 1975. Unit 29 is the exception, being an older stand originating from 1930.

The project area is located in the Western Washington Cascades Physiographic Province (Franklin and Dyrness 1973). The location is such that climatic elements combine to produce a predominantly marine- climate. The effects of various climatic controls can produce entirely different conditions within short distances. Annual precipitation in the project area is 70 to 100 inches with a majority of that in the

44 Silver Creek Thin EA January 2017 form of snow. Topography of the area ranges from valley bottom and toe slopes to steep, smooth or dissected sideslopes with grades from flat to 80%. See Table 5.

Table 5: Silver Creek Thin treatment unit physical setting Unit Number Average Slope Gross Acres Elevation (ft.) Aspect (Stand ID) (%) 1 (522) 26 3698 29 North 2 (9108) 103 3775 30 North 3 (33) 8 3343 6 South 4 (9040) 69 3258 11 Southeast 5 (9041) 20 3394 39 East 6 (9029) 90 2943 31 Southwest 7 (35) 31 4500 31 South 8 (1453) 33 3652 35 South 9 (323) 23 3933 45 West 10 (9570) 43 2840 44 South 11 (9594) 574 2547 5 Flat 12 (9581) 22 2418 43 South 13 (9579) 20 3172 7 South 14 (9593) 260 2960 19 South 15 (31) 267 2960 19 South 16 (9626) 22 2854 22 South 17 (9592) 389 2155 4 West 18 (9561) 98 2644 29 West 19 (9584) 30 2817 43 West 20 (9625) 113 2707 36 North 21 (9558) 56 2298 26 West 22 (9559) 8 2162 9 West 23 (9585) 5 2136 2 Flat 24 (9586) 51 2015 23 North 25 (9588) 23 1917 11 West 26 (41) 38 1990 8 West 27 (43) 101 1990 8 West 28 (9541) 255 1990 8 West 29 (9053) 50 2231 23 Flat 30 (9545) 38 1822 59 West 31 (18) 134 1990 19 South 32 (9051) 33 2111 31 East 33 (9620) 6 2372 43 Northeast 34 (9534) 29 2037 34 North 35 (9533) 93 2204 33 North 36 (9540) 23 3346 20 East 37 (9591) 286 2595 30 East 38 (9524) 8 1899 39 South Total 3478

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Disturbance Regimes Wildfire has historically been the most important forest-destroying agent near Mount Rainier with a correlation between major episodes of fire and periods of prolonged drought (Franklin et al. 1988). Natural fire return intervals of this area are between 200 to over 400 years has shaped a complex mosaic of stand structures across the landscape. More recently, timber harvest has replaced fire as the primary agent affecting change in forest conditions (USDA 1999). Wind throw from winter storms or small downbursts is a minor landscape component and appears to function as an agent of small-scale, within- stand disturbance. Insects and disease behave similarly. Active landslides and potentially unstable slopes are common throughout the Silver Creek Thin planning area.

Landscape Pattern Structural stage describes forest stand conditions on the basis of tree size and canopy diversity and can be the basis by which landscape pattern is determined. Structural stage can also relate to the successional phase of a stand or group of stands. Succession is the process by which a plant community’s species composition and size change over time in response to [or lack of] disturbance (USDA 1997). For this analysis, several structural stages are defined as follows (O'Neil et al. 2001):

• Sparse (CANCOV < 10%)

• Open (CANCOV 10-40%)

• Sapling/pole - moderate/closed (CANCOV > 40, QMD_DOM < 25 cm [10 inches])

• Small/medium tree - moderate/closed (CANCOV >= 40, QMD_DOM 25-50 [10 – 20 inches])

• Large tree - moderate/closed (CANCOV >= 40, QMD_DOM 50-75 [20-30 inches])

• Large/giant tree - moderate/closed (CANCOV >= 40, QMD_DOM >= 75 [>30 inches])

Landscape NFS OTHER

Structure Class % Total Acres % Acres % Acres

Non-Forest 1% 431 0% 108 3% 323

Sparse 2% 562 2% 358 2% 204

Open 7% 2,295 7% 1,618 7% 677

Sapling/Pole 35% 11,582 31% 7,058 45% 4,525

Small/Medium Trees 35% 11,660 34% 7,762 39% 3,898

Large Tree 12% 3,911 15% 3,460 4% 450

Large/Giant Trees 7% 2,412 10% 2,371 0% 41

Totals 100% 32,853 100% 22,734 100% 10,119

46 Silver Creek Thin EA January 2017

Plant Communities The treatment units are part of the western hemlock zone (Topik et al. 1986) and Pacific silver fir zone (Brockway et al. 1983). In the western hemlock zone, western hemlock () is the climax species, Douglas-fir (Pseudotsuga menziesii) the major seral species and western redcedar (Thuja plicata) is prominent. Hardwoods such as red alder (Alnus rubra) and big leaf maple (Acer macrophylla) are minor species while noble fir () and Pacific silver fir () are rare but considered minor seral and climax species respectively. Most treatment units in this zone are herb-rich with the exception of the western hemlock/salal plant association, which has an abundant shrub layer but is herb-poor. See Table 6 for a summary of plant association attributes.

In the Pacific silver fir zone the proportion of precipitation as snow versus rain, variation in soil and air temperature, and soil drainage and fertility characteristics produces a variety of environmental conditions resulting in a diversity of plant associations (Brockway et al. 1983). Pacific silver fir is the major climax specie but Douglas-fir is fairly ubiquitous across all associations in this zone with its long life span, lightweight seed and adaptiveness. Noble fir is erratic in distribution due to heavy seed and relatively short life span. Western redcedar is a warm site indicator that, along with western white pine (Pinus monticola), occurs sporadically while Englemann spruce (Picea englemannii) is generally found in frost pockets.

Table 6. Plant Associations of the Silver Creek Project (Topik et al. 1986 and Brockway et al. 1983) Plant Association Site Timber Opportunity Site Project Units Characteristic Productivity* For Intensive Index- Management 100 Year Base Age Western hemlock/Alaska Moist, cool, 130 Good 135 36 huckleberry/dogwood lower slopes (DF) bunchberry(CHS615) Western hemlock/devil’s Moist, lower 192 Good 172 30 club/swordfern(CHS524) slopes (DF) Western hemlock / Moist and 191 Excellent 161 10,16,22,24 swordfern (CHF125) warm, lower (DF) slope positions Western hemlock / dwarf Mesic and 162 Excellent 142 17,18,21,23,25,26,28, grape/swordfern warm, (DF) 29,31,32,34 (CHS126) widespread Pacific silver fir / coolwort Mesic and cool, 147 Good 122 5,12 foamflower (CFF152) benches and (DF) upper slopes Pacific silver fir / devil’s Wet, low to 166 Low 132 1 club (CFS351) mid-slopes (DF) Pacific silver fir / Alaska Mesic and cool, 105 Good 111 2,9,13,33 huckleberry (CFS257) mid-slopes (DF) Pacific silver fir /big Moist and cool, 101 Moderate 93 7 huckleberry-queencup mid to lower (DF) beadlilly(CFS256) slopes Pacific silver fir / salal Warm, mid to 100 Good 91 8,11,19-20,37,38 (CFS152) lower slopes (DF) Pacific silver fir / dwarf Warm, mid to 73 Moderate 78 3,4,6,14,15,27,35 Oregon grape (CFS151) lower slopes (DF) *capability of site to produce timber at culmination of mean annual increment (cubic feet/acre/year)

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Soil Resources

Existing Condition

Geomorphology and Soil Types Gifford Pinchot National Forest (GPNF) Landtype Association mapping (USDAFS GPNF 1999b, gplta) classifies landforms occupied by the Silver Creek Thin project as:

• Steep Mountain Slopes

• Gently Sloping Uplands

• Glacial Cirques

• Glacial and Lahar Valleys

• Glacial Valleys, U-Shaped

• Uneven, Hummocky Slopes and Earthflows

The Soil Resource Inventory (Wade, et. al., 1992 and USDA FS, 1971) mapped soils in this area. “Soil Management Guidelines, Gifford Pinchot National Forest” (Dec. 17, 1977), as amended, will apply unless on-the-ground assessment indicates a change in the guidelines is necessary. Soils in proposed timber sale units are suitable for timber harvest, in alignment with timberland suitability classification (FSM 2415.2). Unstable slopes are withdrawn from the timber base in Soil Mapping Unit (SMU) 54F if they are assessed and deemed unsuitable for vegetation management because of resource risk. Current site-specific soils information in the project area was collected through field visits. Soil mapping was modified for accuracy at the project scale, reflecting field observations and GIS analysis. The soil scientist conducted field visits in 2014.

Soils within the project area were formed mostly in basalt bedrock, colluvial andesite and breccia, volcanic sediments, and glacial till (Table 7). Silver Creek Thin contains 35 SMUs or complexes across approximately 3500 acres of timber units. Gently sloping valley bottoms and benches of SMU 1, 12, 15, 17, 29, 36, and 58 occupy approximately 960 acres (28%) of the units, while steep slopes from SMU 16, 18, 31, 35, 37, 41, 42, 51, 52, and rocky soils occupy 1,980 acres (57%) of the units. Approximately 525 acres (15%) of the units occupy unstable soil mapping of SMU 54, 54F, 5654, and 57.

Table 7: Summary of soil characteristics in Silver Creek Thin project area (Wade, et al. 1992) Soil Map Surface Unit Acres in Erosion Displacement Compaction Regeneration (SMU) Project Area Fertility Potential Potential Potential Potential 1 1.3 Low Slight Low Low N/C (alluvium) Low- 12 539.8 Slight High Low-Moderate Moderate Moderate 15 172.8 Moderate Slight Moderate Moderate Moderate 16 39.2 Moderate Moderate N/A N/A Moderate 1641 493.7 (blank) Moderate N/A N/A Moderate 17 58.7 Low Slight Moderate Moderate Low-Moderate Low- 29 5.8 Moderate High Moderate Low-Moderate Moderate

48 Silver Creek Thin EA January 2017

Soil Map Surface Unit Acres in Erosion Displacement Compaction Regeneration (SMU) Project Area Fertility Potential Potential Potential Potential 31 120.8 Low Moderate N/A N/A Low-Moderate V. 35 85.6 Low N/A N/A Moderate-Low Severe 37 267.8 Moderate Severe N/A N/A Moderate 41 453.5 Low Moderate N/A N/A Low-Moderate 4116 146.2 (blank) Moderate N/A N/A Low-Moderate 4140 2.1 Low Moderate N/A N/A Low-Moderate 41T 3.4 Low Moderate N/A N/A Low-Moderate 4216 49.2 (blank) Moderate N/A N/A Low-Moderate 4240 3.5 Low Moderate N/A N/A Low-Moderate 51 74.4 Low Moderate N/A N/A Moderate 5116 141.9 (blank) Moderate N/A N/A Low-Moderate 5150 4.5 Low Moderate N/A N/A Low-Moderate 52 1.1 Low Moderate N/A N/A Moderate 5216 97.8 (blank) Moderate N/A N/A Low-Moderate 5250 16.1 Low Moderate N/A N/A Low-Moderate 54 294.4 Moderate Moderate High Moderate Moderate 54F 39.5 Moderate Moderate High N/A Moderate 5654 149.5 Moderate Moderate High Moderate Moderate 57 45.7 Moderate Moderate High Moderate Moderate-High Low- 58 201.1 Moderate Moderate Moderate Moderate Moderate 7 (rocky) 8.0 Low Moderate N/A N/A Low

Fifteen of the eighteen soil types, or 55 percent of project acres, have a moderate potential for surface erosion when exposed. Surface erosion potential rating applies when a disturbance removes all vegetative cover, including litter. Sufficient ground cover would protect against soil displacement and erosion.

Ground-based, off-road equipment is not recommended on unstable slopes or steep slopes. Implementation of Project Design Criteria listed with the Proposed Action would provide sufficient ground cover for soils in the Silver Creek Thin project to prevent excessive soil displacement and erosion.

Soil Disturbance Calculations and Assumptions The extent of National Forest System roads was estimated using GIS analysis and included roads within and adjacent to each unit. Temporary roads and landings were also mapped and approximated using GIS.

For calculating acres of roads, National Forest System roads were assumed 6 meters wide, depending on field observations. Ground based logging landings were assumed one-quarter acre in area, helicopter landings one acre, and skyline-logging landings were one eighth of an acre. GIS data is available in the project file.

Landforms in the units were examined and used to adjust SRI map unit locations at a finer scale where appropriate. SMU polygons clipped by GIS software within units that were less than 0.1 acres total in a unit (because of the GIS operation) were merged with an appropriate SMU adjacent to it within the unit boundaries (Table 7).

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No soils mapped in corporate GIS layers as “unstable” were found to be stable during field investigations. Minor updates to mapping of landforms sometimes change unstable soil polygons, but larger areas look similar to original mapping.

Logging Equipment on Steep Slopes Proposed Action includes allowing the use of mechanical cutting and harvesting machines to fell, limb, and bunch logs on slopes up to 45% within the harvest units, slopes that are rated in the 1992 Soil Resource Inventory (Wade, 1992) as not permitting tractor logging.

Ground-based logging operations (use of mechanical cutting and harvesting machines) would be considered on a case-by-case basis on slopes up to 45 percent, rather than being limited to 35 percent. The equipment would travel downhill on slash beds through the units, not bearing the weight of logs as they travel, and return uphill on roads or gentle slopes approved by the Forest Service, as described in the Soils and Aquatics Mitigation Measures and Design Features.

Mechanical cutting and harvesting component of logging is a relatively low impact step in the entire process. Mechanized felling, limb removal and bunching does not cause soil disturbance associated with movement of the logs, as compared to skidding. Skidding is physically removing trees from a stand by dragging the logs or driving equipment while bearing the logs’ weight in ground based logging operations.

Professional opinion is that use of mechanical cutting and harvesting machines would not represent an increase in the intensity of losses to soil quality because design features would minimize disturbance by the equipment. Project Design Features specify one pass occurring on approved locations that have minimal dynamic and static load for the operations involved. Losses to above ground vegetation growth would likely be short-term based on the more prevalent Forest wide experience with similar activity on gentler slopes. Design features would prevent erosion and mass wasting, and would minimize compaction and displacement. Mechanical cutting and harvesting machines may reduce the effect of skidding trees by positioning them more accurately for retrieval by skidding, helicopter, or cable system equipment.

Professional judgment in support of mechanical cutting and harvesting was informed by field reviews, literature reviews, and discussions with Forest Service employees who are experienced with logging equipment and resulting ground conditions. Examples include:

1. Acceptable or good results on volcanic soils of the East Fork Lewis River and Wind River watersheds observed during field reviews of feller-buncher use. Field reviews of feller-buncher use by Forest Service Soil Scientists on two separate visits showed acceptable or good results on local volcanic soils. 2. Review of literature such as SDTDC Publication #9451 1206, Steep Slope Logging Slash Treatment, gave insight into the abilities of available logging equipment, including the slope limit given in the Forest Plan amendment. 3. Email communication with soil scientists across the Region to make use of their collective knowledge and experience with effects of mechanized equipment on soils.

Soil Productivity and Soil Quality Evidence of ground based logging and other forest product harvest and recreational use exists within the activity area boundaries. Non-system roads and landings created by past timber harvest and not rehabilitated have low to moderate compaction on older, overgrown roads and landings, and moderate to severe soil compaction on heavily used or heavily rocked non-system roads and landings.

50 Silver Creek Thin EA January 2017

Many of these areas are recovering from extensive detrimental soil impacts from previous land management. This analysis assumes that soils in the project area that have already been degraded exist in the project area have also lost soil productivity for the long-term (greater than fifty years).

System Roads The analysis considered system roads to have soils in a non-productive condition in the long-term. Most of the precipitation that falls on a compacted surface becomes surface runoff. The area of system road was estimated using GIS analysis and includes roads within and adjacent to each unit boundary.

National Forest system and non-system roads currently occupy between zero and approximately 9 percent of any unit, as shown in the “Existing Disturbance” column of the table below. This estimate includes verified remnant logging roads and landings, non-field verified estimates of temporary roads, and system roads. Non-system road ranges from zero to approximately 6.7 percent of the area in proposed treatment units.

Timber Harvest Timber harvest occurred historically within and adjacent to Silver Creek Thin project activity areas. Managed stands were clear-cut harvested, followed by planting. Management practices at that time did not restrict machine movement, skid trail density, removal of woody debris or intense burning; therefore detrimental effects to soil were sometimes higher than what Forest Plan standards and guidelines currently recommend. These detrimental conditions continue to exist on the ground in various stages of natural recovery.

Non-System Roads and Landings Compaction on non-system roads, skid trails, and landings range from minimal to severe, with moderate to severe compaction is most prevalent on arterial logging roads, where observed.

Table 8: Extent of detrimental soil conditions (as approximate percent of units)

Old Logging Silver Creek Thin Unit Existing Disturbance*, including Unit Acres Roads & Landings Number System Roads (%) (%)

1 26 5.3 7.8 2 103 4.5 5.2 3 8 4 69 3.5 4.0 5 20 6.7 9.0 6 90 2.0 2.0 7 31 6.5 6.5 8 33 1.4 2.5 9 23 5.0 6.1 10 43 2.6 2.6 11 574 2.5 2.6 12 22 1.7 1.7 13 20 1.9 1.9 14 260 2.7 2.9 15 267 2.9 3.5 16 22 5.0 6.1

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Old Logging Silver Creek Thin Unit Existing Disturbance*, including Unit Acres Roads & Landings Number System Roads (%) (%)

17 389 3.5 4.1 18 98 3.2 3.2 19 30 3.4 3.4 20 113 2.9 3.0 21 56 0.7 0.7 22 8 3.1 3.1 23 5 24 51 2.6 2.9 25 23 5.5 5.5 26 38 2.9 3.5 27 101 3.3 4.4 28 255 3.7 4.3 29 50 2.0 2.0 30 38 3.3 3.3 31 134 2.4 2.5 32 33 4.1 4.1 33 6 34 29 4.0 4.9 35 93 4.5 5.3 36 23 0.3 0.5 37 286 2.0 2.2 38 8 0.4 0.8 Max% 6.7 9.0 Min% (where not zero) 0.3 0.5 *Includes logging roads and landings, unverified estimates of roads, and National Forest System roads.

Slope Stability Two main sources of data were used to analyze effects to slope stability for the Silver Creek Thin EA: GPNF Forest “GeoHaz” data (USDA 1999) and a compiled subset of the Gifford Pinchot Soil Resource Inventory (Wade, et. al. 1992) that isolates potentially unstable soils. Photo interpretation indicated isolated, actively moving landslides within the units. Further, Forest Service soil scientist and experienced aquatics technicians visited units and noted mass wasting in field reports.

Active mass wasting is common throughout the units above Silver Creek, Willie Creek, Lynx Creek, and Lake Creek. Of the 38 proposed units in Silver Creek Thin, 28 contain mapped active landslides or potentially unstable soils.

Active Mass Wasting Natural and management-related active slides are inventoried (USDA 1999) in 22 Silver Creek Thin units (not counting those with only unstable ratings in SRI mapping), and are given specific mitigation to address potential for causing a management related mass wasting event.

Active landslides and recent debris flows would be excluded and buffered from vegetation management, to conform to definitions in the NW Forest Plan Riparian Reserves (NWFP ROD1994); the buffer in this

52 Silver Creek Thin EA January 2017 area was defined as 180 feet from the edge of the slide (see Project Design Criteria for complete list of buffers). Aerial photography revealed a mantle failure in Silver Creek Thin Unit 30 (Figure 8).

Figure 8. Aerial view of Silver Creek Thin Unit 30, June 2006 (top) and June 2009 (bottom)

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Roads Contributing to Resource Damage Forest Roads 75 and 7561 exhibit damage from past debris flows that likely resulted in aquatic resource damage from fill sediment washing into major streams. Sections of these roads are not currently drivable and will be drivable as part of the proposed action (Rockey 2015).

Relevant items from the proposed action (access) considered here include:

22. Repair washouts and replace culverts at mileposts 4.8 and 5.5 of FR 7500000. Reconstruct roadway at MP 1.8 and 2.3 including ditch, shoulder, surface and embankment repair.

23. Un-bury culvert at milepost 1.08 and repair washouts and replace culverts at mileposts 1.25 and 1.3 of FR 7561000.

A site visit by GPNF Forest Geologist to Forest Road 75 milepost 4.8 highlighted a significant management decision regarding road reconstruction on a geologic hazard site. A 2015 site visit report (Dryden 2015) describes a reconstructed crossing downstream of “a steep channel with exposed soils that could lead to another debris flow.” The report concluded that a decision to reconstruct lies in whether “the value of being able to access the timber beyond the failure and restore access in general exceeds the cost of reconstruction at the site,” which will be “subject to the same hazard that destroyed the previous crossing after it had provided decades of service.”

Recommendations for repair on washouts that are likely to reoccur include features that will minimize additional sediment transport to surface waters:

• Replace crossings with a minimal volume of road fill. Suggestions include following the contour and installing a large or open-bottom culvert. A large culvert will also allow for high precipitation flood events that do not result in a debris flow. • Build with a low profile or “dip” that will allow passage of debris over the road, such as the key feature in a ford. In other parts of the watershed, active restoration and reconstruction activities would help reduce sediment input from roads. The Proposed Action would change a few Level 2 roads (open) status to Level 1 (Closed and stabilized) for hazardous sections of Forest Roads 4778000, 4778011, 7561018 and 8500108. Reconstruction items in the proposed action that address these issues include:

19. Repair washouts and replace culverts at milepost 0.39, 0.42, 0.46, 0.87 and 0.91 of FR 4778000

20. Reconstruct length of FR 4778011 including ditch, shoulder and surface repair and culvert replacement at mileposts 0.56 and 0.6.

Natural Stability Risk Rating Gifford Pinchot National Forest NEPA Assistance for the Soil Resource (Wade, et. al. 1992b) classified SRI Natural Stability ratings from Low Risk to Very High Risk as defined below. The SRI defines the Natural Stability rating as “based on the relative stability of the mapping units as they occur in the natural state. This includes any movement or loss other than surface erosion, by slumps, slides and all kinds of deep-seated failures” (Wade 1992).

a) Very High Risk – Generally, Class IV or V Natural Stability Rating, SMU 54F. Sometimes designated as unsuited (for timber management) and removed from timber base via GP FSH 2409.13, Chapter 20 when the SMU is given a suffix "F,” and thus is taken out of the timber base per the “Timber Land Classification.” [Applies to 39 acres in Silver Creek Thin Units 17 and 25.]

54 Silver Creek Thin EA January 2017

b) High Risk – Generally, Class IV or V Natural Stability Rating, SMU 54 and 5654. May be unsuited - has most of the characteristics of slumps and landslides (characterized by erratically leaning trees, slumping topography with bare headwalls, sag ponds and over-steepened pressure ridges, tension cracks; often with riparian vegetation, seeps, and ponds); some timber harvest may occur by individual tree selection, small group selection, or very small CC [Clear Cut]; generally, no roads should be built in these areas - involve Geotech Group and Soil Scientist. These specialists may more accurately map the area and help develop the necessary documentation to move the area to the Very High Risk by GP FSH 2409.13. [Applies to 439 acres in Silver Creek Thin Units 15, 16, 17, 24, 31, 32, 34, and 35.]

c) Moderate Risk – Generally, Class III or IV Natural Stability Rating, SMU 57. Some characteristics of slumps and landslides are evident, careful road location and sale design will allow some timber harvest - involve Soil Scientist. [Applies to 44 acres in Silver Creek Thin Units 15, 17, and 35.]

d) Low Risk – Class I, II, and III Natural Stability Rating. Few if any characteristics of slumps and landslides are present, planned timber harvest design to fit the ground situation can take place. Remember to consider other interpretations. [Applies to all units of Silver Creek Thin.]

Soil Resource Inventory Interpretations for Natural Stability in Soil Map Units 54, 56 and 57 The Soil Resource Inventory identifies approximately 475 acres of potentially unstable areas in proposed project units that include SMU 54, 54F, 5654, and 57. Approximately 100 of those acres occupy the same area as active landslides found through Geohazard mapping or field verification.

Active landslides, whether overlapping with SRI unstable mapping or not, occupy approximately 305 acres within units of the proposed action.

Forest Soil Scientist professional judgment is that the timber harvest prescriptions in the proposed action would mitigate effects to landslide potential in those units listing a “regular thin” or gap avoidance. Some units were field verified by a soil scientist, many of these units showed characteristics of mass wasting.

SMU 54, 57, and 5654 are characterized as High Risk. Project design has resulted in approximately 780 acres of buffers that were modified because of unstable soil mapping and field verification (Table 9).

Recommendations for management on potentially unstable soils mapping includes exclusion of off-road, ground-based equipment on steep slopes (e.g. feller-bunchers) and a light to moderate thin silviculture prescription, as specified in Project Design Criteria. No roads would be built in these areas and road reconstruction plans should avoid entering the unstable areas.

Table 9: Unstable Soils Buffers, Design Features, and Mitigation Measures

Silver Stability Creek Risk Buffer Thin Unit Acres Rating Reason Design Feature and Mitigation Measure

Active Avoid new road construction. Area 11 63.2 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 13 1.0 High Landslide enclosed within no-cut buffer. Mapping

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Silver Stability Creek Risk Buffer Thin Unit Acres Rating Reason Design Feature and Mitigation Measure

Active Avoid new road construction. Area 14 23.8 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 13.6 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 15 2.7 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 52.4 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Avoid new road construction. Light to Moderate Unstable Soil 16 8.5 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Active Avoid new road construction. Area 11.2 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 60.1 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 137.4 Regular thin (retain at least 50% canopy 17 to High Mapping cover) will allow some timber harvest. Unstable Soil Mapping (54F) classified Avoid new road construction. Area 19.2 High area as enclosed within no-cut buffer. unsuitable for timber harvest Active Avoid new road construction. Area 18 2.3 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 19 13.3 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 20 14.9 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 21 1.1 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 22 2.5 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 1.3 High and Unstable enclosed within no-cut buffer. 24 Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 28.0 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest.

56 Silver Creek Thin EA January 2017

Silver Stability Creek Risk Buffer Thin Unit Acres Rating Reason Design Feature and Mitigation Measure

Active Avoid new road construction. Area 25 1.3 High Landslide enclosed within no-cut buffer. Mapping Unstable Soil Avoid new road construction. Area 0.4 High Mapping enclosed within no-cut buffer. Active Avoid new road construction. Area 26 11.3 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 27 22.3 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 28 8.8 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 29 10.3 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 30 9.8 High Landslide enclosed within no-cut buffer. Mapping Active Avoid new road construction. Area 3.0 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 31 16.2 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 80.1 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Active Avoid new road construction. Area 2.3 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 32 1.0 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 2.6 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Active Avoid new road construction. Area 9.9 High Landslide enclosed within no-cut buffer. Mapping Both Active Landslide Avoid new road construction. Area 34 7.8 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 1.4 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Active Avoid new road construction. Area 35 10.6 High Landslide enclosed within no-cut buffer. Mapping

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Silver Stability Creek Risk Buffer Thin Unit Acres Rating Reason Design Feature and Mitigation Measure

Both Active Landslide Avoid new road construction. Area 39.0 High and Unstable enclosed within no-cut buffer. Soil Mapping Avoid new road construction. Light to Moderate Unstable Soil 16.8 Regular thin (retain at least 50% canopy to High Mapping cover) will allow some timber harvest. Active Avoid new road construction. Area 37 68.1 High Landslide enclosed within no-cut buffer. Mapping Total 779.4

Summary of Existing Condition Existing detrimental soil conditions in the project area have reduced soil productivity in the long-term (greater than fifty years). Soils within the project area were formed mostly in eroded andesite and breccia bedrock, volcanic sediments, and glacial till.

Ground-based timber harvest have altered soil properties and potentially decreased soil productivity in the planning area. Damage to soil physical properties on skid trails and landings has recovered over time, but management activities did reduce soil quality where ground-based skidding operations displaced organic surface layers or caused deep compaction.

The analysis estimates existing detrimental conditions are within the 20% Forest Plan Standard for soils (USDA 1990) in all 38 units proposed for timber harvest in this Proposed Action. Compaction on old logging roads, skid trails, and landings ranges from minimal to severe, with moderate to severe compaction being most prevalent on arterial logging roads.

Field investigations revealed features indicating new landslide activity in Units 11, 14, 15, 17, 19, 20, 22, 26, 27, 28, 30, 34, 35, and 37 that the Forest “GeoHaz” corporate GIS layer (USDA 1999) did not show. Landslides and debris flows discovered would be excluded from harvest and assigned no-cut buffers extending to 180 feet away from the active mass wasting feature.

Desired Future Condition (DFC) The Soil Management Objective is to maintain or enhance soil productivity by avoiding long-term detrimental physical and biological soil conditions. Desired conditions include stable soils, controlled erosion, reduced flood potential, improved long-term soil productivity, and a stable drainage network, while implementing land and resource management activities. Soils on system and some non-system roads and landings will not likely return to pre-harvest conditions in the near future.

Effects

No Action There are no direct effects of choosing the No Action alternative. No further losses or gains in soil productivity in the short-term or long-term are expected in this alternative, other than from unrelated activities of other forest management such as trail maintenance, or extraction of special forest products. Detrimental conditions already in the units would remain, ranging from zero to 9%. Existing National

58 Silver Creek Thin EA January 2017

Forest system roads and landings would not be restored and would remain in a detrimental condition for the near future.

Recovery of soil productivity would be slower with no action than the proposed action on areas where decompaction and rehabilitation would occur, and the time needed to reach the desired future condition would take longer without the treatment. Detrimental soil compaction and displacement would remain localized to existing system and non-system roads, trails, and landings.

Under No Action, addressing unauthorized and authorized road issues in the area through decommissioning or restoration would not occur.

In the long-term, soil quality may continue to improve towards the level that existed before management disturbance, but the rate would largely be dependent on vegetation roots’ growth, the resilience of the soil and intensity of the disturbance.

Soil displacement and erosion on existing skid roads would endure for the long-term because soil formation is a slow process, on the order of hundreds of years or more.

Timber Harvest The No Action alternative would involve less new ground disturbance than the Proposed Action. No increase in detrimental soil conditions in the units would occur and no change in soil productivity due to logging related compaction and displacement would occur. Existing non-system logging roads and landings would not be used or restored, and would likely remain in a detrimental condition for the foreseeable future.

Slope Stability The considerable risk of management-induced landslides would continue as before, related to past, present or ongoing, or future actions authorized in other decisions. Sediment transport into surface water will continue to occur from landslides and other disturbances that cause bank erosion, channel scour and channel migration (McConnell 2015). The rate size or number of mass wasting events would not change with the no-action alternative.

Cumulative Effects of No Action Alternative Foreseeable management activities would be, in general, similar to the proposed action alternative. No cumulative effects to soil productivity would occur because there would be no increase in the amount of detrimental soil conditions in the long-term. The no-action would not involve increasing the permanent transportation system.

Summary of Effects There are no direct effects of choosing the No Action alternative. No further losses or gains in soil productivity in the short-term or long-term are expected in this alternative. The risk of management- induced landslides would continue to be very low. The rate, size, or number of mass wasting events would not change with the No Action alternative.

Proposed Action Direct effects due to soil disturbing activities would occur on site and affect only the immediate areas where soils are compacted, displaced, or severely burned. Potential effects of the proposed activities on soil productivity are due to compaction, puddling, displacement, erosion, severe burning, and loss of soil organic matter. The calculations of detrimental conditions related to timber harvest include calculations applicable to the Forest Plan Standards and Guidelines (USDA 1990).

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Timber Harvest No additional losses in soil productivity due to ground based equipment travel are predicted in any units. Unit 38 would have the highest amount of new disturbance as described in the proposed action, up to approximately 14.7 percent soil disturbance due to construction of a new helicopter landing in a relatively small unit.

Project design criteria and mitigation measures would minimize and restore soil compaction and displacement as specified in section 6 of the Project Design Criteria, such that detrimental conditions would not persist over the long-term. Silver Creek Thin Unit 11 has approximately 250 feet of temporary road proposed in Riparian Reserve allocation that would not result in losses in soil productivity.

Between 4.0 and 14.1 percent of the harvest unit areas would be temporarily compacted or displaced by system and non-system roads and landings. Historic landings and non-system roads not used for Silver Creek Thin activities would not be restored and would likely remain in a detrimental condition for the foreseeable future.

Localized soil displacement and erosion would be considered permanent because soil formation is a slow process, lasting hundreds of years or greater. The proposed action is not likely to reduce soil productivity across the units because adjacent soils and remaining subsoil layers would still be a suitable medium for tree growth at the activity area scale.

Generally, the duration and intensity of effects from skid trails is less than temporary roads and landings, but the extent is greater. Measures such as decompaction and re-vegetation are intended to restore productivity, further reducing the extent of effects. Skid trails be minimized and are not expected to result in losses in soil productivity.

Losses in soil productivity on skid trails from the use of ground-based skidders would be relatively low in magnitude and duration (Table 10) compared to the existing conditions because they will recover in the long-term. Measurable losses in soil productivity are not expected. The losses in soil quality would be decreased by the mitigation measures and design features that decompact and restore those areas. This would translate to similar effects on soil productivity.

Table 10. Summary of Soil Productivity Loss by Alternative

No Action Proposed Action

Duration Short-term Long-term Short-term Long-term

Intensity of Soil None None Skid roads: Low to Skid roads: Low level Productivity Loss Moderate level losses losses that have lessened with time. Temporary Roads and Landings: Low level Temporary Roads and losses post-logging, Landings: Low level losses, mitigated post-logging, due to mitigation measures

60 Silver Creek Thin EA January 2017

No Action Proposed Action

Duration Short-term Long-term Short-term Long-term

Magnitude None None Skid roads: Unknown, Skid roads: Minor amounts, (Extent) likely less than 7%, at less than short-term extent. most. Temporary Roads and Temporary Roads and Landings: Minor amounts Landings: Minor post-logging due to amounts post-logging, mitigation measures, less due to logging systems than short-term extent. design.

Locally concentrated losses in soil quality would occur in the short-term due to additional compaction and displacement caused by ground-based equipment on skid trails, roads, and landings. The extent of new soil disturbance from the proposed action is estimated to be less than 14.2 percent of any unit with the prescribed logging system design, including temporary roads, landings, and skid trails. Soil productivity would not be substantially reduced on new temporary roads and landings because Project Design Criteria and Mitigation Measures specify restoration of detrimental soil conditions.

Table 11. Summary of New Detrimental Soil Conditions in Silver Creek Thin

Temporary reconstruction of Silver Unit existing non-system New temporary roads and Total New Disturbance, Creek Unit Acres roads (Miles) Landings (%) including skid trails (%)

1 26 2.8 11.4 2 103 0.3 6.9 3 8 0.9 4 69 0.2 4.2 5 20 0.3 4.3 13.3 6 90 2.1 7 31 3.5 10.0 8 33 0.2 1.8 4.3 9 23 0.1 6.1 10 43 1.3 3.9 11 574 1.0 4.3 12 22 1.7 13 20 0.8 9.1 14 260 0.3 3.2 15 267 1.0 5.4 16 22 4.4 12.7 17 389 1.1 6.3 18 98 0.8 4.8 19 30 0.3 3.7 20 113 1.6 5.4 21 56 2.9 7.3

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Temporary reconstruction of Silver Unit existing non-system New temporary roads and Total New Disturbance, Creek Unit Acres roads (Miles) Landings (%) including skid trails (%)

22 8 0.2 10.1 23 5 7.2 24 51 2.9 7.9 25 23 6.1 26 38 2.9 7.2 27 101 2.4 7.4 28 255 1.5 8.0 29 50 4.9 6.9 30 38 3.3 31 134 0.1 3.2 32 33 4.1 33 6 3.0 3.0 34 29 5.2 35 93 0.3 5.8 36 23 3.5 5.2 37 286 0.3 3.2 38 8 2.8 5.3

Mechanical Processing on Steep Slopes The Proposed Action includes ground based equipment travel with mechanical cutting and harvesting machines on slopes mapped by the SRI that are not rated as permitting ground based logging (Wade, et. al., 1992).

Direct effects to soils due to mechanical processors on slopes up to 45 percent are expected to be similar to those on 35 percent slopes, judging by the amount of area affected and intensity of soil displacement and compaction. Soils potentially affected by this would be discussed with sale administrators when requested when cable or helicopter logging systems are in final design.

A processor is a type of mechanical cutting and harvesting equipment, with an apparatus on the arm that simultaneously removes limbs from the tree and cuts logs to specified lengths. This configuration of mechanical cutting and harvesting equipment would leave tree limbs in the stand, and produce more slash volume for equipment to operate on a slash mat of limbs and tops that is deposited directly in front of the machine.

Minimal area within affected units would have the potential for minor displacement of topsoil along the travelled routes. Use of mechanical cutting and harvesting machines on steep slopes can increase the risk of erosion losses due to soil displacement; however, the probability of it occurring is low because of design features and mitigation measures (see PDC #6.3, 6.4, 6.8, 6.9).

Effects of Management Activity on Slope Stability Based on professional judgment, the risk of triggering a management-induced landslide is low in all units proposed for Silver Creek Thin because of the design features and mitigation measures, such as avoidance of vegetation management and temporary road construction in unstable soils.

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Ratings discussed in the Existing Condition section “Two main sources of data were used to analyze effects to slope stability for the Silver Creek Thin EA: GPNF Forest “GeoHaz” data (USDA 1999) and a compiled subset of the Gifford Pinchot Soil Resource Inventory (Wade, et. al. 1992) that isolates potentially unstable soils. Photo interpretation indicated isolated, actively moving landslides within the units. Further, Forest Service soil scientist and experienced aquatics technicians visited units and noted mass wasting in field reports.

Active mass wasting is common throughout the units above Silver Creek, Willie Creek, Lynx Creek, and Lake Creek. Of the 38 proposed units in Silver Creek Thin, 28 contain mapped active landslides or potentially unstable soils.

Active Mass Wasting Natural and management-related active slides are inventoried (USDA 1999) in 22 Silver Creek Thin units (not counting those with only unstable ratings in SRI mapping), and are given specific mitigation to address potential for causing a management related mass wasting event.

Active landslides and recent debris flows would be excluded and buffered from vegetation management, to conform to definitions in the NW Forest Plan Riparian Reserves (NWFP ROD1994); the buffer in this area was defined as 180 feet from the edge of the slide (see Project Design Criteria for complete list of buffers). Aerial photography revealed a mantle failure in Silver Creek Thin Unit 30 (Figure 8).

Roads Contributing to Resource Damage Forest Roads 75 and 7561 exhibit damage from past debris flows that likely resulted in aquatic resource damage from fill sediment washing into major streams. Sections of these roads are not currently drivable and will be drivable as part of the proposed action (Rockey 2015).

Relevant items from the proposed action (access) considered here include:

24. Repair washouts and replace culverts at mileposts 4.8 and 5.5 of FR 7500000. Reconstruct roadway at MP 1.8 and 2.3 including ditch, shoulder, surface and embankment repair.

25. Un-bury culvert at milepost 1.08 and repair washouts and replace culverts at mileposts 1.25 and 1.3 of FR 7561000.

A site visit by GPNF Forest Geologist to Forest Road 75 milepost 4.8 highlighted a significant management decision regarding road reconstruction on a geologic hazard site. A 2015 site visit report (Dryden 2015) describes a reconstructed crossing downstream of “a steep channel with exposed soils that could lead to another debris flow.” The report concluded that a decision to reconstruct lies in whether “the value of being able to access the timber beyond the failure and restore access in general exceeds the cost of reconstruction at the site,” which will be “subject to the same hazard that destroyed the previous crossing after it had provided decades of service.”

Recommendations for repair on washouts that are likely to reoccur include features that will minimize additional sediment transport to surface waters:

• Replace crossings with a minimal volume of road fill. Suggestions include following the contour and installing a large or open-bottom culvert. A large culvert will also allow for high precipitation flood events that do not result in a debris flow. • Build with a low profile or “dip” that will allow passage of debris over the road, such as the key feature in a ford.

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In other parts of the watershed, active restoration and reconstruction activities would help reduce sediment input from roads. The Proposed Action would change a few Level 2 roads (open) status to Level 1 (Closed and stabilized) for hazardous sections of Forest Roads 4778000, 4778011, 7561018 and 8500108. Reconstruction items in the proposed action that address these issues include:

21. Repair washouts and replace culverts at milepost 0.39, 0.42, 0.46, 0.87 and 0.91 of FR 4778000

22. Reconstruct length of FR 4778011 including ditch, shoulder and surface repair and culvert replacement at mileposts 0.56 and 0.6.

Natural Stability Risk Rating Gifford Pinchot National Forest NEPA Assistance for the Soil Resource (Wade, et. al. 1992b) classified SRI Natural Stability ratings from Low Risk to Very High Risk as defined below. The SRI defines the Natural Stability rating as “based on the relative stability of the mapping units as they occur in the natural state. This includes any movement or loss other than surface erosion, by slumps, slides and all kinds of deep-seated failures” (Wade 1992).

e) Very High Risk – Generally, Class IV or V Natural Stability Rating, SMU 54F. Sometimes designated as unsuited (for timber management) and removed from timber base via GP FSH 2409.13, Chapter 20 when the SMU is given a suffix "F,” and thus is taken out of the timber base per the “Timber Land Classification.” [Applies to 39 acres in Silver Creek Thin Units 17 and 25.]

f) High Risk – Generally, Class IV or V Natural Stability Rating, SMU 54 and 5654. May be unsuited - has most of the characteristics of slumps and landslides (characterized by erratically leaning trees, slumping topography with bare headwalls, sag ponds and over-steepened pressure ridges, tension cracks; often with riparian vegetation, seeps, and ponds); some timber harvest may occur by individual tree selection, small group selection, or very small CC [Clear Cut]; generally, no roads should be built in these areas - involve Geotech Group and Soil Scientist. These specialists may more accurately map the area and help develop the necessary documentation to move the area to the Very High Risk by GP FSH 2409.13. [Applies to 439 acres in Silver Creek Thin Units 15, 16, 17, 24, 31, 32, 34, and 35.]

g) Moderate Risk – Generally, Class III or IV Natural Stability Rating, SMU 57. Some characteristics of slumps and landslides are evident, careful road location and sale design will allow some timber harvest - involve Soil Scientist. [Applies to 44 acres in Silver Creek Thin Units 15, 17, and 35.]

h) Low Risk – Class I, II, and III Natural Stability Rating. Few if any characteristics of slumps and landslides are present, planned timber harvest design to fit the ground situation can take place. Remember to consider other interpretations. [Applies to all units of Silver Creek Thin.]

Soil Resource Inventory Interpretations for Natural Stability in Soil Map Units 54, 56 and 57 The Soil Resource Inventory identifies approximately 475 acres of potentially unstable areas in proposed project units that include SMU 54, 54F, 5654, and 57. Approximately 100 of those acres occupy the same area as active landslides found through Geohazard mapping or field verification.

Active landslides, whether overlapping with SRI unstable mapping or not, occupy approximately 305 acres within units of the proposed action.

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Forest Soil Scientist professional judgment is that the timber harvest prescriptions in the proposed action would mitigate effects to landslide potential in those units listing a “regular thin” or gap avoidance. Some units were field verified by a soil scientist, many of these units showed characteristics of mass wasting.

SMU 54, 57, and 5654 are characterized as High Risk. Project design has resulted in approximately 780 acres of buffers that were modified because of unstable soil mapping and field verification (Table 9).

Recommendations for management on potentially unstable soils mapping includes exclusion of off-road, ground-based equipment on steep slopes (e.g. feller-bunchers) and a light to moderate thin silviculture prescription, as specified in Project Design Criteria. No roads would be built in these areas and road reconstruction plans should avoid entering the unstable areas.

Expected Mass Movement in Unstable Soils of GPNF Soil Resource Inventory Evidence of unstable ground was observed during field reviews in units containing soils mapped with SMU 54, 56, and 57. These SMU’s have a Natural Stability Risk Rating of “Moderate” or “High” and are rated by the Soil Resource Inventory (Wade 1992) as having an expectation of increasing mass movement, compared to the natural state, as a result of certain management activities, including timber removal and road construction. However, these SRI risk ratings for mass wasting presume clear-cutting as the silvicultural prescription, and thus overestimate the risk of mas wasting due to the prescriptions proposed for Silver Creek Thin.

The risk of triggering a mass wasting event is low, based on professional opinion because the design features and mitigation measures guard against triggering landslides, such as a silviculture prescription that would preserve soil strength by cutting less than 50% of trees on potentially unstable soils. Areas that remained stable after previous regeneration harvests are assumed to remain stable after light to moderate thinning.

Expected Mass Movement near Inventoried Landslides (GeoHaz) Additional sediment from units along Silver Creek, and potentially Lake Creek or Willie Creek, would likely reach the creek because of downslope proximity to a debris slide containing road fill, either natural or management related. This applies to system or abandoned roads in areas prone to debris flows. The likelihood of an increase in mass wasting above the existing condition is low where mitigation measures are implemented. Management recommendations include a thinning prescription that retains a living, tree root structure across the unit, which is included as a design feature of proposed action, and a road construction or reconstruction plan that avoids entering slump areas.

Management recommendations include a thinning prescription that retains a living, tree root structure across the unit, which is included as a design feature of proposed action, and a road construction or reconstruction plan that avoids entering slump areas.

Cumulative Effects

Soil Productivity The proposed action, which would integrate project design criteria, in combination with past or reasonably foreseeable future actions on nearby federal land and adjacent state and private land, would not likely increase the amount of detrimental soil conditions in the long-term. Cumulative losses in soil productivity due to management activities in the watershed are limited to permanent features, including National Forest system roads, non-system roads, landings and skid trails that are not decompacted. The proposed action would not involve increasing the permanent transportation system.

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Soil Organisms In the long-term, the Proposed Action alternative combined with all past, present, and reasonably foreseeable management activities would not cumulatively affect localized populations of soil dwelling organisms in the units because populations of soil dwelling organisms would have recovered in the long- term.

Slope Stability The proposed activities (with incorporated design features), in combination with past or reasonably foreseeable future actions on nearby federal land and adjacent state and private land, are not likely to increase the frequency or magnitude of mass wasting events.

However, the Proposed Action does not eliminate the potential for sediment from mass wasting events to reach streams at road crossings that remain in place during a high precipitation event. Effects to water quality and aquatic species are addressed in Silver Creek Thin fisheries and hydrology reports.

Forest Plan Consistency The No Action and Proposed Action alternatives would meet the Forest Plan Standards and Guidelines in all of the units because restoration of compacted soils on old skid roads would occur in units where non- systematic remnant logging roads and skid trails exist, and new soil compaction would be mitigated, as described by PDC 6.20, “Temporary roads and landings will be closed and restored...” Thus, the Proposed Action would not increase the percentage of detrimental soil conditions and would comply with the 20 percent Forest Plan Standard. Vegetation

Existing Condition Vegetation conditions within the proposed treatment units have been determined from plot inventory in stand exams conducted in summer of 2007-2009 and 2014. The Forest Vegetation Simulator Growth and Yield (FVS) model simulated stand growth (Suppose Version 2.02, Westside Cascades Variant). FVS is an individual-tree, distant-independent growth and yield model (Dixon 2002) and all projections were simulated over a 50-year time span. Model extensions used for this analysis include partial regeneration/establishment and the fire and fuels extension.

Industrial logging in the form of clearcutting followed by broadcast burning and planting began in the 1940’s and contributed to the early successional forest of a structurally simple, homogenous, single tree layer having little to no snags, nor any large live trees or large down wood. These plantations are 40 to 60 years old. Stand exam data reveals the units typically have less than two snags per acre that are less than 18 inches in diameter and are usually Douglas-fir. No planting records exist for Units 1, 2, and 10. No records of precommercial thinning exist for units 6, 17, 19, 22, 23, 29, and 38; otherwise, all remaining treatment units have been precommercially thinned.

The treatment units are predominantly in the stem exclusion stage of stand development and can be characterized as stratified, mixed-species stands (Oliver and Larson 1996) in a mid-closed/small tree seral phase of forest succession. These treatment units carry between 187 and 368 square feet of basal area per acre, have quadratic mean diameter at breast height (DBH) between 11 and 17 inches, and consequently have relative densities (Curtis) between 49 and 101 percent. Curtis’ relative density is a measure combining average tree diameter and total basal area of tree cover to determine a simple index of stand density (Table 12). Due to intense forest management, most are structurally simple, homogenous, single

66 Silver Creek Thin EA January 2017 tree layer stands of predominantly Douglas-fir or western hemlock having few to no snags, large live trees or large down wood.

Table 12. Silver Creek Thin Stand Attributes Generated from FVS Unit Year of Origin Trees Per Acre* Basal Area Quadratic Mean Relative Canopy (Stand (ft²/acre)* Diameter Breast Density Cover ID) Height* (Curtis)* Percent* 1 (522) 1955 288 273 13.2 75 82 2 1970 237 219 13.0 61 76 (9108) 3 (33) 1965 234 220 13.1 61 71 4 1963 226 219 13.3 60 71 (9040) 5 1967 377 243 10.9 74 86 (9041) 6 1967 282 211 11.7 62 79 (9029) 7 (35) 1969 384 274 11.5 81 77 8 1962 190 211 14.3 56 64 (1453) 9 (323) 1964 268 254 13.2 70 80 10 1968 340 297 12.7 84 88 (9570) 11 1960 278 252 12.9 70 80 (9594) 12 1966 380 368 13.3 101 92 (9581) 13 1968 280 254 12.9 71 79 (9579) 14 1970 204 189 13.0 52 70 (9593) 15 (31) 1970 286 249 12.6 70 81 16 1966 171 232 15.8 58 70 (9626) 17 1960 339 266 12.0 77 87 (9592) 18 1960 182 235 15.4 60 75 (9561) 19 1969 315 194 10.6 60 80 (9584) 20 1969 380 286 11.8 83 91 (9625) 21 1975 279 225 12.2 65 81 (9558) 22 1966 450 281 10.7 86 85 (9559) 23 1966 251 230 12.9 64 75 (9585) 24 1975 275 227 12.3 65 82 (9586) 25 1973 262 239 12.9 66 83 (9588) 26 (41) 1975 206 234 14.4 62 75 27 (43) 1975 348 238 11.2 71 90 28 1975 283 250 12.7 70 83 (9541)

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Unit Year of Origin Trees Per Acre* Basal Area Quadratic Mean Relative Canopy (Stand (ft²/acre)* Diameter Breast Density Cover ID) Height* (Curtis)* Percent* 29 1930 198 315 17.1 76 73 (9053) 30 1970 185 218 14.7 57 73 (9545) 31 (18) 1975 298 241 12.2 69 83 32 1974 229 231 13.6 63 75 (9051) 33 1967 266 229 12.6 65 78 (9620) 34 1974 219 219 13.6 60 72 (9534) 35 1966 212 244 14.5 64 76 (9533) 36 1967 228 187 12.3 53 74 (9540) 37 1970 207 247 14.8 64 76 (9591) 38 1975 204 172 12.5 49 74 (9524) *for all trees greater than or equal to 5 inches Diameter Breast Height (DBH)

The stands are undergoing differentiation where available growing space is redistributed unequally resulting in differences of tree diameter and height (Oliver and Larson 1996). Densities of these units are approaching the lower limit of the self-thinning zone where competition is creating tree mortality and possibly intense enough for overstory trees to kill understory trees through suppression and moderate to high mortality rates can be expected.

For most treatment units the species composition of the overstory is predominantly sawlog-size Douglas- fir with subordinate amounts of western hemlock and Pacific silver fir. Units 17, 18, and 28 have roughly equal amounts of Douglas-fir and western hemlock but in Units 20, and 25, western hemlock dominates Douglas-fir. Noble fir is sporadic, limited to higher elevation units and never exceeds one quarter of the stand stocking, with the exception of unit 7, which is dominated by noble fir. Western redcedar is more regularly distributed but still considered infrequent. Red alder is similar, however units 12, 21, and 26-28 have adequate stocking levels of red alder to be included as a cut species. Other mature tree species that occur in the project stands include western white pine, black cottonwood (Populus trichocarpa), mountain hemlock (Tsuga mertensiana) and occasionally lodgepole pine (Pinus contorta), and Pacific yew (Taxus brevifolia). Western hemlock dominates the seedling/sapling component of the treatment units with Pacific silver fir and western redcedar supplying subordinate amounts. Douglas-fir, noble fir and hardwood regeneration is generally lacking in the units.

Major contributors to the shrub and herb layer are, Alaska huckleberry (Vaccinium alaskaense), twinflower (Linnaea borealis), vine maple (Acer circinatum), and salal (). Minor and trace amounts of other mesic-type forbs and herbs are present as well. Refer to Botany Silver Creek Specialist Report for further native and invasive plant details.

Tree Damage Laminated root rot (Phellinus weirii) is present in the treatment area but occurs at low levels. Laminated root rot is a substantial predisposing agent for Douglas-fir bark beetle (Dendroctonus psuedotsuga). The beetle is found wherever root disease or windthrow has occurred. This can occur as single tree mortality or group kills. Armillaria root disease (Armillaria ostoyae) is another pathogen common to forest types within the project area and its occurrence is scattered throughout the treatment units. Armillaria root rot

68 Silver Creek Thin EA January 2017

readily kills Douglas-fir but its presence in the treatment units appears to be limited. Vigorously growing trees often confine the fungi to localized lesions and limit their spread up the roots (Williams et al. 1986). Removing infection pockets, and promoting species diversity and vigorous individual tree growth through thinning can reduce the spread and impact of this disease. Light infection levels of hemlock dwarf mistletoe (Aceathobium tsugensis) occur sporadically in the treatment units. White pine blister rust (Cronartium ribicola) has infected mature and immature western white pine where it occurs.

Black bear damage is widespread but minor in the units. The stripping of the tree cambium on the upper boles has caused mortality in Douglas-fir and severe stem wounding and decay in western hemlock. Very little physical damage is present in the treatment units in terms of defects such as fork, crook or sweep. Frost damage in the form of bole cracks on Pacific silver fir and heart rot in western redcedar is noticeable. Other damage to trees in the project units is windthrow or tree top breakage from snow/ice, windstorms or sudden downdrafts.

Desired Future Condition The Desired Future Condition of Late Successional Reserves has characteristics that include large and tall trees of diverse species with a dense, multi-layered canopy consisting of one to several age classes of younger trees established as mortality creates shifting gaps in the overstory layer. Reproduction would consist of more shade tolerant tree species but in larger openings shade intolerant early seral species may also be present. Forest stands in LSR would also contain moderate to high numbers of snags, down logs, trees with physical imperfections such as cavities, broken tops, and large deformed limbs. The understory would be characterized as patchy and consist of shrubs, forbs and moderate to high accumulations of fungi, lichens and bryophytes.

The Desired Future Condition for Matrix lands is such that evidence of land managed intensively for timber production and other commodities is apparent. All tree sizes and mixtures of native species from seedlings to mature sawtimber are well distributed. Accumulated volumes of fuels are light and destructive fires seldom occur. Recreational opportunities are available for hunters, fisherman, off-road vehicle operators and other motorists. Stands are in a condition that is resistant to current biotic and abiotic stresses as well as resilient to future stresses including climate change.

Vegetation Proposal Objectives One action alternative has been developed and maintains the ability to stay consistent with the Silver Creek Thin Project Purpose and Need statement. Commercial thinning from below harvesting the smaller, weaker trees is prescribed on approximately 3,302 gross acres.

Matrix Treatments Treatment units in Matrix will emphasize a traditional approach by thinning stands down to spatially uniform residual densities to ensure that overstory tree layers fully occupy the site and thus maintain timber production. Target relative densities of approximately 35 percent aim to bring treatment units down to the lower limit of full site occupancy and keep densities below the lower limit of the self- thinning zone (60%) for many years (Figure 10). At these densities, treatment units will maintain optimal stand growth, avoid mortality from self-thinning and be more resilient to environmental stressors. These densities, while agreeable to the overstory, are normally too high to allow development and sustainment of a diverse, well-developed understory. Within-stand site-specific variability will be implemented only if necessary to achieve other resource objectives.

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Late Successional Reserve Treatments Treatment units in the Late Successional Reserve portion of the project (Units 8, 9, 12, 13, 24, and 25) will utilize Variable Density Thinning (VDT) techniques to accelerate the creation of within-stand structural and compositional variety of these mid-successional stands and move them more towards an understory reinitiation stage. Variable Density Thinning unevenly thins a unit using differing densities, unthinned (skip) areas and openings (gaps) to promote a structural mosaic. The objective is to create structural components that make the stand more inviting to plant and animal species dependent on late successional habitat more quickly than if natural processes was allowed to take place. Target relative densities of between 25 and 30 percent will return the stand to the start of crown competition, which will emphasize high individual tree growth. These densities should create conditions that make more light available in the understory and higher soil moisture which in turn should promote large tree growth and development of a diverse understory. Imposing tree diameter limits and retaining minor species including hardwoods would also contribute to diversification. Post-treatment stand densities will vary from stand to stand to create variability across the landscape as well. Table 16 describes post-treatment attributes.

Deer and Elk Winter Range (Matrix) Of 871 acres of mid-seral forest plantations proposed for treatment in the Deer and Elk Management Area Category (all Matrix under NWFP), 176 acres are proposed for Light Forest Retention regeneration cuts. Regeneration cuts seek to create complex early-seral forest habitat for wildlife within Matrix allocations. In these treatments, 15% of the existing stands will be retained in a mix of large, uncut aggregates and of trees left singly or in small clumps.

The plantations selected for Light Forest Retention harvest have not reached culmination of mean annual increment (CMAI), however timber production is not the primary objective of the Deer and Elk Winter Range MAC. Mean annual increment is the average annual growth of a stand, which culminates when it reaches its maximum rate of growth. Post-harvest reforestation levels would target the minimum level of 125 trees per acre in following Forest Plan standards and guidelines where planting or seedling density spacing should not be any closer than 12 by 12 foot to ensure adequate openings for forage production (LRMP p. IV-134). Both deviations are being proposed to provide early seral forest for a longer time period primarily for the benefit of wildlife. This is a Forest Plan-specific exception to the CMAI requirement. These treatments and all other proposed actions are consistent with the silvicultural standards and guidelines set forth in the Forest’s management plan and other regulatory documents (LRMP p. IV-135).

Deer and elk forage is one of the objectives of the purpose and need. While thinning can improve these resources somewhat (particularly heavy thinning), optimal levels are provided in early seral forest. The need on a landscape basis to create complex early seral forest in the west Cascades has been recently chronicled in several studies (Franklin and Johnson 2010, Swanson et al. 2011). In contrast to conditions created by industrial clearcuts, complex early seral retains more components of the prior mature stand. Such early seral conditions more closely resemble those following wildfire and other disturbance, and provide for a broad range of life forms, including deer and elk (Franklin et al. 2007).

The design of these treatments also incorporated concepts for complex early seral, to provide a greater ecological benefit. Key items to foster complexity include:

• Retention of 15% of the prior stand in no-cut aggregates and single trees. A portion of these trees would be available for future snags and down logs.

• Almost all created openings at least 5 acres in size, with larger openings preferred. This creates a large enough space for a variety of soil and topographic conditions that lend themselves to

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diverse recovery pathways (Swanson 2012). It provides some opening not affected by the timbered edge’s shading and seed rain.

• Tree planting would occur only to supplement natural regeneration. The restocking objective would be a minimal level. This would delay tree crown closure, permit a longer period for forb and shrubs to dominate, and as whole, extend the early seral phase.

Commercial Yield of Timber A key part of the Purpose and Need of the Silver Creek Thin is to provide a commercial yield of timber to the community consistent with objectives set forth in the Forest Plan and Northwest Forest Plan. The estimated timber volume in each stand evaluated for this proposal is in the table below. Note that the timber product yield from the project is likely to be considerably lower (as much as 40% lower) because this table does not figure in reductions in volume due no-cut buffers required to protect resources (see PDC table under Proposed Action). It also does not depict acreage reductions that typically occur during timber sale preparation caused by unforeseen feasibility, economics, access, or natural resource issues.

Table 13. Available Harvest Volume by Unit UNIT Northwest Forest Plan Allocation LRMP Landing Unit Management Area Category Acres Harvest Volume (MBF) 1.25 1 Matrix Timber Production 367 Matrix 6.38 2 Timber Production 932 Matrix 0 3 Timber Production 86 Matrix 2.25 4 Timber Production 319 Matrix 1.38 5 Timber Production 248 Matrix 1.75 6 Timber Production 533 Matrix 2.75 7 Timber Production 359 Late Successional Reserve 2.00 8 Late Successional 201 Late Successional Reserve 0.88 9 Late Successional 380 Matrix 1.50 10 Timber Production 561 Matrix 18.75 11 Timber Production 5332 Late Successional Reserve 0.38 12 Late Successional 455 Late Successional Reserve 0.50 13 Late Successional 320 Matrix 7.25 14 Timber Production 1086 Matrix 9.25 15 Timber Production 2219 Late Successional Reserve 1.38 16 Late Successional 272 17 Matrix Timber Production/Deer and 15.13 Elk Winter range 4537 Matrix 3.38 18 Timber Production 1082 Matrix 1.00 19 Timber Production 152 Matrix 4.25 20 Timber Production 1425 21 Matrix Timber Production/Deer and 3.00 Elk Winter range 1066 Matrix 0.50 22 Timber Production 122 Late Successional Reserve 0 23 Late Successional 73

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UNIT Northwest Forest Plan Allocation LRMP Landing Unit Management Area Category Acres Harvest Volume (MBF) Late Successional Reserve 2.25 24 Late Successional 557 Late Successional Reserve 1.25 25 Late Successional 312 26 Matrix/Late Successional Reserve Timber Production/Late 2.00 Successional 247 27 Matrix Timber Production/Deer and 3.38 Elk Winter range 990 28 Matrix Timber Production/Deer and 10.25 Elk Winter range 4939 29 Matrix Timber Production/Deer and 3.13 Elk Winter range 3115 Matrix 1.25 30 Timber Production 282 Matrix 3.25 31 Timber Production 929 Matrix 1.38 32 Timber Production 361 Matrix 0.13 33 Timber Production 78 Matrix 1.13 34 Timber Production 145 Matrix 3.75 35 Timber Production 702 Matrix 1.25 36 Timber Production 165 37 Matrix Timber Production/Deer and 5.75 Elk Winter range 2964 38 Matrix Timber Production/Deer and 1.88 Elk Winter range 92 127 Total 38005

Effects

No Action Under the No Action alternative, none of the treatment units in the project proposal will be treated to maintain stand health and vigor. Current land management plans will continue to guide management activities in the future. A spike in activity slash will not occur from the proposed action but long-term fuel loading will increase. Individual tree growth will decline but stand growth will increase. The possibility exists for higher amounts of small dead and downed wood availability. With no management and without disturbance, the dense, single-canopy forest structure of these stands will continue on their eventual path towards a forest with larger trees and multiple canopies.

In this alternative, trees will continue to slow in diameter growth, volume growth and eventually height growth. The stands will maintain high levels of relative density and susceptibility to other stress-related damages beyond competition. Stress makes trees more vulnerable to insect and diseases infestations. Intermediate and suppressed trees are those in the lower strata of the forest canopy. These trees do not receive much sunlight, are not efficient and consequently do not respond well to a release. Intermediate and suppressed trees, while still able to grow in height, will have less energy to devote to disease and insect attacks. If these trees do not succumb to pests or poor vigor, they will eventually experience stem failure.

At some point, the stand could become too unstable to be thinned successfully and recover the expected mortality for economic return. Without the intervention of some disturbance to differentiate and break the stand up, be it logging, fire, wind, disease or insects these stands could remain in this state for another 80-

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130 years. Provided the stand is not subjected to a major disturbance, it could successfully release itself from competition. In this scenario, any advanced regeneration that establishes in additional growing space would suppress once the canopy reclosed and the stem exclusion stage and the lack of diversity for which it is known would protract. This alternative does not meet the objectives in the Purpose and Need to provide for healthy and vigorous stands.

Based on model results tree vegetation will continue to expand in size and density over the next fifty years. When averaged together treatment unit attributes such as basal area, quadratic mean diameter, and density are projected to increase in the future while trees per acre and canopy cover will decrease or stabilize (Table 14).

Table 14. Average Projected Change in Treatment Unit Attributes with No Action

Year Trees/Acre* Basal Area* Quadratic Mean Relative Canopy (sq. ft./acre) Diameter Breast Height* Density* Cover (Curtis) Percent*

2015 274 248 13.4 69 81

2065 212 299 17.2 74 75

*for all trees greater than or equal to 5 inches Diameter Breast Height (DBH)

Proposed Action

Direct/Indirect Effects of Vegetation Treatments Under the Proposed Action, treatment units affected by the project proposal would undergo density reduction to maintain stand health and vigor. Treatment units will be commercially thinned from below whereby trees in the upper strata (dominant and co-dominant) will be released and provided more growing space with the removal of intermediate and suppressed trees in the lower strata. Removing the low-vigor intermediate and suppressed trees will allow for economic return.

The effects of tree thinning are well documented. Thinning of dense stands can reduce competition between trees in the remaining stand and accelerate the growth and diameter of these trees (Davis and Puettman 2007, Roberts and Harrington 2008, Garman et al. 2003). Remaining larger trees will reoccupy available growing space and increase in vigor and diameter, continue growing taller and grow larger crowns. With fewer trees, more light, water and nutrients will be available to remaining trees. Treatment units in Matrix would maintain a continued state of inter-tree competition while maintaining growth more at the stand level and less at the individual tree level (Figure 10). This would be consistent with the

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project’s Purpose and Need to produce commercial yields of wood and optimization of timber in Matrix lands. Fuel loads would see a slight short-term increase and the reduced competition between trees due to thinning would reduce density-dependent mortality in the residual trees, allowing them to be healthier and live longer before succumbing to competition, insects, or disease. This would delay the natural accumulation of snags and downed wood by several decades.

Average Treatment Density by Alternative -Matrix 80 70 60 50 40 Proposed Action 30 20 No Action

Relative Density (Percent) Density Relative 10 0 2015 2025 2035 2045 2055 2065 Decade

Figure 10. Projected Relative Density for No Action and Proposed Action Alternative for All Commercial Treatments in Matrix Lands

The variable density thinning prescriptions for the proposed units in Late Successional Reserve are designed to hasten the development of late successional structure to provide habitat in the future for those species dependent upon such. Commercial tree thinning has the potential to develop structural features characteristic of older forest types, accelerate the creation of structural and compositional variety of mid- successional stands and move them from a stem exclusion stage towards an understory re-initiation stage

Old growth stands with large trees, multi-layered canopies and openings did not begin as dense, single layer stands like the treatment units in the Silver Creek Thin Project. On the contrary, stands of old growth as described were of low density, irregularly spaced trees, and benefitted from prolonged establishment with rapid early growth into large trees with diverse understories (Tappeiner et al. 1997). Chan et al. (2006) in looking at implications of thinning young Douglas-fir plantations to accelerate development of complex stand structure and species diversity found that treated stands exhibited positive responses to all studied thinning intensities; increased overstory canopy development, moderate to good survival and growth of underplanted seedlings, and increased understory species richness and cover.

Under this alternative, commercial thinning is the chief mechanism to create minor disturbance sufficient to prepare the stand for late successional habitat. Areas are designated for commercial thinning from below whereby remaining trees will increase in vigor and diameter, continue growing taller and grow larger crowns. Removing the low-vigor intermediate and suppressed trees will allow for economic return and increase the amount of sunlight to the forest floor.

On these productive Douglas-fir sites, reinitiation of the understory can be accelerated when larger growing spaces are created and remaining larger trees take more time to reoccupy those spaces. Herbs, shrubs and tree seedlings can take advantage of this by seeding and sprouting with the prolonged increase

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of space and light. Overstory trees that cannot fully reoccupy an opening will produce thicker foliage and longer crowns. In turn, tree heights and crown sizes will differentiate creating a multi-storied and layered canopy effect.

Reduced competition between trees due to thinning reduces density-dependent mortality in the residual trees, allowing them to be healthier and live longer before succumbing to competition, insects, or disease. This would delay the development and attainment of some late successional attributes such as abundance of snags and down trees by several decades. Any untreated portions of stands such as skips and inner riparian reserves become an important addition for delivering these decay components in the treated areas sooner albeit in small diameter classes, while growing large trees that will eventually become large snags and logs in the thinned portion of the unit.

On research plots in western Washington beginning in 1994, 35 to 70 year old stands were treated similarly to proposed treatment in the Silver Creek Thin Project LSR by thinning with 10% of the area in skips and 15% in gaps. The area between the skips and gaps were thinned by removing only 10-20% of existing basal area yet individual tree growth increased considerably regardless of the age of the stand (Roberts and Harrington 2008). Early results from this and further studies on these same plots showed understory vegetation increased in coverage and variety (Harrington et al. 2005) and midcanopy trees responded to the treatment as well (Comfort et al. 2010). Variable density thinning, therefore, can increase horizontal and vertical heterogeneity within stands in accelerating development of late successional structural characteristics regardless of stand age. This would be in agreement with the project’s Purpose and Need to accelerate development of old-growth forest characteristics including snags, down logs, large trees, multiple tree layers and species diversity.

Large tree forests, as defined earlier, are single or multi-storied stands greater than 18.0 inches DBH in the Pacific silver fir zone or greater than or equal to 21.0 inches DBH in the western hemlock zone. Tree diameter is projected out for 100 years from present in both alternatives in LSR of this project using these definitions when determining the rate at which large tree forest average diameters can be achieved. Figure 11 shows that treated units currently just above quadratic mean diameter of 14 inches DBH will grow to an average DBH of 18 inches at the beginning of the next decade based on model projections. In contrast, these same units if not thinned as proposed will not realize an average DBH of 18 inches for up to 100 years due to stagnation.

Average Quadratic Mean Diameter by Alternative - LSR 35.0 30.0 25.0 20.0 15.0 Proposed Action 10.0 No Action 5.0 0.0 2015 2035 2055 2075 2095 2115

Quadratic Mean Diameter (inches) Decade

Figure 11. Projected Average Diameter for No Action and Proposed Action for All Commercial Treatments in LSR Stands

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Increasing the average QMD through thinning would match the project’s Purpose and Need for faster attainment of large tree forest to provide increased connectivity to other late successional forest east and north of the planning area.

Table 15 displays treatment unit attributes fifty years after treatment and compares them to a fifty-year period of no action. Size of trees and density will have increased in fifty years, as expected, but number of trees will be reduced while crown closure remains stable.

Table 15. Unit Attributes after Proposed Action Compared with No Action

Trees/Acre* Basal Area* Quadratic Mean Relative Canopy (sq. ft./acre) Diameter Breast Density Cover Height* Percent Percent* (Curtis)* Year 2015 2065 2015 2065 2015 2065 2015 2065 2015 2065 No Action 274 212 248 299 13.4 17.2 69 74 81 75 Proposed Action-- 100 81 147 240 17.2 25.0 35 49 55 57 Matrix Proposed Action-- 73 54 116 200 17.1 26.1 28 39 45 46 LSR *for all trees greater than or equal to 5 inches Diameter Breast Height (DBH)

Tree Planting in Light Forest Retention Cutting Units The light forest retention cutting units (176 acres) may also be planted with trees if natural tree regeneration is insufficient. If needed, planting with a mix of shade intolerant conifers at low density (up to 150 trees per acre) would occur. Tree stocking objectives are at the minimum allowable (125 trees per acre) in order to delay canopy closure and promote a more diverse and complex vegetative composition for a longer time period.

Matrix Regeneration Cuts Light forest retention regeneration cuts are proposed in the upland portion of matrix stands where early seral conditions are desired for wildlife habitat. The retention of a portion of the previous forest stand in aggregates and individual trees is an attempt to develop a more complex early-seral condition, more reflective of the conditions following natural disturbance and meet structural requirements of the NWFP. A minimum of 15% of these stands will be maintained in large, leave patches and individual trees. The cut portion of these stands would resemble patchy seed tree cuts. Less aggregated retention no-cut areas; the cut opening would range in size from 2 to 40 acres and provide the open conditions necessary for early seral vegetation to flourish. Tree planting would only occur if natural seeding cannot meet the reforestation stocking objective of at least125 trees per acre (LRMP p. IV-88). At this low level, early seral vegetation would be provided a longer time period of persistence yet still meet National Forest Management Act requirements. Deer and elk forage production at high levels could occur for up to 30 years.

The following would be retained in cut areas:

• All large trees, snags, and downed logs. Little is present now, mostly large stumps, root wads, or cull logs left near prior landings.

• Approximately 25 tons/acre of tops, limbs, and needles. Slash and below ground roots comprise much of these forests’ stored nitrogen, and would remain on-site for recycling. Half of this volume is carbon and subject to slow release to the atmosphere from decay.

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• 10% of the current tree stock, larger trees. It is expected that half of this component would provide large snags and downed logs for this rotation. Target level is 240 linear feet of downed logs, 20” or larger on the large end (USDA 1994). Target level for large snags is 6.6 snags per acre. The 6.6 snags per acre reflects the 50% tolerance level for snags > 20 inches dbh for the small to medium tree structure stage in the Montane Mixed Conifer habitat type (DecAID 0 MMC_S.inv3, Mellen et al. 2006). This level exceeds the LRMP standard of 2.6 snags per acre for cavity nesting birds. It may be necessary to artificially create these snags and downed logs via topping, girdling, or felling. The largest trees from the current stock would attain the desired 20” size in 20 years, and their conversion to snags and downed logs then, would enrich the latter half of the early seral phase. All other retained trees would be left to grow. Those trees surviving to the next regeneration cut would likely be retained into the following rotation, along with the large snags and downed logs.

Culmination of Mean Annual Increment On lands where timber production is the primary objective, the National Forest Management Act requires a stand to be within 95% of CMAI before it is regenerated using an even-aged silvicultural system. An exception is provided in the LRMP where it is necessary to regenerate younger stands to meet other resource objectives. In order to remain consistent with the forest plan, the light forest retention cuts were applied only to plantations in the Deer and Elk Winter Range MAC, which have not reached culminated mean annual increment (CMAI). The exception is unit 29, which is a naturally regenerated stand that has culminated. Regeneration cuts to the plantations at this time, reduces the total potential wood yield from these stands for this rotation.

Mean annual increment refers to the average annual productivity of a stand over the life of the stand. The age at which the mean annual increment culminates (reaches its maximum) is the harvest age (rotation) that would maximize volume productivity from the stand over its lifetime. To provide optimal wood production, stands should be regenerated near CMAI age. Table 16 lists the projected age of CMAI for each stand based on cubic foot growth, and compare the stand volume (mbf/acre) at that time with the current volume.

Table 16. Total Stand Volumes Present and at Culmination of Mean Annual Increment (CMAI) Unit CMAI Year 2015 Volume (MBF/Acre) Volume (MBF/Acre) at CMAI Year 17E 2025 62 76 21E 2025 45 59 27E 2025 55 68 28E 2025 61 72 37E 2025 58 73 38E 2025 37 52

Regeneration harvest prior to CMAI yield less wood volume than could be obtained by waiting. If done on widespread or consistent basis, such action would reduce the Forest’s Long-term Sustained Yield Capacity (LTSYC) and Annual Sale Quantity (ASQ). However, this proposal has negligible impact on either, given the limited scope of this proposal (176 acres), the relative paucity of other regeneration cuts on the Forest in the past 15 years, and an annual sale output for the past 15 years that is less than the Potential Sale Quantity (PSQ) estimated for the Forest under the Northwest Forest Plan.

Riparian Reserve Non-Commercial Treatment Effects It is proposed to fall and leave approximately 16-30 trees per acre within No Harvest “skip” areas of inner Riparian Reserves. Thinning will be from below targeting Douglas-fir and western hemlock averaging 14 inches DBH to attain approximately 3 percent down wood cover per acre in this diameter class. This

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restoration project will restore the forest function and structure by treating approximately 600 riparian acres of Class II, Class III and Class IV streams. Class II streams are resident fish-bearing perennial streams, Class III streams are non fish-bearing perennial streams that flow throughout the year while Class IV streams are non fish-bearing intermittent streams that cease flowing during the warmest and driest part of the year. Refer to Fisheries Specialist Report for further details.

Under the No Action alternative, the Riparian Reserve Non-commercial treatment would not occur and the stands would be expected to behave similarly to the No Action effects of the commercial component as described above. Due to higher moisture regimes in these riparian areas, however, growth rates and biomass accumulation would likely be greater and wildfire occurrence and severity would be less.

The Northwest Forest Plan states that Riparian Reserves, as described above, should maintain and restore species composition and structural diversity of plant communities. Thinning in riparian stands does result in accelerating the availability of live trees of pool-forming size over time if the original treated stand was of small diameter (Beechie et al. 2000). In the Proposed Action, the objectives are to allow released trees of varied species within the treated riparian areas to grow faster than if left in their current dense condition and contribute to aquatic system stability and complexity. The growth of trees in both height and girth will improve shade in the long-term and provide future recruitment of large wood to the forest floor and/or to the actual stream itself. Leaving thinned trees intact on the ground provides immediate availability of down woody debris that can add to aquatic system stability and complexity as well as support populations of native plant, invertebrate and vertebrate riparian-dependent species.

Riparian Reserve non-commercial treatments can be analyzed using riparian forest characteristics such as shade, down wood, and microclimate.

Thinning in proximity to streams has the potential for a short-term increase in the amount of solar radiation reaching the water surface consequently increasing the stream temperature. Conversely, thinning would increase crown length of remaining trees in the long-term resulting in a deepening of the canopy. Shade amounts are expected to return to pre-treatment levels within 5 years and any of the proposed treatment acreage for Riparian Reserves is along Class IV streams where stream flow during the warmest and driest months does not exist and there is no water to shade.

Down wood will be increased immediately by this action to levels between 3 and 4 % cover. The average 14-inch diameter trees being felled will modify flow hydraulics, contribute to sediment storage, and provide food and cover for plant and animal life in these headwater riparian areas. Treatment unit density will be in a fully stocked or near fully stocked condition after treatment. Expected tree mortality from competition, windthrow and incidental insect and disease attack should continue to re-supply down wood to the stream and adjacent area for many decades.

Treatment unit density and accordingly canopy cover has a prominent effect on air exchange and forest floor exposure to solar radiation. A noticeable effect from tree thinning is the increase in soil and air temperature and decrease of relative humidity in the thinned stand during the hottest and driest months of the year (Olson and Chan 2004).This study also found in thinning 30-70 year old plantations in western Oregon that riparian buffers averaging as narrow as 17 meters wide mitigated the microclimates associated with thinning and thinning did not affect riparian buffer soil temperature and stream temperature. The steepest change in microclimate was often observed within 5 meters from the center of the stream. There is no down wood being created within 5 meters of any stream and all treated areas will retain at least 50 percent canopy cover and a minimum of 120 square feet of basal area per acre.

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Stand Improvement Cut Treatment Effects It is proposed to stand improvement cut 583 acres of young stands across 19 units in the project area. Residual tree density by stand will range from 90 to 300 trees per acre to further objectives of maintaining health and vigor and promoting species and forest structural diversity.

Under the No Action alternative, the stand improvement cutting treatment would not occur and the stands would be expected to behave similarly to the No Action effects of the commercial component as described above. Trees would continue to increase in size and density and become subject to higher levels of competition. Canopies would close quickly and shade out any understory vegetation reducing complexity and diversity. The ability and rate of stand differentiation would diminish and stagnation could occur.

Stand improvement cutting these stands has the potential to produce forage and browse for deer and elk in the short-term, retain minor conifer and hardwood species of different sizes for diversity, retain subsequent slash for on-site nutrient recycling, reduce inter-tree competition while maintaining stand growth and vigor in Matrix lands, and provide unthinned areas (skips) as well as wide-spaced areas (gaps) in LSR to promote structural development of mature and late successional forests and spatial diversity.

Applying the Proposed Action has implications to the landscape over time (Table 17). By the year 2045, the average stand in LSR will have reached large tree stage thus moving approximately 162 treated acres of small/medium trees more towards late successional habitat. These units are sometimes contiguous and usually adjacent to existing large/giant tree forest. Succession into stands with old-growth characteristics will increase overall patch size, reduce contrast and make patch shape more regular. The 583 acres of stands proposed for stand improvement cutting will undoubtedly have moved into the small/medium tree phase by this time reducing the overall amount of sapling-pole stage and increasing the stability of the landscape. The 176 acres of created early seral habitat will be moving from the open stage to the sapling- pole tree stage. The 2017 net treated acres of Matrix thinning will be either in or very close to a large tree state at that point in time. Management direction could at some point reset these stands to an early seral stage with regeneration harvest so it is speculative as to how much of these acres will actually be large tree forest.

Table 17. Change in Project Area Structural Stage as Affected by Proposed Action Structural Stage Acres Percentage of Acres Percentage of Within National Forest (2015) Forested Area (2045) Forested Area Boundary (2015) (2045) Sparse 358 2 358 2 Open 1618 7 1618 7 Sapling-Pole 7058 31 6651 29 Small/Medium Trees 7762 34 5990 26 Large Tree 3460 15 5639 25 Large/Giant Trees 2371 11 2371 11 Total 22627 100 22627 100

Cumulative Effects “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. For this analysis the spatial and temporal bounds for cumulative impacts are the treatment units listed in this project and any management activities within their boundaries in the past 10 years, the present or foreseeable future (5-10 years). There are no known past, present or foreseeable actions, which are impacting or would impact the control of stocking, vigor and health in the proposal treatment units to which the proposed action’s treatments would add (accumulate).

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Summary of Effects Effects to vegetation in the Silver Creek Thin Project below by alternative.

Table 18. Comparison of Alternatives by Purpose and Need Category Purpose and Need Element No Action Proposed Action Alternative Alternative Produce commercial yields of wood and optimization of 0 Acres 2017 Net Acres timber in Matrix lands Create early seral wildlife habitat through 0 acres 176 Acres moderate retention regeneration cuts Actively manage and restore Riparian Reserves by 0 Acres 600 Acres creating down woody debris using non-commercial techniques Commercial thinning in Late Successional Reserves to 0 Acres 162 Net Acres accelerate development of old-growth forest characteristics Stand improvement cut young plantations to reduce 0 Acres 583 Acres tree competition and increase vigor and species diversity Create a sustainable supply of timber and other forest 0 MBF 38,005 MBF products that will help maintain the stability of local and regional economies MBF—thousand board MBF—thousand board feet feet

The control of tree stocking is an important focus of the proposed action in satisfying much of the project’s Purpose and Need. When compared to no action the proposed action would make the most of the integration of treatments with natural processes to more closely resemble Desired Future Conditions. Without action, many of the project’s beneficial aspects would not be realized under natural processes until much later if at all. It is the determination of this analysis that the proposed action will have a positive and beneficial effect on vegetation in the Silver Creek Thin Project.

Compliance with the National Forest Management Act All treatment units are currently classified as suitable for timber production as required by 36 CFR § 219.14. As per 36 CFR § 219.27(b) the manipulation of the tree cover of these treatment units: is best suited to the multiple-use goals established for the area; can be adequately stocked within five years; is not chosen because of highest Net Present Value; is chosen after considering potential effects on residual trees and stands; avoids permanent impairment of site productivity; provides the desired effects on resource yields and is practical. None of the proposed treatments constitutes a type or species conversion.

A Responsible Official may authorize projects and activities on NFS lands using cutting methods, such as clearcutting, seed tree cutting, shelterwood cutting, and other cuts designed to regenerate an even-aged stand of timber, only where (in italics):

• There is assurance that the lands can be adequately restocked within five years after final regeneration harvest (FSM 1921.12g). This applies to the regeneration cut units within Matrix. Given the objective to develop early seral conditions of greater complexity and duration, the restocking objective is 125 trees per acre (NFMA minimum). Plant associations and soil management units indicated successful reforestation to these stocking levels is probable on these sites. Cut units will be surveyed for natural regeneration and supplemented where necessary with planted trees within three years of cutting.

• For clearcutting, it is the optimum method; or where seed tree, shelterwood, and other cuts are determined to be appropriate to meeting the objectives and requirements of the relevant plan (16

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U.S.C. 1604 (g)(3)(F)(i)). For seven stands, a light retention regeneration cut is prescribed as the optimum method to create early-seral forest habitat for wildlife. This cutting method is analogous to a seed tree/shelterwood system without the final removal, promoting a two-age stand (Tilton and Becker 1993). Selection of this silvicultural system and harvest cutting methods is consistent the LRMP Appendix F, “Harvest Cutting Methods.” Retention levels meet specifications in the Northwest Forest Plan for matrix lands.

Uneven-age management systems were not considered due to these light retention regeneration cuts seeking to create open conditions for a robust and longer lasting early seral phase. Uneven-aged partial cut regimes to do not provide open conditions due to the amount and distribution retained large tree stock. Uneven-age group selection methods, with openings typically less than 3 acres, are not large enough to develop early seral of the same duration or complexity. Both of these uneven-age systems require more logging entries and greater road density, which further dissuade their selection with this project.

• The interdisciplinary review has been completed and the potential environmental, biological, aesthetic, engineering, and economic impacts have been assessed on each advertised sale area and the cutting methods are consistent with the multiple use of the general area (16 U.S.C. 1604 (g)(3)(F)(ii)). Refer to the Silver Creek Environmental Assessment and supporting reports.

• Cuts are carried out according to the maximum size limit requirements for areas to be cut during one harvest operation (FSM 1921.12e). The LRMP and Regional guides set the maximum size limit for opening at 60 acres in the western hemlock plant series, and 40 acres in the Pacific silver plant Series. Final opening sizes after removal of aggregated retention areas will be less than 40 acres.

For the above reasons, the Silver Creek Thin proposed action is consistent with the Gifford Pinchot National Forest Land and Resource Management Plan (LRMP), as amended. Because it is consistent with the Forest Plan, it is consistent with the National Forest Management Act. Fire Ecology

Existing Condition Historically, fire has been the most significant disturbance mechanism in the Middle Cowlitz Watershed. Suppression activities since the 1930’s have virtually eliminated potential natural wildfire effects for this watershed. In the pre-suppression era, whether fires were natural or man-caused, the fire events, which can be traced, are very large.

Fires in the Silver Creek planning area tend to be either small (<10 acres) or very large (>1,000 acres). Increased human use over the past century has likely increased the number of human-caused fire ignitions, but fire suppression and generally moist conditions have minimized fire growth. Duration of fires has decreased from historic lengths of a several days or months to a single burn period for most fires.

Evers et al. (1996) summarized the fire ecology of the mid-Columbia region of Oregon and Washington. The authors assigned plant associations into 12 fire groups based on plant species response to fire and the roles those species play during succession. The goal of the report is to help resource managers understand the role of fire in the ecosystems of the mid-Columbia area. Summaries of fire groups present in the Silver Creek planning area are included below.

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Fire Group 8 Fire Group 8 includes most of the western hemlock and Pacific silver fir plant associations found in the mid-Columbia. As such, it includes a wide range of topographic positions, moisture regimes, and temperature regimes. Vegetation types reflect a warm, moist climate to the west, gradually shifting to a cooler and drier climate to the east.

This group generally lacks fine fuels through most of the stand history. Sites containing devil’s club and skunk cabbage may have heavy fuel buildups, but the presence of water keeps these fuels too moist to burn readily and facilitates relatively rapid decay. Old-growth stand conditions (closed canopy overstory of large diameter trees over a lush understory) are common in undisturbed areas, indicating infrequent disturbance. Fuel loadings build rapidly once the overstory begins to die from insect and disease attacks and the canopy breaks up. Conditions become drier in these canopy gaps and can easily provide a suitable fuelbed for fire starts. Loading of 0-3 inch diameter woody fuel ranges from 1.4 to 5.0 tons per acre.

Dominant species, including western hemlock and Pacific silver fir, are extremely fire sensitive due to thin bark, shallow roots, and highly flammable foliage. Fire frequency tends to be low because of the cool, moist habitats, and fire return interval is generally between 150 to 400 years or more.

Large fires within these plant zones generally tend to be stand replacing. Even light surface fire can damage shallow roots. Fire in this group serves to prepare mineral soil seedbeds, produces a mosaic of stand structures and age classes across the landscape, and affects within-stand species diversity. Fire history maps and recent wildfires suggest that most fires are either very small (>10 acres) or very large (>1000 acres). Mid-sized fires are not unknown but appear to depend on a combination of dry conditions and light to moderate winds. Conditions conducive to large fire growth, prolonged drought and strong east winds, occur approximately every 30 years (Pyne, 1982).

Stand replacement fire will dominate during a large fire event under current conditions. Most of the active burning occurs during one burn period but can occur over several burn periods. Low rates of spread and fireline intensities dominate; long smoldering phases can increase fire severity. High intensity fires depend on extreme wind, drought, or both. Fire danger is highest from mid-September through October.

Fire Group 9 Fire Group 9 consists primarily of dry western hemlock plant associations where is the major seral species. On the Gifford Pinchot Fire Group 9 occurs primarily on North and South aspects of the Cowlitz River. Site characteristics include stony, rocky, gravely or otherwise well drained soils, steep slopes and generally dry conditions.

Fuel loadings in this fire group are highly variable, depending on individual stand and site conditions. Generally, Fire Group 9 does not contain duff as deep as Fire Group 8. However, large logs are common. Most sites in the fire group dry out sufficiently and contain enough fine fuels to carry fires in most years. On the Gifford Pinchot, fine fuel loadings range from 2.2 to 4.0 tons per acre with a weighted average of 3.5 tons per acre. Fuel loadings for material larger than three inches in diameter show side variability, ranging from a low of 2.5 tons per acre to 57 tons per acre (Topik at al. 1986).

Fire frequency in Fire Group 9 largely determines stand conditions. Infrequent fires allow Douglas-fir and western hemlock regeneration to establish and provide a fuel ladder into the canopy. Fire probably returned to Group 9 communities roughly every 25-150 years prior to 1900, depending on location. The closed canopy on the Gifford Pinchot suggests a longer fire return interval that is closer to the upper end of the range.

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Prolonged fire exclusion probably has allowed development of denser stands than before white settlement. Stand-replacing crown fires can develop and do not necessarily depend on the combination of prolonged drought and east wind conditions typical of Group 8. In the absence of east winds, topography and rockiness tend to control fire size and shape. Most often, low to moderate rates-of-spread and fireline intensities dominate fire behavior. Because Group 9 is generally found on the lower 1/3 of the slope, fires starting within the group can potentially spread further before fuel conditions change. On the Gifford Pinchot, thick growth of salal and dwarf Oregongrape mixed with a lesser amount of grasses often significantly increases the fine fuels, thereby enhancing rates-of-spread.

Disturbance History Disturbance Area Affected Year

Fire 1 ≈ 6,000 acres Between 1850-1900

Three fires of 1,000 acres or larger burned in the Middle Cowlitz watershed analysis area between approximately mid to late 1800 to 1920. Out of the three one fire burned in the Silver Creek planning area. The fire was approximately 6,000 acres that burned from the Cowlitz valley floor to approximately 2 ½ miles north of the valley bottom. This fire burned sometime between 1850 and 1900.

Fuel Condition and Fire Hazard Unnatural and hazardous fuel accumulations may exist in individual stands within the Silver Creek planning area, but the general landscape condition does not suggest considerable departure from historic or desired future conditions. Potential fire behavior is only a concern during drought conditions in the relatively wet vegetation types present in the planning area.

Desired Future Condition Desired future condition is a healthy, diverse, and resilient landscape that can adapt to future disturbances with minimal negative effects to ecosystems. Desired future conditions with respect to fuels prioritize the protection of communities and other values at risk from wildfire by minimizing potential flame lengths and rates of spread. No communities and few other values exist in the immediate vicinity of the planning area. Desired future conditions with respect to fire ecology prioritize the restoration and maintenance of ecosystem resilience, where appropriate. Landscape conditions show no considerable departure from historic conditions; no fire ecology restoration needs have been identified.

Effects Effects of the proposed action include an increase in surface fuel loading where slash is allowed to remain on site. Increased surface fuel loading increases potential surface fire behavior immediately following treatment. Potential surface fire behavior generally decreases in stands and portions of stands that are piled and burned compared to both existing conditions and post treatment conditions with no slash disposal.

Metrics of crown fire behavior are difficult to quantify, but the proposed action is expected to reduce the potential for crown fire initiation and spread. Crown fire cannot be considered independently of surface fire (Van Wagner, 1977; Alexander, 1988), but predictions can be made about the likelihood of crown fire based on canopy fuel characteristics. A decrease in ladder fuels reduces the likelihood that fires can transition from the surface fuel layer to the canopy and a reduction in the quantity and horizontal continuity of canopy fuels can prevent crown fire spread (Raymond and Peterson, 2005).

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Pile burning can result in site sterilization from intense and prolonged soil heating, adjacent tree mortality, minor threats to wildlife, temporary limitation to public access, and an output of greenhouse gases including carbon monoxide, nitrous oxides, volatile organic matter, and particulate matter with aerodynamic diameter less than 2.5 and less than ten microns (PM2.5 and PM10). Level of emissions is related to the intensity and duration of the fire, which is determined by fuel and weather conditions at the time of burning. Emissions from prescribed burning can be detrimental to firefighter and public health and contribute to greenhouse gas concentrations in the atmosphere. Indirect effects of individual or multiple projects on global climate change are difficult to quantify; therefore, the significance of the effects of this proposed project on global climate change cannot be determined at any scale. Botanical Resources This report evaluates the potential effects of the proposed action on Threatened, Endangered, Proposed and Sensitive (TEPS) plant species in accordance with The National Environmental Policy Act (42 USC 4321 et seq.), the federal Endangered Species Act (16 USC 1531 et seq.), and the National Forest Management Act (16 USC 1604 et seq.). In order to comply with the above, the Forest Service has set forth guidance in FSM 2670, which is designed to ensure that Forest Service actions (1) do not contribute to the loss of viability of any native or desired non-native species or cause a trend toward federal listing for any species; (2) comply with the requirements of the Endangered Species Act; and (3) provide a process and standard which ensures that TEPS species receive full consideration in the decision making process.

This report also evaluates the potential effects of the Silver Creek Thin project alternatives on Survey and Manage (S&M) plant species (USDA & USDI 2001), other rare and uncommon botanical resources of concern, special habitats, and native species (Gifford Pinchot National Forest Land and Resource Management Plan 1990), and incorporates a risk analysis for noxious weed and invasive plant spread, with project design features and mitigations recommended, as directed within FSM 2090 Invasive Species Management. (12/05/2011).

Analysis Methods

Pre-Field Review In order to determine whether the activities proposed in this project pose a potential threat to Regional Forester’s Threatened, Endangered, Proposed or Sensitive (TEPS) species, a review of current information was performed. This review consists of an analysis of the potential effects of the project on known sites of species of concern, or on potential habitat for these species. Aerial photographs, the December 2011 Regional Forester’s Special Status Species List (RFSSSL), forest GIS information, the GEOBOB database, the NRIS –TES database, data from CVS Random Grid Surveys (2005), district files, and other published sources were consulted for the review. This information was then used to determine the likelihood of impacts to these species as a result of the proposed action.

As discussed above, the RFSSSL lists 94 botanical taxa that are documented or suspected to occur on the Gifford Pinchot National Forest. Pre-field review data are summarized in Table 20.

Field Surveys Botanical surveys were conducted in the Silver Creek Thin planning area during the summer of 2015. Surveys were conducted for Sensitive botanical species, based on the Regional Forester’s December 2011 list (USDA Forest Service 2011). Surveys for other rare and uncommon species and Survey and Manage species were conducted as a part of complete species list compilations.

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Due to the seasonal nature of plant identification, it is not always possible to completely survey a given area with a one-time survey; however, the knowledge of plant-habitat relationships, growth habit, and flowering dates helps the investigator in this regard. The phenology of lichens, bryophytes and the Bridgeoporus nobillisimus, are such that they can be identified throughout most of the year. Based upon this, surveys for these species are generally conducted at the same time as surveys for seasonally flowering species.

Survey impractical species depend on components of pre-project clearances other than surveys, including known site searches and habitat evaluations, to provide the information needed to analyze potential risks to the species resulting from project activities. This analysis is then used to prescribe project design features and/or mitigations to address these risks. Survey impractical species include rare and uncommon fungi, and some cryptic species of lichens and bryophytes.

Existing Condition The proposed Silver Creek Thin Timber Sale lies within the Southern Washington Cascades Province of the Pacific Northwest (Franklin & Dyrness 1973). The planning area is located within western hemlock and Pacific silver fir vegetation zones (1973).

Depending on elevation and aspect, the units are dominated by variable amounts of Douglas fir, western hemlock and Pacific silver fir, with a component of red alder in moist or disturbed areas. The understories are mainly dominated by red huckleberry, oval-leafed huckleberry, vine maple, salal or sword fern with devil’s club in perennially wet areas. The plant associations in the project area fall within the Pacific silver fir and the western hemlock series. Plant associations are entirely within the Pacific silver fir series. Many stands have down logs and stumps on the forest floor. Special features such as rock outcrops or cliffs, boulders, and wetlands or seeps were observed in many units. Numerous units also have some component of invasive weeds such as herb robert, noxious hawkweed species, tansy ragwort, and wall- lettuce, amongst others.

The Regional Forester’s Special Status Species List (RFSSSL) of December 2011 currently lists 94 Threatened, Endangered, Candidate, Sensitive and Strategic botanical species documented or suspected to occur on the Gifford Pinchot National Forest. Of these 94, Howellia aquatica is suspected to be in the project area and has a Threatened status. Pinus albicaulis is documented in the project area and is a candidate species under the ESA. The remaining taxa are on the Regional Forester’s Special Status Species List (RFSSSL) and are designated as either sensitive or strategic. The list—in its December 2011 iteration—includes 11 moss species, 23 lichens and 60 vascular plants. In total, 49 of the taxa on the RFSSSL are formally documented as being present on the forest. An additional 3 lichen species are posted on the 2001 Survey and Manage List and are documented as occurring on the forest.

Pre-Field Review A thorough pre-field review of habitat preferences and georeferenced occurrences for all the sensitive taxa known or suspected to occur within the Gifford Pinchot N.F. indicates that 44 taxa have a reasonable likelihood of occurring within the Silver Creek Thin Project area (Table 19). Species were given a high, medium or low likelihood of being in the project area. High likelihood indicates that the species has been documented within 20 miles of the project and suitable habitat exists in the project area. A moderate likelihood rating was given if suitable habitat for a species is known from the project area, and the species is known from the region. A low likelihood was given to species for which to little was known to rule them out. Amongst these, 14 are considered to have a moderate likelihood of occurring within the project confines; two lichen taxa—Cladonia norvegica and Usnea longissima—are considered to have a high likelihood of occurrence. The remainder are all considered to have a low likelihood of occurrence. A single listed vascular plant sensitive species—Sidalcea hirtipes (bristlestem checkerbloom)—has a

85 Cowlitz Valley Ranger District moderate likelihood of occurrence in the project area. With the notable exception of this globally rare taxon, no currently listed sensitive species are recorded in the general project area in the current NRM national database. A full accounting of all the suspected and documented RFSSSL taxa on the forest, including the three Survey and Manage lichen taxa mentioned above, are presented in the Botanical Resource report in the project record.

Table 19. Federally Endangered (E), Threatened (T), and RFSSSL (S/Str), and other Rare and Uncommon (RU) Botanical Species Documented or Suspected to Occur on the Gifford Pinchot National Forest, with an Estimate of Likelihood of Occurrence within the Silver Creek Thin Timber Sale Planning Area. RFSSSL Iteration December 2011

Scientific name Threatened (T), Documented (D) or Likelihood of Species Endangered (E), Sensitive Suspected (S) on Occurrence within the Project (S) or other Rare and the Gifford Pinchot Area - Blank Cells Indicate No Uncommon (RU) Species National Forest Chance Of Occurrence – Shaded Cells Indicate Higher Chances

Botrychium montanum RU D LOW

Calochortus longebarbatus var. S S longebarbatus

Carex densa S D LOW Carex macrochaeta S S LOW Coptis aspleniifolia S S LOW Corydalis aquae- gelidae S D LOW

Erythranthe pulsiferae S S LOW Fritillaria camschatcensis S S MODERATE Juncus howellii S D LOW Montia diffusa S D MODERATE Pedicularis rainierensis S S LOW Polemonium carneum S S LOW Polystichum Str S LOW californicum Potentilla drummondii ssp. breweri Str S LOW Sidalcea hirtipes S D MODERATE Brotherella roellii Str S LOW Bryum calobryoides Str S MODERATE Conostomum Str S LOW tt Elodium blandowii Str D LOW Encalypta brevicollis Str S LOW Pohlia cardotii Str S Schistostega pennata Str D MODERATE Tetraphis geniculata Str D MODERATE Thamnobryum Str S MODERATE neckeroides Arctoparmelia incurva Str D LOW

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Scientific name Threatened (T), Documented (D) or Likelihood of Species Endangered (E), Sensitive Suspected (S) on Occurrence within the Project (S) or other Rare and the Gifford Pinchot Area - Blank Cells Indicate No Uncommon (RU) Species National Forest Chance Of Occurrence – Shaded Cells Indicate Higher Chances Brodoa oroarctica Str D LOW

Calicium adaequatum Str D LOW Chaenothecum subroscida Str D MODERATE Cladonia norvegica Str D HIGH Cornicularia Str D MODERATE normoerica Dendriscocaulon Str D MODERATE intricatulum Dermatocarpon Str D MODERATE meiophyllizum Hypogymnia oceanica Str D MODERATE

Leptogium rivale Str D MODERATE Lobaria linita SM D MODERATE Nephroma occultum Str D MODERATE Phylliscum Str D LOW demangeonii Pilophorus nigricaulis Str D MODERATE Pseudocyphellaria rainierensis Str D LOW Ramalina thrausta SM D LOW Umbilicaria angulata Str D LOW

Umbilicaria havaasii Str D LOW Umbilicaria lambii Str D LOW Umbilicaria vellea Str D LOW Usnea longissima Str D HIGH Usnea sphacelata Str D LOW Vestergrenopsis Str D isidiata

Field Survey Results

Threatened, Endangered & Proposed Plant Species No botanical species that are federally listed as Threatened, Endangered, or Proposed were detected during surveys of the project area.

Sensitive Plant Species No Sensitive botanical species were detected during surveys of the project area. Coptis aspleniifolia was reported from section 23 (13N 7E), but was determined by the botanical survey contractor to be improperly notated (Scot Loring, e-mail communication to Marie Tompkins, COR, 8/2015).

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Rare and Uncommon Botanical Species Occurrences of other rare and uncommon botanical species detected during surveys are listed in the table below. Occurrences are also mapped in the Natural Resource Information System (NRIS) databases.

Table 20. Sensitive and other Rare and Uncommon Botanical Species Occurrences within Silver Creek Thin Proposed Timber Sale Units Location (Stand Sensitive (S) Occurrences (number of sites) ID/Unit) Other Rare and Uncommon (RU)* 9558/21 RU Stenocybe clavata (2)

9593/14 RU Tetraplodon mnioides (2)

31/15 RU Stenocybe clavata (2)

31/15 RU Leptogium rivale (1)

9029/6 RU Pseudocyphellaria rainierensis (1)

9592/17 RU Pseudocyphellaria rainierensis (1)

9592/17 RU Dermatocarpon meiophyllizum (1)

9592/17 RU Tetraplodon mnioides (1)

9625/20 RU Tetraplodon mnioides (1)

9625/20 RU Stenocybe sp. (1 )

9625/20 RU Chaenotheca chrysocephala (2)

9051/32 RU Vibrissea filisporia (1)

9625/20 RU Microcalicium sp. (1)

9594/11 RU Dermatocarpon meiophyllizum

9594/11 RU Leptogium rivale (numerous)

9594/11 RU Tetraplodon mnioides (1)

Most species listed in this table are also Regional Forester’s Strategic Species (2011). Strategic Species are not considered “Sensitive” under Forest Service Manual 2760. Many Strategic species are poorly known (i.e. distribution, habitat, threats, or ). Management direction for strategic species requires field units to record survey and location information in the agency’s corporate Natural Resource Information System (NRIS) databases.

Northwest Forest Plan Survey and Manage Mitigation Northwest Forest Plan Survey and Manage Standards and Guidelines (2001) and associated January 2001 species list apply to all stands proposed for early-seral treatment. The majority of stands in the Silver Creek project area are proposed for commercial thinning, whereas approximately 176 acres of the project area are prescribed for regeneration harvest. At the time of pre-field analysis, this treatment had not yet been proposed, and thus the Survey and Manage mitigation was not initially triggered. However, because all botanical surveys conducted for Silver Creek Thin project included the compilation of complete botanical species lists for each stand, surveys for Survey and Manage species were actually completed. In addition, because most Survey and Manage species are also considered ‘other rare and uncommon’ species, and some are Regional Forester’s Strategic species, site-specific information was collected for these species when detected during surveys. All occurrences of Survey and Manage species are located

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within or just outside stands proposed for commercial thinning, and thereby exempt from the Survey and Manage mitigation (Pechman 2006); however, it is recommended that mitigations for the rare, uncommon and Survey and Manage species occurrences in the Silver Creek Thin planning area be implemented as recommended.

Special Habitats Special habitats, including wetlands, rocky outcrops, meadows, and hardwood gaps were located in a number of units. Protection of these features was incorporated into the project design during the planning process for this project.

Wetland/riparian habitat (Riparian Reserves) Riparian zones and wetlands (wet or seasonally wet) provide important habitat for many botanical and wildlife species, and often support the majority of the botanical diversity present present within stands. Protection of Riparian Reserves has been incorporated into the project design through implementation of no-cut buffers.

Talus and Rocky Outcrops There are a number of rocky outcrops within the Silver Creek Thin planning area. These areas provide habitat for a host of unusual botanical species, including Phylliscum demangeonii, a rare lichen species.

Hardwood Trees and Shrubs Hardwood trees and shrubs, including red alder (Alnus rubra), black cottonwood (Populus balsamifera ssp. trichocarpa), vine maple and bigleaf maple (Acer circinatum and A. macrophylla), dogwood (Cornus nuttallii), hazel (Corylus cornuta) and Cascara (Rhamnus purshiana) add substrate diversity for epiphytic lichens and bryophytes, and provide structural and habitat diversity that encourages understory plant diversity, as well as bird and wildlife diversity. Silvicultural prescriptions within stands proposed for commercial thinning do not target hardwood trees (unless they are a major stand component, which is true for red alder and black cottonwood in some Silver Creek stands) or shrubs; as a result, these elements are retained during harvest.

Effects

Threatened, Endangered, Proposed Plant Species

Direct and Indirect Effects At this time there are no federally listed (threatened, endangered, proposed - TEP) plant species known to occur on the Forest, however one federally threatened species (Howellia aquatilis) is suspected. Howellia aquatilis has an extremely narrow habitat tolerance, generally confined to wetlands with seasonal drawdown. Wetlands to be impacted by this project were surveyed and no TEP species were located. In addition, all wetlands within the project boundaries will receive a no-cut buffer. Thus, project alternatives will have NO EFFECT on federally listed botanical species under either the Action or No Action alternatives.

Cumulative Effects There are no cumulative effects on Threatened, Endangered, or Proposed Botanical Species because there are no direct or indirect effects, under either the Action or the No Action alternatives.

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Sensitive Species

Direct and Indirect Effects No Regional Forester’s Sensitive species were located within the Silver Creek Thin project area, and for this reason, the Action alternative will have NO IMPACT on Sensitive botanical species. The No Action alternative will also have NO IMPACT on Sensitive botanical species.

Cumulative Impacts There are no confirmed Sensitive species occurrences within the Silver Creek Thin project area, and therefore no cumulative impacts to Sensitive species.

Rare and Uncommon Botanical Species of Concern: Botanical species considered rare or uncommon but not listed by the Regional Forester are can be considered as additional botanical species of concern. Surveys performed within and immediately surrounding the Silver Creek project area located eight rare and uncommon botanical species of concern (6 lichens, 1 bryophyte and 1 fungi), including Chaenotheca chrysocephala, Dermatocarpon meiophyllizum, Leptogium rivale, Pseudocyphellaria rainierensis, Stenocybe clavata, Tetraplodon mnioides, Vibrissea filisporia and a species of Microcalicium whose characteristics precluded identification with a dichotomous key; all of these species, with the exception of Dermatocarpon meiophyllizum, Tetraplodon mnioides, Vibrissea filisporia and the Microcalicium sp., are also Survey and Manage species (USDA and USDI 2001).

The sites for these species within Silver Creek project area are, in some cases, among few known to occur across the forest; numbers of known sites on the Gifford Pinchot National Forest range from Chaenotheca chyrsocephala at 3 sites to Stenocybe clavata at 4 sites—both small, cryptic lichens, difficult to find and identify. In other cases, easily identifiable and showy species are known from more sites, but patchily distributed, often because of dispersal limitations or habitat specificity. Such species include Leptogium rivale and Dermatocarpon meiophyllizum, aquatic lichens known from 28 and 2 sites, respectively; in addition to 76 sites of Pseudocyphellaria rainierensis (also known as “old growth specklebelly”), a dispersal-limited epiphytic lichen often associated with old-growth forests or legacy elements remaining in younger forests. Tetraplodon mnioides is the only rare moss species to be found in the project area.This moss species is rare south of the Canadian border and has no prior documentation within the Gifford Pinchot National Forest. Five populations of the carnivore dung-dwelling moss have been identified on roads within the project area.

In order to ensure well-distributed populations of native species, and because many of the ‘other rare and uncommon species’ are also ranked as Strategic, mitigations are recommended (see PDC 1.17) in order to conserve sites and habitat for these species. Strategic species are those species for which more information is still needed to determine whether a conservation status is indicated.

Cumulative Effects As presented briefly above, the cumulative effects area chosen for this analysis is the area of the Cowlitz Valley Ranger District exclusive of the Mineral Block to the west. This analysis area is considered large enough to accommodate sustainable populations for all species being considered despite the potential effects of the Silver Creek project. The choice of the district boundary was determined because the size was suitable, and information about habitat conditions is usually available in terms of mapped political units, although the boundary is not biologically meaningful. The past time horizon for comparison of cumulative effects to rare species is approximately 1900, when large scale European settlement with land clearing began to alter presettlement forest disturbance patterns and habitat availability for rare species.

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The future time horizon is 2030, when all activities associated with the thinning project will have long been complete. Effects will assuredly not end at this, admittedly, artificial 2030 temporal horizon, but effects can be expected to become increasingly speculative in longer time frames. Detailed regional population trend information for listed sensitive taxa is only very rarely available for any populations that may be found within the project area. As such, careful on-the-ground observations of sensitive taxa populations may inform some elements of the cumulative effects analysis.

There has also been a substantial but unquantified amount of timber harvest on private lands within the Cowlitz Valley Ranger District administrative boundary. These projects may have had some additive effects similar to the possible effects of the Silver Creek Thin Project, such as impacts to individuals of TES species causing loss of population connectivity, or effects to habitat suitability such as soil compaction, or loss of shade. Such effects may overlap with the cumulative effects timeline of the Silver Creek Thin Project. No metric is available for impacts to undetected individuals, but pre-project surveys on Forest Service harvest areas are believed to lower the probability of such impacts in recent actions.

In summary, none of the sensitive botanical species that have potential habitat in the project area is so limited in distribution, habitat, or number that project activities, with incorporated design features, are likely to contribute towards a trend leading to federal listing under the TES. Additionally, past or reasonably-foreseeable future actions on nearby federal land and adjacent private land are unlikely to contribute significantly to a trend towards federal listing for these taxa, or threaten the viability of entire populations of taxa as a whole. Noxious Weeds and Invasive Plants FSM 2090 (12/05/2011) Invasive Species Management, directs that requires that Noxious Weed Risk Assessments be prepared for all projects involving ground-disturbing activities. For projects that have a moderate to high risk of introducing or spreading noxious weeds, recent Forest Service policy requires that decision documents must identify noxious weed control measures that will be undertaken during project implementation (FSM 2903.4-7, 12/05/2011). In addition, the Pacific Northwest Region Invasive Plant Program Record of Decision for Preventing and Managing Invasive Plants (USDA FS 2005) provides invasive plant prevention and treatment/restoration standards and direction on all National Forest Lands within Region 6.

Existing Condition Non-native plants include those taxa introduced intentionally or unintentionally to areas where they do not naturally occur. Invasive non-native plants in the Pacific Northwest most often originate from Europe and Asia. Problems arise when the associated natural predators, diseases, and competitors that controlled these species in their native habitats are not present in the habitat where they are introduced. If a species is unchecked by competition or predation, it may become invasive, dominating the site and altering ecosystem functioning. The results may include changes in biodiversity, compressed fire return intervals, soil erosion and hydrology of a site. Other effects include potential poisoning of wildlife and reducing the quality of recreational experiences. There are an estimated 2,000 invasive weed species in the United States. The state of Washington maintains a noxious weed list containing approximately 150 species, ranked A, B, or C according to treatment priority. Lewis County also maintains a noxious weed list, which helps determine treatment priorities on the Gifford Pinchot National Forest.

Invasive weeds are common, especially along roads in the Silver Creek Thin Project area. Scotch broom is of particular concern in areas managed for timber. In previously infested areas, the seed bank is persistent and can remain viable in the soil for 50+ years, only to germinate in abundance at the next disturbance or timber rotation. Scotch broom can also be highly competitive with conifer seedlings. There

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is no effective control for seeds lying dormant in the soil, so the most effective management is to prevent spread and control seed production. Control of infested sites requires consistent treatment and follow-up for many years once plants are allowed to go to seed.

Species ranked as low priority for treatment are species that are common and well distributed throughout the planning area; for these species, active treatment is not pursued on the N. Zone of the Gifford Pinchot National Forest, except in special habitats where invasive species threaten resources at risk, and in gravel pits.

Table 21. Noxious and significant invasive plant taxa expected within the Silver Creek Thin project area Taxon – Specific Taxon – Common WA Noxious Status Centaurea stoebe spotted knapweed class B Cirsium arvense Canada thistle class C Cirsium vulgare bull thistle class C Geranium robertianum herb robert class B Cytsis scoparius Scotch thistle class B Hypericum perforatum St. John’s wort class C Hypochaeris radicata hairy cat’s ear class C Ilex aquifolium English holly no status Leucanthemum vulgare oxeye daisy class C Polygonum x hybrid knotweed class B bohemicum Senecio jacobaea tansy ragwort class B Tanacetum vulgare common tansy class C

Effects

No Action Under the No Action alternative, the proposed thinning and associated road construction and closure would not take place. Weeds would continue to spread locally by natural processes and ongoing motorized use. Motorized use and associated spread of weeds would occur on 10.22 more miles of National Forest System road than in the Proposed Action. With No Action, routine road maintenance and weed control would continue subject to district funding and priorities.

Proposed Action Table 22. Summary of Effects of Silver Creek Thin Proposed Action on Invasive Species Factor Description Indicator Measure Loss of shade Reduced shade Canopy cover reduction Percent. promotes invasive Reduced from about 90% species growth and to residual: dominance Light thin: 49-62% Moderate thin: 42-57 Heavy thin: 40-52 Regeneration: 15

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Factor Description Indicator Measure Ground disturbance Disturbed ground Area of expected Acres – varies with provides a favorable disturbed ground harvest methods and site seedbed for invasive factors plant taxa and a competitively advantageous setting for invasives relative to native species Conduits or pipelines Continuous corridors of New and reconstructed Miles – approximately 15 for weed establishment reduced shade and roads miles of new temporary in new areas repeated disturbance roads and reconstructed provide a pathway of roads will access this favorable habitat for project. invasive plant taxa to spread, and also provide a path for vectors such as vehicles. Weed vectors: One of the ways weed Spot rocking areas in Loads of rock and gravel materials seeds are moved from need of road metal to one area to another – in facilitate efficient haul gravel or pit materials routes. Weed vectors: project One of the ways weeds Presence of heavy Equipment movements equipment are moved from one equipment that may from infested to place to another – on carry soil or seeds. Any uninfested project area. project equipment vehicle may also carry seeds. Preexisting weed Existing populations can Weed species recorded Known invasive populations in project spread seed during the in units populations and potential areas seasons of work or may seed bank exist in the seed bank.

Under the Silver Creek Thin Proposed Action alternative, there would be ground disturbance, and opening of the canopy during the course of timber harvest activities. Ground disturbance exposes an available seedbed for noxious weeds, while timber harvest exposes newly created disturbed areas to increased sunshine, ideal conditions for early seral species including weeds. Areas experiencing ground disturbance within the timber sales would, therefore, be susceptible to noxious weed and invasive plant colonization (Sutherland and Nelson 2008), particularly since there are already invasive species growing along access roads to the units and in some of the units. Current canopy closure is estimated to be 90%. Canopy closure would be reduced to 40-60% after thinning. Tree canopies are expected to close after thinning within 20 years. Therefore, the effect of increased light within stands is expected to be reduced through time.

Roads function as “pipelines” for invasive plants to spread, both by providing corridors of increased light levels and repeated disturbance, and for transport (Von der Lippe and Kowarik 2008, Taylor et al. 2011). All temporary roads proposed for construction (Table 2) are proposed for post-project closure. The risk of weed introduction associated with road use is expected to be temporary on these project roads. However, weeds that do establish on temporary roads may or may not be controlled, depending on future budget allocations.

Movement of materials such as road construction gravel is also one of the principle methods noxious weed species are mobilized around the forest (Peterson 2008). The Gifford Pinchot National Forest, in the last couple of years, has begun a more comprehensive and consistent weed control program, particularly in gravel pits. However, some noxious weeds, such as scotch broom, have a long-lived seed bank and seed may remain in pit materials or underlying areas from earlier years. Seed can also blow into pits or be

93 Cowlitz Valley Ranger District moved by birds from the surrounding area, or by vehicles that use the pits. Although pit materials are required to come from sources judged weed-free by a weed specialist (R6 2005 Weed ROD standard 6), seeds in the material cannot typically be seen, and therefore this standard cannot eliminate all weed transport. Therefore, there is always a risk of weed introduction when materials are moved from place to place. This risk is being reduced each year with more consistent weed management. Spot rocking will assuredly be required on some roads planned for the Silver Creek Thin Project. To greatly reduce the risk of the spread of noxious weeds on the project, only freshly blasted and crushed rock will be utilized; old existing gravel piles will not be utilized.

Weeds that do establish in the disturbed areas may or may not be controlled depending on available funding. Project design standards for weeds should reduce, but are unlikely to eliminate the risk.

Table 23. Potential Effects of Silver Creek Thin Restoration Projects on Weeds

Project Invasive weed impacts Comments

Snag and down wood Creation of snags and down wood for wildlife would creation (dependent on have a minor effect of reducing canopy temporarily yes available funding) and thus providing some opportunity for weed invasion Hampton Wetlands Proposed project involves removing a culvert and Restoration perhaps some stream channel disturbance – yes disturbed soil will create minor substrate availability for invasive plants Close and stabilize roads There may be disturbance to the roadbed during 47-213, possibly 7534 or stabilization activities like culvert removal. This most of the spurs, and would have a temporary effect of creating 75-043 and spurs. Could conditions favorable to weeds as in the analysis be from 3 to 5 miles total. above. In the long-term, closed roads are expected yes to be shaded by growing canopy cover, experience less disturbance from traffic, have greater native plant cover on the road surface, and to have fewer new weeds introduced on motorized equipment. Therefore, the long-term effect of road closure would be to diminish weed populations. Silver Creek Riparian This proposed project includes removal of canopy, Down Wood and Tree thus opening up the forest floor to more insolation. Release yes Placing woody debris would also involve some ground disturbance in a riparian area where the potential for weed infestation is probably high. Decommissioning of FSR Possible significant effect of disturbance to road 47 road at E. Fork Silver prism / culvert removal sites. yes Creek and the 4700194 road Remove old log bunk Minor effect of local disturbance creates a stream crossing sites to substrate for weed colonization. yes restore watershed function Silver Creek Riparian Project would both open up the canopy and create and Instream Restoration yes disturbed ground that could allow for a significant amount of weed infestation. Unplug culvert that has Would most probably decrease the potential for eroded side of the 4745 weed infestations. road forming a gully, which empties into a no wetland area. Plugging of inlet and gullying need to be addressed

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Project Invasive weed impacts Comments

FSR 7500065 Project will create disturbances that may promote decommission and yes weed infestations, but with time the project would culvert removal most probable decrease weed infestation potential FR 4773 culvert Project will likely reduce the potential for weed installation, re- infestations no established stream flow path Fish passage structural Replacing multiple culverts will create ground improvements on FR disturbances that promote weed infestation stream crossings Aquatic possibilities Organism Passage – FR yes 4700 at MP 4.8 and 7.5; FR 4725 at MP 0.48; FR 4740 at MP 1.9, 5290 @ MP 4.0 Thinning small, young This project would open up canopy and allow light trees to maintain health to the forest floor potentially stimulating the and vigor in matrix lands invasion of noxious plant taxa and the Nisqually Late yes Successional Reserve portion of Silver Creek Thin project

Control measures In order to control invasive weed colonization and spread under the Proposed Action, weed-spread prevention and weed control activities are recommended to occur before, during and after project activities. Because invasive weeds are widely established in the Silver Creek Thin project area on the roadsides, the Forest Service would not expect to eradicate most of them. The goal is to prevent invasive plants from spreading further, particularly in association with the disturbance of thinning the stands and roadwork.

Prevention Draft direction from the Council on Environmental Quality states, “Prevention is considered the first line of defense against invasive species, and is often the most biologically effective and cost effective means of minimizing the spread and impact of invasive species. The Office of Technology Assessment report, Chap. 4, Table 4-4, provides cost-benefit ratios on the prevention of 14 potential serious invasions. Prevention was calculated to be consistently cost effective. The ratios of the benefits of preventing the invasions compared to the costs of preventing the invasions ranged from 1,661:1 to 6.78:1.” (2009).

Noxious Weed and Invasive Non-Native Species Risk Assessment with Project Design Criteria and Mitigations Forest Service Manual direction requires that Noxious Weed Risk Assessments be prepared for all projects involving ground-disturbing activities. For projects that have a moderate to high risk of introducing or spreading noxious weeds, recent Forest Service policy requires that decision documents must identify noxious weed control measures that will be undertaken during project implementation (FSM 2081.03, 11/29/95). To be in compliance with the EIS for Managing Competing and Unwanted Vegetation, it is also recommended the applicable Standard Procedures to Reduce the Risk of Spreading Weeds be implemented in all projects, regardless of weed risk ranking. In addition, the Pacific Northwest Region Invasive Plant Program Record of Decision for Preventing and Managing Invasive Plants (USDA 2005) provides invasive plant prevention and treatment/restoration standards and direction on all National Forest Lands within Region 6.

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Risk Ranking Factors and Vectors considered in determining the risk level for the introduction or spread of noxious weeds are:

FACTORS A. Known noxious weeds in close proximity to project area that may foreseeably invade project. B. Project operation within noxious weed population. C. Any of vectors 1-8 in project area.

VECTORS 1. Heavy equipment (implied ground disturbance including compaction or loss of soil “A” horizon.) 2. Importing soil/cinders/gravel/straw or hay mulch. 3. ORVs or ATVs. 4. Grazing. 5. Pack animals (short-term disturbance). 6. Plant restoration. 7. Recreationists (hikers, mountain bikers, etc.…). 8. Forest Service or other project vehicles.

High, moderate, or low risk rankings are possible. For the high ranking, the project must contain a combination of factors A+C or B+C. The moderate ranking includes any of vectors #1-5 in the project area. A low ranking would include any of vectors #6-8 in the project area, or known weeds within or adjacent to the project area without vector presence.

Table 24. Risk for Spread of Noxious Weeds in Silver Creek Thin

Factors Vectors Risk Ranking

A, B, C 1, 2, 7, 8 High

Cumulative Effects Please see Botanical Resources section for cumulative effects boundary and time horizons, and General Comments Regarding Cumulative Effects for other actions planned in the cumulative effects area. Past land clearing, road building, and trade have introduced invasive plant species to the Cowlitz Valley Ranger District. Invasive plants have established on most roadsides and in many riparian areas, only alpine areas remain largely free of invasive plant species.

The environmental impact statement for the site-specific invasive plant treatment project detailing known sites is available at http://www.fs.fed.us/r6/invasiveplant-eis/site-specific/GIP/. The Proposed Action for the Silver Creek Thin project is expected to contribute to the further spread of invasive plants, through ground disturbance, canopy reduction, and road construction. The No Action alternative is not expected to increase weed spread. The incremental increase in invasive plant populations, added to the effects of past practices and activities on private land, will reduce the capacity of the district to provide habitat for native species and produce timber products (USDA Forest Service Pacific Northwest Region Invasive Plant Program: Preventing and Managing Invasive Plants, section 1.1). The Project Design Criteria and proposed mitigation would ameliorate but not eliminate this cumulative effect.

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Wildlife The purpose of the wildlife specialist report is to document the existing condition of the wildlife resources and determine the effects of the Silver Creek Thin project on federally listed species and their critical habitats. This section also includes an analysis of impacts to Region 6 Sensitive and Survey & Manage (S&M) wildlife species, and Management Indicator Species (MIS) identified in the February 1990 Gifford Pinchot National Forest Land and Resource Management Plan, as amended.

Analysis Issues and Indicators

Habitat Fragmentation According to the 1997 Middle Cowlitz watershed analysis “most of the watershed which flows into Silver Creek was a contiguous forest of large trees (200 years or older) in 1900.” Past timber harvest activity in the headwater sub-basins of Silver Creek, such as Upper Lynx Creek, has resulted in a highly fragmented landscape leaving small remnant patches of late successional habitat. Almost 20 years ago when the Middle Cowlitz analysis was conducted, 52% of the watershed was in a grass/pole structural condition with most of the land in this category occurring on private land, or land that was formerly under private ownership. Today these stands are not likely providing quality early seral habitat, rather they are dense stands of young conifers generally in need of thinning to improve habitat conditions for wildlife.

Figure 12. Upper Silver Creek showing highly fragmented late-successional forest There are large patches of contiguous late successional stands in the lower part of the project area lying in the three sections of LSR situated in the middle of the drainage, East Fork Silver Creek, and in Upper Silver Creek. According to the 1997 Middle Cowlitz watershed analysis on both National Forest and private land, 19% of the watershed was in a large tree (generally 200 years or older) structural stage. Given that no harvest of old growth forest has occurred within the past 20 years, this percentage would still be valid today. Of the 6th field subwatersheds within the Middle Cowlitz 5th field watershed, Upper Silver Creek had the highest number of acres in the large tree structural stage (3,360 acres) that comprised 45% of the subwatershed. The East fork Silver subwatershed had the highest percentage in large tree

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structure (59%) that consisted of 1,270 acres of older forest stands. Lower Silver had 2,301 acres, or 32%, of large tree structure. Therefore, large patches of suitable habitat do exist in the Silver Creek project area for species associated with old growth or late successional habitat, such as the northern spotted owl and marbled murrelet, but not nearly the amount that existed before extensive timber harvest occurred within the past 50 years.

High Road Density Approximately 263 miles of open roads exist within the 51.5 mi2 (33,007 acres) of the Silver Creek subwatershed (HUC 170800040505 – 6th field) that includes the Gifford Pinchot National Forest (GPNF) and private lands (see Hydrology section for more detail). Approximately 35.6 mi2 of the Silver Creek subwatershed is National Forest and 15.5 mi2 is private. The total length of Forest Service roads (Level 1 and 2 roads) is 133 miles with approximately 5.1 miles of those roads are outside of the GPNF boundary. Only level 1 (41 miles) and 2 (92 miles) roads exist within the subwatershed. The current Forest Service road density value for part of the Silver Creek subwatershed is 3.73 mi/mi2 that is above the high-risk value of 3 mi/sq. mi. for wildlife. On the non-Forest Service side of the Silver Creek subwatershed the road density is 8.4 mi/mi2. The road density for all of Silver Creek subwatershed is 5.1 mi/mi2 with 69% of the subwatershed belonging to Forest Service. The current status (open, decommissioned, etc.) and future disposition of roads on the non-Forest Service side is unknown.

Threatened, Endangered, and Proposed Species Table 25. Summary of Status and Effects to Threatened, Endangered, Candidate, Sensitive and Survey and Manage, and Management Indicator Species in the Silver Creek Thin Project Area *- Species with project effects analysis because they are known to or are likely to occur in the project area and/or suitable habitat is present in project area; LAA – Likely to adversely affect; NLAA – May affect, but not likely to adversely affect. MIIH - May impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

SPECIES NAME SPECIES STATUS Species habitat Species Effect/Impact D: Documented present within or documented summary S: Suspected adjacent to the in project project area area Mammals *Gray Wolf Endangered(D) Yes No NLAA Canis lupus Cascade Red Fox USFS Sensitive (D) No No No Impact Vulpes vulpes cascadensis Grizzly Bear Threatened (S) Yes (but not known to No No Effect Ursus arctos occur on forest) Townsend’s Big-eared Bat USFS Sensitive (D) No No No Impact Corynorhinus townsendii *California Wolverine ESA Proposed (D) Yes No NLAA Gulo gulo *Mountain Goat USFS Sensitive (D) Yes Yes MIIH Oreamnos americanus Keen’s Myotis USFS Sensitive (S) No No No Impact Myotis keenii *Pacific Fisher USFS Sensitive (D) Yes Yes MIIH Martes pennanti Birds *Marbled Murrelet Threatened (D) Yes No LAA Brachyramphus marmoratus

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SPECIES NAME SPECIES STATUS Species habitat Species Effect/Impact D: Documented present within or documented summary S: Suspected adjacent to the in project project area area *Critical Habitat for the Designated Yes ___ LAA Marbled Murrelet *Northern Spotted Owl Threatened (D) Yes Yes Not likely to Strix occidentalis caurina jeopardize *Critical Habitat for the Designated Yes ___ LAA Northern Spotted Owl *American Peregrine Falcon USFS Sensitive (D) Yes No No Impact Falco peregrinus anatum Common Loon USFS Sensitive (D) Yes No No Impact Gavia immer *Northern Goshawk USFS Sensitive (D) Yes Yes MIIH Accipiter gentilis *Bald Eagle USFS Sensitive (D) No No No Impact Haliaeetus leucocephalus *Harlequin Duck USFS Sensitive (D) Yes Yes MIIH Histrionicus histrionicus Great Gray Owl USFS Sensitive (S) No No No Impact Strix nebulosa Reptiles & Amphibians Sharptail Snake USFS Sensitive (D) Yes No No Impact Contia tenuis *Cope’s Giant Salamander USFS Sensitive (D) Yes No MIIH Dicamptodon copei *VanDyke’s Salamander USFS Sensitive (D) Yes No MIIH Plethodon vandykei Oregon Spotted Frog USFS Sensitive (D) No No No Effect Rana pretiosa *Larch Mtn. Salamander USFS Sensitive (D) Yes No MIIH Plethodon larselli *Cascade Torrent USFS Sensitive (D) Yes No MIIH Salamander Rhyacotriton cascadae Butterflies Barry’s Hairstreak USFS Sensitive (S) No No No Impact Callophrys gryneus barryi Johnson’s hairstreak USFS Sensitive (D) Yes No No Impact Callophrys johnsoni Golden Hairstreak USFS Sensitive (D) No No No Impact Habrodais grunus Mardon Skipper USFS Sensitive (D) No No No Impact Polites mardon Great Basin Fritillary USFS Sensitive (S) No No No Impact Speyeria egleis Mollusks *Puget Oregonian USFS Sensitive, Yes Yes MIIH Cryptomastix devia Survey and Manage (D) Columbia Gorge Oregonian USFS Sensitive, No No No Cryptomastix hendersoni Survey and Manage (S)

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SPECIES NAME SPECIES STATUS Species habitat Species Effect/Impact D: Documented present within or documented summary S: Suspected adjacent to the in project project area area *Evening Fieldslug USFS Sensitive, Yes No MIIH Deroceras hesperium Survey and Manage (S) Western Ridged Mussel USFS Sensitive (S) No No No Impact Gonidea angulata *Warty Jumping Slug USFS Sensitive, Yes No MIIH Hemphillia glandulosa Survey and Manage (D) *Keeled Jumping Slug USFS Sensitive, Yes No MIIH Hemphillia burringtoni Survey and Manage (S) *Malone's Jumping Slug USFS Sensitive, Yes No MIIH Hemphillia malonei Survey and Manage (D) *Panther Jumping Slug USFS Sensitive, Yes No MIIH Hemphillia pantherina Survey and Manage (D) Barren Juga USFS Sensitive (S) No No No Impact Juga hemphilli hemphilli *Oregon Megomphix USFS Sensitive (S) Yes No MIIH Megomphix hemphilli Crowned Tightcoil USFS Sensitive (S) No No No Impact Pristiloma pilsbryi Shiny Tightcoil USFS Sensitive (S) No No No Impact Pristiloma wascoense *Blue-gray Taildropper USFS Sensitive, Yes No MIIH Prophysaon coeruleum Survey and Manage (D)

Northern Spotted Owl The northern spotted owl (NSO) is an interior forest dwelling, medium-size owl that is highly specialized to prey on a diet of primarily arboreal rodents. The northern spotted owl was listed as federally “threatened” under ESA in 1990 and populations have continued to decline, especially correlated with the range expansion and increase in population density of the barred owl (Strix varia) within the range of the northern spotted owl.

Suitable NSO habitat is generally described as mature or old growth forest that has a moderate to high canopy closure; a multi-layered, multi-species canopy dominated by large overstory trees, a high incidence of large trees with various deformities (e.g. cavities, broken tops, dwarf mistletoe infections); numerous large snags, accumulations of fallen logs, and sufficient open space below the canopy for owls to fly through. Stands that provide these attributes and structure are referred to as nesting, roosting and foraging (NRF) habitat. Spotted owls also use a wider array of forest types for roosting, foraging and dispersal, including more open and fragmented habitats. NSO dispersal habitat at a minimum consists of stands with adequate tree size and canopy closure to provide protection from predators and minimal foraging opportunities, generally described as stands with an average diameter of 11 inches and 40% canopy closure. Generally, 50% of the landscape should be maintained to provide dispersal habitat to maintain habitat connectivity between patches of suitable habitat (Thomas et al. 1990).

In the Washington Cascades, an average spotted owl territory encompasses over 6,000 acres (USFWS 1992). For management purposes, a 1.8-mile radius circle is used to map spotted owl territories. Within the annual home range, there is a core area of concentrated habitat use during the nesting season

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(Bingham and Noon 1997). The core area contains the nest tree, alternate roosting sites, and the nest patch, which is roughly a 70 acre area surrounding the nest site that is heavily used by juvenile spotted owls prior to dispersal (Miller 1989). For management purposes, a nest patch is represented by a 300- meter radius circle. Spotted owl monitoring has indicated that established spotted owl territories are fairly stable, and that some territories may be occupied by different pairs of spotted owls over many years (Forsman et al. 1984). The actual nest-tree used within a territory may change from year to year, but alternate nest trees are usually located within the same general core area (equal to a 0.7-mile radius around an established activity center) (Forsman et al. 1984).

Existing Condition According to the 1997 Middle Cowlitz Watershed Analysis, there were nine nesting pairs and one territorial single NSO within the Middle Cowlitz watershed, and seven NSO home range areas that overlapped into the watershed boundary. At the time of the watershed analysis, eight of these 16 nesting pairs were considered an “incidental take” under US Fish and Wildlife Service guidelines for being below the threshold amount of suitable habitat within the core and home range area of the sites. Since the time of the 1997 watershed analysis, there are now ten historic NSO activity sites that have core or home ranges that occur within the project planning area proposed stand boundaries.

According to the 1997 analysis, of the 39,924 acres of federal land in the Middle Cowlitz watershed, there were 16,863 acres (42%) of suitable nesting, roosting and foraging habitat acres within the watershed. An additional 2,500 acres, or 6%, provided foraging habitat and an additional 10%, or 3,846 acres provided dispersal habitat. Since nearly 20 years has passed with very little timber harvest on federal land in the watershed, more of the landscape would now provide dispersal habitat. Therefore, the amount of dispersal habitat within the watershed would currently be approximately 60% of the land in federal ownership, and possibly more on non-federal land as well.

A minimum of 2,663 acres of NRF habitat within a 3.6-mile diameter home range area and 500 acres within the core area are necessary in Washington Cascade forests for the persistence of the spotted owl according to the US Fish and Wildlife Service. Threshold amounts of NRF habitat within the home range and core area radius of the mapped activity center were mapped using the GP forest’s GIS owl habitat layer. See the table below for these results.

Table 26. Approximate Acres NRF Habitat within NSO Historic Activity sites and in Silver Creek Thin NSO Site Name Acres of Suitable Acres of Suitable Acres of suitable Acres of non- and ID number NRF w/in 0.7 mile NRF w/in 1.8 mile habitat in suitable habitat radius Core Area radius Home treatment units within treatment Range within home units inside Home range area Range radius Grassy #505 763 4,306 43 425 Watch #520 526 2,148 0 197 Silver #515 645 2,800 0 179 Purcell #513 590 3,283 0 35 Silver 2 #5503 482 2,870 0 62 Silver 3 #5504 396 2,643 0 374 (core=27.5) Whalehead #5802 229 1,786 0 75 Mary Kiona #558 550 2,713 0 141 Catt #444 453 2,402 0 44 Catt-Cave #446 156 1,289 0 30

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Species Occurrence Informal spot calling conducted by Robert Pearson detected spotted owls at all of the historic locations, with the exception of Grassy, Watch, and Mary Kiona sites in the southern portion of the project area. The Mary Kiona historic NSO site has not been detected since 1995. The Grassy and Watch sites have not been accessible for several years due to road washouts, but they still are presumed to be occupied sites. Pearson has detected spotted owls, either single birds or pairs, at the historic activity sites Silver, Silver 2, Silver 3 and Purcell in the project area within the past 3 years, and 2 juveniles were detected at the Purcell #513 site in August of 2014. In addition, Cave and Catt-Cave sites were detected during spot calling for the recent Nisqually Thin Project. Formal surveys using the current spotted owl survey protocol have been not been completed for this project so it is unknown whether suitable habitat other than the historic sites is occupied; however, all of the historic sites regardless of recent detections are considered to be potentially occupied.

Barred Owl Occurrence Several barred owls (Strix varia) have been detected in the Silver Creek area (Pearson, 2014). The most recent NSO recovery plan (USFWS 2011) lists the presence of barred owls as one of the greatest threats to the recovery of spotted owls. Barred owls compete with spotted owls for habitat and resources for breeding, feeding and sheltering, therefore any loss of habitat has the potential to intensify the competition by reducing the total amount of these resources available to the spotted owl and bringing barred owls into closer proximity with the spotted owl (USFWS 2011, p. I-9). Recent studies found that the amount of old forest habitat at the core of spotted owl home ranges was the most important factor affecting the likelihood of continued site occupancy (Dugger et al, 2011). Studies have shown that barred owls prefer lower elevation and less steep terrain (Livezey, 2007) and seem to be associated with moist, productive sites (Weins 2012, Singleton et al, 2010). The NSO Recovery Plan now recommends not only conserving, but also restoring older, multi-layered forests across the range of the spotted owl (USFWS 2011, p. I-8).

Effects – No Action No thinning of dense, young stands would occur and consequently there would be no potential acceleration of growth rates of residual trees by reduced competition through a reduction in stand density. Thus, no long-term beneficial effects to spotted owl habitat would occur in the No Action alternative and no improvement in existing dense stands that may be too dense for owls to disperse.

In the No Action alternative, there would be no loss of suitable NSO foraging habitat and no thinning of dispersal habitat within the core area of a historic activity site, therefore no potential increase in negative competitive interactions with barred owls from project activities. There would be no early seral habitat creation and therefore no temporary decrease in dispersal cover in the project area. There would be no increase in disturbance in the project area from the project activities and therefore no potential adverse effects to nesting spotted owls.

There would be no restoration activities and no reduction in road density or habitat fragmentation as a result of closing roads in interior forest, and therefore the potential for the long-term beneficial effect would be foregone. There would be no snag creation in foraging habitat.

Effects – Proposed Action

Effects to NSO Habitat The majority of the proposed treatment units are young, dense stands (managed plantations) regenerated through timber harvest, broadcast burned and subsequently planted between 1955 and 1975. Most of the

102 Silver Creek Thin EA January 2017 treatment units are either dispersal or are in stands too dense to provide dispersal habitat. The harvest prescription for approximately 2,003 acres is commercial thinning. On approximately 176 acres, the intent is to create early seral habitat to improve forage production on deer and elk biological winter range, and on those acres, the target residual canopy cover percent would be 10 to 15%. Approximately 33 acres of suitable NSO foraging habitat would be treated to create complex early seral habitat in unit 29, (stand 9053) and 10 more acres in the stand would be thinned; otherwise, no NRF habitat would be commercially thinned or otherwise affected in the remainder of the proposed treatment units. Unit 29 is the only location where early seral habitat would be created in suitable NSO habitat, the remainder of these locations would be in either dispersal or in stands that are too dense to provide dispersal habitat.

Unit 29 is located within the home range of the historic NSO site known as Grassy, #505, last detected in 2002. The eastern unit boundary is approximately 1.25 miles west of the historic site location. Within the home range radius of NSO site #505 there are 4,306 acres of suitable NRF habitat, therefore with the reduction of 43 acres of foraging habitat the home range would have approximately 4,263 acres of NRF habitat remaining post-treatment. Unit 29 is a naturally regenerated, 85-year-old stand at approximately 2000 feet elevation that has retained legacy features from a previous stand that includes large diameter trees up to 100 inches DBH and many snags and large pieces of down wood. Barred owls are known to be using habitat in Unit 29 because a barred owl was heard in the stand during mollusk surveys. Unit 29 is also adjacent to unsurveyed suitable NRF habitat and could be within the core area of an undetected NSO site.

Many of the proposed harvest units are on land that was traded to the Forest Service from private timberlands in the 1970s. Stands have high canopy cover ranging from 64 to 92 percent and high tree densities that range from 171 to 450 stems per acre that are over 5 inches DBH, with most of the units having 200 to 300 stems per acre (see Vegetation section for more detail). Stands with over 300 stems per acre may actually be too dense to be dispersal cover because the interlocking limb structure would preclude flight through canopy by dispersing owls. Past research has indicated that at densities over 300 trees per acre the stands are too dense for optimal dispersal cover (Hanson et al, 1993). Stem densities over 300 per acre are found in units 5, 7, 10, 12, 17, 19, 20, 22 and 27, for 461 treatment acres. Of these 461 acres of these high stem density stands, 58 acres would be converted to early seral habitat with a target canopy cover of 10 to 15 per cent, which is too open to provide dispersal cover. The post-treatment residual percent canopy cover in the commercial thinning treatments would be 40 to 60% on 403 acres of the very dense stands, which would make give them more functional dispersal habitat structure. Commercially thinned units would still provide dispersal cover after thinning because the post-treatment canopy cover would remain over 40%; however, 176 acres of forage openings in the project proposal would not provide dispersal habitat post-treatment.

Commercial thinning intends to accelerate the attainment of large structure by promoting faster growth in the residual stand post-treatment. Chan et al. (2006) in looking at implications of thinning young Douglas-fir plantations to accelerate development of complex stand structure and species diversity found that treated stands exhibited positive responses to all studied thinning intensities, increased overstory canopy development, had moderate to good survival and growth of underplanted seedlings, and increased understory species richness and cover. Several research studies have shown that commercial thinning can be beneficial to the development of late successional characteristics by promoting stand diversity and by accelerating the development of understory shrubs, which provide habitat for small mammals that spotted owls prey upon (e.g., Cary and Wilson 2001, Lindh and Muir 2004, Gomez et al. 2005). However, the effects of commercial thinning on spotted owls are unclear and not well documented in the published literature. Hanson and others (1993, p.73-74) suggest that commercially-thinned stands would be functionally non-suitable during project implementation because spotted owls are likely to avoid these areas during the commercial thinning operation due to the presence of logging equipment and the

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activities associated with timber harvest. Meiman and others (2003, p.1258) tracked the response of a single male spotted owl following commercial thinning in young Douglas-fir stands in the Oregon Coast Range. Commercial thinning resulted in significantly reduced use of the thinned area during and after harvest, and a shift in use away from the thinned stand. Hicks and others (1999, p.23) documented spotted owls using thinned stands for roosting 6 months after thinning, suggesting that use of thinned stands by spotted owls for roosting may occur rapidly following thinning in some areas. It is likely that spotted owls will avoid active harvest units while thinning operations are underway and may resume use of the stands at some point post-treatment.

Effects of Disturbance to Spotted Owls The use of helicopters, excavators, chainsaws, and other motorized equipment will introduce increased levels of sound and human activity into project area over the next 10 years. Proposed project activities would occur mainly after the early nesting season period (March 1 to July 15) and continue until the end of the spotted owl-nesting season of September 30. Noise and activities associated with commercial thinning and road construction have the potential to affect spotted owls in the project area. The response of spotted owls to project noise and activities is not well defined and is variable among individual owls. Spotted owl responses to noise disturbance range from no apparent reaction, to an alert response where the owls are attentive for the duration of the activity, to a flush response (Delaney et al. 1999, p.68). Significant disruption during the early spotted owl nesting season (March 1–July 15) occurs when noise or project activity disturbs nesting behavior to adult or juvenile spotted owls to the extent that they flush away from an active nest during incubation or a nestling to flushes away from the nest prior to being fully fledged; or an adult aborts a feeding of nestlings.

Disturbance from Helicopters Mexican spotted owls exposed to helicopter noise during nesting season exhibited alert responses (i.e. head turning towards noise) when helicopters were an average of 0.25 mile (400 m) away. In the same study, owls did not flush from their roosts until the sound exceeded 92 dBA and occurred within a distance of less than 344 feet (105 m) (Delaney et al. 1999). The authors suggest that spotted owls are more likely to respond to slow helicopter maneuvers such as hovering or landing than fast, by-pass maneuvers. If a helicopter were hovering in close proximity to a spotted owl nest, the owls would be exposed to high levels of noise, potential visual disturbance, and rotor wash from the helicopter. Based on Delaney et al.’s findings, the potential disruption zone for helicopters overflights is 110 yards above suitable spotted owl habitat. Helicopter overflights that maintain a minimum altitude of 110 yards above suitable spotted owl habitat are not likely to disrupt spotted owl nesting behaviors or result in a flush response. This is less than the 105-meter (115-yard) distance that Delaney et al. suggest would eliminate all spotted owl flush responses from military helicopter overflights, but is greater than the 89-meter (97- yard) maximum distance reported for a spotted owl flush response from helicopter overflights. At helicopter landing zones, or locations where helicopter logging operations are occurring adjacent to suitable nesting habitat during the early spotted owl nesting season (March 1 to July 15), the potential disruption zone is considered to be a 110-yard radius around the landing zone.

Disturbance from Chainsaws and Motorized Equipment Delaney et al. (1999) reported that Mexican spotted owls exposed to chainsaw noise flushed when chainsaws were operated within a distance of 344 feet (105 m) and the Equivalent Average Sound Level (LEQ; average sound level over time) for chainsaws was greater than or equal to 46 dBA LEQ. This sound level (46 dBA) was approximately 20 to 25 dBA above the natural background ambient levels. However, only 2.8 percent (1 of 36) of the chainsaw trials at distances greater than 197 feet (60 m) resulted in a flush response, but over 70 percent of chainsaw trials at distances less than or equal to 197

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feet (60 m) resulted in a flush response. The sound levels associated with the chainsaw tests were in the range of 54 to 61 dBA at 197 feet (60 m).

Not all spotted owls exposed to chainsaw or motorcycle noise in these studies flushed, and spotted owls that were previously exposed to chainsaw noise were less likely to flush during subsequent exposures, suggesting some spotted owls have the ability to tolerate or habituate to such disturbances (Delaney et al. 1999). Spotted owls also did not flush from nests during incubation or brooding of nestlings, suggesting that spotted owls are reluctant to leave the nest during the early stages of the breeding cycle (Delaney et al. 1999, p. 71; Delaney and Grubb 2003, p. 22). The experimental disturbance trials indicate that the combination of noise and human activity can cause nesting spotted owls to flush in certain situations, even at relatively low levels of noise above the background ambient conditions. Due to the variability of spotted owl responses to ground-based disturbances and the potential problems associated predicting sound attenuation, an estimated distance of 65 yards (60 m) is a reasonable distance to assume a flush response is likely to occur from ground-based, motorized activities. This distance applies to activities that generate sound levels that are less than 92 dBA, which includes chainsaws and most heavy equipment.

Noise and activity disturbance associated with forest management during the early spotted owl-nesting season could result in flushing a spotted owl adult or juvenile away from a nest. Flushing from a nest site is considered a significant disruption of nesting behavior because flushing a nesting owl increases the risk of predation to the eggs or nestlings. The greatest risk to spotted owls from disturbance is causing a pre- fledged juvenile to flush. It is common for pre-fledged owlets to leave the nest and perch on adjacent branches before they can fly (Forsman et al. 1984, p. 36). Owlets in this stage of development are vulnerable because if they fall to the ground before they are able to fly they have a higher risk of mortality. Forsman et al. (1984, p. 36) notes that seven of nine owlets that fell or jumped from the nest prematurely were killed by the fall or disappeared before reaching the flying stage.

Predation mortality of juvenile spotted owls is common, and is the leading cause of death of fledglings (Forman et al. 2002, p. 18). Spotted owls are preyed upon by great horned owls (Bubo virginianus) (Forsman et al. 2002, p. 18), presumably by northern goshawks (Accipiter gentilis) and red-tailed hawks (Buteo jamaicensis) (Forsman et al. 2002, p. 27). It is likely that flushing a spotted owl from its nest or causing a nestling to flush from the nest prematurely would increase the chances of a juvenile being predated.

The proposed project activities are not expected to result in an outright nest failure, the abandonment of a nest by the adult pair of spotted owls, or reduced fitness or survival of adult spotted owls. In experimental disturbance trials with spotted owls, none of the spotted owls exposed to disturbance abandoned their nests, and there was no difference in the reproductive success between experimental and control groups (Delaney et al. 1999; Delaney and Grubb 2003). Based on these studies results, the potential disturbance effects to spotted owls have a relatively low risk for resulting in reduced individual fitness or nesting success. However, due to the proximity of several harvest units adjacent to unsurveyed NRF habitat, it is possible that disturbance to an undetected NSO could occur.

Limited operating period (LOP) restrictions will be implemented as part of the proposed action (see PDC #2.1 in Proposed Action section) to limit potential disturbance to historic NSO nest sites and activity centers as well as unknown spotted owl sites that may exist in unsurveyed suitable nest habitat in the project area. The LOP will be from March 1 to July 15 for harvest operations that occur within the portions of units that are within 110 yards of unsurveyed suitable NRF habitat. This seasonal restriction will avoid potential disturbance effects to any spotted owls associated with the historic spotted owl core areas. Harvest activities that occur during the latter half of the spotted owl-breeding season (July 15 – September 30) would not disrupt nesting spotted owls. In the late nesting season, juvenile spotted owls have fledged and are able to thermoregulate, fly short distances, and are no longer completely dependent

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upon the adults for daily feedings (Forsman et al. 1984). A flush response from either an adult or juvenile at this stage of development is not likely to reduce the juvenile owls’ fitness or ability to survive. Thus, the biological effect of potential noise disturbance that occurs during the late nesting season is considered to be less important than exposure to disturbance during the early nesting season period.

Proposed vegetation treatment units that are adjacent to unsurveyed suitable NRF habitat include 5-9, 11- 18, 20, 21, 24-26, 29, 30, 34-36, and 38. These units border suitable habitat for an approximate total edge length of 36,975 feet of old growth edge. Assuming a disturbance distance of 65 to 110 yards from the unit boundary into the adjacent stand, the total area of potential disturbance is approximately 300 acres. Not all of this area would be exposed to disturbance over the course of one nesting season, but on a unit- by-unit basis over the several year time period of project activities.

The early season LOP (March 1 to July 15) will also apply to all the restoration and road construction activities where they occur in or within 110 yards of unsurveyed suitable NRF habitat. These include the proposed road closure/stabilization of the 4700213, 4778, 8500108 and a portion of the 47 road that would cause disturbance to approximately 150 acres of suitable nesting habitat. The development (blasting) at two quarries would cause noise disturbance to approximately 70 acres of suitable nesting habitat. The package of road reconstruction and repair projects that include the asphalt reclamation on the 47 and 85 roads, repairs and reconstruction on the 4745000, 4778042, 4700184, 4773000, 4740015, and 75 roads, would cause noise disturbance to approximately 100 acres of suitable nesting habitat. The total area of noise disturbance to NRF habitat from road restoration and reconstruction work would be approximately 320 acres.

Project Design Criteria #2.1-2.4 explain the Limited Operating Periods that will be required for the thinning treatments. The LOP’s will also apply to the proposed pre-commercial thin units with the same criteria for those within core areas and adjacent to historic sites.

Competition with Barred Owls Studies have shown that barred owls prefer lower elevation and less steep terrain (Livezey, 2007) and seem to be associated with moist, productive sites (Weins 2012, Singleton et al, 2010). These studies suggest that barred owls tend to push the spotted owls into the steeper, higher elevation sites that are sub- optimal habitat and much less productive in terms of prey abundance, and recent studies emphasize the importance of maintaining all suitable NRF habitat in alleviating the competition for resources between the two species (Dugger et al, 2011). The proposed action is not expected to have a substantial effect on competition between barred owls and spotted owls for prey items and territory because the proposed action maintains almost all suitable NRF habitat in the historic spotted owl territories and throughout the action area, with the exception of Unit 29 where approximately 43 acres of suitable foraging habitat that will be mostly converted to early seral habitat. However, because of the intense competition between the species for habitat and territories, any habitat manipulation within the core area of a spotted owl territory, even dispersal habitat, has the potential to increase negative competitive interactions with barred owls, particularly where the amount of suitable habitat is below threshold levels within the core area. The proposed action would result in the reduction of 43 acres of suitable foraging habitat within the home range of a historic NSO site (Grassy #505) that is not below threshold for NRF; however, the reduction of even a small amount of suitable foraging habitat could increase competition for resources between spotted and barred owls.

Effects to NSO Prey Species The effects to spotted owl prey, including northern flying squirrels and voles, from commercial thinning treatments have been the subject of several research projects. These studies tend to suggest that while there may be short-term negative effects to forest structure there are long-term beneficial effects in

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accelerating growth leading to large tree structure that may take decades to realize (Wilson and Forsman, 2013).

Restoration Effects As part of the proposed action, snags will be created from healthy green trees in stands adjacent to treatment units that meet criteria for foraging habitat (not within known nest stands). The intent is to provide habitat for northern flying squirrels, an important prey species, in NSO foraging habitat. The creation of larger snags (20 to 30 inches diameter) would have a beneficial effect to spotted owls.

In addition, roads proposed to close and stabilize will improve interior forest habitat by reducing fragmentation, as well as increase habitat security for deer and elk winter range. The proposed action includes 10.22 miles of closing and stabilizing existing system roads.

Effects of Interdependent Activities Project activities that are directly related or interdependent to the commercial harvest activities include 7.54 miles of temporary road construction, use of 7.35 miles of existing non-system roads, and re-opening and reconstructing 3.5 miles of system roads that are currently unusable due to many years of no maintenance. Other activities include road closures and other restoration activity, haul route maintenance (such as brushing, etc.), 13.3 miles of asphalt reclamation on the 47 and 85 roads, and hazard tree removal. Haul routes pass through approximately 28 miles of NRF habitat and, so assuming approximately two hazard trees per mile exist, around 56 hazard trees may be removed in suitable NRF habitat and cause additional noise disturbance. Blasting for rock source material will occur at two quarries in the project area. Because these inter-related activities will not degrade NSO habitat and will have early season LOPs where adjacent to unsurveyed suitable habitat, there are no habitat removal or disturbance to nesting owls effects expected due to these activities.

Summary of Effects The proposed action would commercially thin approximately 2,000 acres of habitat that is not suitable NRF or foraging within the home range areas of 10 historic NSO activity sites. The commercial thinning that provides either dispersal habitat or is otherwise non-suitable would remain as dispersal habitat post- treatment. 176 acres of early seral habitat creation in the proposed action would not provide enough canopy closure for dispersal habitat for an estimated 40 to 50 years. Approximately 33 acres of suitable NSO foraging habitat within the home range radius of 1 historic NSO site would be converted to non- suitable early seral habitat and an additional 10 acres would be thinned that is also adjacent to unsurveyed suitable NRF habitat with site occupancy unknown. The proposed action would include a full season LOP for marbled murrelet (MAMU) until September 23 for the unit within suitable NSO habitat (because it contains suitable MAMU nest trees), so that would include almost the entire NSO nesting season that ends September 30. The early nesting season LOP (March 1 to July 15) would apply for all portions of units within 110 yards of unsurveyed suitable NSO nesting habitat.

The purpose of the proposed action is to accelerate growth rates by reducing stand density in the commercial thin units and to create early seral habitat within deer and elk winter range for increased forage production. If the commercial thinning treatments are successful the long-term effect would be beneficial to the northern spotted owl because the intent is to increase growth rates on the residual trees which would accelerate the attainment of late successional stand structure. The proposed project’s thinning treatments are consistent with the recommendations in the revised NSO recovery plan that encourages active forest management to promote development of late successional habitat even if it results in short-term adverse effects to spotted owls. However, the proposed action is not consistent with the recommendation in the recovery plan to maintain all suitable habitat because 43 acres of suitable

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foraging habitat will be cut in the proposed action. In addition, the proposed action has the potential to increase negative competitive interactions with barred owls by reducing the amount of suitable foraging habitat. Therefore, the Silver Creek Thin Project May Affect, and is Likely to Adversely Affect the northern spotted owl.

Cumulative Effects State and private lands adjacent to National Forest boundary within the Silver Creek drainage may be harvested for timber to an unknown intensity into the future. Timber harvest is scheduled in the near future on adjacent state land in Catt Creek. Private timberland management in the watershed will not provide for suitable NSO habitat but there may be some short-term dispersal habitat capability between generally short harvest rotation periods. On Forest Service land ownership, the effects of this project are considered to be cumulative to thinning and restoration projects done under nearby Nisqually Thin Project (currently in implementation) and Silver Watch timber sale (1990s). This project will not push the affect determination for NSO into a “likely to adversely affect” for the cumulative analysis area.

Northern Spotted Owl Critical Habitat The US Fish and Wildlife Service published the final rule for revised spotted owl critical habitat in the December 4, 2012 Federal Register (77 FR 71876). The effective date of the revised critical habitat was January 4, 2013. Primary constituent elements (PCEs) are the specific characteristics that make habitat areas suitable for nesting, roosting, foraging, or dispersal (77 FR 71876:71884). The PCEs identified in the revised spotted owl critical habitat rule include 1) forest types in early-, mid-, or late-seral stages that support the spotted owl across its geographic range; 2) nesting and roosting habitat; 3) foraging habitat; and 4) dispersal habitat (77 FR71876:72051-72052). The proposed action includes the commercial thin of 1,675 acres and pre-commercial thin of approximately 535 acres within the boundaries of spotted owl critical habitat, specifically the West Cascades Unit 5, subunit WCC-2.

Revised spotted owl critical habitat on the Gifford Pinchot National Forest is designated in four subunits (table below). These subunits are associated with the West Cascades Central (Unit 5) and East Cascades North (Unit 7) critical habitat units that encompass National Forest lands in the southern Washington Cascades. Critical habitat subunits located on the Forest are expected to provide demographic support for the overall spotted owl population.

Table 27. Summary of NSO Critical Habitat (CH) subunits and baseline habitat conditions in Silver Creek area Percent Forested, % of CH of CH in Total Nesting/ Non- CH Unit CH Sub Dispersal but not in nesting/ designated roosting forested Name Unit acres dispersal nesting/ roosting CH acres acres acres acres roosting and dispersal West Cascades WCC-1 225,272 93,567 61,148 69,316 1,241 41.5% 68.7% Central (Unit 5) West Cascades WCC-2 279,420 130,857 88,471 53,331 6,761 46.8% 78.5% Central (Unit 5) West Cascades WCC-3 394,462 202,922 124,705 60,303 6,532 51.4% 83.1% Central (Unit 5) East ECN-6 81,842 49,983 16,845 14,068 946 61.1% 81.7% Cascade

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Percent Forested, % of CH of CH in Total Nesting/ Non- CH Unit CH Sub Dispersal but not in nesting/ designated roosting forested Name Unit acres dispersal nesting/ roosting CH acres acres acres acres roosting and dispersal North (Unit 7) Source: USFWS 2013 -Reinitiation of consultation for 2012 northern spotted owl critical habitat – letter of concurrence for ongoing timber sales on the Gifford Pinchot National Forest, dated February 28, 2013.

Effects – No Action There would be no beneficial effect to dispersal habitat in units that are currently too dense to function as quality dispersal habitat and no long-term beneficial effect of putting the stands on a higher growth curve by reducing stem density. There would be no loss of PCE 3 habitat.

Effects – Proposed Action 1,675 acres of Silver Creek Thin project treatment units are in Critical Habitat in subunit WCC-2. Most of the units are proposed for commercial thinning to a residual canopy cover ranging from 40 to 60%, but 176 acres are proposed for deer and elk forage openings. A total of 419 acres in units with over 300 trees per acre within CH are currently too dense to provide dispersal cover. Of the 1,675 acres of total commercial harvest treatment, approximately 1,256 acres provide NSO dispersal cover. Included in the 1,256 acres are 43 acres that also provide suitable foraging habitat. The post-treatment canopy cover target for all treatment units would be from 40 to 60% in the commercial thin units, so they will remain above the 40% minimum threshold of canopy cover to provide for spotted owl dispersal habitat. Units planned for forage openings (17, 21, 22, 27, 28, 29, 37 and 38) are targeted for post-treatment canopy cover of 10 to 15%, so they will be below the 40% canopy cover requirement to meet dispersal habitat criteria. Of the 419 acres that are currently too dense for dispersal, 64 acres are targeted for early seral forage openings, so their status will remain non-suitable. The other 355 acres that are currently too dense will be upgraded to dispersal cover, since they will retain at least 40% canopy cover. The net result of the thinning and early seral prescription treatments to units in CH is that of the 1675 acres of treatment units, 43 acres will be converted from suitable foraging to non-suitable, 136 acres will be converted from dispersal to non-suitable, and 355 acres will be upgraded from non-suitable to dispersal habitat in designated Critical Habitat. Change in acres by habitat type due to the Proposed Action is shown the table below.

An additional approximately 535 acres are planned for pre-commercial thinning in the proposed action. The pre-commercial thin units do not currently provide dispersal habitat.

Table 28. Pre-treatment and post-treatment habitat acres in CH in Silver Creek Thin

Habitat Type Pre-Treatment Acres Post-Treatment Acres

Non-Suitable 419 200

Suitable Foraging (included in dispersal) 43

Dispersal 1,256 1,475

Total acres 1,675 1,675

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The USFWS revised the scale at which effects to the dispersal habitat are evaluated on December 4, 2012 with PCE (77 FR 71939):

“Northern spotted owl critical habitat PCE 4 (habitat to support the transience and colonization phases of dispersal) provides a life-history need that functions at a landscape-level scale and should be assessed at a large scale than the other PCEs. Potential scales of analysis include the local watershed (e.g., fifth-field watershed) or subwatershed (e.g., sixth-field watershed), a dispersal corridor, or a relevant landform.”

Landscapes that contain at least 50 percent of forest cover that is either suitable habitat or dispersal habitat are considered capable of supporting successful spotted owl dispersal (Thomas et al. 1990). While there is uncertainty regarding the forest conditions required for spotted owl dispersal, it is assumed dispersal success is better in landscapes where habitats more closely resemble suitable habitat (USFWS 2011).

The project action area occurs within the watershed boundary of Silver Creek that is split into several 6th- field subwatersheds within the Middle Cowlitz 5th field watershed. The entire 5th field watershed is a total of 84,432 acres, of which 53% or 44,598 acres are in private ownership. According to the 1997 Middle Cowlitz Watershed Analysis, on National Forest and private land, 19% of the watershed was in a large tree (generally 200 years or older) structural stage. Of 39,924 acres of federal land within the watershed, 16,863 acres (42%) provided NRF habitat for NSO, and an additional 6,346 acres (16%) provided foraging and dispersal habitat. Therefore, at the time of the watershed analysis, 58% of the federal land in the 5th field would have provided at a minimum dispersal habitat. Given that no harvest of old growth forest has occurred within the past 20 years, the percentage of NRF habitat would still be valid today, and much of the grass/pole structural stage is likely providing dispersal habitat.

Of the 6th field subwatersheds within the Middle Cowlitz 5th field watershed, Upper Silver Creek had the highest number of acres in the large tree structural stage (3,360 acres) that comprised 45% of the subwatershed. The East Fork Silver subwatershed had the highest percentage in large tree structure (59%) that consisted of 1,270 acres of older forest stands. Lower Silver had 2,301 acres, or 32%, of large tree structure

Both the local landscape and critical habitat subunit WCC-2 (at 78.5%) are above the 50% minimum threshold for dispersal habitat.

In the proposed action, the effects to PCE 1 would include a loss of 43 acres of suitable foraging habitat for a period estimated to be 80 to 100 years. In addition, approximately 143 acres of young/mid-seral stands (of which 64 acres that currently do not provide dispersal habitat) would be converted to an early seral condition that would no longer provide dispersal cover for a period of 40 to 50 years. Approximately 355 acres non-suitable habitat would be converted to dispersal habitat by the treatment in units that are currently too dense to meet dispersal habitat criteria. There would be no effect to PCE 2 because no nesting and roosting habitat will be treated. There would be a negative effect to PCE 3 because 43 acres of suitable foraging habitat would be harvested, of which 33 acres would be converted to complex early seral habitat and 10 acres commercially thinned. However, proposed snag creation in suitable foraging stands adjacent to treatment units that would improve habitat for prey species in those stands. The proposed action treatment should accelerate the development of foraging habitat in the majority of the treatment units that are currently dense, young stands without a lot of structure or diversity, creating beneficial effect to PCE 3 in the project area.

The proposed thinning would affect 1,256 acres of dispersal habitat (PCE 4), but the post-treatment canopy cover on all but 143 acres would be retained at 40 to 60 percent cover, and therefore still provide

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enough canopy to meet the minimum dispersal requirement. The proposed action would improve the quality of 355 acres of dense young forest into functional dispersal cover by reducing high stem densities. The high stem densities of 315 to 450 trees per acre found in these stands may preclude the ability of these stands to function as dispersal habitat because of the interlocking limbs blocking flight in the mid- canopy layers of the stand.

Cumulative Effects There be no cumulative effects to Critical Habitat in sub-unit WCC-2 due to the Silver Creek Thin project.

Summary of Effects to NSO Critical Habitat In summary, most of the proposed actions effects to designated Critical Habitat are either neutral or beneficial in promoting attainment of suitable NRF habitat. However, due to the conversion of a minor amount of suitable foraging habitat to non-suitable, and the conversion of approximately 79 acres of dispersal habitat to non-suitable, the proposed action May Affect, and is Likely to Adversely Affect designated Critical Habitat for the northern spotted owl.

Marbled Murrelet

Existing Condition The marbled murrelet is a small Pacific seabird that nests in interior old growth forests generally within 55 miles of saltwater where it goes to feed during the nesting season. A member of the family Alcidea, or Auk family, this species was listed as threatened under the ESA in 1992. Listing was due to population decline associated with loss of nesting habitat and other threats including the decline in quality of the marine environment in which the bird spends the majority its life history. The threats to this species include habitat destruction and modification in the terrestrial environment from timber harvest and human development that have caused a great reduction in the amount of nesting habitat and unnaturally high levels of predation resulting from forest edge effects created by high levels of past regeneration harvest and road building activities.

In the southern portion of this species range in Washington, Oregon and California, suitable nest habitat is in old growth conifer forests. The marbled murrelet selects platforms such as large or forked branches or branches with deformities caused by mistletoe for nesting. This species does not construct a nest; it merely lays the single egg that it produces annually in a depression formed usually by moss, or duff or litter, on the branch that provides the platform for the nest. Specifically in Washington, the conditions that provide for suitable nest trees for marbled murrelets are live conifer trees that are either western hemlock, Douglas-fir, Sitka spruce and western red cedar in multi-story large-tree structure stands that provide platforms for nesting defined as limbs greater or equal to four inches in diameter and at least 33 feet above ground. Suitable nest stands should have at least two platforms per acre that have horizontal and vertical protective canopy cover which is very important for this cryptic species in protecting the nest from predation. Minimum stand size is not well defined but marbled murrelets are known to use stands as small as seven acres (US FWS Recovery Plan, 1997).

The most important component of murrelet nest trees is the presence of platforms. Old-growth, mature, or younger coniferous forests with appropriate structure can provide these platforms. A platform may be a depression on a branch, an area where a limb branches, a surface created by a deformity such as a dwarf mistletoe broom, a debris/moss platform or stick nest equal to or greater than 4 inches in diameter including associated moss, lichen, or duff if present. Any forested area with one observed platform is capable of supporting a nest (Evans, Mack et al. 2003). Platforms may be clumped in one area or

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dispersed throughout the forested area. Trees capable of providing suitable nest platforms are generally over 30 inches in diameter. Hamer (1995) correlated tree size with number of platforms and found that the mean number of platforms per tree increased rapidly with an increase in tree diameter from 19.6 to 78.7 inches. The mean number of platforms on trees 19.6 inches in diameter was approximately 0.2, and at 29.9 inches it was 0.8, while at 78.7 inches the mean increased to more than 5 platforms per tree. Therefore, trees less than 20 inches in diameter are unlikely to provide nest platforms, with the exception of mistletoe brooms in western hemlock, where relatively small diameter trees may be used for nesting.

Nest stands are generally located in low elevation old growth forests. According to Hamer (1995), detection rates declined sharply with an increase in elevation over 3,308 feet and more than 39 miles from saltwater. The 1997 Marbled Murrelet Recovery Plan states that 80% of nests in the Pacific Northwest were located on the lower or middle third of the slope at an average elevation of 1,090 feet. Hamer quantified various stand characteristics to describe high probability of occupancy and found that these stands had a mean of 37 platforms/acre, a stem density of 20 dominant trees/acre (+32 inch dbh), 83% canopy closure, 39.7 inch mean dbh of western hemlock, 49 % moss coverage on limbs and a low index of lichen cover. These stands had a mean elevation of approximately 500 feet and mean slope of 50%. High probability stands were found to be at a maximum elevation of 945 feet and had minimum values of 4 platforms/acre, 12 dominant trees/acre, 29% canopy closure, 33.5 inch mean dbh of western hemlock, 5% moss cover and 38 inch mean tree DBH. The highest elevation nests found in Washington (at the time of publication) were a little over 3,200 feet and over 98% of all detections in Washington were below 3,308 feet. In the South Cascades, physiographic province the highest occupied stand was found at 3,447 feet approximately 8 miles south of Alder Lake in Lewis County that would be approximately 20 miles to the west of the Silver Creek project area.

The nesting season for marbled murrelets in Washington is defined as April 1 to September 23. During incubation, which occurs over a period of approximately 30 days, the adults take turns incubating the single egg in 24-hour shifts. Once hatched the chick is fed up to 8 times a day usually at dawn and dusk but these daily flights by adults to marine feeding areas from inland nesting sites can occur at all times of day. The fledging period is 28 days and once fledged, the young alcid flies directly to the marine environment.

Nest failure is often due to predation, especially by corvids, and edge effect has a negative influence on murrelets because it increases the nest exposure to predation. Thus horizontal and vertical canopy cover is very important for nest selection for this species. Marbled murrelets also rely on other morphological (cryptic coloration) and behavioral adaptations to reduce predation, such as feeding during low light level periods of the day, and it these adaptations that make it difficult to find murrelet nests.

The Silver Creek project planning area ranges from elevations at approximately 2000 to 4000 feet. The project area is approximately 52 air miles from the southern Puget Sound, which is the closest saltwater environment. The entire project area is within the 55-mile zone considered the farthest potential distance from marine foraging to suitable nesting habitat for marbled murrelet in Washington. Within the subwatersheds of the project area, there are approximately 8,790 acres of suitable nesting habitat within the large tree structure category.

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Figure 13. Silver Creek Thin Marbled Murrelet Habitat

Species Occurrence Although limited surveys by Forest Service personnel have been conducted, no marbled murrelet nest sites are known to exist within the Silver Creek Thin Project area. Surveys for marbled murrelet were conducted in Silver Creek for the Silver Watch Thin project in the late 1990’s and no murrelets were detected during those surveys. Murrelet surveys for the proposed Silver Creek Thin project were not conducted. There are several observations of marbled murrelets a few miles west of the project area

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dating back to 1992. There are several observations and possibly nest sites in the Mineral Block area (about 15 to 30 miles northwest of Silver Creek) and the 1995 Hamer study mentions a nest in the Mineral Block area 8 miles south of Alder Lake. Radar surveys conducted in Mt. Rainier National Park on the Nisqually River detected murrelets flying up the Nisqually, about 7 miles north of the northernmost portion of the Silver Creek Thin project planning area (ABR Inc., 2009).

Effects – No Action There would be no commercial harvest, road closures and other restoration actions in the No Action alternative. No disturbance to potential nest sites would occur and there would be No Effect to marbled murrelet.

Effects – Proposed Action

Habitat Effects The majority of the treatment units in the proposed action are in dense, young stands that are regenerated from clearcut harvests from 1955 to 1975, and these stands generally do not contain trees large enough to provide suitable nest platforms. Unit 29, however, is an 85-year-old naturally regenerated stand that does provide suitable nest platform trees because of the legacy features that are found in the stand that includes large diameter trees up to 100 inches DBH and many snags and large pieces of down wood. The proposed treatment in most of Unit 29 is to create complex early seral habitat by retaining the legacy features and leaving 10 to 15% canopy cover of the remaining trees post-treatment. The stand would no longer provide suitable nesting habitat because it would be too open, even though the large trees with suitable platforms would be retained. Prior to inclusion of Unit 29 in a timber sale contract, surveys according to protocol (12 visits during the nesting season for 2 seasons) would be required to determine marbled murrelet occupancy in the stand. If occupancy is detected a ½ mile radius buffer will be designated to protect the nest stand. Because marbled murrelets have high site-fidelity to nesting habitat, loss of occupied nesting habitat would cause displacement to potentially marginal habitat, which may expose nesting murrelets to a higher risk of predation and other adverse effects.

The mean diameter of trees in the proposed treatment units ranges from 10.7 to 17.1 inches DBH. Trees over 20 inches in diameter do occur in the treatment units but are not common, with the exception of Unit 29 where trees over 20 inches are common. Generally, the larger trees in the treatment units will be retained and the smaller trees removed, and all units will have a maximum diameter harvest limit to promote variability and retain legacy features.

The following table shows the total length (in meters) of unit boundary adjacent to suitable marbled murrelet nesting habitat, or old growth forest, in the proposed treatment units. The total length of “old growth edge” in the project area is approximately 12,114 meters (13,325 yards) along 26 proposed treatment units.

Table 29. Estimated meters of old growth (OG) edge adjacent to Silver Creek Thin Units

Unit # Old growth edge (meters)

4 105 5 65 6 230 7 60 8 310 9 870 11 1620

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Unit # Old growth edge (meters)

12 60 13 575 14 485 15 1325 16 665 17 1265 18 245 20 400 21 670 24 120 25 490 26 275 29 175 30 339 34 120 35 280 36 490 37 600 38 275 Total OG 12,114 meters Edge

Disturbance Effects The potential adverse effects to murrelets from project activities are noise and visual disturbance associated with the use of chainsaws and heavy equipment adjacent to suitable murrelet nesting habitat during the nesting season and rotor wash associated with helicopter operations at potential landings adjacent to suitable habitat during the nesting season. Using GIS measurements the amount of potential suitable nest habitat that would be exposed to disturbance from timber harvest activities was calculated based on a distance of 100 meters from the edge of the treatment unit into a suitable nest stand. The ground-based distance is based on recommendations from murrelet researchers that advised buffers of greater than 100 meters to reduce potential noise and visual disturbance to murrelets (Hamer and Nelson 1998, p. 13, USFWS 2012b). There are approximately 300 total acres that would be exposed to noise disturbance using the estimated total edge of approximately 12,114 meters (13,225 yards). Murrelets potentially within the approximately 300 total acres of nesting habitat located adjacent to the proposed thinning units and roadwork could be exposed to noise and visual disturbance for the duration of the proposed action. The adverse effects from disturbance could include disrupting normal feeding behavior or flushing breeding birds from a nest and increased risk of predation, in addition to added stress that may reduce nesting success.

There are 71 acres of proposed helicopter units and 5 potential helicopter landings identified in the project. Suitable nesting habitat occurs adjacent to approximately 10 acres of helicopter units and murrelets that may be nesting in stands adjacent to helicopter units could be exposed to the adverse effects of rotor wash in addition to the high decibel levels of low helicopter overflights multiple times during the proposed action.

Helicopter rotor wash can cause saplings, decaying trees, and loose debris from tree tops to fall, and can create hazardous conditions from dust and flying debris underneath the ship (WCB 2005). Large helicopters hovering near canopy level during logging operations can create a potential for direct injury or mortality to murrelets from the rotor wash underneath the helicopter. Helicopter logging safety guidelines

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developed in British Columbia recommend a 300 foot-radius safety zone for timber fallers working underneath ships that are hovering below 500 feet above ground level (WCB 2005). This safety zone is recommended to avoid exposing timber fallers to overhead hazards created by rotor-wash, and also provides a worst-case approach to analyzing risk for injury to murrelets. Approximately 10 acres of murrelet habitat adjacent to helicopter logging units will be exposed to rotor-wash. Published literature regarding helicopter impacts on wildlife focuses on noise and visual stimuli, rather than potential injuries caused by rotor wash; however, effects from rotor wash may occur. The close approach of helicopters to nesting habitat adjacent to treatment units must be considered, including noise and/or visual disturbance and severe rotor wash, both of which could cause an incubating adult murrelet to flush off a nest. In a worst-case scenario, rotor wash could cause an egg or chick to fall off a nest branch or prematurely fledge, or cause direct injury to an egg or chick from flying debris or falling branches.

A timing restriction is incorporated into the project design criteria (PDC #2.2) that will impose a daily operating restriction that will avoid project activities during the murrelet’s peak feeding activity periods during dawn and dusk hours. This daily restriction will reduce but not eliminate the potential for adverse disturbance effects or disrupted feeding attempts because murrelets may feed their young during mid-day hours as well. The timing restriction requires no harvest activity in the 2 hours after sunrise and the 2 hours before sunset for those units bordering potential nest stand, and will be in place until the end of murrelet nest season. A helicopter yarding timing restriction will also be implemented for helicopter units adjacent to potential nesting habitat.

The sunrise/sunset timing restriction will also apply to all the restoration and road reconstruction activities where they occur within 110 yards of suitable murrelet nesting habitat. These include the proposed road closure/stabilization of the 4700213, 4778, 8500108 and a portion of the 47 road that would cause disturbance to approximately 150 acres of suitable nesting habitat. Development (blasting) at the two quarries would cause noise disturbance to approximately 70 acres of suitable nesting habitat. The package of road reconstruction and repair projects, that include the asphalt reclamation on the 47 and 85 roads, repairs and reconstruction on the 4745000, 4778042, 4700184, 4773000, 4740015, and 75 roads, would cause noise disturbance to approximately 100 acres of suitable nesting habitat. The total area of noise disturbance to suitable murrelet nesting habitat from road restoration and reconstruction work would be approximately 320 acres.

Edge Effects – Windthrow and Predation Risk The proposed commercial thinning in the managed stands will reduce overstory canopy cover from 64 to 92 percent to 40 to 60 percent the treated stands. Thinned areas with canopy gaps can be vulnerable to windthrow damage when located in topographically vulnerable positions. On the Olympic Peninsula, variable density thinning resulted in a blowdown rate of about 8 trees/ha in thinned stands, but the overall level of wind damage was similar to unthinned stands (Roberts et al. 2007). Based on this study, it appears that the risk of windthrow adjacent to thinned stands is relatively low compared to clearcut areas, and that the rate of windthrow adjacent to thinned stands is comparable to that found in unmanaged stands.

No research has evaluated predation risk in thinned areas adjacent to murrelet habitat. Studies of predation risk adjacent to clear-cuts have shown that closed-canopy simple structured forests have the lowest predation risk compared to recent clearcut edges, or interior old-forest habitats (Malt and Lank 2009). Murrelet nests located within 50 m (164 ft) of high contrast edges created by recent clearcuts are 2.5 times more likely to be disturbed by predators relative to nests located in adjacent interior forest (Malt and Lank 2009). This increased predation risk is associated primarily with Steller’s jays (Cyanocitta stelleri) because they are habitat generalists that respond positively to forest fragmentation and

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preferentially use forest edges due to the abundance of berries and insects in recent clearcuts (Malt and Lank 2009).

There will be 110-yard buffers on all the proposed early seral forage openings where they occur adjacent to large tree structure stands that provide potential nesting habitat. No gaps will be located within 100 feet of a treatment unit edge where the unit boundary abuts suitable nesting habitat and a one-tree width of intermingled canopy along old-forest edges will be retained to maintain direct canopy cover to any adjacent old trees with suitable murrelet platforms. This is expected to reduce potential edge effects associated with gaps, including increased predation risk and habitat degradation associated with windthrow and microclimate changes. The treatment units will be thinned to between 40 to 60% canopy cover and will result in more open stand conditions adjacent to murrelet habitat but the retention of 40 to 60% canopy cover (relative densities of 25 to 35%) will continue to provide a reduced level of overstory canopy cover adjacent to murrelet habitat. Considering the limited area of habitat affected relative to the total available habitat in the project area, the short-term risks of potential increased predation is low and will subside as canopy cover in thinned stands recovers over time. Diverse canopy structure resulting from the stand treatments will be beneficial to the long-term development of murrelet habitat in managed stands.

Effects of Inter-related Actions Restoration activities that are proposed as part of the project may occur adjacent to potential murrelet nesting habitat and have the potential to cause disturbance during the nesting season. All activities that will occur adjacent to large tree structure stands will have an early NSO LOP restriction of March 1 to July 15 and an LOP of 2 hours after sunrise and the 2 hours before sunset for those units bordering potential nest stands that will be in place until September 23, the end of the murrelet nest season. These activities include road closures, road maintenance, asphalt reclamation, temporary road construction, quarry development, existing road reconstruction and hazard tree removal. The total area of noise disturbance to suitable murrelet nesting habitat from these inter-related actions would be approximately 320 acres. Additionally, because haul routes pass thru approximately 28 miles of suitable nesting habitat, up to approximately 1,500 acres of suitable nesting habitat could be exposed to noise disturbance from the use of chain saws to cut hazard trees, but this is difficult to quantify without knowing the extent of hazard tree removal that would be needed. Assuming that 2 trees per mile would need to be felled, the area of potential disturbance from hazard tree removal would be approximately 1 acre of total additional disturbance along haul routes.

Cumulative Effects The effects of the proposed project would accumulate to the effects of timber harvest on adjacent state and private timberland. On private timber land, forest practices generally maximize timber production and cut and replant forest stands every 40 to 60 years, which does not allow for the long time periods, from 100 to 250 years, for suitable nest stands to develop. Large tracts of private timberland will likely never provide future murrelet nest habitat.

The reduction and modification of nesting habitat in old growth and mature forests through commercial timber harvests, human-induced fires, land conversions, and other natural causes such as fires, insect and other pathogens, and windstorms are serious threats to the recovery of marbled murrelet populations. Past timber harvest practices, such as those that have occurred in the Silver Creek drainage over the past 50 years or so have resulted in a high amount of habitat fragmentation. Changing the existing habitat by fragmenting the forest into small patches of suitable habitat surrounded by open space affects the habitat quality. Increased forest fragmentation can reduce nesting success by allowing increased predation of nests by raptors (great horned owls, sharp-shinned hawks, peregrine falcons) and corvids (jays, ravens, crows).

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Effects Determination Project activities will occur during the nesting season in stands adjacent to large tree structure stands that are potential marbled murrelet nesting habitat. The commercial timber harvest activities will create substantial noise disturbance (by the use of heavy equipment, chainsaws and helicopters) that will affect approximately 300 acres of potential marbled murrelet nesting habitat in stands adjacent to treatment units because there would be no late season LOP (until September 23). Effects from helicopter use (rotor wash and high noise levels) would affect approximately 10 acres of potential murrelet nesting habitat. Units that are adjacent to potential nest stands will have operating season restrictions that allow harvest activities to commence July 15. In units adjacent to potential nest stands disturbance from commercial harvest activity may disrupt the feeding cycle should it occur during daytime hours and that could have an adverse effect to nesting success. Therefore, it is expected that as proposed with no late season LOP and the loss of 43 acres of suitable nesting habitat, the Silver Creek Thin Project May Affect, and is Likely to Adversely Affect the marbled murrelet.

Marbled Murrelet Critical Habitat The LSR portion of the proposed Silver Creek Thin project is within the marbled murrelet 51,360 acre CHU WA-11-d that is in the Nisqually late successional Reserve Assessment area. CHU WA-11-d contains large, unfragmented patches of mature and late successional forest habitat in the Skate Creek sub-basin and more fragmented habitat elsewhere. Designated marbled murrelet Critical Habitat in the Silver Creek Thin project area occurs in 3 separated sections that are interspersed among Matrix land allocations. There are five units (12, 13, 16, 24 and 25) in the proposed action that total 109 acres that occur within these Critical Habitat areas.

The final rule for revised murrelet critical habitat designation, (76 FR 61599:61607[October 5, 2011]), identified the PCEs for murrelet critical habitat as 1) individual trees with potential nesting platforms and 2) forested areas within 0.5 mile of individual trees with potential platforms with a canopy height of at least one-half the site-potential tree height.

Effects – No Action Under the no action alternative there would be No Effect to marbled murrelet Critical Habitat in CHU WA-11-d.

Effects – Proposed Action PCE 1s are not expected to be directly affected by the proposed action. Due to the young stand ages (from 40 to 49 years) and consequently small tree diameter and height, marbled murrelet nest trees are not likely to be found within the proposed treatment units, however they could potentially occur within units on small diameter western hemlock with mistletoe platforms. The mean diameter of trees in the proposed treatment units within marbled murrelet CH range from 12.3 to 15.8 inches DBH. Trees over 20 inches in diameter do occur in the treatment units but they are not common. Generally, larger trees in the treatment units will be retained and the smaller trees removed. The mean murrelet nest tree diameter in the Pacific Northwest is 83 inches and murrelet nest stands are usually characterized by large trees (DBH ≥ 32-inch dbh), moderate-to-high canopy closure, and a multi-storied canopy (USFWS 1997, Hamer and Nelson 1995). Thus, the proposed project’s treatment units within CH are not likely to have trees of the appropriate stature and structure of murrelet nest stands.

Larger trees considered hazard trees near landings and roads may be felled as part of project activities and these trees may provide suitable platforms, but murrelet densities in the Silver Creek drainage are most likely very low and the probability of felling an occupied nest tree is therefore extremely low. Removal of a PCE 1 is an adverse effect to critical habitat due to the loss of trees with platforms suitable for murrelet

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nesting. Loss of suitable nest trees eliminates the value of these trees for future nesting and represents a significant impact to the conservation value of the habitat for murrelet recovery.

In the long-term, the proposed action is likely to accelerate the overall growth and structural development of PCE 1s in the thinning units by reducing stem densities and increasing growth rates.

The second Primary Constituent Element is described in the final rule as “forested areas within 0.5 miles of individual trees with potential nesting platforms and a canopy height of at least one-half the site- potential tree height.” The final rule states: “these forests may reduce the differences in microclimates associated with forested and unforested areas, reduce potential for windthrow during storms, and provide a higher probability of occupancy by marbled murrelets.” PCE 2s provide microclimate protection and visual cover required for protection of nests from predators. PCE 1s are present outside the units in adjacent suitable murrelet nesting habitat. The proposed treatment units include PCE 2s, or stands within 0.5 miles of PCE 1s with trees that are at least one-half the site-potential tree height for the area.

The proposed thinning of PCE 2s may change the microclimate and cover characteristics of PCE 1s that are along the edge of thinning units where the units abut old forest stands. This then may affect the suitability of those PCE 1s for nesting, or may increase the chance of windthrow that could damage or fell a PCE 1 or damage its platforms. This effect would be somewhat reduced by the light thinning treatments that are to be implemented, retaining approximately 40 to 60% canopy cover and relative density of 25 to 35 percent which would ameliorate micro-climate change effects. The project design criteria specifies that gaps will not be located within 100 feet of old forest edge and a 2 tree width of intermingled canopy along old-forest edges will be retained to maintain direct canopy cover to any adjacent old trees with suitable murrelet platforms. The proposed treatments will not result in any creation of “hard edge” to suitable nest habitat, but will reduce the buffering quality of the approximately 2,106 yards of “soft edge” of unit boundaries along old forest edge within Critical Habitat.

Therefore it is expected that the Silver Creek Thin project May Affect, and is Likely to Adversely Affect marbled murrelet CHU WA-11-d due to thinning of 109 acres of PCE 2, which could alter the microclimatic effects along approximately 2,106 yds. of edge adjacent to old forest stands that contains individual trees with potential nesting platforms.

Cumulative Effects There are no cumulative effects to CHU WA-11-d expected to accrue to the proposed action.

Gray Wolf Gray wolves are wide-ranging predators that can exist in a variety of habitat types. They are habitat generalists in terms of terrain and vegetation (Boyd 1999, Oakleaf et al. 2006). Their survival depends on the availability of cover and relatively secure areas that allow them to avoid humans and escape persecution (Fritts et. al. 2003, Carroll et al. 2003). To successfully inhabit an area they require a year- round prey base of wild ungulates (Boyd et al. 1995, Fritts and Carbyn 1995). An abundant source of ungulate prey (deer and elk) is present on the Gifford Pinchot National Forest as well as a relatively high level of habitat security in much of the forest where road access is limited.

The basic social unit of a wolf population is a mated pair, and a wolf pack is generally a mated pair along with one or more generations of their offspring (Mech 2000, Mech and Boitani 2003). Pups are born at a natal den in spring (generally mid-to late April) and remain there with their mother for about 2 months (Boyd 1999). During this time, any disturbance that results in the female leaving the den may expose the pups to predation or inclement weather. The sensitivity of females to human disturbances at den sites varies greatly among individuals (Boyd 1999). From the den, the pups are moved to a rendezvous site,

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where they remain, usually under the care of one adult, while other adult members of the pack hunt. Wolf packs vary widely in the number of rendezvous sites they may use in a summer and the amount of time spent at them (Boyd 1999). Denning and rendezvous are sensitive time periods because human disturbance at both den and rendezvous sites may cause wolves to move in response to the disturbance.

Gray wolf numbers have been on an increasing trend in Washington State in recent years, beginning with the discovery of the Lookout Pack in North Central Washington in 2008. In 2011, the Teanaway Pack was discovered in Central Washington near Cle Elum that is approximately 70 miles northeast of the project area. As of December 2014, there were 16 confirmed wolf packs and 68 individual wolves in Washington. They are all in North Central and Eastern Washington and none is known in the Southern Cascades at this time. While wolf numbers have increased in the eastern portion of the state and they are no longer listed as “endangered” under the ESA there, they are still classified as “endangered” in the western 2/3rds of Washington State and are listed as state endangered.

Gray wolves are known to occur on the Cowlitz Valley Ranger District but confirmed sightings are not common. There have been several unverified sightings or reports of howling on the district in recent years. A wolf sighting at White Pass was reported in the spring of 2015. There are a couple of unverified records of gray wolf within the planning area in the agency wildlife database of record. The possible sightings may be transient individuals and, so far, there is no evidence of pack formation on the district or any known den sites. Silver Creek is potential habitat for gray wolves because it provides good habitat security since much of the area is inaccessible to vehicles due to road washouts, and there is a fair abundance of large ungulate prey.

Effects – No Action Under the No Action alternative, the project would not occur and there would be no increase in human disturbance in the project area associated with commercial and non-commercial vegetation treatments and road reconstruction. There would be no decrease in open road density in the project area with the proposed road closures and consequently no improvement to habitat security for wolves. There would be no increase in forage production to wolf prey species.

Effects – Proposed Action The implementation of the proposed project would not adversely alter habitat for wolves and affects approximately 3,500 gross acres within the Silver Creek drainage. The area affected by the timber harvest treatments is a relatively small area of the landscape scale for this wide-ranging carnivore species, but associated activities such as timber hauling, road maintenance and other restoration work would affect a larger area.

The negative potential project effects to gray wolf would be a short-term increase in disturbance that may cause avoidance of the area during project activities. Activities associated with project implementation would be an increase in noise and disturbance over ambient levels that are normally low in the area. There would be an increase in human activity associated with the commercial harvest treatments, pre- commercial thinning, road closure and stabilization and other restoration work that includes the use of heavy machinery, skyline operations and possibly helicopters, chain saws and associated log-hauling and slash-piling activities. The non-commercial treatments of thinning would also constitute a short-term increase in human disturbance in the project area that would likely cause habitat avoidance.

The commercial harvest and associated log hauling, in addition to the closure of roads and other restoration activities, will likely occur over the course of several years (5 to 10), and will be a substantial increase in the amount of human activity in the project area. The disturbance effect could cause habitat avoidance of the project area by wolves because of human activity. However, given the large home range

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areas used by wolves and the relatively small scale of the project on the landscape, the project would likely cause wolves, if present, to move into adjacent habitat that is present, especially to the east of the project area, that would provide ample habitat security for human avoidance.

The proposed action would result in a small increase in forage production for deer and elk that are important prey species for wolves. There may be a slight beneficial effect to wolves as a result of increased forage production, which may attract more prey species to the project area. This effect would be temporary, however, and may last for a period of approximately 20 years.

Road access into wolf habitat reduces habitat security. The proposed project would re-open approximately 3.5 miles of system roads that are currently “ecologically” closed because they have not been maintained for several years. In some cases, these currently un-drivable roads are barely discernable on the ground. These roads would be reopened for project use and remain opened after the timber harvest is completed. However, the proposed action would also close and stabilize approximately 10.2 miles of system roads and improve habitat security for wolves as well as wolf prey big game species. The long-term effects of the proposed action would therefore be beneficial to wolves because of the reduced post-project road density. However, because of the increase in disturbance over ambient levels that would be associated with project activities for a period of approximately 5 to 10 years, and a slight increase in open road density during project activities, it is expected that the proposed action May Affect, but is Not Likely to Adversely Affect the gray wolf as a result of implementing this project.

Cumulative Effects The expected disturbance effects from the proposed action would accumulate to activities on adjacent state and private land that could also cause habitat avoidance by wolves. These activities would include regularly scheduled timber harvest on short rotations, in addition to hunting and other recreational uses. The proposed project would be cumulative to the disturbance effects from the Nisqually Thin project just to the north of Silver Creek as well, that may occur simultaneously or overlap in time with the Silver Creek Thin project activities.

Potential disturbance from the proposed project would be cumulative to potential disturbance from other on-going timber harvest and construction projects on the district that include Woods Cr. Stewardship, Kirk Thin, Upper Cispus Thin and Iron Horse Thin. Pinchot Partners Restoration is an ongoing timber harvest project near Packwood that could potentially disturb wolves over the next several years. Ongoing activities that could also disturb wolves on the district include general human use of the forest for recreation, hunting, gathering special forest products and woodcutting, road maintenance and snowmobiling.

In general the many watersheds that comprise the Cowlitz District provide ample habitat for wolves and abundant prey should a pack become established here. Even if multiple projects were happening simultaneously on the district wolves could easily avoid human activity because of the amount of land area that is undisturbed and available to them.

Sensitive Species

Wolverine Wolverines are uncommon inhabitants of northern coniferous forests and are circumboreal in distribution, inhabiting the higher latitude regions of Eurasia and North America. These largest terrestrial members of the weasel family are very nomadic and range over extensive areas during annual movements. Carrion constitutes a major portion of wolverine diets in addition to predation on small to medium-sized animals. They generally use remote habitat and avoid areas near human habitation (Banci 1994).

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Wolverines are intolerant of human disturbance at the maternal den sites. Wolverines give birth in dens from late February to March. Dens are located in large boulder talus, or accumulations of woody debris, on high elevation, north-facing slopes where snow remains the longest. Copeland and Harris (1994) described denning habitat as subalpine cirque areas with large talus on north aspects.

There are no known wolverine denning sites in the project area and no observations of tracks or other sign has been reported to occur in the project area. Potential denning habitat does not occur in the project area because of the relatively low elevation of the watershed. However, prey is available within the analysis area and these wide-ranging, opportunistic carnivores may occasionally occur in the project area. Wolverines are known to occur in the Southern Cascades (Cascades Carnivore Project, 2011) and they range over very large areas (North Cascades Wolverine Study, Aubry et al, 2011).

Effects – No Action Under the No Action alternative, the project would not occur and there would not be the increase in human disturbance in the project area that would be associated with the commercial and non-commercial treatments. There would be no change in open road density and no potential increase in forage production for prey species. There would be No Impact to wolverine.

Effects – Proposed Action As with the gray wolf, adverse effects to wolverine habitat are not expected as a result of project implementation. The amount of habitat affected is not a substantial amount of area within the very large home ranges of this species, which is several hundred square miles (Aubry et al, 2011). The increase in ambient disturbance levels at the site will be a potential adverse effect to wolverines should they be using habitat in the project area during implementation.

Effects to wolverine prey are expected to be a short-term negative effect but a long-term beneficial effect with the proposed action. Deer and elk will likely avoid the project area during the harvest activities, but the thinning treatment may have a slight effect in increasing understory production that would provide more forage after the thinning treatment. The 176 acres of proposed forage openings would also temporarily provide increased forage production. The same is true for potential rodent prey species, such as mountain beaver, that would benefit from more understory production.

The proposed project would affect the open road density in Silver Creek because approximately 3.5 miles of currently closed roads would be re-opened for project use and remain open post-project. However, the beneficial effects to wolverine would be a post-project net reduction in road density because the project proposes to close and stabilize 10.2 miles of system roads.

Project activities that will cause disturbance include timber harvest with cable and ground-based machinery and possibly helicopters will be a substantial increase over ambient noise levels and would likely cause habitat avoidance by wolverines. Therefore, we expect that implementation of the proposed project may impact individuals … but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species for the wolverine.

Cumulative Effects The effects of the proposed action would be cumulative to the on-going uses of the project area and past timber harvest and road building.

Fisher The fisher (Pekania pennanti) is a mid-sized carnivore in the weasel family (Mustelidae) that occurs only in the temperate and boreal forests of North America. Fishers historically occurred throughout the

122 Silver Creek Thin EA January 2017 forested areas of Washington State including most of western Washington, the Selkirk Mountains of northeastern Washington, and the Blue Mountains of southeastern Washington. Because of their valuable pelt, fishers were trapped intensively throughout much of their range. Over-exploitation of fisher populations in the late 1800s and early 1900s caused a widespread contraction of the fisher range in North America and the loss of fishers from most of the U.S. and much of southern Canada. Population declines prompted the closure of fisher trapping seasons in many states in the early 1900s; however, these season closures came too late to protect many fisher populations. Beginning in the 1940s, wildlife managers and resource managers began reintroducing fisher populations to restore a valuable furbearer, a valuable predator of porcupines, and a missing member of the carnivore community. The fisher is among the most successfully translocated carnivore species, owing to the fact that most fisher populations were extirpated as a result of over-exploitation rather than loss of habitat (Lewis et al, 2013).

In December of 2015, the Washington Department of Fish and Wildlife (WDFW) began a fisher reintroduction project in the Southern Cascades, starting with the release of 23 fishers at the Cispus Center on the Cowlitz Valley Ranger District (CVRD) of the Gifford Pinchot National Forest (GPNF). They have dispersed from the original release site and are now widely distributed on the GPNF. Additional releases are planned for the winter of 2016/2017 and up to 80 animals may be released in the effort to reintroduce fisher into the Southern Cascades.

Natural History and Species Occurrence Suitable fisher habitat can be described as low elevation, closed canopy forests with complex vertical and horizontal structure. Where their habitat associations have been studied in western North America, fishers commonly prefer low- and mid-elevation landscapes dominated by mid- to late-seral forests with moderate-to-high canopy cover where large woody structures such as large cavity trees, snags, and logs are relatively common features (Raley et al. 2012). Past studies have examined the use of habitat structures for denning and rest sites, finding that fishers rely on tree cavities for denning and prefer large diameter, deformed trees for rest sites (Zielinski et al. 2004).

Forests with moderate-to-high canopy closure are likely to provide overhead cover and escape cover for fishers because they are good climbers. In addition, high canopy cover provides suitable microclimates for den and rest sites and a sufficient canopy to intercept snow that would otherwise accumulate in greater depths on the forest floor and potentially impede efficient travel. Fishers will cross small forest openings to access forest stands within their home ranges, however they will typically avoid large open areas (e.g., wetlands, meadows, agricultural fields, and clearcuts). Recent studies suggest that female fishers may be more selective of habitats than males at the home range scale, and at finer scales, as a result of their dependence on woody structures for den sites and greater security requirements than males although these relationships remain poorly understood (Lewis et al, 2016).

Fishers have diverse diets that include small mammals, birds, plants, and fungi (Zielinski et al, 2004). An important prey item of fishers is the snowshoe hare (Lepus americanus) that prefer forests with dense understories. Another potential prey species in the Cascades is mountain beaver (Aplodontia rufa). Mountain beaver are known to colonize recently cleared forests, and they decline in abundance as stands age (Hacker and Coblentz, 1993). Fishers also prey on many sciurids, microtines and other small mammals.

The proposed project area provides excellent fisher habitat because of the occurrence of large tracts of old growth forest in the Silver Creek watershed and relatively scarce human presence. The proposed project area is located approximately 10 air miles to the north of the Cispus Center release site which is easily within dispersal distance for these moderately wide-ranging carnivores, therefore fisher are likely to occur in the project area.

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Effects - No Action There would be no increase in disturbance, no increase in open road density and no loss of potential denning habitat in the project area and therefore no impact to fisher. Fisher habitat would remain unchanged from the current condition.

Effects - Action Alternative The potential adverse project effects to fisher should they be in the project area include a short-term increase in disturbance that may cause avoidance of the area during project activities. Activities associated with project implementation would be an increase in noise and disturbance over ambient levels that are normally low in the area. There would be an increase in human activity associated with the commercial harvest treatments, pre-commercial thinning, road closure and stabilization and other restoration work that includes the use of heavy machinery, skyline operations and possibly helicopters, chain saws and associated log-hauling and slash-piling activities. The non-commercial thinning treatments would also constitute a short-term increase in human disturbance in the project area that would likely cause habitat avoidance.

Road access reduces habitat security for many species. The proposed project would re-open approximately 3.5 miles of system roads that are currently “ecologically” closed because they have not been maintained for several years. These roads would be reopened for project use and remain opened after the timber harvest is completed. In addition, several miles of temporary roads would be constructed and several miles of existing temporary roads would be re-opened for project activities. All temporary roads would be closed after the project is completed. The proposed action would also close and stabilize approximately 10.2 miles of system roads, therefore a small post-project net increase in habitat security for fisher.

The commercial harvest and associated log hauling, in addition to the closure of roads and other restoration activities, will likely occur over the course of several years (5 to 10), and will be a substantial increase in the amount of human activity in the project area. The disturbance effect could cause habitat avoidance of the project area by fishers because of human activity.

The proposed action would commercially thin approximately 2,000 acres of mid-seral stands that do not currently provide much understory plant production. The thinning would result in a temporary increase in understory plant production that would attract fisher prey species such as snowshoe hare. The early seral forage openings would contribute to more potential forage for fisher prey species and may benefit fishers if they are utilizing habitat in those areas. This effect would be temporary, however, and may last for a period of approximately 20 to 30 years until the canopy closes in again and trees grow up in the forage openings.

Because of the disturbance effect caused by timber harvest operations and road reconstruction work, the implementation of the proposed project may impact fishers should they be present and would likely cause habitat avoidance where the disturbance occurs. Fisher habitat in the project area would be impacted by the proposed harvest of Unit 29 since that unit contains large live and dead standing and fallen trees that would provide potential denning structures. There may also be a potential loss of snags and down wood from clearing and hazard tree removal. Despite these impacts to fisher habitat, the proposed project will not contribute to a negative trend in viability of this species on the forest because of the minor amount of habitat affected. Therefore, given the increase in disturbance over ambient levels that would be associated with project activities for a period of approximately 5 to 10 years, a small decrease in potential denning habitat, and a slight increase in open road density during project activities, the implementation of the proposed project may impact individuals and habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species for the fisher.

124 Silver Creek Thin EA January 2017

Cumulative Effects The disturbance effects and impacts to habitat from the Silver Thin project would accumulate to similar effects from the adjacent Nisqually Thin project to the north of the Silver Creek watershed. In addition, several other timber sales on the district are active and the proposed project’s effects would be cumulative to those as well.

Sensitive and Survey and Manage Species This proposed action complies with the Northwest Forest Plan as amended by the 2001 Record of Decision and Standards and Guidelines for Amendments to the Survey and Manage, Protection Buffer, and other Mitigation Measures Standards and Guidelines. Pre-disturbance surveys were conducted and site management applied consistent with the January 2001 species list.

Amphibians Although suitable habitat is found within the 5 subwatersheds of the project area, there are no known records of any of the sensitive salamander species within these subwatersheds. The four sensitive salamanders that are known to occur on the CVRD are Van Dykes, Larch Mountain, Cope’s Giant and Torrent.

Cope’s Giant and Cascade Torrent Salamanders The Cope’s giant salamander (Dicamptodon copei) is a predominantly aquatic species associated with clear, cold streams that rarely transforms into terrestrial adults. Dicamptodon copei is almost always found in its aquatic form in fast moving streams. This species is rare-to-uncommon on CVRD based on surveys performed to date.

The Cascade torrent salamander (Rhyacotriton cascadae) is a semi-aquatic species that is relatively common in cold stream edges at mid- and higher elevations. Adults may be found along stream banks and during wet periods, they may venture into upland areas. There are no records of this species in the project planning area.

According to the 2011 Conservation Assessment for this species (Howell and Magiulli, 2011), Rhyacotriton cascadae occurs along the west slope of the , from just north of the Cowlitz River and State Route 12, Washington, south to the Middle Fork of the Willamette River, Oregon. Within this area, the species is patchily distributed.

The conservation assessment lists the main suspected threats as forest management activities that increase water temperature, turbidity, peak flow or debris flow events, and habitat degradation and fragmentation. Key threats are timber harvest, impassable culverts, road construction and maintenance, and chemical applications. Additional concerns include fire, disease, predation, human recreational activities, volcanism, mining, and climate change. Considerations for maintaining or improving local populations of this species include managing sedimentation; retaining riparian buffers to provide stream shading, near- stream terrestrial ambient moisture regimes, large wood recruitment, and terrestrial dispersal habitat; minimizing riparian management activities; and enhancing connectivity between habitats.

Rhyacotriton cascadae is listed by the U.S. Forest Service and BLM in Washington as Sensitive. It is also a Washington State Candidate species and Species of Concern. The Natural Heritage Network considers the species to be “G3,” a global rank which categorizes it as “either very rare and local throughout its range or found locally (even abundantly at some of its locations) in a restricted range” and S3, a state ranking for both Washington and Oregon, which classifies it as “rare or uncommon.” The status of the Cascade torrent salamander is currently under review for ESA listing.

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Effects – No Action In the No Action alternative, there would be no timber activities, no restoration actions, and no road closure work, and therefore there would be no impacts to aquatic salamanders.

Effects – Proposed Action According to the 2011 Conservation Assessment, several studies have addressed the effects of timber harvest activities on R. cascadae and Rhyacotriton spp. Generally, reduced abundances have been found in several studies examining the youngest age classes of managed stands (i.e. clearcut stands). The studies suggest these stream dwelling salamanders are not associated with forest canopy conditions but rather the consequences of harvest activities to stream habitats (increasing stream temperatures, increasing sedimentation and possibly peak flow events. Some studies suggest riparian buffers offer protection to the salamanders.

Project Design Criteria that include riparian buffers in harvest units that are implemented to limit sedimentation, increased water temperature, and effects to peak flows will serve to minimize impacts to aquatic salamander species. However, the proposed restoration work that includes culvert removal has the potential to cause short-term increases in stream turbidity from sediment pulses that could adversely impact aquatic or semi-aquatic amphibians like Cope’s giant salamander and Cascade torrent salamander. Therefore the proposed Silver Creek Thin project “May impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.”

In general proposed road closure and stabilization restoration work should serve to stabilize adverse effects to the above-mentioned indicators and result in long-term benefits to aquatic habitat in the project area.

Cumulative Effects The potential adverse impacts to Cope’s giant and Cascade torrent salamanders from the proposed project would be cumulative to effects from other projects that are planned for the reasonably foreseeable future that include potential road closure and stabilization work. Future adverse effects that may be expected to occur to these aquatic invertebrates are continued sediment delivery to streams from fairly high road densities in these watersheds that, depending on funding levels, may or may not receive adequate road maintenance and occasionally will fail during rain on snow and other such events when culverts tend to get plugged.

Van Dykes Salamander The Van Dyke’s (Plethodon vandykei) salamander is a rare species with few historic sites known to exist on CVRD, and it is a Category “A” Survey and Manage species. This species occurs in high gradient streams, waterfall splash zones, moist talus associated with adjacent old growth forest and abundant large woody debris and cave entrances. The conservation concern is primarily that the species occurs in isolated sites with limited connectivity, although the biological distribution of the species is not fully known. Potential habitat for Van Dyke’s exists within the subwatersheds of the project area but is not found within treatment units.

Effects – No Action In the No Action alternative, there would be No Impact to Van Dyke’s salamanders.

126 Silver Creek Thin EA January 2017

Effects – Proposed Action Because this species is associated with riparian areas, potential adverse project effects to the Van Dyke’s salamander in the commercial thin treatment units are expected to be minimized with the protection provided by riparian buffer zones. Habitat inside vegetation treatment units is highly unlikely to be suitable for Van Dyke’s salamanders. However, habitat for the species is present within the larger project area, though occurrence has not been documented. The proposed road closure work will involve culvert removal and consequently could affect aquatic habitat. Therefore, the proposed project “May impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.”

Cumulative Effects There are no projects planned in the reasonably foreseeable future that would impact Van Dyke’s salamander. Primary threats to this species are considered to be road building and timber harvest, and in particular channel scouring from mass wasting events. Poor road maintenance could be a potential adverse effect to this species if slope failures occur in the future.

Larch Mountain Salamander There are only a few sites on the Cowlitz Valley Ranger District where the rare and sensitive, Category A Survey and Manage, Larch Mountain Salamander (Plethodon larselli) has been documented. These sites form the northern extremity for this species once thought to only occur on lava talus slopes along the Columbia Gorge. It is suggested that this species is a declining relic that once occupied a much broader geographic area (Aubry et al 1987; Herrington and Larson, 1985). Its habitat includes talus slopes, cliffs, and old-growth forests surrounding those features.

Effects – No Action In the No Action alternative, there would be no impacts to the Larch Mountain salamander.

Effects – Proposed Action Suitable habitat for the Larch Mountain salamander does not occur within the majority of treatment units, but may be present in Unit 29 where large woody debris, highly decayed snags and down wood are interspersed among small rocky outcrops. The majority of the treatment units are young stands that are 40 to 60 years old, the result of regeneration harvest and therefore they are structurally simple, single tree layer having little to no snags, nor any large live trees or large down wood. There are no talus slope or cliff features within the majority of the units that would be suitable Larch Mountain salamander habitat. Potential adverse project effects to the Larch Mountain salamander in the commercial thin treatment units are expected to be minimized with the protection provided by riparian buffer zones, the non-entry into old growth and retention of large woody debris.

Surveys were conducted in Unit 29 where some suitable habitat may occur, and there was no detection of Larch Mountain salamander. Therefore, the proposed project “May impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.”

Cumulative Effects Few past projects have had known sites of Larch Mountain salamanders because the habitat for this species is generally not in harvest units. However, past road building for timber sales doubtless impacted Larch Mountain salamander habitat, but the extent will never be known because surveys for this species were not required prior to the Northwest Forest Plan on 1994. One occurrence was documented in the Kirk Thin planning area but the site was not in a harvest unit, hence no impact was expected. Since the

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Larch Mountain salamander is a Category A Survey & Manage species, potential sites have to be surveyed in future proposed project areas, and if the species is present then buffer zones will be used to protect the site.

As the species is thought to be a declining relic species and quite rare it is considered to be susceptible to extirpation through catastrophic events. Road building and other ground disturbing activities are considered primary threats to this species. Even with strong protection measures of sites on federal lands, according to the cumulative effects assessment in the Final Supplemental EIS for the NWFP, population size of the Larch Mountain salamander will be reduced with loss of populations on nonfederal lands and this risk to the species could result in long-term population uncertainty.

Summary of Proposed Action Effects for all sensitive and Survey and Manage salamander species The project will incorporate riparian buffers of various widths depending on a variety of considerations. Riparian buffers would serve to protect species associated with riparian habitat, including sensitive salamanders. Because the treatment units are in young managed stands and generally lack habitat features such as large down wood and decayed snags that provide habitat, there is a low probability of salamander occurrence in the treatment units with the exception of Unit 29 that does contain these features and rocky outcrops.

Closing and stabilizing 10.2 miles of system road will include removal of existing culverts. This work has the potential to affect salamander habitat in streams. The project area contains large areas of unstable soils and numerous mass wasting events have occurred in the recent past, often as a result of intensive past timber harvest and extensive road building that has occurred in much of the Silver Creek drainage. These past events have likely an adverse effect on stream dwelling salamanders. Some washouts such as the East Fork of Silver Creek road crossing will remain closed. Others, such as the washout on the 75 road, will be repaired and remain open post-project. It can be expected to wash out again, however, and the fill material used to repair the washout will likely negatively impact stream dwelling salamander downstream. There are 3.5 miles of currently closed roads with numerous washouts that will be repaired and remain open post-project, and many of the repaired washouts can be expected to wash out again in the future.

The riparian buffers would serve to protect species associated with riparian habitat, however, there is a minimal chance of destruction of habitat or direct mortality from project activities, therefore the proposed action may impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species for sensitive salamander species.

Mollusks Sensitive and Survey & Manage mollusk species exist in or near the project area according to records the Forest Service wildlife database. Surveys conducted for the Silver Watch timber sale in the 1990s detected the Puget Oregonian (Cryptomastix devia) snail at several locations within the project area.

Most of the Proposed Action fits under the first exemption from the 2001 Survey and Manage standard identified under the Pechman Order of 2006, “Thinning projects in stands younger than 80 years old.” Pre-disturbance surveys are required in suitable habitat in stands that are over 80 years in age for Category A and C S&M species.

Surveys were conducted according to protocol in Silver Creek Thin proposed stands that are over 80 years old, and in the stands where treatments other than thinning are prescribed. Puget Oregonian snails were found at two locations in Unit 29.

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The following table shows the Category A and C (rare or uncommon, pre-disturbance surveys practical) Survey & Manage (S&M) mollusk species that are known or suspected to occur on the Gifford Pinchot NF and the associated habitat.

Table 30. Survey and Manage Mollusks on the Cowlitz Valley Ranger District

Species Status Comments

Puget Oregonian Documented Relatively common on CVRD. This species is strongly associated with bigleaf maple (Cryptomastix devia) Category A Survey and Manage trees, usually with a moist understory containing swordferns (Burke et al 2005). All sites are below approximately 2700 elevation.

Keeled Jumping Slug Suspected Found in moist conifer forests, associated with conifer logs and/or heavy ground cover Hemophilia burringtoni Category A Survey and Manage of low vegetation, litter and debris.

Warty Jumping Slug Suspected Habitat similar to H. burringtoni, conifer logs and/or heavy ground cover of low Hemphillia glandulosa Category C Survey and Manage vegetation,litter and debris

Oregon Megomphix Suspected For Washington, records indicate this species has a low-elevation distribution from (Megomphix hemphilli) Category A Survey and Manage Olympia to the Columbia River that does not include any National Forest. The Oregon Megomphix occurs at low to moderate elevations, below the zone of seasonally persistent snow pack. Megomphix snails are most often found within the mat of decaying vegetation under sword ferns and bigleaf maple trees and near rotten logs.

Malone jumping-slug Documented Very rare species on CVRD (3 known locations), all north of Cowlitz River in old- (Hemphillia malonei) Category C Survey and Manage growth stands. Coarse woody debris is an important habitat feature for this species.

Blue-gray tail-dropper Documented Very rare species on CVRD (4 known sites), three of which are in the Woods LSR. (Prophysaon Category A Survey and Manage Habitat is coarse woody debris and coeruleum) deciduous leaf litter, especially bigleaf maple. All known sites are in old-growth Douglas-fir stands with large bigleaf maples and other deciduous trees.

Hoko Vertigo Suspected Arboreal and considered an old-growth and riparian species, found on smooth trunks (Vertigo new species) Category A Survey and Manage and lower limbs of deciduous trees and

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Species Status Comments

shrubs, or in leaf litter within 200 meters of streams, seeps or springs.

Effects – No Action There would be no impacts to sensitive and S&M mollusk species in the No Action alternative.

Effects – Proposed Action Sensitive and S&M mollusk species that are known or suspected to occur on the Cowlitz Valley Ranger District are generally associated with late successional stands. Almost all proposed treatment units are in relatively young, managed stands that are the result of regeneration harvest and were also broadcast burned. The exception to this is Unit 29 that is a naturally regenerated, 85 year old stand with legacy features. The Puget Oregonian snail (Cryptomastix devia) was found in two locations in Unit 29 during spring surveys in 2015. There were also two locations of Puget Oregonian snails found during surveys conducted in the proposed Silver Watch Thin Unit 23 in the 1990s. Silver Watch Unit 23 is the same stand as Silver Creek Thin Unit 29. Sites found during the 2015 survey of Silver Creek Thin will have the standard no-cut protection buffers. In addition, sites previously located for Silver Watch Thin will be re- located and if found, will be buffered for the Silver Creek Thin.

Surveys according to protocol were not conducted in the majority of the treatment units where under 80 year old plantations will be commercially thinned. Surveys were conducted in some of the proposed early seral forage openings where suitable habitat may be found, and in Unit 29. Where found, any locations of sensitive or survey and manage mollusk species will have standard protection buffers. In addition, S&M mollusk sites that have been found in past projects, such as the Silver Watch Thin project that overlaps the current Silver Creek Thin project, will be relocated and buffered if they occur within planned treatment units. However, surveys may not locate all of the sensitive and survey and manage mollusks present, and so proposed treatments will alter micro-climatic conditions within the units. Therefore, although occurrence in the majority of the treatment units is unlikely, the proposed project may impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species to sensitive and survey and manage mollusk species as a result of implementing the proposed project.

Cumulative Effects There are no future timber sales planned for the reasonably foreseeable future in the project area that would be cumulative to the projects effects. The proposed project’s effects (changes to microclimate, known sites in Unit 29) would accumulate to the effects of the adjacent Nisqually Thin project that will happen in the near future.

Harlequin Duck Harlequin ducks breed on fast moving, higher gradient rivers and streams, hence rapids, and winter along rocky coastlines. Harlequin ducks may be present on Silver Creek during the breeding season. Suitable nesting habitat is present but surveys for harlequin ducks that were conducted on Silver Creek in 2013 did not detect any harlequin ducks.

Effects – No Action There would be no potential disturbance to nesting harlequin ducks on Silver Creek and therefore No Impact.

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Effects – Proposed Action Project activities that are near riparian corridors have the potential to disturb breeding harlequin ducks. A no-harvest riparian buffer 300 feet wide is part of the prescription for the units along Silver Creek. The riparian reserve buffer will somewhat limit disturbance to harlequin ducks on Silver Creek, so there is little potential for disturbance to breeding harlequins. In addition, many of the units along Silver Creek have a timing restriction for the NSO early nesting season that would limit disturbance to breeding harlequin ducks. Consequently, there is a low probability that the proposed project “may impact individuals” from increased disturbance and will not likely have any habitat effects to harlequin ducks because of the riparian buffer distances.

Cumulative Effects There are no other on going or planned for the near future timber sale projects near Harlequin duck habitat on Silver Creek to which the proposed projects effects would accumulate.

Bald Eagle Bald eagles winter in the Cowlitz Valley but they have not been observed in the project area. There are no known bald eagle nesting sites within the project planning area. Because they are not known to occur in the planning area, either during the nesting season or winter months, there are No Impacts expected to bald eagle.

Peregrine Falcon Peregrine falcons require cliffs for nesting that are usually near water bodies that provide habitat for their waterfowl prey. In Washington, typical prey items for peregrine are shore birds, waterfowl and passerines. No peregrine nests are known to exist in the project area but potential habitat for peregrine falcons does occur within the project area. However, because they do not occur in the planning area, there are No Impacts expected to peregrine falcon from the proposed activities.

Management Indicator Species The following species are listed as Management Indicator Species for the Gifford Pinchot National Forest. All are known to occur or could potentially occur in the project area. The following section discloses the effects to these species, with the exception of northern spotted owl, which has already been discussed.

• Northern spotted owl – Represents species requiring mature and old-growth forest. • Pine marten, pileated woodpecker – Represents species requiring mature and old-growth forest. • Cavity excavators – Represents species requiring snags and down logs. • Wood duck – Represents species requiring mature and old-growth deciduous riparian habitat. • Goldeneye – Represents species requiring mature and old-growth coniferous habitat. • Deer and Elk • Mountain goat

Pine Marten The pine marten (Martes americana) is a small forest carnivore that preys on squirrels, voles, mice, and snowshoe hares. Marten are typically associated with late-seral coniferous forests with closed canopies, large trees, and abundant snags and down wood (Zielinski et al. 2001). Down logs provide habitat for prey and subnivean (under snow) access points and down logs and snags provide rest and den sites for

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marten. Thomas et al. (1993) and FEMAT (1993) list marten as “closely associated” with late successional and old-growth forests and the old-growth elements of large snags and down logs. Their reports also indicate a strong relationship of marten with riparian areas.

There are records of marten occurrence in the wildlife database in the project area in late successional stands. Potential marten habitat is throughout the project area near most of the proposed treatment units that are adjacent to late successional stands. The treatment units are likely to be within the home range areas of marten that inhabit the general project area. The treatment units are likely to be within the home range areas of marten that inhabit the general project area.

Effects – No Action There would be no commercial harvest and non-commercial treatments of the proposed stands and thus no potential disturbance effects to marten in the no action alternative and No Impacts. However, there would be no beneficial effects to marten from the post-project net reduction in road density. There would be no loss of suitable foraging habitat. There would be no beneficial creation of snags.

Effects – Proposed Action The proposed treatment units do not provide the attributes (down wood, snags, etc.) of good marten habitat so there is a low likelihood of direct loss of marten habitat from the commercial thin harvest prescription, with the exception of Unit 29 that does provide suitable habitat features for marten. It is possible that the low habitat quality treatment units are used by marten at least as travel corridors between patches of higher quality habitat, and may also serve as foraging areas. Project activities have a high likelihood of causing disturbance to marten and consequently habitat avoidance.

Implementing the proposed project will decrease access to interior forest marten habitat by closing and stabilizing 10.2 miles of road, however the proposed action will also re-open 3.5 miles of currently closed roads. The net decreased access will be beneficial to marten because open roads into marten habitat allow access for potentially illegal trapping. The proposed action would also create snags in spotted owl foraging habitat that would be beneficial to marten as well. However, because of the disturbance effect caused by the use of heavy machinery and tree felling in units adjacent to suitable marten habitat, and the loss of 43 acres of suitable marten habitat, the implementation of the proposed project may impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species from increased disturbance to pine marten.

Cumulative Effects The effects of the proposed action will be cumulative to loss of habitat from past timber harvest in the Silver Creek drainage that resulted in a large reduction of marten habitat. The disturbance effect from project activities will also accumulate to the disturbance effects of the adjacent Nisqually Thin project, which could occur over almost the same time period.

Pileated Woodpecker Pileated woodpeckers (Dryocopus pileatus) use mature, closed-canopy stands for nesting and roosting, but may use younger (40-70 years) closed-canopy stands for foraging if large snags are available. Large snags and decadent trees are critical habitat components for pileated woodpeckers while down logs do not appear to be an important foraging substrate for pileated woodpeckers on the west side of Oregon and Washington ( Raley and Aubry 2006).

Pileated woodpeckers occur in the project area and foraging sign can be seen in older stands in the project area. All of the treatment units are within home ranges of this species that uses relatively large patches of

132 Silver Creek Thin EA January 2017

forest for foraging. Some proposed treatment stands, such as stand #9053 (Unit 29), contain large snags that could be used for nesting and provide foraging habitat for this species.

Effects – No Action Under the no action alternative there would be no commercial harvest and non-commercial thinning, therefore high canopy cover would be maintained in the proposed stands. Under this alternative, there would be no adverse impacts to pileated woodpeckers. There would be no loss of suitable habitat; however, there would be no long-term benefits to the acceleration of attainment of large tree structure in the treatment units.

Effects – Proposed Action The proposed action is not likely to adversely affect pileated woodpecker habitat in the majority of the treatment units because they do not provide suitable nesting and foraging habitat. The majority of the treatment units do not have large diameter snags that this species requires for nesting or many snags of the smaller size classes. The proposed action will adversely affect habitat for this species with the proposed early seral creation and some commercial thinning in Unit 29 where suitable habitat does occur, because this unit contains legacy features from an older stand that includes several large snags.

In addition, many of the treatment units are adjacent to potential nesting and foraging habitat for pileated woodpeckers because they border old growth forest. Project activities will likely disturb pileated woodpeckers where timber harvest occurs adjacent to nesting and foraging habitat within a home range area, and may cause avoidance of habitat.

The commercial thinning will reduce the effect of suppression mortality in the very dense young stands and therefore fewer small diameter snags and down wood will be created in the next few decades. Small diameter snags are used for foraging by many woodpecker species. This effect would be offset by the long-term beneficial effects to pileated woodpecker habitat because the treatments are intended to accelerate growth rates to attain large tree structure, and will also enable understory development that would provide a multi-storied canopy. As part of the restoration component of the project, snags will be created in NSO foraging stands that will benefit pileated woodpecker as well. These snags would be large enough to provide potential nesting habitat for pileated woodpeckers as well as foraging habitat. The proposed road closures in the project will also have beneficial effects to pileated woodpeckers because they will reduce fragmentation of interior forest habitat.

Therefore, it is expected that implementation of the proposed project may impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species from the loss of 43 acres of suitable nesting and foraging habitat and increased disturbance to pileated woodpeckers.

Cumulative Effects Species such as the pileated woodpecker that require late successional/old growth forest habitat benefit from forest management practices that promote habitat for the northern spotted owl. Past timber sales and associated road building, especially from the 1950s to approximately 1990, removed and fragmented much of the old growth forest on the district. By the time the spotted owl was listed under ESA roughly 90% of the old growth forests of the Pacific Northwest were gone. Populations of other species that depended on this ecosystem also declined. With the implementation of the Northwest Forest Plan in 1994 future trends for these species should be in a positive direction.

On-going and future activities that have adverse effects to forest interior species, to which the impacts of the proposed project will accumulate, include maintaining road access thru late successional forests where

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hazard trees are routinely cut and potential exists for illegal and wood-cutting. The proposed project’s effects will accumulate to the disturbance from the adjacent Nisqually Thin project to the north of Silver Creek that will likely overlap in time.

Cavity Excavators Primary cavity excavator species include many woodpecker species that usually, but not always, require standing dead trees, or snags, to excavate cavities for nests that many secondary cavity-nesting species will also use. Defective live trees are commonly used by primary cavity excavators. The stands where past regeneration harvest has occurred, however, generally are almost entirely lacking in large standing snags. Some of the proposed stands, such as stand #9053 (Unit 29), are naturally regenerated from wildfire and contain legacy features that include large trees with dead tops and large snags and thus good habitat for woodpeckers.

Historically fire played a major role in the creation of dead wood habitat that many species of wildlife require for nesting, foraging or habitat in general. The black-backed woodpecker makes use of both large and small patches of dead trees for nesting and foraging, reaching its highest densities in forests with numerous trees recently killed by fire (Saab et al. 2009). The black-backed and many other woodpecker species play a keystone ecological role in burned forests by excavating nest cavities that are later used by secondary cavity-nesting birds, including western and mountain bluebirds, chickadees, nuthatches, and small forest owls. Woodpecker cavities are also utilized by innumerable forest invertebrates and mammals, such as marten and several bat and squirrel species.

Historic Reference Conditions DecAID is an advisory system that provides advice on managing for decayed wood. DecAID is a summary of the current knowledge and best available data on dead wood in Pacific Northwest ecosystems. The DecAID approach chooses a “reference point” in time where some data is available on forest structure and compares that data to the current condition. The Gifford Pinchot National Forest has used data from the mid-1930s as a reference point. DecAID data derived from unharvested plots in the mixed montane conifer forests in the West Cascades region of Washington show data from “naturally regenerated” or unharvested stands.

This data indicates that for smaller diameter snags over approximately 10 inches diameter, the mid-point averages for density are in the range of approximately 10 to 25 per acre, and the larger snags over approximately 20 inches diameter are found at lower densities, ranging from 0 to 8 per acre over most areas (Figure 14). Field reviews have found that the treatment units in the proposed units have snag densities well below average levels found in unharvested plots in the West Cascades province, generally of 1 to 2 per acre of < 20 inches in diameter.

It is important to remember that the unharvested inventory data are represented as vegetation conditions from plots measured at a single point in time and the current conditions express events that have occurred over past decades to centuries. Snags and down wood have been altered to an unknown degree by fire suppression and other human influences.

DecAID presents information on wildlife use of snag diameter, snag density, down wood diameter, and down wood cover, and on the range of natural (unharvested) and current (all) conditions of snag density and down wood percent cover by diameter classes. It is a statistical summary of published research data on wildlife and forest inventory data. This information can help managers evaluate the effects of forest conditions and existing or proposed management activities on wildlife that use snags and down wood. DecAID can also help managers decide on snag and down wood sizes and levels needed to help meet wildlife management objectives for a particular project or area.

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DecAID advises that the best available wildlife data indicate that to manage for a diversity of species which rely on snag habitat, provide snags larger than 80 cm (32 in) dbh and up to 138 cm (54 in) dbh when available, and to manage for the complete range of snag sizes to provide snags for all species on the curve. Data indicate American marten use very large snags for resting and denning. These large snags are rare in this habitat, thus, as far as possible, all large snags and defective, especially hollow trees should be maintained to provide wildlife habitat.

DecAID recognizes that dead wood habitat is not naturally evenly distributed across the landscape because it is a function of forest type, aspect and elevation. Fire regimes are an important factor in dead wood habitat. Because of decades of fire exclusion areas with a frequent historical fire regime may have missed several fire cycles.

A portion of project planning area occurs in the Nisqually LSR, where, according to the Nisqually LSR assessment, stands over 80 years old had an average of 37 snags per acre that were an average diameter of 16 inches. Down wood was present at an average of 212 pieces per acre that had a large end diameter of 16 inches or greater.

The DecAID analysis for the project planning area resulted in the data shown in the following table. The data reveals that in the Westside Lowland Conifer Hardwood habitat type that occurs on 7,044 acres in the Silver Creek subwatershed, most of this habitat type provides snag habitat in the lower tolerance levels for cavity nesting birds, including pileated woodpecker.

Distribution of Snags ≥ 10" dbh Westside Lowland Conifer Hardwood Forest Silver Creek Thin Project Area Comparison of Reference Condition from DecAID to Existing Condition from GNN 2012 data

30 Existing Condition Reference Condition 25

20

15

% of Landscape % of 10

5

0

Snags/acre

Figure 14. Distribution of Small Snags in WLCH Forest in Silver Creek Project Area

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70%

60%

50%

40% Big Brown Bat

30% Cavity-nesting Birds Long-eared Myotis 20% Long-legged Myotis 10% Pileated Woodpecker (nest) Pileated Woodpecker (forage) 0% Percent of Percent of Percent of Percent of project area project area project area project area providing providing providing providing habitat habitat at 30- habitat at 50- habitat at at<30% 50% tolerance 80% tolerance ≥80% tolerance level level level tolerance level

Figure 15. Wildlife tolerance levels for snags >=19.7” dbh percentage of westside lowland conifer- hardwood forest in the Silver Creek Thin project area that provides habitat for species based on GNN 2006 data.

45% 40% 35% 30% 25% 20% Cavity-nesting Birds 15% Bushy-tailed Woodrat 10% Douglas Squirrel 5% Northern Flying Squirrel 0% Percent of Percent of Percent of Percent of project area project area project area project area providing providing providing providing habitat at<30% habitat at 30- habitat at 50- habitat at ≥80% tolerance level 50% tolerance 80% tolerance tolerance level level level

Figure 16. Wildlife tolerance levels for snags >= 9.8” dbh percentage of westside lowland conifer- hardwood forest in the Silver Creek Thin project area that provide habitat for species based on GNN 2006 data.

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Effects – No Action In the no action alternative none of the proposed treatments would occur. Snags would continue to develop over time as suppression mortality occurs. It is likely that the no action scenario would result in more small diameter snags and down wood in the stands in the near future, as they succumb to disease and other density dependent agents of mortality. Existing snags that occur within the treatment units would be more likely to be retained in the no action scenario. However, no additional snags would be created in adjacent foraging habitat.

Effects – Proposed Action The proposed commercial thinning treatments would slow the process of suppression mortality within the units because competition for growing space within the high-density stands would be diminished. Therefore, the treatments would result in fewer small diameter snags and down wood in the near future because reduced competition between trees due to thinning reduces density-dependent mortality in the residual trees, allowing them to be healthier and live longer before succumbing to competition, insects, or disease. This would delay the development and attainment of some late successional attributes such as abundance of snags and down trees by several decades. Any untreated portions of stands such as skips and inner riparian reserves become an important addition for delivering these decay components in the treated areas sooner albeit in small diameter classes, while growing large trees that will eventually become large snags and logs in the thinned portion of the unit. In the long-term, the units would provide larger diameter snags and down wood in roughly 50 to 100 years if thinned because growth rates would be increased by the thinning.

Some snags would be cut during harvest operations, temporary road construction, road closure, and the creation of landings due to safety considerations, and some downed logs would be disturbed or crushed during project implementation. Some of the larger diameter snags that occur in Unit 29 may have to be felled for the cable logging systems to be implemented. Snags that are left standing after thinning would be more prone to windthrow than they would have been without thinning. There would likely be some loss of the remaining snags within a few years after harvest, which would become down wood.

The proposed action would also create 20 to 30 inch diameter snags in adjacent foraging stands that would have an immediate benefit to cavity excavator species.

Cumulative Effects Past regeneration harvest activities on approximately 50 percent of the National Forest land in the watershed and private industrial timberland has greatly reduced the abundance of snags from historic levels. There are still relatively abundant small and large snags in the mature forests within the Silver Creek drainage.

Snag creation in the project area and adjacent areas predominantly occurs where natural fires burn until suppression activity occurs. The projects effects to dead wood habitat will therefore largely accrue to effects of natural fires that occur in the future.

Goldeneye Duck Goldeneye ducks may occur on small lakes found within planning area. As is the situation for wood ducks, there are no project activities located near small lakes or wetlands with the exception of a potential wetlands restoration project on Hampton Creek. If the project is implemented it would be in the fall outside of the breeding season so nesting birds would not be affected. Therefore, no impacts to goldeneye ducks are expected as a result of project activities.

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Wood Duck Wood ducks may occur on small lakes found within planning area. There are no project activities located near small lakes or wetlands with the exception of a potential wetlands restoration project on Hampton Creek. If the project is implemented it would be in the fall outside of the breeding season so nesting birds would not be affected. Therefore, no impacts to wood ducks are expected as a result of project activities.

Deer and Elk Management direction in the 1990 Gifford Pinchot Forest Plan is to “maintain habitat for about the current potential population of elk, with an increase of about 10 percent for deer.” The Forest Plan identifies a Desired Future Condition (DFC) of at least 44% of habitat in optimal cover in winter range (USDA, 1995a). Most of the project area is in summer range for deer and elk, but a portion of the northern area is within biological winter range generally under 2200 feet elevation.

Optimal cover has been described as stands at least 40 feet in height with 70% canopy cover (Thomas et al, 1988, Thomas et al, 1979) and a continuous layer of sub-dominate trees that provide thermal regulation at the ground level as well as visual screening for security. The forest plan identifies optimal cover stands as having average tree diameters over 21 inches. According to the 1997 Middle Cowlitz Watershed Analysis, optimal cover coincided with the large tree structural category and the Middle Cowlitz watershed as a whole contained only 16% of optimal cover in biological winter range (BWR). The BWR in the entire 5th field watershed encompasses 39,000 acres, of which 12,439 acres is on National Forest land. Almost all of the optimal cover in the watershed is on National Forest, so the vast majority of non-federal land is not in an optimal cover structural condition. However, quality early seral forage is also not found in abundance on federal land, and the ideal situation for elk is to have a juxtaposition of cover and forage. The Middle Cowlitz watershed analysis also identified high road densities specifically in BWR. Therefore, the quality of BWR could be improved on the National Forest portion of BWR in the watershed by means of the creation of small forage openings in the project area.

The elk that occur in the project area (Cervus elaphus) are within the boundary of the South Rainier elk herd area. The 2002 WDFW South Rainier Elk Herd Plan states that the South Rainier elk primarily winter along the Cowlitz River, from Packwood to Randle. Field review of the proposed treatment stands found deer and elk sign scarce in general and it appears that the project area does not provide high quality habitat for big game in general. Black-tailed deer were occasionally observed during field reconnaissance in the project area.

The WDFW herd plan identifies continual loss of summer and winter habitat on National Forest land due to LSR management direction, and expects a substantial decrease in the carrying capacity of these lands to support elk populations. Records from Mt. Rainier National Park indicate low elk numbers there until the 1950’s when the elk population increased significantly. This coincided with logging activities outside of the park that increased the carrying capacity on elk winter ranges by increasing forage production of grasses and shrubs. Intensive logging, generally in the form of clear cutting, greatly changed the character and structure of the forests outside of the park, resulting in a patchwork of second and third generation stands. As National Forest land was logged creating more open and favorable habitat for elk, many large groups of elk remained outside of the park year-round and are now considered to be resident elk. Many of these resident elk remain below 3,000 feet for the entire year, while other migratory elk still move into alpine meadows during summer and retuoptrn to the lower valleys in winter.

In the past, there has been concern about maintaining adequate forage in BWR that could be limiting to population potential for deer and elk. Recently the attention has shifted more to summer range because of several factors that include the management practices of fire suppression coupled with the absence of regeneration harvest that have decreased the amount of early seral habitat in deer and elk summer range

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over the past two decades. Naturally structured early seral forest in the Pacific Northwest is thought to be important for a variety of species, including many ungulates, and has purportedly declined from “historic landscape proportions.” (Swanson 2012, Nyberg and Janz 1990, Toweill et al. 2002).

An analysis of the proportion of various seral stages in the Silver Creek watershed was conducted by forest ecologist, shown in the following figure. Her analysis revealed that the amount of the watershed in the closed, mid-seral structure was much higher than historic levels. These stands are also the majority of the treatment units. In the mid-seral structural stage, the stands provide poor quality elk habitat because they are not providing optimal cover and in general not quality forage either. According to Hudec’s analysis “seral stage A (early seral) is slightly underrepresented (4% vs. historical 5%) in the North Pacific Maritime Mesic-Wet Douglas-fir/Western Hemlock forest type (representing much of the project area) on National Forest land……and, seral stage B, which is the current condition of the stands proposed for treatment, is abundant or overrepresented” (when compared to historic levels on the landscape).

Figure 17. Silver Creek Seral Stages; A=early seral, B=mid-seral closed, C=mid-seral open, D= late seral open, E=late seral closed.

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The westside elk habitat model was used to identify high value habitat in the Silver Creek Thin planning area. Scientists from state, federal, private, and tribal entities have developed new habitat selection models, to be used in conjunction with an elk nutrition model that incorporates updated research for management application in western Oregon and western Washington (Rowland et al, 2013). The models provide managers with contemporary tools to evaluate nutritional and habitat conditions for elk at landscape scales commensurate with all-lands management of the species among diverse partners. The models focus on summer range, because this period is considered most important to elk productivity in this region. Model users cannot only evaluate current nutritional conditions and predicted use by elk but also evaluate effects of land management, such as thinning projects or road closures, on elk.

The model uses a combination of four covariates that consistently explained patterns of elk habitat use based on radio-telemetry data collected over 5 years from three primary study areas:

(1) Elk dietary digestible energy (higher DDE, higher predicted elk use); (2) Distance to roads open to public access (farther from roads, higher use); (3) percent slope (flatter slopes, higher use); and (4) Distance to cover/forage edge (closer to edge, higher use).

The following figure displays the results of the current condition in the watershed. The green areas are high value (highly preferred) versus the orange areas that are low value. The figure shows that the amount of high value elk habitat is minimal in the watershed, and is also not located the area designated as Forest Plan winter range.

Figure 18. Westside Elk Habitat Model for Silver Creek Thin Project Area

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Effects – No Action In the no action alternative, the proposed project would not be implemented and there would be no creation of early seral forage habitat in biological deer, and elk winter range. There would also be No Impacts from the increase in disturbance associated with project implementation and probably no change in the amount of use of the area by recreationists and hunters. There would be no road closures that increase habitat security for deer and elk.

Effects – Proposed Action The 1997 Middle Cowlitz Watershed Analysis identified shortage of cover for big game as an issue in the watershed. At the time of the watershed analysis 52% of the watershed was in a grass/pole structural stage. As almost 20 years has passed, that area is now mostly in a small tree structural condition that does not provide either forage or optimal cover. The proposed project will thin approximately 2,000 acres of young stands that have very high canopy cover to a range of 40 to 60% in the majority of the treatment units. This treatment would improve the stand’s ability to develop into optimal cover by increasing growth rates. Early seral forage openings will be created on 176 acres in the project area that are in biological winter range, which would have a beneficial effect to deer and elk. However, of those 176 acres, 33 acres of optimal cover in winter range would be converted to early seral habitat (in Unit 29) and will no longer provide cover for many decades. The remaining areas of forage openings will be in young stands that do not provide optimal cover so the majority of the created openings will not reduce optimal cover in the project area.

The near term effect of the proposed action will be beneficial because deer and elk benefit when understory production is increased which is expected to occur as a result of the early seral forage openings and thinning treatments. This effect will be short-lived, however, perhaps 10 to 30 years, until canopy cover once again limits understory forage production. The commercial thinning treatments will also accelerate the development of optimal cover conditions in the stands by increasing growth rates and promoting understory development that would improve hiding and thermal cover characteristics.

There will be a short-term increase in disturbance during project implementation activities that will likely cause habitat avoidance during project activities. Therefore, the disturbance effects of the proposed action may impact individual deer and elk. In general, the proposed project would have beneficial impacts to habitat with the creation of the forage openings and a potential increase in forage from commercial thinning. The project would reopen approximately 3.5 miles of currently closed roads that will remain open post-project, but the proposed project would also close and stabilize 10.2 miles of roads that would be a net increase in habitat security.

Cumulative Effects Past harvest activities in Silver Creek have created early-seral forage habitat that is now largely gone as the plantations have grown up and canopies closed. Future timber harvest on National Forest land in the watershed is not likely to include large regeneration units as had been done in the past. The beneficial effects to forage for deer and elk from the proposed project could accumulate to future forage production from gaps created by future projects as well as root-rot pockets and other natural disturbance events such as wind throw.

All of the events that create early-seral conditions on the forested habitat in the Silver Creek drainage only do so for a short period of time because of the rapid rate of forest growth. Large-scale wildfires of the past-created extensive early-seral habitat, but these types of events are not as likely to occur in the future because of active fire suppression.

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Mountain Goat Mountain goats have recently been added to the R6 sensitive species list. They may be present in the Silver Creek project area where suitable habitat is present, such as Whalehead Ridge, but sightings are not common; however, records of mountain goat are found in the NRIS wildlife database near Whalehead Ridge. Suitable habitat consists of steep, rocky escape cover adjacent to open foraging areas and large tree forest used for thermal protection and cover in winter. The project area is not identified as providing mountain goat winter range and may not be important mountain goat habitat compared to other areas on the district.

Effects – No Action Under this alternative, the proposed project would not be implemented and there would be no potential increase in disturbance to mountain goats. Forest stands will continue to develop into better quality optimal cover albeit more slowly without thinning. There would be No Impacts to mountain goats.

Effects – Proposed Action If mountain goats are present during project activities then increased disturbance from the proposed project may result in short-term habitat avoidance. We do not expect any adverse effects to habitat for mountain goats as a result of the proposed project in terms of affecting cover. Thinning will increase growth rates of residual trees thus improving conditions as optimal cover over time. However, since potential habitat occurs in the area the project may impact individual mountain goats from disturbance and would likely have a long-term beneficial impact to cover.

Cumulative Effects There are no cumulative effects to mountain goats that are expected to occur in the reasonably foreseeable future in the project area as a result of planned timber sales. The proposed project will reduce open road density which will somewhat ameliorate the effects of maintaining fairly high road densities in the watershed. Open roads in mountain goat habitat are considered a leading threat to this species.

Snowmobile routes do bisect goat winter range and use of these will continue in the future. Potential disturbance to wintering mountain goats is possible from other winter recreational activities as well.

Neotropical Migratory Birds The Migratory Bird Treaty Act (MBTA) of 1918 implements various treaties and conventions between the U.S., Canada, Japan, Mexico and the former Soviet Union for the protection of migratory birds. Under the act, it is unlawful to pursue, hunt, take, capture (or kill) a migratory bird except as permitted by regulation (16 U.S.C. 703-704). The regulations at 50 CFR 21.11 prohibit the take, possession, import, export, transport, sale, purchase, barter, or offering of these activities, or possessing migratory birds, including nests and eggs, except under a valid permit or as permitted in the implementing regulations (Director's Order No. 131). A migratory bird is any species or family of birds that live, reproduce or migrate within or across international borders at some point during their annual life cycle.

Executive Order 13186 and FWS MOU The U.S. Fish and Wildlife Service (FWS) is the lead federal agency for managing and conserving migratory birds in the United States; however, under Executive Order (EO) 13186 all other federal agencies are charged with the conservation and protection of migratory birds and the habitats on which they depend. This Executive Order directs federal agencies to avoid or minimize the negative impact of their actions on migratory birds, and to take active steps to protect birds and their habitat. In response to this order, the Forest Service has implemented management guidelines that direct migratory birds to be

142 Silver Creek Thin EA January 2017 addressed in the NEPA process when actions have the potential to negatively or positively affect migratory bird species of concern. Executive Order 13186 directs federal agencies to avoid or minimize the negative impact of their actions on migratory birds, and to take active steps to protect birds and their habitat.

This Executive Order also requires federal agencies to develop Memorandum of Understandings (MOU) with the FWS to conserve birds including taking steps to restore and enhance habitat, prevent or abate pollution affecting birds, and incorporate migratory bird conservation into agency planning processes whenever possible. The FS MOU with the FWS covered the period 2008-2013. The Forest Service is currently operating under an extension of the original MOU until the new document is finalized.

The purpose of this MOU is, “to strengthen migratory bird conservation by identifying and implementing strategies that promote conservation and avoid or minimize adverse impacts on migratory birds through enhanced collaboration between the Parties, in coordination with State, Tribal, and local governments.”

Under the MOU, the FS Shall:

Address the conservation of migratory bird habitat and populations when developing, amending, or revising management plans for national forests and grasslands, consistent with NFMA, ESA, and other authorities listed above. When developing the list of species to be considered in the planning process, consult the current (updated every 5 years) FWS Birds of Conservation Concern, 2008 (BCC), State lists, and comprehensive planning efforts for migratory birds. Within the NEPA process, evaluate the effects of agency actions on migratory birds, focusing first on species of management concern along with their priority habitats and key risk factors. To the extent practicable:

a) Evaluate and balance long-term benefits of projects against any short- or long-term adverse effects when analyzing, disclosing, and mitigating the effects of actions.

b) b. Pursue opportunities to restore or enhance the composition, structure, and juxtaposition of migratory bird habitats in the project area.

c) c. Consider approaches, to the extent practicable, for identifying and minimizing take that is incidental to otherwise lawful activities, including such approaches as:

1. altering the season of activities to minimize disturbances during the breeding season;

2. retaining snags for nesting structures where snags are underrepresented;

3. retaining the integrity of breeding sites, especially those with long histories of use and;

4. giving due consideration to key wintering areas, migration routes, and stop-over habitats.

5. minimizing or preventing the pollution or detrimental alteration of the environments utilized by migratory birds whenever practical by assessing information on environmental contaminants and other stressors relevant to migratory bird conservation.

PIF Bird Conservation Regions (BCRs) Bird Conservation Regions (BCRs) are ecologically distinct regions in North America with similar bird communities, habitats, and resource management issues. BCR’s are a hierarchical framework of nested ecological units delineated by the Commission for Environmental Cooperation (CEC). The BCR is approved by the North American Bird Conservation Initiative (NABCI) Committee.

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The overall goal of these BCR lists are to accurately identify the migratory and resident bird species (beyond those already designated as federally threatened or endangered) that represent our highest conservation priorities. BCR lists are updated every five years by the US Fish and Wildlife Service. The proposed Silver Creek Thin project is in BCR 5.

Figure 19. North American Bird Conservation Regions The Birds of Conservation Concern 2008- (updated every 5 years) In December 2008, the U.S. Fish and Wildlife Service released The Birds of Conservation Concern Report (BCC), which identifies species, subspecies, and populations of migratory and resident birds not already, designated as federally threatened or endangered that represent highest conservation priorities and are in need of additional conservation actions.

While the bird species included in BCC 2008 are priorities for conservation action, this list makes no finding with regard to whether they warrant consideration for Endangered Species Act (ESA) listing. The goal is to prevent or remove the need for additional ESA bird listings by implementing proactive management and conservation actions. It is recommended that these lists be consulted in accordance with Executive Order 13186, “Responsibilities of Federal Agencies to Protect Migratory Birds.” In the BLM and FWS MOU, both parties shall: Work collaboratively to identify and address issues that affect species

144 Silver Creek Thin EA January 2017 of concern, such as migratory bird species listed in the Birds of Conservation Concern (BCC) and FWS’s Focal Species initiative. (BLM and FWS MOU, 2012, Section VI, page 4).

This report should also be used to develop research, monitoring, and management initiatives. BCC 2008 is intended to stimulate coordinated and collaborative proactive conservation actions among Federal, State, Tribal, and private partners. The hope is that, by focusing attention on these highest-priority species, this report will promote greater study and protection of the habitats and ecological communities upon which these species depend, thereby contributing to healthy avian populations and communities.

BCR 5 (Northern Pacific Forest U.S. portions only) Yellow-billed Loon (nb) Olive-sided Flycatcher Western Grebe (nb) Willow Flycatcher (c) Laysan Albatross (nb) Horned Lark (strigata ssp.) (a) Black-footed Albatross (nb) Oregon Vesper Sparrow (affinis ssp.) Pink-footed Shearwater (nb) Purple Finch Red-faced Cormorant Pelagic Cormorant (pelagicus ssp.) Bald Eagle (b) Northern Goshawk (laingi ssp.) Peregrine Falcon (b) Black Oystercatcher Solitary Sandpiper (nb) Lesser Yellowlegs (nb) Whimbrel (nb) Long-billed Curlew (nb) Hudsonian Godwit (nb) Marbled Godwit (nb) Red Knot (roselaari ssp.) (nb) Short-billed Dowitcher (nb) Aleutian Tern Caspian Tern Arctic Tern Marbled Murrelet (c) Kittlitz's Murrelet (a) Black Swift Rufous Hummingbird Allen's Hummingbird

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(a) ESA candidate, (b) ESA delisted, (c) non-listed subspecies or population of Tor E species, (d) MBTA protection uncertain or lacking, and (nb) non-breeding in this BCR.

The project area occurs in the Northern Pacific Forest BCR region. Birds of conservation concern that may occur in the Silver Creek Thin project planning area include the peregrine falcon and bald eagle (addressed in the sensitive species section), the marbled murrelet (addressed in the T&E section) and the northern goshawk. They also include olive-sided flycatcher and rufous hummingbird.

Northern goshawks are known to occur in the planning area and an active nest was found in one of the proposed units in 2014. In 2015, this nest was field checked and found not to be active. Should the nest be active during timber harvest operations timing restrictions that cover the nesting period will be imposed to prevent nest failure.

A conservation strategy for land birds in coniferous forests in western Oregon and Washington was prepared by Bob Altman of American Bird Conservancy for the Oregon-Washington Partners in Flight (PIF) (Altman and Alexander 2008). The strategy is designed to achieve functioning ecosystems for land birds by addressing the habitat requirements of 20 focal species. Recent PIF Conservation Plans identify species of importance by Avifaunal Biome Regions. The Silver Thin project area is located in the Pacific Biome Region (Rich et at, 2004)). The PIF Conservation Plan states that, among other problems, the main conservation issues for birds in this region are related to effects of forest management (e.g., timber harvest, fire suppression), and loss of wetlands and riparian woodlands. Conservation concerns for a few of the focal species are discussed below.

Vaux’s swifts are associated with late successional conifer and mixed conifer/deciduous forests (Bull & Collins, 1993). They have been shown to be more common in old growth than in younger stands but they will nest in snags in burned or logged forests. Declines in population for this species are thought to be partly a response to the reduction of old growth forest. The conservation focus for this species is large snags. They nest and roost in large-diameter, hollow trees that are alive or dead and in woodpecker excavated cavities in heartwood fungus-infected live conifers (especially those excavated by pileated woodpeckers) that are usually in >70% canopy closure stands. Vaux’s swifts feed on aerial insects such as moths and flies.

Brown creepers are yearlong inhabitants of montane conifer and mixed deciduous/conifer forests and can be considered as a forest-interior nesting species (Dobkins, 1994). Thus, this species may be sensitive to forest fragmentation. The PIF conservation focus for this species is large trees. This species has been shown to be significantly more abundant in old growth forest and the reduction of large trees across the landscape may be a reason for the extensive decline in population. They nest beneath loose bark on conifers, less frequently on deciduous trees. Brown creepers are gleaners of insects, spiders and other invertebrates with a preference for large Douglas-fir as foraging substrates. They also feed on flying insects and infrequently on nuts and berries.

Olive-sided flycatchers are summer residents of montane and riparian coniferous forest, especially burned areas with abundant standing snags (Dobkin, 1994). They usually nest in conifers and feed almost exclusively on aerial insects. They have decreased in abundance in the West, possibly because of forest fire suppression, but also possibly because of loss of wintering habitat in Central America. The PIF conservation focus for this species is edges and openings created by wildfire.

Varied thrush are associated with mesic mixed conifer forests. They are omnivorous understory gleaners and often forage in loose debris on the forest floor. The PIF conservation focus for this species is structurally diverse, multi-layered forest. The conservation strategy recommends blocks of late successional forest with >60% canopy closure.

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Effects - No Action Under the no action alternative, the project would not be implemented and conifer canopy cover would remain the same as the current condition in the proposed stands, and as the process of forest succession progresses would increase in some stands and possibly decrease in others as a function of density dependent mortality. No thinning would occur that could potentially increase habitat diversity and accelerate growth rates thus there would be no long-term benefit to bird species that are associated with late-successional forests. No benefits would accrue to species associated with early seral habitat.

Effects - Proposed Action The Silver Creek Thin units are in mid-seral structural stage and most of the units have very simplified understories that generally lack a diverse shrub layer or deciduous understory trees necessary for many bird species. As the objective of thinning is to accelerate tree growth rates and promote the development of late successional structure, thinning will eventually benefit late-seral species such as pileated woodpeckers.

In general, the stands to be treated do not currently have large snags or residual large trees so the effects to species that require these as habitat, such as Vaux’s swift and brown creeper, will be minimal (see cavity excavator and pileated woodpecker effects section). Existing snags will be protected in skips; just as existing large live legacy trees will be retained. Species that require high canopy cover, such as the hermit warbler, may be adversely affected by the thinning treatments that reduce canopy volume; however, this is a relatively short-term effect. Species associated with mid-seral forest may be using the treatment units for nesting habitat and could be adversely affected by the harvest activities where these coincide with the nesting period; however, some of the proposed treatment units have NSO early nesting season timing restrictions that will serve to limit disturbance to nesting bird species in those units. Consequently, since not all of the project area is covered under the NSO early nesting season LOP, the proposed action “may impact individuals or habitat but will not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.” The proposed treatment will reduce canopy cover for a few decades until high canopy cover develops and eventually the stands mature into late successional forest.

Species associated with early-seral habitat are unlikely to be using habitat in the treatment units and are not expected to be adversely affected by the harvest operations. The creation of approximately 176 acres of forage openings will benefit species associated with early seral habitat, such as orange-crowned warbler.

Cumulative Effects The effects of the proposed action will be cumulative to the effects of several other on-going and planned for the near future vegetation management projects on the district that include North Fork Thin, Woods Cr. Stewardship, Packwood Thin, Upper Cispus Thin, Kirk Thin, among others. Most of these projects are thins and will result in moderate and eventually high canopy closure, thus benefiting species that require mid-to late-seral structure. Species that require early-seral structure will in general not benefit from these treatments because no regeneration harvest units are planned, with the exception of the forage openings created in some of the North Fork sales.

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Hydrology and Water Quality

Resource Indicators and Measures Table 31. Summary of Hydrology and Water Quality Indicators and Measures for Analysis

Used to address Purpose & Need Resource Element Resource Indicator Measure Source Or Key Issue Road network mi2 Yes Aquatic Conservation drainage connection Peak Flow Strategy Objectives

Percent change (ACSO) Thinned unit (canopy) Yes Distance (ft) of primary shade to LRMP, ACSO, Forest- Summer Stream Primary Shade perennial stream Yes wide Management Temperature (fish and non-fish Direction bearing) Exposed Surface Area of Skid Trails BMP, Standards and Sediment Regime and Landings that mi^2 or acres Yes Guidelines, ACSO could contribute to sediment delivery Change in Opened canopy in percent Canopy thinned stands within Cover or Shade LRMP, Standards and Microclimate Yes one site potential tree over Riparian Guidelines height stream post harvest

Methods

Peak Flow

Peak flow changes due to drainage road network extension: Peak flow analysis used Wemple’s stream channel network extension method described by Wemple et al. (1996) to determine potential change in flowpaths. Wemple et al. proposed that roads modify drainage density by extending the total length of effective surface flow by including roads as part of the stream channel network thereby affecting the timing of stream flow. This stream channel network extension can be estimated by adding the length of road segments discharging runoff directly to stream channels, and by adding the length of newly eroded gullies located on hillslopes where channels did not previously exist. Formulae are detailed in the Hydrology specialist report.

Proximity to streams plays a large role on the roads’ stream network contribution (McCune, 2010). Roads act as new flowpaths for water in a watershed by increasing the overall drainage density (Furniss et al, 2000). High-density road networks are more likely to affect hydrological parameters than low density ones (Lugo et al, 2000). Road cut-banks also intercept water from overland surface flows into drain ditches helping to speed up the transport of water into stream channels. These interception processes effectively increase the overall drainage density (Wemple et al., 1996; WFPB 1997). Cross drain or ditch, relief surveys in the watershed of Silver Creek were sometimes found to be “stream connected” due to the close proximity to nearby intermittent or perennial stream channels.

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Wemple et al provided a process to determine peak flows based on the amount of network drainage connectivity (drainage density) in a watershed. Surface runoff from road surfaces and drainage ditches along the side of roads also help transport water to streams much faster which can cause an increase in peak flows in less time. High road density values usually have high stream crossing density values and are indicators on the increased risk for excessive sediment contribution into nearby streams.

This GIS road network analysis did not include decommissioned roads since they are considered to be recovering and are removed from drainage network to streams. Road crossings counted and were determined either to be a perennial or intermittent stream crossings. Other crossings such as cross drains were sometimes included in the count for this exercise if a channel has formed and is connected to a nearby stream.

Peak flow due to amount of canopy cover: Aggregate Recovery Percentage (ARP) is a measure of change on hydrologic recovery. ARP method assumes that the greatest likelihood for causing some long-term cumulative effects on forest hydrologic processes is through the influence of vegetation change on peak flows during rain-on-snow events within the transient snow zone (1,500 to 3,500 feet) (USDA, 2003). It is an index of a watershed’s degree of hydrologic impairment from past clear-cut timber harvesting when excessive vegetation removal contributed to increased peak flows that may have adversely affected stream channel habitat conditions. The ARP model compares the amount of an analysis area within the transient snow zone that is recovered against a threshold value (midpoint value). The procedure is based on the assumption that stands below “hydrologic maturity” (lacking an average DBH>8” and canopy closure at 60% or greater) allow for faster snow melt during rain on snow events and if enough stands within any one drainage area are disturbed at the same time, higher peak flows would occur. Increased melting can increase the magnitude or frequency of peak flows, which can cause a change in pool frequency and quality, erode banks, widen stream channels and leave behind shallower channels. An ARP value that falls below 60 percent over a larger area of subwatershed indicates the need for a more intensive analysis and field review if a proposed activity will further reduce the hydrologic recovery of the area. A stand is considered 100% hydrologically recovered once it reaches an average DBH of 8 inches with canopy closure of at least 70%.

Areas thinned to a canopy closure of less than 40 percent are considered hydrologically immature and therefore would potentially contribute to increased runoff at the stand scale, and may contribute to increased peak flows at various drainage scales. Thinned canopy closure would become more reflective of open conditions rather than mature forest conditions. The degree to which these stand scale changes are manifested as changes in stream flow at various drainage scales is dependent upon a number of factors related to both the extent and intensity of changes to forested conditions, and characteristics of the drainage and subwatershed. Grant et al, (2008) found peak flow increases from changes to hydrologic maturity diminishes as drainage size increases, and detection of peak flow increases was limited to peak flows of moderate frequency and magnitude with a return period of six years or less (Grant, et al, 2008).

The reference point of 40% canopy cover was established from the collective professional judgment of hydrologists on the Gifford Pinchot National Forest in order to evaluate proposed thinning projects in absence of research findings. Snow accumulations on the ground are expected to increase as a result of decreased interception in the forest canopy in stands thinned to less than 40% canopy closure. Snowmelt may become more rapid with snowpack facing greater exposure to wind and other elements that cause snowmelt, and the removal of some portion of the stand would tend to cause increased soil moisture levels as a result of lower evapotranspiration. Changes in snow accumulation and snowmelt occur spatially with incremental changes in a number of process components. These conditions would occur in a thinned stand until the canopy closure redevelop.

149 Cowlitz Valley Ranger District

Using the National Marine Fisheries Service Pathways Criteria ARP values of 70% or less on a subwatershed (6th field HUC) scale represent an elevated risk of increased peak flows, values of 70 – 80% represent a moderate risk of increased peak flows and values of greater than 80% represent only minor changes to watershed hydrology, and a value of 95% or greater is considered relatively undisturbed. Indicator criteria is used to determine if pathway is Properly Functioning, Functioning at Risk or Not Properly Functioning as defined by the National Marine Fisheries Service’s Pathways and Indicators Criteria for Threatened and Endangered Species.

In watershed studies in the western states showed that overall thinning less than 40 percent of a watershed is unlikely to cause a detectable change in the size of peak flows in rain dominated areas and would result in only a 14 percent increase in the size of peak flows in the transient snow zone (Elliot, et al, 2010).

Summer Stream Temperature Summer stream temperature is approximated based upon change in the primary shade zone area of (minimum) 60 feet on each side of a stream channel that is 20 feet wide or less. Studies have shown that maximum shading ability is reached within a width of 80 feet and that 90% of that maximum is reached within 55 feet (USDA Forest Service and BLM, 2010). Once effective shade decreases below 80% (220 Basal Area) it will begin to have an effect on increasing water temperature (USDA Forest Service and BLM, 2010).

Sediment Regime Change in sediment is measured from pre-harvest to post-harvest on exposed surface area on haul routes, landings, skid trails and temporary roads in order to determine the potential detrimental effect and the potential for sediment delivery to stream. Post-harvest change includes system roads recommended for close and stabilize which will affect total exposed surface area.

Haul routes, skid trails, temporary roads, landings in units are recognized sources of direct pathways and are contributors of sediment to streams in many forested ecosystems (Bilby et al., 1989, Wemple et al., 1996). Numerous studies have shown that roads contribute sediment to streams, (McCune, 2010). The creation of skid trails, construction of landings and temporary roads, and the use of haul routes have the biggest potential to create erosion and sediment transport into nearby water bodies (Bilby et al, 1989).

“No Harvest” buffer widths also have bearing on post-harvest effects from exposed surface areas in connection to roads or skid trails. Lakell III, 2010 studied three different buffer zones (7.6, 15.2, and 30.4 meters) and found that 97% of management related erosion in a watershed can be trapped on-site within the harvest area before reaching the stream. A 10 meter wide (33 feet) buffer zone can reduce the delivery of sediment from skid trails to streams by 95% (Lacey, 2000). Harvested clearcut units that generated rills or sediment plumes had limited penetration into adjacent buffer zones but erosion features from skid trails showed greater potential to connect to a stream (Litschert, et al, 2009). Also, in Rashin Edward B. et al. indicated that a 10-meter setback for ground disturbance can be expected to prevent sediment delivery to stream from about 95% of harvest related erosion features. Incorporating appropriate ‘“No Harvest”’ buffer widths around riparian areas in a harvesting unit will ensure transported sediments filter out onto the forest floor and limit the movements of sediment from reaching nearby water bodies.

Microclimate Microclimate is measured as the change in canopy cover from pre-harvest to post-harvest canopy cover outside of the no-harvest buffers within the interim riparian reserve, e.g. commercial thinning in managed stands within the one potential tree height. This includes early seral successional stage creation utilizing light forest retention techniques for wildlife winter forage.

150 Silver Creek Thin EA January 2017

Streams in riparian reserves influence air temperature and humidity and create microclimate gradients extending laterally from streams (Olsen, et al. 2007). Strongest stream effects on air temperature and relative humidity have been observed within 10 to 15 m of the stream channel (Rykken et al., 2007). Narrow buffers can be effective in maintaining stream center microclimate conditions and therefore the steep near-stream microclimate gradients that may extend 10-20 m from streams in intact stands (Anderson et al., 2007). Rykken also suggested that microclimate gradient was similar within a no harvest area to that of a riparian buffer adjacent to a clear cut.

Unavailable Information We were not able to obtain logging history or additional hydrology resource information outside (west) of the Gifford Pinchot National Forest boundary, which makes up 31% of the 33,007 acres Silver Creek subwatershed and therefore that area is excluded from this analysis.

Existing Condition

Hydrologic Background and Description During the summer of 2014, field surveys inside the candidate harvest units identified and verified existing and non-mapped perennial and intermittent stream channels and wetlands.

Approximately 0.5 mile of fish bearing perennial streams (Class 2 stream), 8.95 miles of non-fish bearing perennial streams (Class 3 stream) and 27.9 miles of intermittent channels (Class 4 stream) were surveyed in Silver Creek Thin candidate treatment stands, for a total of approximately 33,007 acres, or 51.57 square miles. Major fish bearing perennial streams are Silver Creek, Lynx Creek, and Lake Creek. All three streams have fish barriers preventing fish from reaching the upper headwaters. The fish-bearing portion of Lynx Creek starts from the confluence of Silver Creek to several miles upstream. The first few hundred feet of Lynx Creek from the confluence of Silver Creek lie within the Gifford Pinchot National Forest while the remaining several miles of stream lies outside of the Forest Service boundary. Numerous unnamed perennial and intermittent stream reaches exist throughout the Silver Creek subwatershed. Many identified stream channels were verified and corresponded correctly with the GIS stream channel database while a few stream channels were newly identified and subsequently added to the GIS stream layer.

Table 32. Summary of Hydrologic Indicators and Existing Condition

Current Existing Measure Resource Element Resource Indicator Condition (Quantify if (No Action) possible) 6.35 mi/mi2 Road network Miles per square drainage connection mile Peak Flow Canopy unchanged with ARP ARP Percentage 64 to 92% canopy cover Shade zone Affected Primary Distance (ft) of Summer Stream area currently Shade Zone Area shade zone Temp covers more (60ft) affected than 60 ft. Exposed Surface Only current Area of Skid Trails, system roads in Sediment Regime Landings, Temporary Mile² or acres use. No change Roads and Haul on sediment Routes that could regime.

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contribute to sediment delivery Percentage of Thinned stands within stands thinned No thinning. one site potential tree Microclimate within 180ft of Microclimate height width (180ft ) stream by unchanged from stream harvest units

Silver Creek subwatershed is not within a designated Key watershed under the NWFP. The project area boundary is entirely within the Silver Creek subwatershed with the exception of a small portion of one harvest unit on the East end of the Silver Creek subwatershed overlapping onto the Willame Creek subwatershed (Figure 19). Approximately 69% (35.6 mi2) of Silver Creek subwatershed is located on the Gifford Pinchot National Forest while the remaining 31% (15.5 mi2) of the subwatershed reside on private and state lands to the west of the Forest Service boundary. Elevation ranges from 1500 feet at unit #38 near the 75 road to 4500 ft. at stand unit #2 near the 8511 road to the north part of the project boundary. Silver Creek is tributary to the Cowlitz River. Majority of harvest units fall within the transient snow zone (1,500 to 3,500 feet) except for six harvest units located above 3,500 feet (units #1, 2, 4, 5, 33, and 35) in the northwest area of the project area.

There are three identified 303(d) listed stream segments for water temperature: Silver Creek (lower portion before Cowlitz River), Lake Creek (small segment up to the confluence with Silver Creek), and Lynx Creek (from confluence with Silver Creek to upstream outside Forest Service boundary, approximately 8,000 ft. stream segment with most of it outside the boundary).

Approximately 263 miles of open roads exist within the 51.5 mi2 (33,007 acres) of Silver Creek subwatershed (HUC 170800040505 – 6th field) includes the Gifford Pinchot National Forest (GPNF), state and private lands. Total length of Forest Service roads (Management Level - ML 1 and 2 roads) is 133 miles, with approximately 5.1 miles of those roads outside of the GPNF boundary. Only ML1 (41 miles) and ML 2 (92 miles) roads exist within the subwatershed. Current road density in the Silver Creek subwatershed on National Forest land is 3.73 mi/mi2. Road density values greater than 3 mi/mi2 are “Not Properly Functioning” according to the National Marine Fisheries Service’s Pathways and Indicators Criteria for Threatened and Endangered Species. Road density is 8.4 mi/mi2 on non-Forest Service lands within the Silver Creek subwatershed. Road density for the entire Silver Creek subwatershed is 5.1 mi/mi2. Current use and future disposition of roads on the non-Forest Service side is unknown.

There are approximately 679 stream crossings in the Silver Creek subwatershed on Forest Service land. Crossing are counted are over ephemeral, intermittent, and perennial stream channels. Average distance between culverts (cross drains and stream channel culverts) is approximately 480 feet.

Stands in riparian reserves are typically undersized and lack late successional characteristics due in part to historic stand-replacement fires and past timber management activities (e.g. clear-cut logging) up to the stream’s edge. Dense pole and small tree structural stages with slow tree growth and little existing potential for large woody debris recruitment were found in Riparian Reserves of Lake Creek, Lynx Creek and Willie Creek drainages (Middle Cowlitz Watershed Analysis, p. 4-9).

152 Silver Creek Thin EA January 2017

Figure 20. Catchments within the Silver Creek subwatershed. Labels correspond Managementto labels on ARP Direction map in Middle Cowlitz Watershed Analysis (1997).

Desired Future Condition Desired Future Conditions of riparian health, water quality and water quantity for the subwatersheds identified in this project are outlined in the Gifford Pinchot National Forest Land and Resource Management Plan (USDA, 1990 “Forest Plan”) as amended. All management activities will meet Forest Service Region 6 Streamside Management Goals (FSM 2520, R6 Supplement 2500-90-1, 8/1/90) to help protect or enhance water quality, fish, riparian vegetation, and other aquatic resources. Standards and

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Guidelines from the Northwest Forest Plan for Riparian Reserves require that management activities in reserves do not retard or prevent attainment of the Aquatic Conservation Strategy objectives.

The Desired Future Condition (DFC) relates to the goal of restoring biological and physical conditions such as riparian-dependent resources for improved watershed health. This includes the closing and stabilizing roads following harvest activities to enhance riparian connectivity and wildlife habitat security. The goal of the Aquatic Conservation Strategy Objectives is to “maintain and restore ecosystem health at watershed and landscape scales to protect habitat for fish and other riparian-dependent species and resources and restore currently degraded habitats.” A goal that also ensure that our national forests are conserved, restored, and made more resilient to climate change, while enhancing our water resources.

Effects

No Action

Peak Flow

Stream Drainage Network Stream drainage network will remain unchanged with no new road construction and no closure and stabilization of system roads. Peak flow will not be influenced by changes in the stream drainage network from the No Action Alternative.

ARP Existing ARP will continue to improve at an approximate rate of 1-2% per five-year period with increasing numbers of stands in a condition of hydrologic recovery (Trees with 8” DBH and stand canopy closure of greater than 60%) in the Silver Creek catchments. The potential of increased peak flows from the lack of hydrologically recovered stands within four catchments (2E, 2F, 2G, and 2H) continues in the No Action Alternative. Certain stream reaches have poor habitat complexity, limited sediment storage and bank instability, which may in part be an effect of increased peak flows along with lack of large instream wood from previous stream cleanouts.

Summer Stream Temperature We can expect stream temperature will continue to remain relatively unchanged and may fluctuate over time in response to large-scale changes to watershed conditions, catastrophic events and climate change. Existing impaired 303(d) streams in Silver Creek, Lynx Creek and Lake Creek are expected to follow similar temperature pattern as previous years with some but not all years exceeding the state water temperature standards of an average 7-Day maximum of 16oC. Generally, continued growth of trees along streams will provide the necessary streamside shading and reduce any large swings on diurnal fluctuation.

Sediment Regime

Exposed Surface Area Typical road-related flood damages and other erosional and aggradation processes that may affect future aquatic and water quality concerns:

• Stream channel aggradation associated with upslope and side channel failures • Mass failures of hillslope and/or cutbanks into stream channels • Excessive fluvial erosion of hillslopes, cutbanks, or road surface

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• Road crossing failure at stream crossings • Stream diversion at stream crossings • Fish passage blockage at stream crossings Road surface conditions vary from recently closed roads that are very similar to Level 2 roads conditions used by the public, to road surfaces that have already begun to revegetate with plant growth (e.g. moss, grasses, shrubs, trees) and accumulated biomass (e.g. fallen woody debris, leaf litter, duff). The increased biomass accumulation on Level 1 roads over time reduces the road’s ability to transport concentrated water and sediment to nearby stream channels. The amount of sediment concentration during runoff events on a closed road where plants and increased duff layer were already beginning to occur was found to be a magnitude lower than from Level 2 open roads (Foltz et al, 2009). Many of the Level 1 road surfaces are considered to be undergoing hydrological recovery. Existing road network for Level 2 roads contribute sand-size and smaller sediment during runoff events. Larger runoff events will help transport larger sediment size rocks such as pebble and gravel. Use of mitigation measures across the forest such as water bars, ditch maintenance, culvert cleaning, out-sloping of roads and broad base road dips to help keep sediment delivery localized and minimized. Erosion is expected to continue at the same rate in various parts of the subwatersheds from landslides, surface erosion, fillslope, and cutslope road failures with the No Action alternative.

Microclimate

Thinned stands within one site potential tree height width (180 ft.) from stream Microclimate (air and soil temperatures, moisture, and humidity) is to remain largely unchanged while stand development continues to grow providing slowly increased canopy structure, and undergrowth of vegetation.

Proposed Action Possible effects from ground disturbing activities are increased risk of displaced/disturbed soils entering streams from the use of landings, temporary road construction activities, and active use of haul routes and to a lesser extent logging operations within units. Likely effects will be localized erosion within the units and sediment movement from roads and landings. Most sediment mobilized from the logging operations within the units is expected to filter out in the No Harvest areas between the activity area and any stream course or waterbody. Sediment produced from the roads and landings may be delivered in minor amounts to nearby adjacent streams during appreciable rainfall events.

Table 33. Silver Creek Thin Project Effects to Hydrologic Indicators Resource Resource Indicator No Action Effect Proposed Action Effect Element Peak Flow Road network 6.35 mi/mi2 Slight decrease in stream drainage drainage connection network to 6.7 mi/mi2 During harvest activity, road density in Silver Creek subwatershed will temporarily go up slightly with 7.41 miles of temporary road creation to help access some of the harvest units. Post-harvest sale will see a reduction of 7.41 miles temporary roads, 7.43 miles on the removal of existing non-system roads. 15.22

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Resource Resource Indicator No Action Effect Proposed Action Effect Element miles of close and stabilize system roads out of 133 miles of system road. Close and stabilize system roads will reduce the overall network drainage density from 6.9 to 6.7 mi/mi2 Peak Flow Aggregate Recovery Canopy unchanged with Approximately 2.5% (176 ac) of the Percentage 64 to 92% canopy cover 7063 acres in catchment 2J for wildlife openings with canopy cover of 10 to 15%. Approximately 21% (1,486 ac) of the 7063 acres in catchment 2J with canopy cover from 40 to 60%. Catchment 2J (7063 ac) current, pre-harvest ARPs at 75 to 79% will see slight downward adjustment on ARP value and should remain within the mid-70s rating. Remaining 517 acres with canopy cover from 40 to 60% in other catchments. Overall ARP values in Catchments 2E, 2G, 2H, 2K and 2T will see little or no downward adjustment Summer Stream Primary Shade Zone Shade zone area Primary shade zone remains Temp currently covers more unaffected. 60 ft. shade zone area than 60 ft. would be untouched by thinning and early seral openings. Sediment Regime Exposed Surface Area Only current system Increased temporary change of of Skid Trails, roads in use. No change additional exposed surface area. Landings, Temporary on sediment regime. Exposed surface area reduced (15.2 Roads and Haul miles for close and stabilize system Routes that could roads and 7.4 miles closing existing contribute to sediment temp roads) post-harvest treatment. delivery Effects will be limited over short distances downstream. Any sediment delivered will be diluted as it moves down through the subwatershed to the point that it is indistinguishable from background levels. Microclimate Thinned stands within No thinning. Microclimate Influence to microclimate in outer one site potential tree unchanged in perennial riparian reserves limited to height width (180ft ) and intermittent streams intermittent and perennial, non-fish- from stream bearing streams from upslope thinning. Affect is limited and short- term. Potential but minor short-term change to microclimate due to young stand (thinning. Minimal change in overall canopy cover. 1 Canopy opening of 10 to 15% for wildlife openings for a total of 51 acres. Canopy percentages between 45 to 60% for most harvest units.

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Peak Flows

Stream Drainage Network Post-harvest stream drainage network will see a slight downward change from 6.9 mi/mi2 to 6.7 mi/mi2with no new road construction and limited closure and stabilization of system roads (approximately 15.2 miles) including the removal of culverts, which will reduce stream network connections. Pre and post road density for the Silver Creek subwatershed will change from 5.1 mi/mi2 to 4.9 mi/mi2. No roads will be decommissioned. The magnitude and timing of peak flow are somewhat improved.

Aggregate Recovery Percentage Among the 2,179 acres of harvestable area in proposed harvest units make up 6.6% of the entire Silver Creek subwatershed. Majority of proposed harvesting units (~85%) take place in catchment areas with current maximum ARP values much greater than 60%. ARP values greater than 60% indicates a catchment where most stands have sufficient structure (8” dbh and greater than 70% canopy cover) to not change snowmelt and runoff rates.

ARP value below 70 percent indicate the process of snow melts and runoff have been affected in enough area to create a risk of increased peak flows in the streams. A more intensive analysis and field review (Level II analysis) is needed if it is anticipated the proposed activity will further reduce the hydrologic recovery of the area. However, in this project area, the greatest change to the catchment ARPs is 1,303 acres within Catchment 2J (Table 35) with 176 acres converted to an early seral stage to enhance winter wildlife forage openings. Forage openings will produce a 10 to 15% canopy opening in several harvest units. All of the proposed wildlife forage openings are in Catchment 2J representing 2.5% of the area. The conversion of 1,303 acres, which includes the 176 acres of forage openings in Catchment 2J, is 18.4 percent of the total area of the catchment. Majority of the thinned units will reduce the canopy cover to less than 50 to 60% with a few units down to 40 to 45% (56 acres worth) along with 176 acres of wildlife forage openings will have canopy openings down to 10 to 15%. Changes in canopy openings are not considered to be great enough detectable change to affect peak flows for Silver Creek.

Peak flow increases generally approach the 10-percent detection limit (minimum detectable change in flow) at recurrence intervals less than 6 years. (Grant, et al, 2008). Using the graph on “Peak flow response to harvest in the transient snow hydrologic zone” on page 35 in Grant’s paper using the Mean reported change line shows it to fall well under the 10% detection limit threshold due to the overall harvested area accounting 6.6% of Silver Creek subwatershed. Post-harvest treatments in the Silver Creek subwatershed should not measurably affect peak flows to the degree detectable.

Clearcuts or harvest treatments going below 40% canopy cover have an increased risk on greater peak flow. Wildlife opening of 176 acres in Catchment 2J will have a resultant canopy cover of 10 to 15%. Wildlife opening constitutes 2.5% of the area in Catchment 2J. It is the only harvest treatment area that will go below 40%. Post-harvest ARP values will see a slight downward change within the range of mid- 70s due to the small percentage of the area affected by clearcuts (wildlife opening with 10 to 15% canopy cover). All other harvest units (517 acres) in in Catchments 2E, 2G, 2H, 2K and 2T will see little or no downward adjustments on post-treatment ARP values. All pre-commercial thins (583 acres) in 19 different harvest units will not reduce canopy cover to less than 40% and will not also change current ARP values (Table below).

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Table 34. ARP Values in Silver Creek Subwatershed by Catchment ID

Acres of Percent of 1996 Current Harvest Harvestable Percent of harvestable ARP** ARP Units by areas Total area to Value by Value Catchment Catchment Catchment outside of Harvestable catchment Catchment for 2015 ID Area (ac) ID buffers (ac) Areas (%) area ID (%) (%) 2E 3877.7 128 62 2.85 1.6 38 42 - 46

2F 2484.9 0 0 0 0.0 21 25 - 29 2G 4543.9 9 9 0.41 0.2 32 36 - 40 2H 3683 367 267 12.25 7.2 34 38 - 42 2J 7062.7 2074 1303 59.8 18.4 71 75 - 79 2K* 7404.6 399 249 11.43 3.4 59 63-67 2M 2121 3 3 0.14 0.1 90 >94 2T 1829.2 512 286 13.13 15.6 66 70 - 74 Total 33007 3478 2,179 100 6.6 *Approximately 9 acres of harvest unit 1453 lies on the Willame Creek subwatershed (13,463 acres)

Summer Stream Temperatures Existing impaired 303(d) streams in Silver Creek, Lynx Creek and Lake Creek are expected to follow similar temperature patterns to previous years with some but not all years exceeding the state water temperature standards of an average 7-Day maximum of 16oC. Generally, continued growth of trees along streams will provide the necessary streamside shading and reduce any large stream temperature swings. Harvested areas will not impact primary shade zone and will remain outside of the 60 feet minimum for shade zone protection area.

Sediment Regime In the proposed action, several types of road-related activities and constructions have the potential to produce sediment delivery into nearby water bodies. These actions include log haul along main routes, road maintenance and reconstruction, new temporary road construction, open old temporary roads, temporary landing construction, use of skid trails in ground-based units, and culvert upgrades for road reconstruction and restoration activities.

Construction of temporary roads, landings and skid trails will generate more exposed surface areas during the harvesting interim. The construction of 7.4 miles of new temporary roads to allow easier access to certain areas in harvest units will see temporary sediment delivery in localized areas. Up to 855 temporary spots have been selected to be used as ground, helicopter or skyline landings located outside of riparian reserves, wetlands, unstable slopes and identified geohazard areas as required mitigation measures. National Forest system and non-system roads currently occupy between 0 to approximately 15 percent of any units which includes verified remnant logging roads and landings, non-field verified estimates of temporary roads, and system roads. Non-system roads alone range from zero to approximately 13.7 percent of the units. For calculating acres of roads, National Forest System roads were assumed to be an average of 6 meters (20 feet) wide based on field observations. Ground-based logging landings were assumed to be one-quarter acre in area, helicopter landings one acre, and skyline logging landings were one eighth of an acre. Approximate extent of new detrimental soil conditions is depicted in the Soil Resource report.

158 Silver Creek Thin EA January 2017

Approximately 2.5 miles of Level 1 roads and 4.5 miles of Level 2 roads pass through the Riparian Reserves of intermittent and perennial streams within harvest units. Majority of road areas in Riparian reserves are from road crossings with few roads that run parallel to a stream channel. These segments are: FR 4778043 - 0.6 mile of road sections along Willie Creek; FR 8522 – 0.43 mile of road sections along Silver Creek and an unknown intermittent tributary to Silver Creek, and FR 4778 – 0.7 mile of road sections along Silver Creek.

A road segment that connects to a culvert is “stream connected” which increases the effective drainage length. Stream connected roads are at risk of discharging sediment directly into a stream channel during precipitation events. The effective drainage length found on proposed transportation routes averages 480 feet in the Silver Thin project area. With approximately 291 crossings along proposed transportation routes and some existing temporary roads multiplied by an average road width of 20 feet and by the effective drainage length (480 feet in length) approximates an equivalent of 64 acres of exposed surface areas as potential source for sediment delivery to streams. Approximately 185 crossings on proposed transportation routes are within the Silver Creek subwatershed, and 106 crossings spread out within five subwatersheds, Big Creek subwatershed Kiona Creek subwatershed Davis Creek-Cowlitz River subwatershed Willame Creek and Skate Creek subwatersheds

Level 1 and 2 roads will be used as haul routes while the main arterial routes are the 47, 63, 75 and 85 Forest Roads. Level 1 (administratively closed) and Level 2 system roads will be reconstructed to ensure proper road conditions for haul. Prior to thinning operations existing system roads (haul routes) are to be brought up to standards for hauling activities. This includes all system roads ( Level 1 roads 14.51 miles, Level 2 roads 64.15 miles), and temporary roads (0.43 mile). This also includes reclamation of asphalt (mileposts 0 to 6.5 on Forest Road 8500000; mileposts 18.59 to 21.10) on Forest Road 5200000 and from mileposts 0-3, and 10.3 to 17.1 on Forest Road 4700000.

A temporary increase in sediment delivery during appreciable rainfall events will occur from road construction activities, including the replacement or additions of culverts. To minimize impact from sediment delivery and erosion all reconstruction activities will take place during the dry season only, and will follow all specifications stated in the Memorandum of Understanding between Washington Department of Fish and Wildlife and USDA-Forest Service Region 6 (WDFW, USDA 2005).

Sloped roads containing surface aggregates or native surface, roads adjacent to steep side-slope (fill slope) and roads that cross streams or are in close proximity to streams contribute sediment delivery into nearby stream channels. Sediment delivery will pulse during high flow events during and between rainfall events. There may be some localized sediment deposition and/or turbidity on the bigger streams during and after culvert replacements, which could temporarily affect aquatic life. Sediment delivered will become diluted as it is distributed downstream and no longer detectable against background levels.

The timing and seasonal use (e.g. dry or very low wet periods) of haul routes for this project will be an important factor, as well as implementation of Project Design Criteria and Mitigation Measures to help limit the amount sediment delivered into surrounding stream systems. Wet season haul will require functional stream road crossings, rocked roads, and ditch flow relief onto the forest floor. Many roads are outsloped or crowned allowing some of the surface water to disperse over to the side of the road onto the vegetated forest floor and/or into road diches that connect to a culvert or cross drain.

As part of the ongoing restoration effort on the Gifford Pinchot National Forest, upgrading of culverts at stream crossings will help improve fish passage and reduce risk of culvert failure during storm events thus preventing any mass sediment and debris pulse downstream.

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Microclimate Proper microclimate is a crucial part of riparian reserves function on maintaining moisture and temperature. With minimum buffer widths of 45 to 75 feet, air temperatures within 30 feet of streams have shown to be little affected by upslope thinning (Mazza, 2009). Other studies suggest of 45 m (150 ft.) on each side of stream with 70 to 80% overstory coverage (predominately Douglas-fir and western hemlock to help maintain a natural riparian microclimate environment along the streams adjacent to clear cuts in areas of moderate to steep slopes (Brosofske, et al, 1997). No Harvest buffer widths in the proposed action range from 60 feet to 300 feet for depending on water body type.

Short-term effects on microclimate from thinning stands in the outer riparian reserves may include slight increase in air temperatures and decreased humidity upslope within the harvest area of the riparian reserves. Forest canopy directly influences understory microclimate by reducing solar radiation through interception by leaf surface area (Aussenac, 2000). The topography helps shade the streams and reduces the amount of time for direct solar radiation to heat the soil, air and water. Direct solar radiation is the primary driver of air and soil heating (Anderson et al., 2007). Studies have shown that maximum shading ability is reached within a width of 80 feet and that 90% of that maximum is reached within 55 feet (USDA Forest Service and BLM, 2010). Once effective shade decreases below 80% (about 220 Basal Area) it will begin to have an effect by increasing water temperature (USDA Forest Service and BLM, 2010). With these factors in place, reducing canopy cover should have little impact to the surrounding stream's microclimate. Canopy cover will see diminished cover over the short-term.

The introduction of LWD into Silver Creek as part of the proposed action will quickly help reduce or moderate stream temperatures, which are an essential part of microclimate controls. Spatially complex temperature patterns arise from variations in heat flux across air-river and river-groundwater interfaces as part of the heat flux across air-river and river-groundwater interfaces (Sawyer, 2012). LWD reintroduction is a promising strategy to improve vertical connectivity in rivers and increase thermal patchiness within the hyporheic zone (Sawyer, 2012).Positive long-term benefits will see an increase on multi-structure stand, improved protection of microclimate, tree growth acceleration, and better quality trees.

Table 35. No-harvest buffer acres (total 1299 acres) in all Riparian Reserves in Silver Creek Thin Project

No-Harvest Inner Stream Class or Riparian Reserve Feature area (acres)

Class 1 33 Class 2 346 Class 3 79 Class 4 555 Wetlands 56 Slides 47 Other geohazards 183

Table 36. Thinned Acres in Outer Riparian Reserves under Silver Creek Thin Proposed Action

Stand ID Class 1 Class 2 Class 3 Class 4

18 2.3 12.4 31 34.7 33 0.25 35 0.55 4.5

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Stand ID Class 1 Class 2 Class 3 Class 4

41 1.6 3.6 43 2 7.9 522 2.8 1453 6.6 9029 3.7 4.2 9038 7 9040 1.8 0.3 9 9041 0.5 9051 3.3 9053 3.2 9108 0.9 5.1 9524 0.5 9533 1 1.3 9534 0.1 9540 0.3 3.9 9541 26.5 9545 0.7 9558 0.4 1 9561 1 10 9570 1.77 0.9 9579 0.4 0.6 9581 2.5 9584 9586 0.5 9588 2.1 9591 25.3 9592 2.8 32.6 9593 5.6 11.3 9594 17.4 4.1 10.8 9625 5 Subtotal 6.3 34.2 21.6 226.5

Cumulative Effects “Cumulative Effect” 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. Activities considered for this analysis are in the table below.

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Table 37. Activities considered in cumulative effects analysis for hydrologic resources and effects

Action Description Date

Past

Timber harvest Managed plantation stands were commercially harvested. Past 1955 - 1975 activities may have contributed excess sediment delivery due to limited implementation of BMPs

Timber harvest and pre- Managed stands were harvested and pre-commercially thinned. 1996 – 2010 commercial Over 2,000 acres of thinning over the last 15 years. Improved BMP implementation reducing the impact on water quality.

Present and Ongoing

National Forest System Maintenance and management of system roads on lands within the Ongoing roads listed subwatershed. Minimal effect with localized impact.

Special forest products Commercial harvest, sale and free use of forest products create soil Seasonal harvest disturbances away from system roads and may introduce contaminants and invasive species. Relatively low extent and effect in this watershed.

Forest Trails, Management of forest trails including erosion work, route signing, Ongoing unauthorized trails and maintenance. User-created trails and dispersed recreation disturb soils and reduce soil quality. Minimal extent and effect in this watershed.

Foreseeable Future

Road and Culvert Over the next 5 to 10 years failures and slides are expected to Unknown Failures, and slides occur related to durational rainfall

Road Reconstruction Over the duration of Silver Creek road reconstruction activities Within 2 years

Road Decommissioning Potential future road decommissioning or close and stabilize will Unknown or Close and Stabilize reduce road-stream extension, and reduce sediment delivery

Introduction of LWD in Improve frequency of LWD to closely match historical baseline and Within 5 years Silver Creek help improve habitat complexity, sediment storage and bank protection by introducing more Large Woody Debris

Global climate change Changes to atmospheric conditions may affect vegetation growth, Already begun, effects soil temperature and moisture regimes, increased or decreased changes temperatures and heavy precipitation events. expected

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Aquatic Conservation Strategy

Objective 1: Maintain and restore the distribution, diversity, and complexity of watershed and landscape-scale features to ensure protection of the aquatic systems to which species, populations, and communities are uniquely adapted. Riparian Reserves are protected from harvest activities through design features (no-harvest buffers and riparian drop-and-leave restoration treatments) that will protect riparian areas from the effects of canopy reduction and timber harvest by altering stand development and move towards late successional characteristics with dense, multi-layered canopy consisting of one to several age classes of younger trees.

Objective 2: Maintain and restore spatial and temporal connectivity within and between watersheds. Lateral, longitudinal, and drainage network connections include floodplains, wetlands, upslope areas, headwater tributaries, and intact refugia. These network connections must provide chemically and physically unobstructed routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. Spatial and temporal connectivity within and between watersheds would be maintained at the landscape scales over the short and long-term. Headwaters and drainage network connections would continue to be unobstructed and allow refugia to remain intact chemically and physically. Removal of culverts on temporary and system roads is a recognized benefit helping restore connectivity. Riparian reserves in the upper headwaters of the Silver Creek subwatershed will remain protected allowing continuous riparian reserves to remain connected across subwatershed divides to other riparian reserves allowing continuous protection across subwatersheds. Some habitat species within headwater areas may benefit from unbroken habitat corridors connecting riparian areas across ridgelines. This will help fulfill the continuing life history requirements of aquatic and riparian-dependent species.

Objective 3: Maintain and restore the physical integrity of the aquatic system, including shorelines, banks, and bottom configurations. The physical integrity of aquatic systems, including shorelines, banks, and bottom configurations would not be negatively affected at the site or at the landscape scale over the short or long-term. Adhering to project design criteria (such as dry season operating restrictions and sediment control requirements) the proposed vegetation, road, and restoration treatments would not negatively affect shorelines, banks or bottom configurations.

Objective 4: Maintain and restore water quality necessary to support healthy riparian, aquatic, and wetland ecosystems. Water quality must remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities. Project Design Criteria such as the required No Harvest buffer zone of Riparian Reserves will ensure that treatment activities will not affect water temperature. Mitigation measures and project design features will ensure that water quality remain within the range that maintains the biological, physical, and chemical integrity of the system and benefits survival, growth, reproduction, and migration of individuals composing aquatic and riparian communities.

Project design criteria includes normal operation period during the dry season to ensure proper road conditions for hauling and road maintenance. Proximity of temporary roads to stream channels is limited, which would allow sediment to be filtered through the forested vegetated floor prior to entering stream channels. Sediment delivery would not result in a measureable increase in stream sediment deposition. Increase in turbidity would not measurably alter the biological, physical, or chemical integrity of streams. Project design criteria and mitigation measures follow the USDA Forest Service guideline on National

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Best Management Practices for Water Quality on National Forest System Lands. Aquatic and riparian dependent species’ survival, growth, reproduction, and migration would be maintained.

Objective 5: Maintain and restore the sediment regime under which aquatic ecosystems evolved. Elements of the sediment regime include the timing, volume, rate, and character of sediment input, storage, and transport. By following the Project Design Criteria for this proposed action sediment input would be minimized where continued hydrologic maturation in a subwatershed can be seen in terms of timing, volume of flow, flow rate, and character of sediment input, storage and transport at landscape scales in the short and long- terms. PDC for road related activities includes timing restrictions designed to help minimize sediment delivery from roads by operating during the dry season and specify when to avoid activities when adverse wet weather conditions occur. Applying proper BMPs will minimize sediment delivery outside of the no- harvest buffer areas. Any increase in sediment levels from road maintenance would not be detectable above background levels following the first few substantial rain events. The amount of sediment entering streams from road related activities would be minimal. Following the first winter and thereafter sediment entering streams would decrease to the point of being negligible.

Applying the No Harvest buffer zones creates area where equipment-caused erosion should not occur and where eroded materials within the units can filter out onto the forest floor, preventing sediment from being delivered to steams. Changes in channel characteristics would not be measurable. Timing, volume, rate, and character of sediment input, storage, and transport would be maintained allowing aquatic ecosystems to benefit.

Objective 6: Maintain and restore in-stream flows sufficient to create and sustain riparian, aquatic, and wetland habitats and to retain patterns of sediment, nutrient, and wood routing. The timing, magnitude, duration, and spatial distribution of peak, high, and low flows must be protected. In-stream flows are expected to be maintained with no measurable changes to stream drainage network or changes to the rate of snowmelt or runoff within the thinned units, and because limited area will be converted to early seral conditions. Canopy cover will continued to be maintained between 40 and 60 percent in thinned units.

The timing, magnitude, duration, and spatial distribution of peak, high, and low flows will not be affected by this project proposal. Instream flows will continue to create and sustain riparian, aquatic, wetland and microclimate habitats.

Majority of proposed harvesting units (~85%) take place in catchment areas with current maximum ARP values greater than 60%. The remaining proposed harvesting units with lower ARP values make up only 1% of the entire subwatershed. Hydrologically mature stands would not contribute to increased runoff and increased peak flows at various drainage scales. Project will continue to maintain the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands.

Objective 7: Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands. Design features for this project will help protect riparian areas such as streams, ponds, meadows, floodplains and wetlands from harvest activities. No Harvest buffers have been prescribed for all waterbodies and stream channels to help protect riparian vegetation from being damaged or removed.

Reduction in canopy cover and vegetation outside of No Harvest buffer zones should not affect the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands.

164 Silver Creek Thin EA January 2017

Objective 8: Maintain and restore the species composition and structural diversity of plant communities in riparian areas and wetlands to provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability. Vegetation treatments are designed to help improve the health, vigor, and species diversity while maintaining the sustainability of stands to provide future timber and wildlife habitat needs through silvicultural prescriptions. High amounts of Riparian Reserves in the Lake Creek, Lynx Creek and Willie Creek drainages are in dense pole and small tree structural stages with slow tree growth and little existing potential for LWD recruitment. Silver Creek Thin project will help improve habitat complexity, sediment storage and bank protection by introducing more Large Woody Debris in key stream reaches such as Silver Creek. Other improvements include maintaining the composition and structural diversity of plant communities in riparian areas and wetlands with established No Harvest buffer widths. This will help protect riparian areas from outside harvest activities. Buffers provide for the protection from surface erosion, bank erosion and channel migration as a result of excess sediment deposition. Trees will be left in place along stream banks within the No Harvest zones to allow opportunities for sufficient coarse woody debris. Buffer zones will help provide adequate summer and winter thermal regulation, nutrient filtering, appropriate rates of surface erosion, bank erosion, and channel migration and to supply amounts and distributions of coarse woody debris sufficient to sustain physical complexity and stability. With these in place, it is expected that species composition, structural diversity, and overall function of Riparian Reserves will continued to be maintained with the goal of attaining late successional characteristics.

Objective 9: Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate riparian-dependent species. Riparian-dependent plant and animal species in the planning area would be unaffected by either action alternative due to No Harvest riparian buffers (inner riparian areas) required under the Proposed Action. Thinning in the outer riparian areas will follow a similar prescription to the upland (non-Reserve) thinning unit and follow relevant PDC to promote species diversity and protect other resources (wildlife, botanical, etc.) indicated.

Consistency with Other Laws, Policies, and Regulations The Clean Water Act (CWA of 1977 and subsequent amendments) establishes the basic structure for regulating discharges of pollutants into the waters of the United States and regulating quality standards for surface waters. The CWA made it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained.

Section 303(d) of the Clean Water Act requires states, territories, and authorized tribes to develop a list of impaired waters not meeting water quality standards. The law requires that they develop priority rankings for waters on the lists and develop Total Maximum Daily Load (TMDL) for those waters. A TMDL is a calculation of the maximum amount of a pollutant that a water body can receive and still safely meet water quality standards.

The State of Washington has accepted management designation from EPA for implementation of the CWA. The State Department of Ecology maintains a list of impaired water bodies and promulgates water quality standards that apply to all waters.

The Forest Service has an Memorandum of Agreement with the Washington State Department of Ecology (MOA 2000) in which the Forest Service agrees to manage NFS lands to protect and maintain water quality so that water quality laws and regulations are met or exceeded. This agreement includes commitments that the Forest Service will implement Best Management Practices (BMPs) to protect water

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quality and beneficial uses and meet or exceed the requirements of the Clean Water Act and state water quality laws and regulations, as contained in the state Forest Practices Rules (WAC 222). This agreement also includes the Forest Service is responsible for notifying Ecology when water quality problems are noted on National Forest System lands.

Forest Service Manual 7443 requires BMPs for any projects. The 2012 technical guide “National Best Management Practices for Water Quality Management on National Forest System Lands,” guides agency performance and accountability in managing water quality consistent with the Clean Water Act. Implementation of Project Design Criteria is integral to carrying out the Proposed Action for Silver Creek Thin. PDC associated with this project will meet the intent of 2012 BMPs and thereby the requirements of the Clean Water Act.

Floodplains: Executive Order 11988 is to avoid adverse impacts associated with the occupancy and modification of floodplains. Floodplains are defined by this order as, “. . . the lowland and relatively flat areas adjoining inland and coastal waters are including flood prone areas of offshore islands, including at a minimum, that area subject to a one percent [100-year recurrence] or greater chance of flooding in any one year.”

The Silver Creek Thin project is not expected to have any adverse impacts on floodplains due to no- harvest buffers, other design criteria, and BMPs being implemented, and the size, scope, and timing of logging operations for the proposed units.

Wetlands: Executive Order 11990 is to avoid adverse impacts associated with destruction or modification of wetlands. According to the order, a wetland is an area “inundated by surface or ground water with a frequency sufficient to support and under normal circumstances does or would support a prevalence of vegetative or aquatic life that requires saturated or seasonally saturated soil conditions for growth and reproduction. Wetlands generally include swamps, marshes, bogs, and similar areas such as sloughs, potholes, wet meadows, river overflows, mud flats, and natural ponds.”

Several small wetlands were located in the Silver Creek project area. Project design criteria include establishing no-harvest buffers around riparian water bodies and wetlands to protect them. The proposed action for this project will have little or no effect on these wetlands. Fisheries

Resource Indicators and Measures This report evaluates effects to the fisheries resource through indicators of effects to instream and riparian habitat (Table 38). Information on the related issues of water quality and water quantity is available in the Hydrology Report (USDA 2015a).

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Table 38. Fish affected resource summary and evaluation criteria and measures for Silver Creek Thin. Affected Potential Resource Threat Indicator1 Reference Resource TES Fish Risk of potential increased fine particles Volume of road fill material NWFP ACSO 3-5, 8. spawning and to stream sediment at stream crossings input into high risk channel NWFP FW -2 incubation during reconstruction at sites where road crossings which are located in failure is considered a high risk due to geologically hazardous areas, geologic hazards with high risk of failure and proximity to listed fish habitat TES fish Risk of physical disturbance to fish and Proximity, probability, and Research – Folz (2007) elements of their critical habitat magnitude of impacts to Listed NWFP ACSO 3-5. critical habitat Fish Habitat PACFISH (USDA USDI 1994) 1 Proximity to LFH is defined as < 0.75 miles from ESA species distribution or their critical habitat

Methods

Information Sources The Region 6 Level II fisheries survey procedure provided data to contribute to this analysis, in addition to proposed harvest stand surveys (2014), headwater stream surveys, and direct observation by Forest Service hydrologist, hydrologic technicians, and fisheries biologist. There is data on stream inventory dating back to the turn of the century with more recent survey protocol initiated in approximately 1987.

This report was informed by the Hydrology Resource Report, which relied on Aggregate Recovery Percentage (ARP) watershed model used to estimate potential changes in stream energy. For this analysis, decreasing ARP values indicate increasing potential stream energy. Stream channel conditions were evaluated for risk of mass wasting and channel stability at stream crossings and areas within proximity of listed fish habitat were analyzed to determine the potential direct and indirect effects of fine sediment production and delivery. Soil mapping helped to inform areas of high risk using Soil Resource Index as per the Soils Resource Report (USDA 2015c).

Headwater channel inventory was conducted on all stream courses to positively identify their location and evaluate channel stability. A modified Pfankuch Channel Stability assessment (Pfankuch 1975) was done to evaluate stability indicators and assign a risk rating. In addition, all road crossings were evaluated to describe their existing condition.

Incomplete and Unavailable Information This report lacked recent updated information on fish species compositions in Lynx Creek. There was very little information available on conditions of private land within the Middle Cowlitz watershed. Site- specific information on roads was largely drawn from stream inventory data.

Existing Condition

Fish distribution and species composition summary Anadromous species documented as present in the planning area include Chinook salmon, Coho salmon, and steelhead trout, which inhabit approximately six river miles (RM) in the project. Fish attain only limited access to tributaries: Lake Creek, East Fork Silver Creek, and Willie Creek, due to natural channel barrier features (e.g. waterfalls and cascades). Surveys done following the 1996 flood of record concluded that a waterfall at RM 2.7 was no longer a barrier due to considerable channel aggradation, whereby upstream fish migration was probably extended to approximately RM 5.5. Thus, anadromous fish distribution extends up Lynx Creek approximately five miles onto private land (USDA 1997, USDA

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2014). Resident rainbow and cutthroat trout are found in the mainstem Silver Creek and in major tributaries including East Fork Silver Creek, Lake Creek and Lynx Creek (USDA 1997). Table 39. TES Fish Species Presence within the Silver Creek Project Area

Stream Name Resident Anadromous Stream Name Start-Stop RM1 Species2 Start-Stop RM1 Species2 Silver Creek 0.0 – 12.5 Rb 0.0 - 5.5 Sh ,Co, Ch, East Fork Silver 0.0 – 0.75 Rb, Ct 0.0 - 0.1 Sh ,Co, Lake Creek 0.0 - < 0.2 Rb, Ct 0.0 - < 0.1 Sh Lynx Creek 0.0 - 5.3 Rb, Ct 0.0 - 5.3 Sh Willie Creek 0.0 - < 0.1 Rb, Ct 0.0 - < 0.1 Sh Miller Creek 0.0 - 1.4 Rb, Ct 0.0 - 0.5 Sh, Co 1 RM – Total river miles within the Silver subwatershed on Federal ownership, except for Lynx Creek, for which anadromous distribution is almost entirely on private land. 2 Species Code - Ch = Chinook, Co = Coho, Sh= Steelhead, Rb = Rainbow and Ct = Westslope Cutthroat Trout. Species are listed in priority of their likely distribution in the project area. From: USFS Fish Distribution Database, 2008

Life history The life history of fish varies by species. An assortment of life stages of fish is present in the planning area throughout the year (Table 40). Onset of the rainy season typically initiates migration into natal spawning streams. Adult anadromous fish spawn and die shortly afterwards while resident fish persist for many years in fresh water. Approximately 2-3 months after spawning, juvenile fish emerge and reside in freshwater for an additional 5-36 months. Juvenile anadromous fish typically leave freshwater with spring snowmelt. Table 40. Typical freshwater life history of native salmonids fish found in the Silver Creek Thin analysis area. Months Migrate to Species Spawn Emergence Out migration Present streams (count) Chinook July - Aug Aug - Sept Oct - Dec July - Aug 7-8 Steelhead March - May Mar - Apr Late July April - June 12-36 Coho Nov - Jan Dec - Jan Mar - April May - Aug 5 Rainbow trout May - June June July Resident Resident Costal Cutthroat1 Oct - Nov Feb- Mar Late July May 1-48 1 Coastal cutthroat display four distinct life history forms including resident, fluvial, adfluvial and anadromous. Adapted from Wydowski and Whitney 2003, Groot and Margolis 1991

Riparian Habitat indicators - Stream Condition Summary The planning area riparian habitat is rated as “functioning at unacceptable risk” due to several key components.

Large Wood Recruitment Potential Large wood (LW) levels rate as "functioning at unacceptable risk". Woody material is found in low accumulations in the low gradient sections of the river. Wood was historically removed from the floodplain during timber operations, and currently wood is in late stages of decay (class 4 – 5). Riparian stands in the analysis area are currently mostly composed of undersized trees, which are ineffective at contributing LW due to historic stand-replacement fires and past timber management activities on federal, state, and private lands. The Grass/Pole seral stage dominates the riparian area on average, with Lynx

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Creek most heavily dominated by young stands and the East Fork Silver Creek most heavily dominated by mature trees (Table 41).

Table 41. Riparian seral stages in the Silver Creek planning area Stream Name Pre NHD Miles of Riparian Riparian Seral Stage1 7th field Stream Area (ac) Grass/Pole Small Mature Non forest Silver Creek/ low 02J 51 2501 44 11 42 3

Silver Creek/ up 02K 60 1633 37 11 48 5

E. Fork Silver 2M 19 728 17 16 57 10

Lake Creek 02E 31 1132 57 25 13 5

Willie Creek 02T 15 599 48 4 47 1

Lynx Creek / low 02 G 37 1261 69 16 15 0

Lynx Creek /Up 02H 34 934 78 3 19 0

max 78 25 57 10

min 17 3 13 0 avg 50 12 34 3 1Riparian seral stage from Mid. Cowlitz Watershed Analysis (1997) adjusted by 4% to account for tree development over that time span. Non-Forest is assumed to have remained the same

Pool Quality/Large Pools Pool Quality/Large Pools rated as "at unacceptable risk.” Many pools observed are less than 1 meter deep and many of the pools lack cover (USDA 2005). Pool forming features (e.g. large wood) is underrepresented (approx. 5 pieces LW/Mi) which contributes to low pool numbers.

Channel Stability Channel stability and the risk of sediment input is, in part, a function of land forms and physical processes that shape the valley and channel types (Rosgen and Silvey 1996), coupled with land management (e.g. density and vigor of vegetative cover, road construction and other disturbances). Aquatic inventory conducted in 2014 classified an inherent channel stability index (Pfankuch 1975) for all headwater channels (126 streams). The channel stability conditions within the project area are typically high in risk factors including steep channel gradient and mobile coarse substrate. Upper banks and sides are generally dominated by small trees with low density and vigor. There are many instances of side slope failure and various forms of mass movement (USDA 2014, USDA 2015c soils) particularly evident in in middle reaches of Silver Creek and its tributaries between East Fork Silver and Lynx Creek. The table below displays the Pfankuch channel stability summary by stream class and risk rating.

Stream bank stability is rated as "at risk.” Areas of chronic instability (e.g. bank cutting, channel widening) are observed throughout the watershed. Post-1996 flood and subsequent high water events caused numerous instances of catastrophic head cutting and torrent scour influencing both lower and

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upper banks. Of the 34 harvest units surveyed with streams, virtually all (97%) had at least one stream with high to moderate risk of instability. 109 streams (89%) of the inventoried channels indicated having high to moderate stability risk. Of channels with elevated risk, most (76%) are class IV streams, followed by Class III (21%), and finally Class I and II, which combined, represent 3% of the channels with increased risk (Table 42).

Table 42. Channel stability risk index for channels inventoried in the Silver Creek Thin project area (modified from Pfankuch 1975) Channel Stability Risk Rating by Channel Inventory Stream Class Summary (Count) High Risk 53 Class 2 1 Class 3 12 Class 4 40 Moderate Risk 56 Class 1 2 Class 3 11 Class 4 43 Low Risk 17 Class 1 2 Class 2 3 Class 3 5 Class 4 7 Grand Total 126

Fish Presence by Stream

Silver Creek Resident salmonids present in Silver Creek include rainbow trout and west slope cutthroat trout. Anadromous fish, including Chinook and Coho salmon, and steelhead trout, extend up to RM 5.7, approximately 2.8 miles past the barrier historically reported by Bryant (1949). Level II stream surveys (USDA 1997, 2014a) reported considerable channel aggradation following the 1996 and subsequent floods, which have made this reach accessible to anadromous fish.

Lynx Creek Rainbow trout are throughout Lynx Creek up to reach 16 (approx. RM 6.2). Anadromous fish may be able to access Lynx Creek due to natural recent channel aggradation and navigate to approximately RM 5.3. There is good pool habitat in the lower reaches provided by Bedrock / Big Boulder Plunge Pools. Cover is provided by boulders and turbulence. Waterfalls likely punctuate fish distribution between reaches of Lynx Creek. The habitat complex transitions to a Boulder Pocket Pool and Big Boulder Constriction in nearly all upstream reaches (2-11, 12). This habitat supports good cover from boulders and supports relatively abundant adult resident populations as well as fry. Fish populations were high at all sample sites (USDA 1987). Reach 11 is the only stream segment with LW providing substantial habitat. Even reach 7, which is dominated by bedrock with little shade and cover, supported high populations of rainbow trout (USDA 1987).

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Willie Creek Resident rainbow trout were found only in the lowest portion of Willie Creek near the Silver Creek confluence and up to Reach 2. Much of the Willie Creek has available fish habitat but no fish were found in field inventories above this point (USDA 1988b). It is unlikely that anadromous fish make it to Willie Creek due to natural migration barriers downstream in Silver Creek near RM 5.5.

Lake Creek Lake Creek is the outlet stream from Watch Lake and flow in into Silver Creek. Resident rainbow trout and westslope cutthroat trout are assumed to exist downstream from the lake in small numbers. Anadromous fish are confined to the very lower segment near the Silver Creek –Lake Creek confluence.

Listed Fish Species and/or Critical Habitat There are eight fish species considered in this assessment (Table 43). Federally listed fish populations and/or their critical habitats are distinguished by populations described as Evolutionary Significant Units (ESU) or Distinct Population Segment (DPS), which are under the jurisdiction of National Marine Fisheries Service (NMFS) or US Fish and Wildlife Service (USFWS). There are four species that are not federally recognized but have State listing status. The status of all recognized populations and, where applicable, Federal Register notice and date of listing is identified. Finally, the best available presence/absence data is summarized for each species including the assessment of available habitat, prefield review (literature and survey records) and results of field reconnaissance conducted in the summer of 2014. Table 43. Species listing status according to Federal Endangered Species Act status and Washington State listing status as per Priority Habitat and Species List (PHS) (WDFW 2012).

Federal Listing Status Presence (P)/Absence (A) (NMFS) /Unknown (U) ESU, DPS, or

State Listing Species Critical Critical Status Habitat Species

Habitat Field Recon Habitat Review Prefield Available Available

Chinook Salmon Lower Designated Oncorhynchus Colombia Threatened Candidate P1 p U

tshawytscha River

Steelhead Trout Lower Designated Oncorhynchus Colombia Threatened Candidate P1 p U

mykiss River Lower Columbia Under River Coho salmon Lower Colombia Threatened developmen P1 p U (Oncorhynchus River t mykiss).

Under Bull Trout Salvelinus Lower Colombia Threatened developmen Candidate P1 U A confluentus River t Pacific Eulachon Southern Threatened Designated Thaleichthys Candidate P1 A A Population pacificus Pacific Lamprey Species of Not Entosphenus NA Concern NA P1 A A Designated tridentata

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Federal Listing Status Presence (P)/Absence (A) (NMFS) /Unknown (U) ESU, DPS, or

State Listing Species Critical Critical Status Habitat Species

Habitat Field Recon Habitat Review Prefield Available Available

Pygmy Whitefish NA Sensitive NA NA A A A Prosopium coulteri

Olympic Mudminnow NA NA NA Sensitive A A A Novumbra hubbsi

Mountain Sucker Catostomus NA NA NA Candidate P U A platyrhynchus

Leopard Dace NA NA NA Candidate A A A Rhinichthys falcatus

1 Available Habitat lies above impassable barrier at Mayfield Dam

Effects

No Action

Summary of Effects Under the No Action alternative, transportation system management would not take place. Natural passive restoration would likely occur at a moderately slow rate as road systems gradually revegetate. Chronic sources of road related sediment would likely continue near baseline levels (see Hydrology Report).

Watershed restoration projects would not occur under the No Action alternative. Key baseline indicators, which limit LFH, will continue to function at an unacceptable risk. In general, riparian reserves will be slow to attain Aquatic Conservation Strategy objectives; instream conditions will continue to perform below desired condition with minimal pool development. Roads will likely remain a chronic source of fine sediment to LFH. However, sediment produced due to catastrophic failure of unstable roads may be relatively low because past failures have already removed most road fill material and purged system.

Short-term and long-term effects

Transportation system management - effects on instream sediment Existing low magnitude and persistent sources from periodic road failures, slumps and washouts of surface sediment may continue to deliver fine material (< 0.84 mm) to LFH and impact sediment composition particularly in stream reach 3 (RM 2.7-3.9) between the East Fork Silver to Lynx Creek along Silver Creek and its tributaries. This low-gradient reach is most likely to store sediment. Road segments within areas of mass failure in proximity to TES species are likely to continue to contribute low to moderate levels of sediment. However, a substantial portion (approx. 5490 cubic yards) of the road fill source material has been redistributed due to preexisting road failures. As such, the 22 stream crossings with existing road fill failures currently pose a relatively low risk to adding more anthropogenic sediment to the system.

Maintaining the existing dense vegetative cover on abandoned roads (washed out Level II roads) may help reduce the short-term risk of surface soil erosion. The primary source of anthropogenic fine sediment

172 Silver Creek Thin EA January 2017 under the No Action alternative is expected to originate directly or indirectly from existing system and non-system roads (see Hydrology Report (USDA 2015b) and Soil Report (USDA 2015c). Several road sites with partial washouts will remain in disrepair and provide a source of chronic sediment delivery including portions of FR 7500, 7500064, 756100 and 7561018.

Risk to instream habitat will likely remain at the existing condition with the No Action alternative. Channel-forming processes and flow timing will continue to operate at a baseline level (USDA 2001) and should have no different effect to quality and quantity of LFH than its current condition. Large wood recruitment and channel transport mechanisms will generally persist at the “unacceptable risk.” Natural sediment traps in the form of logjams will be unavailable and the sediment element will function below desired conditions.

Watershed Restoration Effects to Listed Fish Habitat Watershed restoration projects would not occur under the no action alternative. As a result, those key baseline indicators, which limit LFH, will continue to function at an unacceptable risk.

Riparian Reserves and Large Wood The planning area riparian reserve indicator is rated as “functioning at unacceptable risk”. Lack of large wood is a key component to the proper function and process of riparian reserves. Consequently, reserve areas delete of LW will continue to “functioning at unacceptable risk" in the short-term. Woody material is located only in small accumulations. Instream wood is in small quantities (approx. 5 pieces/mi) in the low gradient sections of the river. Riparian conditions will slowly move in a positive trajectory as wood, previously removed from reserves and floodplain is restored.

Riparian reserves will be slow to attain Aquatic Conservation Strategy objectives. Stand structure and diversity will be underdeveloped. Riparian stands in the analysis area will be typically undersized and ineffective at contributing LW in the short-term. The dominant Grass/Pole seral stage may persist for several decades. Recruitment of large wood will be delayed, commensurate with riparian stand development.

Pool Quality/Large Pools Pool Quality/Large Pools indicators will likely continue to function “at unacceptable risk". Many of the pools will be relatively shallow (< 3 feet deep) and many of the pools lack cover. Lack of large wood will continue to detract from channel forming process and manifest itself in an underrepresentation of quality pools.

Long-term Effects Under the No Action Alternative, no new ground disturbance is proposed. Long-term stream habitat conditions would gradually move in a positive direction from the baseline conditions for nearly all habitat indicators. Passive restoration and natural forest maturation will lend to reform of properly functioning channel conditions. The rate of natural succession and watershed recovery will be relatively slow where no active restoration is proposed (Figure below).

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Comparison of Watershed Recovery With and Without Watershed Restoration

Recovery rate w/ restoration Recovery rate w/o restoration Aquatic Proceses

Recovery of Waterhed, Riparian, and Riparian, of Waterhed, Recovery 0 100 200 Time (years)

Figure 21. Qualitative comparison of the rate of recovery for watersheds with and without watershed restoration. FEMAT 1993

Transportation system management– effects on instream sediment The risk of fine sediment delivery will decrease over time if conditions remain relatively undisturbed. Natural development of stand structure and increased vegetative cover will incrementally reduce the long- term risk of surface soil erosion; however, the chronic washout of the road system is expected to continue to directly and indirectly contribute as a persisting source of fine textured sediment under the No Action alternative (see Hydrology Report (USDA 2014b).

The risk of road-related deep seated mass movement and sources of unconsolidated stream sediment will be reduced as roads hydrologically recover (become overgrown and resume proper drainage) and stands mature over several decades. Increased seral structural development will eventually strengthen root cohesion and moderate subsurface soil moisture content through increased evapotranspiration. This should result in a long-term gradual reduction in risk of mass movement.

Watershed Restoration Effects on Listed Fish Habitat Under the No Action alternative, the long-term risk to LFH should diminish at a moderately slow rate. Instream and riparian habitat conditions may improve through passive restoration and decreased ground disturbance. Watershed indicators targeted by restoration projects and currently “functioning at unacceptable risk” should gradually transition toward a positive trajectory.

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Riparian Reserves The planning area is currently “functioning at unacceptable risk.” Large wood is "functioning at unacceptable risk". Woody material is located only in small accumulations in the low gradient sections of the river. Historically, wood was removed from the floodplain by timber operations.

Riparian reserves will be slow to attain Aquatic Conservation Strategy objectives. Stand structure and diversity will be underdeveloped. The short-term riparian stands in the analysis area will be typically undersized and ineffective at contributing LW. The dominant Grass/Pole seral stage may persist for several decades. Recruitment of large wood will be delayed, commensurate with riparian stand development.

Pool Quality/Large Pools Pool Quality/Large Pools will likely continue to function “at unacceptable risk.” Many of the pools will be relatively shallow (< 1 meter deep) and many of the pools will lack cover. The lack of large wood will continue to detract from channel-forming process and manifest itself in an underrepresentation of quality pools.

Undisturbed riparian reserve areas will slowly move toward desired condition through development of mature stands and increased down wood. Areas in the Silver Creek subwatershed with heavy past timber management will benefit from passive restoration most including Lynx Creek and Silver Creek. Risk to channel stability will gradually improve as riparian stands develop and ground cover increases over the next several decades.

Riparian reserves are expected to graduate toward mature stands in the coming decades. The current densely stocked stands with tight spaced overstory (approx. 80% canopy closure) will succeed toward larger diameter trees with wide spacing and fuller canopy. The shade component in riparian reserves will slowly reestablish as stands mature and reach their site potential tree height. Natural density-dependent mortality will lend itself toward increased wood both instream and on the forest floor. However, the riparian stand diameter class and height is likely to be suboptimal for several decades.

Instream habitat and channel-forming process such as pool development will have positive response to natural structural development in riparian reserve. Large wood recruitment and channel transport mechanisms will gradually improve to a fully functioning condition. However, with No Action, there will be no riparian silvicultural treatment, and therefore structural development and species diversification of riparian reserve will proceed at a relatively low rate.

Proposed Action

Summary of Effects The proposed action contains transportation system management elements that my increase the risk of sediment delivery into streams within proximity to ESA listed fish and their critical habitat including road reconstruction crossing development in unstable channel segments.

There is substantial road reconstruction of system road including 17.2 miles, 22 crossing and 11 harvest units and associated transportation systems, which are in proximity to listed fish habitat. Transportation system management has an increased risk of failure on steep slopes, geohazard areas, and inventoried channels with instability. The risk of increasing reestablishing more than 5490 CY of fill material in these crossings may increase the negative impacts of road-related sediment delivery. Some road segments will remain on the landscape after harvest is completed.

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There is limited transportation management activity proposed within stream corridors. Only six acres of listed NMFS fish species habitat is within cutting units. Fish-bearing streams or critical habitat is located downslope in proximity of treatment areas.

No new permanent roads are proposed. Approximately 14.7 miles of temporary road will be constructed and removed upon completion of harvest activities. 10.1 miles of system road segments will be closed and stabilized, some of which have a history of chronic failure and/or catastrophic failure.

There may be a negative and short-term effect to sediment and substrate indicators due to road reconstruction and stabilization activities at the site scale. Potential risk of road failure and subsequent delivery to spawning habitat is relatively high due to geologic instability in areas of reconstruction. Effects to TES species are likely to be limited to indirect effects to spawning constituent elements of critical habitat.

Short-term and Long-term Effects

Timber Harvest Activities The proximity of timber harvest and associated transportation system management ranges from 0.01 – 6.7 miles from LFH distribution throughout the project area (Table 44). Instream activities within 0.75 miles of LFH with channel connectivity are in “proximity” for the purpose of this analysis. Channels are “connected” by high gradient transport streams (e.g. Rosgen A and B channels). Management activities within proximity may directly or indirectly transfer effects to LFH through channel transport mechanisms if channels are connected (Folz 2007). This proposal contains ten harvest units in proximity to LFH. There are four streams associated with five harvest units (units 31, 29, 37, 38, and 32) with a total of 22 stream crossings, which are in proximity of LFH. Primarily fish species present in all cases include steelhead, Coho, and Chinook, with suitable habitat present in proximity for all life stages (Migration, Adult Holding, Rearing, and Spawning).

Table 44. Proposed harvest units in proximity (< .75 mi) to Listed Fish Habitat (LFH) in Silver Creek Thin project area (Outer) Distance to Road Maintenance Riparian Area LFH 2 (Re)construct Stream Harvested Unit (mi) Crossing (Count) (Ac) 26 0.1 4.7 27 0.1 8.9 31 0.2 4 14.7 38 0.1 0.5 29 0.3 1 3.2 32 0.4 1 3.3 28 0.4 3 26.5 37 0.4 13 25.3 25 0.5 2.1 35 0.6 2.3 34 0.6 0.1 22 91.6

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Transportation System Management There are approximately 45 miles of road maintenance and 17.8 miles reconstructed (22 reconstruction sites) within proximity to LFH. These road treatments will include reconstruction of crossings within geologically unstable potions of the watershed concentrated in T. 13 N. R. 7E. Sec 27, 28, 33, and 34. There are approximately 2.2 miles of temporary road to be (re)constructed in proximity to LFH. Possible points of sediment delivery include unnamed intermittent tributaries to Silver Creek, which FR 75 crosses. Temporary road construction is estimated to be needed on up to 15 miles, most of which is outside of riparian reserves.

There is a relatively high probability that road reconstruction and road stabilization activities following harvest and haul will result in short-term sediment delivery due to surface erosion at approximately 22 sites. Sediment is likely to reach LFH due to the close proximity (< .75 miles) and steep nature of Rosgen A type transport channels that flow into Silver Creek. These transport channels have shown past active and current torrent scours along with mass movement along geologically unstable slopes (USDA 2014b). Some currently failed stream crossings (e.g. FR 7500 @ MP 5.8) apparently persisted with decades of service until 2011 when a torrent scour apparently overwhelmed the pipe and subsequently washed out approximately 1000 yards of fill (USDA 2015a). Other pipes along 7500064 appeared to have washed several decades ago shortly after commercial harvest (USDA 2014b). Reconstructed road crossings on geologically hazardous areas will be subject to the same hazard that destroyed the previous crossing (USDA 2015a). Consequently, there is a relatively high risk of failure at some time in the future. Project Design Criteria and best management practices reduce construction related sediment but it is not likely that designs can significantly reduce the overall risk of failure. Temporary road construction is not expected to cause sediment delivery to streams or affect stream channel substrate indicator due to PDC, which include riparian buffers, timing restrictions and relatively distant proximity from streams.

The magnitude of erosion due to reconstruction activities is expected to be short-term and include surface erosion during and following construction activities. This effect is expected to last approximately two growing seasons or until native vegetation becomes established. Potential long-term or delayed effects of large-scale sediment delivery (approximately 5490 CY) at approximately seven crossings including Forest Roads 4778011, 7500, 75064 and 7561018. Several culverts are planned for replacement, which may be removed following harvest activities. Reconstruction activities could result in a short-term low magnitude negative effect. However, if the large-scale geologic-induced landslides result in repeated catastrophic failure, there could be a substantial volume of sediment delivered with a lasting effect up to one or more decade until the channel is able to naturally process the material.

Road stabilization will reestablish normal runoff processes and nearly eliminate flows that currently negatively impact road surfaces. Road stabilization will result in a long-term beneficial effect to stream function and process.

The geographic area and distribution in which disturbance would occur is relatively limited within the Silver Creek subwatershed. The lower Silver Creek (02J) and Lake Creek (02E) 7th field subwatershed have highest inherent risk of sediment delivery to LFH. This includes geologically unstable portions of the watershed within proximity to LFH concentrated between E. Fork Silver Creek and Lake Creek in T. 13 N. R. 7E. Sec 27, 28, 33, and 34. This stream reach is approximately 2.8 miles long and includes reaches 3-5 of Silver Creek. Fine sediment typically introduced from road failure may have a negative impact on fish habitat including channel substrate and promote embeddedness particularly in reach 3 where suitable spawning gravels exist. Sediment transport function of Silver creek should dissipate and disperse the introduced material downstream as it integrates into the river system.

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The duration of the effect of a substantial sediment plug generated from mass failure in Silver Creek may persist for several years as material is processed and redistributed in the system. The low gradient C channel (reach 3) is most likely to retain sediment for an extended period of time. This reach, coincidentally, is most likely to support spawning and rearing of TES species, which require the coarse gravels, and cobbles substrate. Due to the diverse life histories of three listed species present including Chinook (spring and fall), Coho and steelhead (winter), susceptible early life stages (spawning and incubation) are likely to be present for all of the year. The timing of the initiation of landslide material is most likely during the rainy season (Oct 1-July 1) when ground is saturated and conditions are opportune for mass movement.

The frequency and magnitude of disturbance associated with catastrophic road failure is linked to number of factors perhaps most critical is precipitation. Given a sizeable rain event, there is an increased likelihood of a single event generating large-scale disturbance, including road failure. Listed fish habitat is likely to have a negative response to increase fines (< 0.84 mm) generated from road failure which are deposited within spawning habitat in reach 3 of Silver Creek. Indirectly, this would have a negative impact on the quality and quantity of spawning gravel, which currently range in size from very course gravel to cobble. The effect to TES species is likely to be limited to indirect effects to spawning and incubation.

Watershed Restoration Effects to Listed Fish and Critical Habitat Under the Proposed Action, the long-term risk to LFH should diminish and both resident and anadromous overall fish habitat should have a positive response at an increased rate over baseline conditions. Instream and riparian habitat conditions may trend in the positive direction as a result of active restoration projects aimed at addressing limiting factors to salmonid survival. Watershed indicators targeted by restoration projects and currently “functioning at unacceptable risk” should positively respond to efforts to restore watershed the function and process. The transition toward a positive trajectory should be marginally noticeable in the short-term although some processes, including tree structural development, will take decades to achieve desired future conditions. There may be some low magnitude and short-term effects resulting from watershed restoration projects (Table 45).

Table 45. Silver Creek Thin Restoration Projects Effect to Fish and Fish Habitat Project Project Description 2 Evaluation Factors 3 Biological ID1 Name / Size Proximity Magnitude Duration outcome (ac) Frequency 1 Pre Commercial Thin 0.0 No - - Discountable 2 Snag creation 0.0 No - - Discountable 3 Remove culvert near Hampton Creek 0.1 Yes Yes No Insignificant 4 LWD recruitment along 3.8 miles of Silver 10.0 Yes Yes No Insignificant Creek 5 Clean drainage structure on FR 4700 and 0.2 Yes No - Insignificant 474500 6 Remove abandoned non function culverts 0.3 No - - Discountable 7 Noncommercial felling of drop and leave trees 0 Yes Yes No Insignificant in riparian area and stream 8 Replace culvert on FR 477300 0.1 No - - Discountable 9 Close Stabilize FR 47000 for 1.4 miles 0.1 Yes Yes No Insignificant 10 Culvert upgrades for Aquatic Organism 0.4 Yes Yes No Insignificant Passage on FR 4700, FR 4715, FR 4725, and FR 5290 11 Road closure including: 7561018, 4778011, 50 Yes Yes No Insignificant 4700213, 7500065, 477800, 750047, 7500048, 85000108, 4700 1 Project identification and description are cross-referenced to description listed on pg. 12 (other restoration activities in vicinity of the project area) and roads proposed for closure and stabilization.

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2 Project description size is anticipated acres of ground disturbance generated by the activity 3 Evaluation Factors derived from ESA Analytical Process (USDI, USDA, and USDC 2004). Project located less than 0.75 miles from listed fish habitat are considered in proximity. Project effects vary by location and its spatial and temporal scale. Only those projects located with proximity to fish habitat and sufficient magnitude and duration/frequency could affect fish resources, and all other activities are discountable. Those projects lacking magnitude, frequency or duration should result in an insignificant effect to fish resources. Upland restoration projects are expected to have a discountable effect to fish and fish habitat.

Effects summary- Proposed Action

Direct and Indirect Effects Direct effects on juvenile salmonids from work area isolation and fish relocation for instream or near- stream projects include mechanical injury during capture, holding, or release, and potential horizontal transmission of disease and pathogens and stress-related phenomena. Stress approaching or exceeding the physiological tolerance limits of individual fish can impair reproductive success, growth, resistance to infectious diseases, and survival (Wedemeyer et al. 1990). If electrofishing is used to salvage fish, it may increase stress loads. Harmful effects of electrofishing are detailed by Snyder (2003) and include internal and external hemorrhage, fractured spines, and death. Electroshocking results in mortality under certain circumstances. However, if construction took place without work area isolation, typically more fish would be injured or killed. Risk is reduced by proper handling technique and minimizing the exposure to stress. Strict adherence to all fish removal PDCs will reduce risk of injury.

Short-term and Long-term Restoration work conducted instream or near-stream may have short-term (typically lasting less than one week, depending on the duration of instream work) temporary effects to fish and their habitat. Heavy equipment may be used in the stream for replacing culverts and adding structure. Equipment use in water could temporarily affect salmonids and critical habitat, including impacts on redds, smothered or crushed eggs and alevins, increased total suspended sediment and deposition, and temporary disrupted migration. Salmon are particularly vulnerable during the fall and winter, when adult salmon are migrating and spawning, and the spring, when eggs and fry are still present in the substrate. The activities could temporarily displace fish from preferred habitat such as side channels and deep pools, into inferior habitats or high velocity waters. However, because of the PDC describing seasonal restrictions imposed by in-water work windows, these effects should have minimal lasting effects.

Unavoidable short-term adverse effects resulting from these activities include disturbance of riparian vegetation, exposure of bare soil, increased stream turbidity, increased fine sediments in stream substrates, and increased risk of chemical contamination from fuel and lubricants. Where work area isolation is required (e.g. dewatering and fish isolations), fish will be disturbed by capture and relocation procedures.

There should be a short-term positive response to fish and their habitat through restoration practices, which will in some cases, increase accessibility, add habitat complexity and diversification.

Long-term beneficial effects instream projects may promote a positive response in terms of fish passage and restoration of natural stream channel processes and function. Removing fish-passage blockages will restore spatial and temporal connectivity of streams within and between watersheds where fish movement is currently obstructed. The restoration of stream structure is may benefit survival and general health of fish. Improved channel complexity and diversity is likely to positively influence fulfillment of fish life history requirements, especially foraging, spawning, and rearing. At a larger scale, improved channel

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connectivity and increased fish habitat components will improve fish population abundance spatial structure.

Cumulative Effects Spatial and Temporal Context for Effects Analysis This analysis uses the Middle Cowlitz 5th field watershed scale to evaluate cumulative effects for proposed Silver Creek Thin activities in the Silver Creek subwatershed. The temporal scale describes effects up to 50 years or approximate timeframe for reestablishment tree structural development to affectively influence channel-forming process. The scale of analysis is adapted to evaluate relevant effects of past, present, and foreseeable future projects overlapping in time and space with the proposed action regardless of ownership, and includes relevant likely actions on state, private, and federal lands. Planned and ongoing projects in the analysis area Silver Creek Thin is expected to have no significant direct effects and some measureable indirect negative and positive effects within the action area. The Middle Cowlitz watershed is expected to provide substantial ongoing commercial timber harvest opportunities now and into the foreseeable future, primarily on federal Matrix allocations (4,500 ac) and on private lands (31,500 ac). Typical periodic commercial thinning (40-60 yr. old stands) followed by regeneration harvest (60-120 yr. old stands) is typical of commercial timber management (age varies by ownership) (USDA 1997). Current non- functional watershed conditions on heavily managed private lands are expected to persist or trend in the negative trajectory with or without the actions proposed by Silver Creek Thin. Sustaining quality habitat on National Forest within the Silver Creek subwatershed should moderate potential negative effects of private commercial harvest. Silver Creek Thin should not measurably contribute negative cumulative effects to the Silver Creek subwatershed downstream (>3 miles) of the project planning area.

Some long-term positive effects may be realized though timber management and other restoration activities. Commercial and non-commercial thinning operations on approximately 4,600 acres of managed stands on National Forest lands will develop stand structure and function. Ongoing restoration activities should prompt a slow and steady, positive, long-term trend for watershed indicators. Discernible improvements in riparian area conditions are expected to occur on National Forest lands where the predominant riparian structure class currently is dominated by sapling/pole, or small-tree (30-80 year old stands) in class I and II stream corridors including: Silver Creek (RM 2.5 RM), Lake Creek 1 RM) and Lynx Creek (1.5 RM). Approximately 10 miles of road stabilization will serve to restore hydrologic processes and function. Table 46 summarizes the project response to cumulative effects.

Table 46. Past, Present, and Reasonably Foreseeable Future Activities and Cumulative Effects of Silver Creek Thin for Middle Cowlitz Watershed Analysis Area

Effect of Past, Action Description Timeframe Present, Future Action Past Activities

Managed plantation stands were commercially harvested. Insignificant Timber harvest Past activities may have continue to contributed excess 1955 - 1975 negative short- sediment delivery due to limited implementation of BMPs term. indirect

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Effect of Past, Action Description Timeframe Present, Future Action Managed stands were harvested and pre-commercially thinned. Over 2,000 acres of thinning over the last 15 years Insignificant Timber harvest and on NFS lands. More than 40,000 acres of private land. 1996 – 2010 negative short- pre-commercial Improved BMP implementation reducing the impact on water term. indirect quality. Present and Ongoing Activities

Maintenance and management of system roads on lands Insignificant National Forest within the listed subwatershed. Potential for sediment Ongoing negative short- System roads delivery in short-term. term. indirect Commercial harvest, sale and free use of forest products Insignificant Special forest create soil disturbances away from system roads and may Seasonal negative short- products harvest introduce contaminants and invasive species. Relatively low term. indirect extent and effect in this watershed.

Management of forest trails including erosion work, route Insignificant Forest Trails, signing, and maintenance. User-created trails and dispersed Ongoing negative short- unauthorized trails recreation disturb soils and reduce soil quality. Minimal term. indirect magnitude and extent in this watershed.

Foreseeable Future Activities

Over the next 5 to 10 years failures and slides are expected to occur particularly in areas identified as geologically hazardous. Severity of impact related to duration, magnitude Insignificant Road and Culvert and timing of extreme precipitation. Road response is Unknown negative short- Failures, and slides conditional upon maintenance and general upkeep of road term. indirect system. Road reconstruction and upkeep has potential for disturbance and sediment delivery. Potential future road decommissioning or close and stabilize Road will reduce road-stream extension, and reduce sediment Insignificant Decommissioning delivery. Short-term loss may result with sediment delivery. Unknown negative short- or Close and Road treatment of chronic road sediment should benefit long- term. indirect Stabilize term aquatic resource.

Predicted changes to atmospheric conditions may affect Global climate vegetation growth, soil temperature and moisture regimes, Ongoing Unknown. change effects increased or decreased temperatures and more extremes in annual precipitation and individual events.

583 acres of pre-commercial thinning across 19 units to reduce inter-tree competition maintain health and vigor and Pre commercial Insignificant promote species and forest structural diversity. Residual tree Thinning to improve Ongoing negative short- density by stand will range from 90 to 300 trees per acre. Forest Health term. indirect More than 4500 acres of young stands are on line for PCT (USDA 1997)

Create snags and Create snags from trees 20 to 30 inches in diameter at breast Insignificant down wood to height (DBH) in stands adjacent to treatment units to improve 5-15 yrs. negative short- promote aquatic foraging for species dependent upon late successional term. indirect habitat habitat. Clean drainage Removal of improperly functioning culvert to re-establish Insignificant structures and re- natural flow and water levels between wetland and Hampton 5-15 yrs. negative short- establish natural Creek term. Indirect. flow lines

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Effect of Past, Action Description Timeframe Present, Future Action Positive indirect long-term

Clean drainage structures and re- Clean drainage structures and re-establish natural flow lines Insignificant establish natural of stream channels along Forest Road 4700000 in Unit 11 5-15 yrs. negative short- flow lines to and along Forest Road 4745000. term. indirect improve hydrologic function

Remove abandoned, non-functional stream crossings on Insignificant Remove existing, non-system roads to restore natural streamflow, negative short- abandoned, non- channel habitat, vegetative cover and substrate while 5-10 yrs. term. Indirect functional stream improving natural sediment regime and transport where these Positive long crossings sites occur within proposed treatment units. indirect long-term

Non-commercial felling and leaving of 16-30 trees per acre Structural treatment with average diameter of 14 inches across approximately 600 Insignificant of riparian reserve acres of No Harvest “Skip” Riparian Reserves expected to 5-15 yrs. negative short- to restore function contribute to aquatic system stability and complexity along term. indirect and process Silver Creek, East Fork of Silver Creek, Lake Creek and Willie Creek. Insignificant Large woody debris recruitment, riparian planting and bank negative short- Structural treatment stabilization to restore water quality and fish habitat along 3.8 5-15 yrs. term. Indirect of instream habitat miles of Silver Creek. Positive long indirect long-term Insignificant Replacement of undersized culvert at milepost 0.1 of Forest negative short- Replacement of Road 4773000 near junction of Forest Road 4700000 5-15 yrs. term. Indirect undersized culvert junction. Positive long indirect long-term Close and stabilize approximately 1.4 miles of FR 4700000 in Insignificant proximity of East Fork of Silver Creek to include the removal negative short- Close and stabilize of culverts, asphalt, and any protective road railings. Allow 5-15 yrs. term. Indirect roads natural revegetation and growth over former road and/or Positive long seed and mulch and apply other applicable Best indirect long-term Management Practices. Upgrade culverts at stream crossings to improve fish Insignificant Upgrade culverts at passage on North Fork Willame Creek at Forest Road (FR) negative short- stream crossings to 4700 (mileposts 4.0) and unnamed tributary to Willame Creek 5-15 yrs. term. Indirect improve fish at FR 4715 (milepost 1.0), West Fork Willame Creek on FR Positive long passage 4725 (milepost 0.48), and unnamed tributary to Muddy Fork indirect long-term Cowlitz on FR 5290 (milepost 4.8).

Create snags from trees 20 to 30 inches in diameter at breast Wildlife Snag height (DBH) in stands adjacent to treatment units to improve creation to promote 5-15 yrs. No Effect foraging for species dependent upon late successional habitat diversity habitat.

Summary of Cumulative Effects of Silver Creek Thin Project Cumulative effects from the proposed Silver Creek Thin when combined with past, present and reasonably foreseeable future activities may have recognizable but insignificant effects primarily due to ongoing road treatment and anticipated restoration activities in this project area. Inherently poor slope

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stability lends itself to higher risk and increased magnitude of project effects due to increased potential for sediment delivery on disturbed ground or reconstructed stream crossings. However, the relatively short duration of the project reduces cumulative effects to insignificant.

The cumulative effect for Silver Creek Thin will result in a trend toward maintaining the long-term function and process of the aquatic ecosystem. Fine sediment may reach the stream through log haul and road construction operations. Minor detectable quantities of sediment generated from logging and restoration project disturbance should be short-term and may reach listed fish habitat. Commercial harvest in riparian reserves should result in unmeasurable short-term effect on stream temperature and large wood recruitment due to a no-harvest protective buffer. Both of these indicators should trend toward a positive long-term trajectory when stands mature (canopy shade exceeds 80%). All other indicators should remain unchanged or improve as a result of the proposed action (Table 47).

Table 47. Summary of Cumulative Effects for Silver Creek Thin.

Baseline Condition Silver Creek Thin Cumulative Effects INDICATORS Properly At Risk Not Properly Positive Neutral Negative Functioning Functioning Water Quality: Temperatures x Long-term X short-term Sediment x Trend X short-term Chem. Cond./Nut. x X Habitat Access: Physical Barriers x X Habitat Elements: Substrate x X Short-term LW x Long-term X Short-term Pool Frequency x X Pool Quality x Long-term X Off-channel Habitat x X Refugia x X Channel Cond. & Dynamics: Width/Depth Ratio x Long-term X Stream bank Cond x X Floodplain x X Connectivity Flow/Hydrol: Peak/Base Flows x X Drainage Network x X Increases Watershed Conditions: Rd Density & Loc. x Trend X Disturbance Hist. x Trend X Riparian Reserves x Trend X

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Proposed, Endangered, and Threatened Species Determination The biological assessment for ESA listed fish in the Lower Columbia River ESU habitat determined the proposed action may affect essential elements of critical habitat due to relatively high magnitude and fair probability of sediment delivery resulting from the proposed reconstruction of roads in proximity to listed fish habitat. Proposed road construction in geological hazardous areas may result in recognizable sediment delivery of road fill material in the event that the high risk and geologically unstable road systems continue along historic trends of failure. The analysis determined that the effects of the proposed transportation system management project element may have a negative effect in the short-term resulting from potential sediment delivery and potential loss spawning habitat for Lower Columbia River ESU fish in the Middle Cowlitz watershed. Road reconstruction and to a lesser extent log haul are likely to result in short-term sediment delivery due to surface erosion at approximately 22 sites. Sediment is likely to reach critical habitat due to the close proximity (< .75 miles) and likelihood for high gradient tributaries to transport sediment Silver Creek from upslope. These transport channels have shown past active and current torrent scours along with mass movement originating from geologically unstable slopes. Reconstructed road crossings on geologically hazardous areas will be subject to natural disturbance the same hazard that washed out the previous crossing. Consequently, there is a relatively high risk of failure at some time in the future. Project design criteria and best management practices will serve to reduce construction related sediment, but will not meaningfully alter landscape-scale features of instability and are not likely to impede the overall risk of failure.

While slope failure is a natural and often beneficial process in stream evolution, the disproportionate volume of fine particle size (<0.18 mm) in road fill material construction is likely to have a negative effect if it reaches nearby spawning habitat in Silver Creek. Long-term indirect effects may include both catastrophic and chronic sources of sediment delivery to critical habitat in the likely event historically unstable road segments again fail. The risk of future geologic instability and road failure and delivery of additional sediment is an ongoing risk. There are no direct effects expected to individuals of the listed and proposed listed fish species.

An Effects Determination Key was completed for the Silver Creek Thin for listed NMFS fish species and proposed critical habitat (Table 48). Table 48. Project Effects Determination Key, Silver Creek Thin. Do any of the indicator summaries have a positive (+) or negative (-) conclusion? Yes Are the indicator summary results only positive? No If any of the indicator summary results are negative, are the effects insignificant or discountable? No

Consequently, the effects determination for the Silver Creek Thin is “may affect, likely to adversely affect” (LAA) Lower Columbia River steelhead trout, Lower Columbia River Chinook and Coho salmon critical habitat (including proposed Coho CH) for these three fish species. The analysis conclusions supporting the LAA effect determination are summarized here.

Transportation Management 1. The proposed action contains elements will increase the risk of sediment delivery into streams within proximity (< 0.75 mi) to ESA listed fish and their critical habitat. Negative effects may result from components of transportation system management including road reconstruction, crossing (re)development in geologically hazardous areas and unstable channel segments. 2. There is substantial road reconstruction proposed including; 17.2 miles, 22 crossing and 11 harvest units which are in proximity to listed fish habitat. Transportation management has an increased risk of failure on steep slopes, geologically hazard areas and channels inventoried as high risk of instability (USDA 2014). The proposed replacement of more than 5490 cubic yards of fill material in these

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crossings may increase the negative impacts of road-related sediment delivery. Those reconstructed road segments remaining on the landscape after harvest is completed will increase the risk of sediment delivery due to road failure. 3. There is limited activity in Riparian Reserves, no-cut riparian buffers on all streams, and post-harvest treatment of roads and landings. Only approximately 6 acres of class I stream Riparian Reserves are within actual cutting units. Fish-bearing streams or critical habitats are located downslope in proximity of treatment areas. 4. No new permanent roads are proposed. Approximately 14.7 miles of temporary road will be constructed and removed upon completion of harvest activity. Approximately 2.2 miles of temporary road are proposed in proximity to LFH. 5. There are approximately 10.1 miles of system road that will be closed/stabilized with this proposal. Removal of these roads segments will reduce risk of future failure especially where roads are located in areas of instability and chronic failure and / or catastrophic failure. The summary of effects determination for Proposed, Endangered, Threatened and Sensitive (PETS) species is summarized in the table below.

Table 49. Summary of effects determination for ESA listed species in the Silver Creek Thin analysis area. Species Distinct Population Status Effects Determination Segment Individuals Critical Habitat Spring Chinook Lower Columbia River Threatened NLAA LAA (Oncorhynchus tshawytscha) Steelhead trout Lower Columbia River Threatened NLAA LAA (Oncorhynchus mykiss) Coho Lower Columbia River Threatened NLAA LAA (Oncorhynchus keta) Bull trout Columbia River Threatened No Effect NA (Salvelinus confluentus) Pacific Lamprey NA Species of No Effect NA (Entosphenus tridentate) Concern Pacific Eulachon Southern Population Threatened No Effect NA Thaleichthys pacificus) Pygmy Whitefish NA Sensitive No Effect NA Prosopium coulteri Olympic Mudminnow NA NA No Effect NA Novumbra hubbsi Mountain Sucker Catostomus NA NA No Effect NA platyrhynchus Leopard Dace NA NA No Effect NA Rhinichthys falcatus Determinations: NLAA-Not Likely to Adversely Affect; LAA- Likely to Adversely Affect, NA-Not Applicable

Essential Fish Habitat

Magnuson-Stevens Fishery Conservation & Management Act The Sustainable Fisheries Act of 1996 (Public Law 104-267) amended the Magnuson-Stevens Fishery Conservation and Management Act (Magnuson-Stevens Act) to require federal agencies to consult with NOAA Fisheries on activities that may adversely affect “Essential Fish Habitat” (EFH). Essential Fish Habitat is defined in the Act as “those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity.” Essential Fish Habitat includes all freshwater streams accessible to anadromous fish, marine waters, and intertidal habitats. Essential Fish Habitat in the Cowlitz River subbasin was designated for Coho and Chinook salmon (NOAA 2004).

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The evaluation criteria by which risk to EFH is assessed is based upon sediment regime changes to spawning habitat. The risk to EFH due to the No Action alternative is Low; for the Proposed Action the risk is considered to be Moderate. The complete analysis is available in the Fisheries Biological Assessment.

The Matrix of Pathway Indicators analysis (USDA 1998, USDA 2004) supports the finding that the proposed action may affect but not likely adversely affect EFH including “those waters and substrate necessary to fish for spawning, breeding, feeding, or growth to maturity”. The project will have No Effect within the cumulative effects analysis area. The proposed action will have No Effect to the Lower Cowlitz and all EFH outside of the cumulative effects analysis area. Coho Salmon Lower Columbia River Coho salmon (O. kisutch) have been observed in Silver Creek from the mouth up to RM 5.7 and are expected to occur where there is habitat within the lower 0.1 RM of East Fork Silver Creek, Lake Creek, and Willie Creek on NFS lands. Silver Creek’s Coho salmon habitat is greatly impaired by urban development, including concrete flumes and buildings built over the stream channel.

The Silver Creek Thin proposed action May Affect Lower Columbia River Coho salmon in the upper watershed and will have No Effect in the lower watershed below Cowlitz Falls Dam. Spring Chinook Salmon Spring Chinook salmon (O. tshawytscha) have been observed in the Silver Creek from the mouth up to RM 5.7, and are expected to potentially occur in the lower 0.1 miles of Lake, E. Fork Silver, and Willie Creek. Silver Creek spring Chinook salmon habitat is greatly impaired by urban development including concrete flumes and buildings built over the stream channel. Hamilton Creek anadromous fish habitat is limited by culverts and barriers in the lower 0.5 miles.

The Silver Creek Thin proposed action May Affect Lower Columbia River spring Chinook in the upper watershed and will have No Effect in the lower watershed.

Effects Determination for Essential Fish Habitat for Proposed Action Lower Cowlitz The proposed action will have “No Effect” to EFH on the Lower Cowlitz for Lower Columbia River Coho salmon and Lower Columbia River Chinook salmon. The effects of Silver Creek Thin will be unrecognizable to Lower Cowlitz EFH due the following key factors: 1) substantial physical separation (> 58 river miles) between downstream habitat and the proposed action; 2) the three mainstem Cowlitz River dams will capture any potential sediment before it is transported to the lower river; 3) the relatively minor level of disturbance from the proposed action will be indiscernible from the baseline level of natural sediment production in watershed. This activity is not expected to have a direct or indirect impact to EFH Upper Cowlitz The Silver Creek Thin proposed action “May affect, and is likely to adversely affect” listed NMFS fish species and critical habitat, and proposed critical habitat (see Fisheries Biological Assessment, 2015).

Transportation system management has a relatively high risk to EFH under the proposed action primarily due to sediment production related to reconstruction of roads. There are no new stream crossings proposed but reconstruction in up to 22 crossings in proximity of LFH will add approximately 5,490 cy of road fill material into stream channels through continued torrent scour and mass wasting events. The impacts on riparian reserves will be minimized by the substantial retention of forest canopy and considerable riparian buffer. Thinning activities in the outer riparian reserve (Class I and II streams) will

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retain canopy closure, on average, near 50 percent. The inner 300 feet of the riparian reserve will remain a no-harvest buffer. This treatment should retain adequate shade and channel stability for “at risk” streams currently listed as 303(d) water quality limited water bodies. Rationale for EFH Determination Effects determination for Chinook and Coho salmon are based on the following rationale: 1. Proposed timber management is moderately limited in intensity. Harvest prescriptions will retain forest structure and composition to maintain and/or improve aquatic ecological health.

2. The duration of road treatment may persist on unstable ground and could result in ongoing source of sediment where geologically unstable road segments are reconstructed.

3. Proposed management actions are consistent with and/or will not prevent the attainment of Aquatic Conservation Strategy Objectives (USDA, USDI 1994) at the 5th field watershed scale.

4. The Gifford Pinchot Land Resource Management Plan (LRMP) employs the three Aquatic Conservation Strategy (USDA, USDI 1994) components including watershed analysis, riparian reserves, and key watersheds designation intended to maintain species viability.

5. Proposed management actions are consistent with the LRMP Standards and Guidelines.

6. Proposed timber management and associated road development is determined to pose a low risk to maintaining salmonid viability as per Consideration of Extinction Risk for Salmonids (Reimans et al. 1993).

7. Proposed Project Design Criteria to improve drainage, maintain or restore stream shade to moderate stream temperatures, develop stand structure to promote stream cover and large woody debris recruitment potential, and reduce sediment transport and erosion potential (see Mitigation Measures listed in EA, BA).

8. There will be no net gain of roads with the Silver Creek Thin and all temporary and skid roads and landings will be pre-approved and restored following logging activity.

9. Road closure and stabilization will be a component of this timber sale (but will be consulted on under the ARBO II authority).

10. Lower Cowlitz River EFH is geographically separated from the proposed action and more heavily influenced by downstream dams and agricultural practices.

USFS Management Indicator Species (MIS) for Fisheries Species Management Indicator Species (MIS) are established at the forest level and used forest-wide as a gauge of freshwater ecosystem health. The 1990 GPNF LRMP designated several fish species as representative of habitats forest-wide including the following:

• Indicator 1: Cutthroat/Steelhead (a combined indicator to represent habitat capability for resident and anadromous fish species)

• Indicator 2: Bull Trout (represents cold water fish species)

Indicator 1: Cutthroat and steelhead trout are present in the analysis area. The proposed action has a discountable risk of indirectly affecting cutthroat and steelhead stream habitat. The proposed action poses a low risk to aquatic resources resulting from one or more project element. The transportation system

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management of the proposed action is expected to have an effect to sediment indicators during implementation phase and beyond. These effects are limited to indirect consequences of both long-term and short-term road failure that may have measurable effects to fish habitat. The timing of this effect is largely driven by natural disturbance (e.g. high precipitation and flooding). The project is also expected to have some positive effects as road maintenance and restoration projects restore hydrological function and process.

The scale of effects are likely limited to portion of the subwatershed where road maintenance and habitat restoration project are within proximity to MIS species including Upper and Lower Silver, Lake Creek and Lynx Creek 6th field watersheds. This project should not contribute significantly outside of the Silver Creek subwatershed to past, present or foreseeable future projects overlapping in time or space and should not contribute to the cumulative effects of other management actions.

Species viability for Cutthroat/Steelhead indicator species at a Forest or Plan level is expected to be unchanged in the short-term. Cutthroat/steelhead population trends should follow on a positive trajectory on the long-term as forest habitat conditions gradually move toward a mature successional stages of development and roads are restored to a properly function condition. Indicator 2. There is no known bull trout distribution or designated critical habitat within the analysis area. Bull trout survival, particularly spawning success, is typically limited to very cold water and clear clean spawning substrate (Rieman and McIntyre 1993). Bull trout surveys (USDA 2002) evaluated several river systems with quality habitat conditions following methods according to Interim Protocol for Determining Bull Trout Presence (Peterson et al. 2000). No surveys were conducted in the Silver Creek subwatershed. The surveys did not detect presence of bull trout in the Upper Cowlitz basin including high probability areas of Clear Fork Cowlitz, Upper Nisqually River, and Upper Cispus watershed. Furthermore, ongoing juvenile trapping at the Cowlitz Falls Fish Facility have never detected bull trout during their 20 years of operation and for these reasons bull trout are considered to be absent from the basin. The proposed action should not directly or indirectly affect baseline conditions in a way, which would increase the risks to bull trout survival. The project effects are limited in magnitude duration and scale and are therefore discountable. This project should not contribute significantly to past, present or foreseeable future projects overlapping in time or space and should not contribute to the cumulative effects of other management actions. There is no effect expected from project actions on Forest-wide viability for the Bull Trout indicator species.

Aquatic Conservation Strategy Objective Consistency Determination The NWFP requires that a project “meet” or “does not prevent attainment” of the Aquatic Conservation Strategy Objective (USDA USDI 1994) at the site scale. Table 50 is the ACS consistency finding for the Silver Creek Thin proposed action. Each ACSO was evaluated for the fish resource and determined if the action Does Not Meet, Maintains and/or Restores. Actions that “maintain” the existing condition or lead to “restored” condition in the long-term “meet” the intent of the ACS (ROD B-10).

Table 50. ACS Consistency Summary for Silver Creek Thin. ACS # Objective Summary No Action Proposed Action

1 Habitat diversity Maintain Maintain 2 Connectivity Maintain Maintain 3 Physical integrity Maintain Maintain 4 Water quality Maintain Maintain 5 Sediment regime Maintain Maintain 6 Stream flow Maintain Maintain 7 Flood inundation Maintain Maintain

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ACS # Objective Summary No Action Proposed Action

8 Species composition Maintain Maintain 9 Species distribution Maintain Maintain

The proposed action does not retard or prevent the attainment of the Aquatic Conservation Strategy objective at the site scale. A detailed discussion of each ACS objective along with rationale for the ‘maintain’ determination for overall watershed resources may be found in the Hydrologic Resources section (EA pages 161-163).

Both water quality and sediment (ACS objective 4 and 5) may be affected by the proposed action. Expected short-term sediment delivery from transportation management and log haul may be observed at the site scale. However, these losses are inherently short-term or may be reduced though BMP, mitigation measures, project design criteria, and proposed restoration.

Restoration projects are anticipated to have positive effects and lend to attainment of ACSOs. Restoration projects are assumed to be an integral part of the proposed action. This harvest entry should benefit the proper drainage of existing roads that may not have been constructed to a current standard or did not receive appropriate post-harvest treatment in the last harvest entry and show clear signs of instability.

The Silver Creek Thin proposed action should not significantly alter the baseline conditions. The magnitude and duration of road failure associated with the Silver Creek Thin is commensurate with active and past active catastrophic landslides of the past several decades. The proposal to close / stabilize approximately 10 miles of road projects should reduce the risk of catastrophic failure on these select road miles. Heritage Resources Heritage properties include objects, sites, buildings, structures, and districts. These properties are physical remnants of human culture during history. The analysis area for heritage resources in this EA is the area of ground disturbance included in the Proposed Action or the Area of Potential Effect (APE). The APE includes treatments using heavy equipment associated with logging, burning, temporary road construction, road closure, and terrestrial and aquatic restoration projects.

In compliance with 36 CFR 800.3(f), initiation of the National Historic Preservation Act Section 106 process included notification to four federally-recognized tribes, including the Cowlitz Indian Tribe, Squaxin Island Tribe, the Nisqually Indian Community, and the Yakama Nation. Notification letters were sent on June 9, 2014 to the designated cultural resources program manager for each of the tribes, with an invitation to consult regarding the proposed project. No responses were received from any of the tribes contacted.

Existing Condition The Heritage Resource Survey for the Silver Creek Thin project was completed in the fall of 2014 and the final report summarizing its results was submitted to the same four tribes concurrently with submission of the report to the Washington State Historic Preservation Office (DAHP) on December 1, 2015.

Effects

No Action There will be no effect to historic and cultural resources if the No Action alternative is selected.

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Proposed Action No cultural resources that are eligible for, or included on the National Register of Historic Places will be affected by the Proposed Action. On this basis, the District Archaeologist recommended an agency determination of “No historic properties affected” (36 CFR 800.4 (d)(1)) for the project. The determination was concurred with by the Washington SHPO on December 1, 2016. Concurrence with the agency determination was also received from the Nisqually Indian Community on December 1, 2015 and from the Squaxin Island Tribe on December 21, 2015. No response was received from the Cowlitz Indian Tribe or the Yakama Nation during the consultation period. Recreation and Visual Quality

Existing Condition

Landscape Character Landscape character gives a geographic areas its visual and cultural image and consists of a combination of physical, biological, and cultural attributes. Each attribute contributes to the uniqueness of the landscape and gives a particular place meaning and value and helps define a “sense of place.” Landscape character provides a frame of reference from which to determine scenic attractiveness and to measure scenic integrity.

Landscape Character Attributes Views of snow-capped mountain peaks, large rock outcrops, water, and open forests with lush undergrowth and large, tall trees contribute to the scenic quality visible in parts of the Silver Creek project area.

The landform is mountainous with moderate to steep slopes, broad and narrow valleys and incised canyons. Elevation ranges from about 1,000 feet above sea level along US Highway 12 to about 5,400 feet at Purcell Mountain. Outstanding rock outcroppings and volcanic intrusions prominent at higher elevations provide increased scenic variety.

The project area is dominated by stands, which are now fully stocked plantations. Some have been managed with pre-commercial thinning and many more are in need of this kind of treatment. At the lower elevations, Douglas-fir is the most abundant tree species in these plantations; however, many other tree species are present, such as western hemlock, western red cedar, big leaf maple, and red alder. At the higher elevations, plantations were planted with a mix of species -usually Douglas-fir and noble fir. These higher elevation sites also naturally develop into mixed stands of various species like Pacific silver fir, mountain hemlock, and subalpine fir.

Water is abundant in this landscape including several large natural lakes and ponds and numerous perennial streams and creeks.

Cultural attributes are primarily associated with traditional uses by the Cowlitz and Nisqually Tribes, including berry picking, foraging, and hunting. Other cultural attributes associated with the area include historic sites (homesteads, farms, and trails), livestock grazing, and early logging.

Landscape Character Context and Scenic Integrity Upon closer inspection of the project area, the viewer perceives a predominantly near natural appearing landscape with some evidence of human disturbance. Disturbances (including natural and human-caused

190 Silver Creek Thin EA January 2017 fire, logging, and insect and disease) and recovery processes have had the greatest influence on vegetation pattern.

In its purest definition, “integrity” means perfect condition; however, in scenery management, degrees of integrity are defined as very high to very low (Agriculture Handbook Number 701). The frame of reference for measuring achievement of scenic integrity levels is the valued attributes of the “existing” landscape character “being viewed”.

Much of the project area has low scenic integrity. Foreground views include relatively dense Douglas fir forests. Individual or clumps of large diameter trees are intermixed with natural appearing openings and a dense understory. Big-leaf maples are common. Understories include vine maple, huckleberry, salal, sword fern, and devil’s club. Dead trees, both standing and fallen, are present, as are old tree stumps, which add to the rich texture and variety in these stands. Vegetation and/or landform prevent most views beyond foreground.

Scenic attractiveness Scenic attractiveness is a measure of the landscape’s scenic importance based on common human perceptions of the intrinsic scenic beauty of landforms, rock forms, water forms, vegetation patterns, and cultural features. It reflects varying visual perception attributes of variety, unity, intactness, coherence, mystery, uniqueness, harmony, balance, and pattern. The frame of reference for scenic attractiveness is landscape character. There are three levels of scenic attractiveness, which identify the scenic quality of natural landscapes (Agriculture Handbook Number 701.)

Class A - Distinctive: areas where features of landform, vegetative patterns, water forms and rock formation are of unusual or outstanding scenic quality.

Class B - Common: areas where features contain variety in form, line, color and texture or combinations thereof but which tend to be common throughout the landscape province and are not outstanding scenic quality.

Class C - Undistinguished: areas whose features have little change in form, line, color, or texture. Includes all areas not found under Classes A and B.

The Silver Creek project area has Class B landscapes across much of the area. The project area does offer views into Class A landscapes including Mt. Rainier and Mt. Adams.

Landscape visibility Landscape visibility addresses the relative importance and sensitivity of what is seen and perceived in the landscape. It is a function of many important interconnected considerations such as the number and context of viewers, duration of views, degree of discernable detail (which depends in part on the position of the viewer, i.e. the landscape being viewed may be superior, level with or inferior to the viewer) and season variation. The landscape visibility inventory and analysis consists of three elements, including travel ways and use areas, concern levels, and distance zones.

◊ Existing travel ways and use areas are identified and classified to determine which viewer position would be most relevant and useful in the landscape visibility analysis. Travel ways represent linear concentrations of public viewings, including highways, roads, trails, rivers and other waterways. Use areas are spots that receive concentrated public viewing such as vista points, trailheads, campgrounds, ski areas or towns , subdivisions and private land within or adjacent to national forests. Landscapes are viewed to varying degrees from different locations and differ in their importance. Concern levels assist in scenic inventory and analysis by ranking

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this importance according to public opinion. There are three concern levels. The type of area and the level of use is an adequate indicator in discerning the level of interest people are likely to have about forest scenery.

◊ Distance zones, the third element of landscape visibility, is the concept of distance and visual impact. Increasing the distance from an observer to an activity reduces the apparent impact and ability to identify details on the activity area. A visible activity is considered to be in one of three distance zones for scenery analysis. The Foreground Distant Zone (FG) extends from an identified viewing location or viewpoint to ½ mile, Middleground (MG) is from ½ to 4 miles, and Background (BG) is the area visible from 4 miles and beyond from the viewpoint (Agriculture Handbook Number 701).

Within the Silver Creek project area, important viewsheds are described below:

◊ Cowlitz Valley - US Highway 12: this follows the Cowlitz River for several miles. It also crosses several creeks, including Silver Creek. Mt. Adams and Mt. Rainier can be viewed from various points along the Highway. It is surrounded by views of Kehoe, Cockscomb, and Purcell Mountains, and Pompey Peak. This is also part of the White Pass Scenic Byway. The byway is 124 miles of rural, two-lane highway. It has been designated as a highway of statewide significance and is also one of three year-round passes over the Cascade Mountain range.

◊ Sawtooth Loop - Forest Roads 84 and 85: most commonly accessed from Skate Creek Road/Forest Road 52 off Highway 12 in Packwood, this loop provides a mostly forested drive, opening in various spots to provide vistas of Whalehead Ridge and large parts of the project area.

The Constituency Constituent information examines the importance of scenic quality and aesthetic experience to people who have an interest or a stake in a particular place.

Constituent information specific to the Silver Creek project area highlights three groups of people who have an interest or stake in forest management. They include: A) recreationists; B) forest visitors; and C) residents. There is considerable overlap in these three constituent groups. For example, residents and forest visitors often enjoy recreational activities on the National Forest.

Recreational enthusiasts make up one constituent group in the Silver Creek project area. With a large and active population in the Seattle Metropolitan area, there is currently a high local demand for recreational and sightseeing opportunities. The 2002 SCORP analyzed the demand and projected growth of recreational activities. The following information is based on surveys conducted in Washington.

Table 51. Projected Increase in People Participating in Different Recreation Activities from 2013 and 2023

Estimated 10 Year Change Estimated 10 Year Change Activity Type 2002 - 2013 2013 - 2023

Sightseeing +26% +42%

Wildlife Viewing/Photography +23% +37%

Hiking or Walking +23% +34%

Canoeing/kayaking +21% +30%

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Estimated 10 Year Change Estimated 10 Year Change Activity Type 2002 - 2013 2013 - 2023

Sightseeing +26% +42%

Picnicking +20% +31%

Camping - developed RV style +10% +20%

The SCORP was developed to meet the requirements of the Federal Land and Water Conservation Fund (LWCF) Act of 1965, which is designed to conserve outdoor recreation resources for all residents and future generations in the United States. However, the SCORP also serves the broader purpose of providing a plan for meeting public demand and determining priorities for the acquisition, renovation, and development of recreational resources.

The SCORP serve as a statewide management tool to help decision-makers better understand and prioritize recreation issues statewide. While the percentages in the table below represent a statewide inventory, the table displays some of the most common types of use in or around the project area.

Table 52. Percent People Participating in Various Recreational Activities in Washington in 2013

Activity Type 2013 Use

Picnicking 80%

Wildlife Viewing/Photography 59%

Hiking or Walking 59%

Sightseeing 57%

Camping 42%

Canoeing/kayaking 11%

Many recreation uses are valued within or around the Silver Creek project area. These take the form of camping, hiking, fishing, picnicking, viewing wildlife and scenery, and Off-Highway vehicle travel. These types of activities are provided in a variety of landscape settings or sites, such as dispersed recreation sites, trails, and roads.

Forest visitors - Unlike recreationists who use the Silver Creek landscape for an activity, forest visitors are drawn to the area because of its scenic and environmental attributes, such as the mountains, large rock outcrops, the water, and fall color. Recreationists are drawn to the same attributes, but they tend to inter- mix scenic enjoyment with an activity.

The majority of Silver Creek forest visitors are on their way to Mt. Rainier National Park and High Rock Lookout, or are seeking camping or hunting opportunities. Many come to access the area’s unique motorized trails or to pick special forest products such as salal and huckleberries. These visitors have preconceived expectations of what a forest should look like. Many return year after year to the area, expecting to view and enjoy the same “natural” landscape.

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According to the National Visitor Use Monitoring Results for the Gifford Pinchot National Forest (NVUM), the top five recreation activities of forest visitors include viewing scenery (driving), viewing wildlife, hiking or walking, relaxing and visiting historic/prehistoric sites.

Residents and nearby communities - Most residents live in the small towns of Morton, Randle, and Packwood, and dispersed private land along State Highway 12 outside the project area. Although these towns are outside of the project area, they are still a concern of forest managers because of their proximity.

Formerly logging and mill towns, operating mills remain only in the towns of Randle and Morton. Today most residents of these towns depend on tourism to the area and the national forest. Many visitor-related services and businesses accommodate visitors to the area, such as motels, lodges and cabins, often promoting the scenic beauty and mountainous environment surrounding the area.

With thousands of visitors encouraged to come to the area throughout the year, resident’s value the surrounding landscape and mountainous environment. They are concerned when changes to the landscape they value occur because changes will indirectly impact their way of life.

Travel corridors - Travel roads and trails play a major role in viewing the landscape scenery in the Silver Creek project area. All the constituents, including residents, forest visitors and recreational users, place high value on the travel corridors around and through the forested areas.

Landscape Character Goals Landscape character goals are derived by carefully balancing the constituents concerns or desires with the opportunities and constraints of the landscape and its ecosystems. They are management prescriptions designed to maintain or modify the existing landscape character to achieve a desired future state.

In summary, the project area has low to moderate visibility, moderate recreation demand and use, and residents and visitors like to see high quality scenery. Vegetation treatments in the area should be designed with these things in mind.

◊ Goal 1 - The overall desired landscape character is a predominantly natural appearing forest with scenic quality that is sustainable over the long-term.

◊ Goal 2 - Valued natural scenic elements are visible from recreation areas and travel corridors, and are sustained and enhanced through active management.

◊ Goal 3 - Create forest conditions that resist large scale insect infestations and sustain long-term preponderance of live tree in valued recreation areas and travel corridors.

Desired Condition

LRMP Direction

Scenery The visibility of management activities as a result of intensive management has decreased in response to new emphasis on protection of such resources as old growth and the spotted owl. Viewshed corridors contain a significant amount of old growth retained for spotted owl habitat. The view from major scenic travel ways appears naturals or blends with the landscape. Evidence of human activities is frequently more dominant in forested areas where timber management occurs.

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Recreation The overall management of the Forest is strongly influenced by the recreation demands and needs being placed on it. There is a wide variety of both developed and dispersed recreation opportunities. There is a balance of opportunities based on recreation demand. Dispersed recreation sites and areas continue to provide the greatest capacity for recreation use of the Forest.

LSR Assessment

Scenery Most lands in LSR will meet or exceed the visual quality objective of retention. Human uses in the LSRs will conform to the Roaded Natural classification of the Recreation Opportunity Spectrum.

Recreation Compatible human uses expected to continue in the LSRs and which are related to recreation include:

◊ Hunting and fishing.

◊ Hiking and camping.

◊ Developed and dispersed campground and picnic areas

Effects

No Action The no action alternative would achieve a natural appearing forest with little evidence of management.

Deviations from a natural appearing forest are roads, recreation sites, signs, and past harvest areas. Scenic integrity may move from low to moderate in the absence of active management.

Over time, however, the project area would lose more of its valued and desired landscape character attributes; conifers would grow tall and thin and forests would become denser, with little or no understory.

Further, as stand density increases, the landscape would eventually move further from a sustainable forest, and increase the risk of events such as insect and disease epidemics or crown fire. Results from insect and disease epidemic would mostly likely be visible from many locations of the project area. Scenic values may be lost.

Recreational values would remain the same.

Proposed Action

Direct and Indirect Effects

Moderate Thin (Units 1 – 7, 10, 11, 14, 15, 17 – 21, 23, 26 – 28, 30- 38) The majority of units would receive a moderate thinning treatment with a residual percent canopy cover of 50 – 60%. Units 2 – 4, 6, 7, 11, 15, and 17 would be visible in the foreground from Forest Road 85. Units 11, 17 – 21, 27, 28, and 30 would be visible in the foreground from Forest Road 47. Units 32 – 35 and 37 would be visible in the foreground from Forest Road 75. The remaining units (1, 5, 10, 14, 23, 26, 31, and 38) would not be visible from main travel routes. However, units 10, 11, 18 – 21, 28, and 30 would be visible from Purcell Mountain and Whalehead Ridge.

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Heavy Thin (Units 9, 12, 16, 25/Units 8, 13, 24/Units 22, 29) These units would receive a heavy thinning treatment with residual percent canopy covers of 45 – 50%, 40 – 45%, and 10 – 15% respectively. Unit would be visible in the foreground from Forest Road 84. The remaining units would not be visible from main travel routes. However, unit 29 would be visible from Purcell Mountain and Whalehead Ridge.

Thinning of conifers would result in direct effects to scenic quality, including visible slash piles, landings, log decks, equipment staging areas, and tree stumps. These effects are unavoidable during the implementation phase, and except for tree stumps, would be short-term (one to three years).

Skyline corridors would introduce contrasting line in the landscape. Evidence of these corridors would last from five to 10 years.

New temporary roads would be constructed to access some thinning in the project area. These roads would also create visible lines that are not natural appearing and often include visible cut and fill slopes that may detract from the overall scenic quality.

Access for efficient management of vegetation would have temporary direct effects to both scenery and recreation during the implementation phase, particularly on Forest Roads 47, 75, and 85. As these roads are already in place, they would not have a direct long-term effect on scenery or recreation, and would meet the VQOs and Recreation Opportunity Spectrum of the LRMP. Improved access typically means improvements for recreationists.

Closure and stabilization of roads would have a positive effect to scenic quality. Closure of roads would have a direct effect to recreation by limiting driving access. Users could still hike in for hunting, fishing, or dispersed camping purposes.

In Units 17, 21, 27, 28, 37, and 38, wildlife openings within these units would also enlarge existing openings and create new openings. Although these wildlife openings would be evident in the landscape, their form and line would be repeated at the same scale as natural openings common in these areas. In addition, these openings would be mitigated with existing foreground vegetation and/or no-cut areas any riparian areas. In two or three growing seasons, grass and small plant species would cover the exposed ground.

For all other thinning units with project design standards in place, the effects would be expected to meet the LRMP and LSR Assessment low (modification) and high (retention) scenic integrity for these areas.

Activities related to aquatic and hydrologic function such as culvert removal, large woody debris recruitment, and cleaning of drainage structures to improve stream habitat and restore natural flow would have little to no effect on scenery or recreation.

Cumulative Effects The spatial boundaries for analyzing the cumulative effects to Scenery and Recreation are units directly adjacent to roads and as seen from certain viewing points such as Purcell Mountain because treatment activities will be visible.

The temporal boundaries are activities occurring over the next 5 – 10 years because activity schedules are often limited due to seasonal closures, weather, and contracting.

Thinning would enlarge existing openings and create new openings. In some units, created openings would add visual depth and diversity to the existing stands.

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Over time, (30 years) thinning would have created a natural appearing forest, with more large diameter trees intermixed with natural appearing openings and a diverse plant understory.

Wildlife openings would have vine maple, alder and/or huckleberry growing in them. The landscape in these areas would have an increase in hardwood diversity and distribution.

Long-term, the scenic integrity would be increased from low to high.

Regulatory Framework

Land and Resource Management Plan The Gifford Pinchot National Forest Land and Resource Management Plan provides standards and guidelines for scenic and recreational values:

Scenery Visual Quality Objectives should be considered for viewsheds seen from campgrounds, viewpoints, picnic areas, and other developed sites, as well as those seen from designated travel routes such as rivers and roads.

The Visual Quality Objectives were been mapped for the Gifford Pinchot National Forest in the Forest Plan (1990) and provide current overarching scenery management direction for the project area. In general, the project area is to be managed to provide for low scenic integrity with some areas of high scenic integrity by managing for Retention and Modification:

Retention: management activities are not visually evident to the casual forest visitor.

Modification: management activities may visually dominate the characteristic landscape. However, activities of vegetative and landform alteration must borrow naturally established form, line, color, and texture. Alterations should appear as a natural occurrence when viewed in foreground or middleground.

The table below provides a crosswalk between terminology and component changes in the Visual Management System and the Scenery Management System (See Appendix A in Agriculture Handbook 701).

Table 53. Crosswalk from Forest Plan Visual Management System to Scenery Management System

LAND AND RESOURCE VISUAL MANAGEMENT SCENERY MANAGEMENT MANAGEMENT PLAN (LRMP) SYSTEM SYSTEM

Visual Quality Objectives Scenic Integrity Objectives Management Area Categories * (VQO) (SIO)

Unroaded Recreation w/o Timber Harvest-U, Late Successional Retention High Reserve-LSR

D/E Winter Range-ES, Timber Modification Low Production-TS

*Management Area Categories identified within the project area and Visual Quality Objectives within those Categories.

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Recreation The Recreation Opportunity Spectrum class assigned in each Management Area is the minimum level acceptable and should be met by all activities. Geologic, hydrologic, and other features should be evaluated for their recreational value. Trails should be managed according to one of three management levels to which they are assigned. Facilities should be maintained to current standards. The Forest Travel Plan will provide information on where travel is permitted or limited.

Forest Management Goals

Scenery

“Provide natural-appearing scenery from the high use (most important) recreation travel routes and use areas. On other areas of the Forest, management activities may be visible, but should blend with natural conditions to the extent possible.”

Recreation

“Provide a diverse range of dispersed recreational, interpretive, and educational opportunities. Provide a full range of trail experiences and difficulty levels for a variety of users. Provide safe, well-maintained facilities for developed recreation within a range of development levels.”

Forest Management Objectives

Scenery

“Visual Quality is to be maintained in a near-natural appearance for selected scenic travel routes which include: All major scenic highway viewsheds … and most major wilderness portals. Lands within recreation allocations and lands surrounding with developed sites will be managed to maintain their scenic quality.”

Opportunities to restore landscapes containing undesirable visual impacts to a desired visual quality level will be identified. The Visual Management System is to be used in all resource programs to maintain high levels of scenic quality.

Recreation

◊ Dispersed Recreation: about 73% of the Forest will provide roaded recreation. In management areas with a recreation emphasis, the social, physical, and managerial settings will monitored to assure that recreation attributes which facilitate the desired opportunity setting are being protected the importance of driving for pleasure will be recognized in transportation planning and road management.

◊ Trails: trail system planning will continue to be an integral part of all project planning to assure continuation of a top quality trail program.

Forest Management Area Categories The Silver Creek project area is located within five Management Area Categories (MAC), including: Unroaded Recreation without Timber Harvest, Late Successional Reserve, Visual Emphasis, Deer and Elk Winter Range, and Timber Production. Management Area Goals, Desired Future Condition, and/or Standards and Guidelines as it affects timber removal and the scenic resource are addressed below.

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Unroaded Recreation without Timber Harvest (MAC-U) Desired Future Condition “A natural to predominately natural appearing environment has been maintained: changes are largely the result of natural succession; …other management activities are few in number and not conspicuous.” Vegetation may vary widely from natural openings to mature old-growth stands. Standards/Guidelines Timber Planning and Inventory: Trees may be removed for safety reasons, or to enhance recreation; e.g., to create a scenic view.

LSR (from ROD) Desired Future Condition Desired late successional and old-growth characteristics that will be created as younger stands change through successional development include: 1) multispecies and multilayered assemblages of trees, 2) moderate to high accumulations of large logs and snags, 3) moderate to high canopy closure, 4) moderate to high numbers of trees with physical imperfections such as cavities and broken tops, and 5) moderate to high accumulations of fungi, lichens, and bryophytes. Standards/Guidelines Thinning may occur in stands up to 80 years old regardless of the origin of the stands. The purpose of these silvicultural treatments is to benefit the creation and maintenance of late successional forest conditions. Dispersed recreational uses, including hunting and fishing, are generally consistent with the objectives of Late Successional Reserves. Use adjustment measures such as education, use limitations, traffic control devices, or increased maintenance when dispersed and developed recreation practices retard of prevent attainment of LSR objectives.

Deer and Elk Winer Ranger (MAC-ES) Desired Future Condition “Management activities, including timber harvest, are locally apparent. Tree species and sizes are varied and well distributed. Optimal cover may be present…..” Standards/Guidelines “….significant deference to partial retention [for] limitation on the size of regeneration timber harvest units in immediate foreground areas. ….should have little adverse effect upon deer/elk outputs across the MAC as a whole.”

Timber Production (MAC-TS) Desired Future Condition “Evidence of land managed intensively for timber production…is apparent. All tree sizes and mixtures of tree species…are well distributed. Accumulated volumes of fuels are light….” Standards/Guidelines Where appropriate, recreational activities compatible with intensive commodity management may be encouraged.

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Compliance with LRMP and Other Relevant Laws, Regulations, Policies and Plans The No Action alternative is compliant with the LRMP and other relevant plans. The Proposed Action is compliant with the LRMP and other relevant plans, given that project design features and mitigation measures are followed.

Forest Plan Consistency Summary

No Action would achieve a natural appearing forest with little evidence of management; however, as stand density increases, the potential for catastrophic disturbance becomes greater. In this case, scenic values may be lost. Recreational values would remain the same.

The Proposed Action would temporarily decrease scenic quality and, potentially, recreational values as a result of visible slash piles, landings, log decks, equipment staging areas, and tree stumps. With project design standards in place, the effects are expected to meet the LRMP and LSR Assessment for low (modification) and high (retention) scenic integrity for the project area.

Summary of Environmental Effects

No Action No action would achieve a natural appearing forest with little evidence of management; however, as stand density increases, the potential for catastrophic disturbance becomes greater. In this case, scenic values may be lost. Recreational values would remain the same.

Proposed Action Thinning would temporarily decrease scenic quality and, potentially, recreational values as a result of visible slash piles, landings, log decks, equipment staging areas, and tree stumps. These effects are unavoidable during the implementation phase, and except for tree stumps, would be short-term (one to three years). Thinning would also enlarge existing openings and create new openings. In some units, created openings would add visual depth and diversity to the existing stands.

Over time, (30 years) thinning would have created a natural appearing forest, with more large diameter trees intermixed with natural appearing openings and a diverse plant understory. Long-term, the scenic integrity would be increased from low to high.

Skyline corridors would introduce contrasting line in the landscape. Evidence of these corridors would last from five to 10 years.

New temporary roads would be constructed to access some thinning in the project area. These roads would also create visible lines that are not natural appearing and often include visible cut and fill slopes that may detract from the overall scenic quality.

Access for efficient management of vegetation would have temporary direct effects to both scenery and recreation during the implementation phase, particularly on Forest Roads 47, 75, and 85. As these roads are already in place, they would not have a direct long-term effect on scenery or recreation, and would meet the VQOs and Recreation Opportunity Spectrum of the LRMP.

Closure and stabilization of roads would have a positive effect to scenic quality. Closure of roads would have a direct effect to recreation by limiting driving access. Users could still hike in for hunting, fishing, or dispersed camping purposes.

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Activities related to aquatic and hydrologic function such as culvert removal, large woody debris recruitment, and cleaning of drainage structures to improve stream habitat and restore natural flow would have little to no effect on scenery or recreation. Economics

Existing Condition The Economic Profile System – Human Dimensions Toolkit (EPS-HDT) draws from published statistics from government sources to produce detailed socioeconomic reports of counties, states, and regions. EPS- HDT was used to create a report to show a range of measures for Lewis County, at a glance. Measures are also shown for rural parts of Washington State as a whole (“non-metro”), and the whole United States. Similarities and differences are easily recognized amongst these areas, and provide an economic context for the Silver Creek Thin.

Land Base Understanding the makeup of the land base in an area is important because some actions on federal lands may affect the local economy, particularly if federal lands are a large portion of the land base. Lewis County has a larger proportion of its land base in Federal ownership, predominantly Forest Service, as compared with the other geographies (Figure 22).

Figure 22: Percent of total land area in Federal ownership in Silver Creek Thin vicinity Use Sectors Commodity sectors consist of employment in timber, mining (including oil, gas, and coal), and agriculture (Figure 23). These sectors have the potential to use federal public lands (for example, for timber harvesting, energy development, and grazing, and recreation) for the extraction of commodities. Lewis County has a higher percentage of employment in the timber sector (10.94%) than other sectors

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within the county, and a greater percentage of jobs in commodity sectors than non-metro Washington or the USA in general.

Figure 23. Commodity Sectors as Percent of Total Employment in Silver Creek Thin vicinity Travel and tourism sectors provide goods and services to visitors to the local economy, as well as to the local population. These industries are retail trade; passenger transportation; arts, entertainment and recreation; and accommodation and food services. The exact proportion of the jobs in these sectors attributable to expenditures by visitors, including business and pleasure travelers, versus by local residents, is unknown. In 2011, Lewis County had around 15% of jobs in industries that relate to travel and tourism, which is similar to the national percentage (Figure 24). However, the proportion of that industry related to recreation is smaller in Lewis County than either non-metro Washington, or the US overall. Public lands play an important role in stimulating local employment by providing opportunities for recreation. Communities adjacent to public lands can benefit economically from visitors who spend money in hotels, restaurants, ski resorts, gift shops, and elsewhere. While the information in this report is not an exact measure of the size of travel and tourism sectors, and it does not measure the type and amount of recreation on public lands, some proportion of this industry near the Silver Creek Thin project is likely recreational hunting, camping, and hiking on the National Forest.

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Industries that include Travel & Tourism, Percent of Total Private Employment, 2011 20% 18% 16% 14% 12% 10% 8% 6% 4% 2% 0% Washington Lewis County, U.S. Non-Metro WA Retail Trade Arts, Entertainment, & Recreation* Passenger Transportation* Accommodations & Food*

Figure 24. Industries including travel and tourism in Silver Creek Thin vicinity

Economy In many counties, non-labor income (e.g., retirement and investment income, government transfer payments) can be more than a third of all personal income. As the baby boomer generation retires, this source of income will continue to grow. A high dependence on non-labor income can be an indication of an aging population and/or the attraction of people with investment income. Public lands activities may affect these constituents. Lewis County residents rely slightly more on non-labor income than the other non-metro Washington areas reported, the USA as a whole (Fig. 25 ).

Non-Labor Income, Percent of Total Personal Income, 2011 60% 49.6% 50% 47.3%

40% 34.1% 30%

20%

10%

0% Washington Lewis County, U.S. Non-Metro WA

Figure 25. Non-labor income as percent of total personal income in Silver Creek Thin vicinity

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Nationally, services account for more than 99 percent of new jobs growth since 1990. If services are a large proportion of existing jobs and a large portion of new jobs, public lands may play a role in creating a setting that attracts and retains service-related businesses. Recreational and environmental amenities of public lands may also serve to attract temporary or seasonal service occupations. Lewis County had slightly lower private employment in services as compared with the other locales (75.7%, Figure 26).

Figure 26. Services as percent of private employment in Silver Creek Thin vicinity Government can be a major employer in some locales, particularly in rural areas or where significant government facilities are located, such as Forest Service offices. Federal employment related to public lands provides relatively stable and high wage jobs in many communities. Despite the large federal land base, government employment in Lewis County is lower than typical for non-metro Washington (Fig. 27).

Figure 27. Government employment as percent of total in Silver Creek Thin vicinity

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Summary Not all counties, regions, or states are the same. It is important to understand the differences and similarities between locales because land management actions may affect areas differently, depending on demographics, the makeup of the economy, and land use characteristics. This analysis highlighted some of the key factors related to the economic context of the Silver Creek Thin project. Other statistics and reports that may provide more depth to this summary are available in the project record and through the EPS-HDT website (Headwaters Economics 2013).

Effects

Financial Analysis A financial analysis of the proposed action for Silver Creek Thin project was prepared to display anticipated costs and revenues.

Most of the project is assumed to be implemented within a five-year time span. No inflationary rate, discount rates, or changes in real value were used for costs and benefits. These rates and changes are assumed to be offsetting within this relatively short time span. All values displayed in the table below are in present (2015) U.S. dollars.

Table 54. Silver Creek Timber Sale Revenue and Costs

Action Alternative Purchaser Elements $/Unit Units Value

Road Reconstruction ($1,170,000)/total 1 ($1,170,000) Road Maintenance ($131,460)/total 1 ($131,460) New Non-system Road Construction ($25,000)/mile 7.41 ($185,250) Existing Non-system Road Reconstruction ($15,000)/mile 7.43 ($111,450) Non-system Road Stream Crossing Construction ($2,500)/crossing 4 ($10,000) Logging – Ground Based (stump-to-truck) ($122)/mbf 7,795 ($950,990) Logging – Skyline (stump-to-truck) ($200)/mbf 28,989 ($5,797,800) Logging – Helicopter (stump-to-truck) ($500)/mbf 1,221 ($610,500)

Log Haul ($60)/mbf 38,005 ($2,280,300) Slash Piling – Machine ($281)/acre 256 ($71,936) Cover Slash Piles ($70)/acres 256 ($17,920) Erosion Control (landings) ($420)/acre 127 ($53,340) Timber Value – Douglas-fir $342/mbf 19,053 $6,516,126 Timber Value – Hem /Fir $304/mbf 18,952 $5,761,408

Subtotal Sale Revenue $356,588

Purchaser Competition Factor (40%) ($142635) Subtotal Sale Revenue $213,953 Forest Service Elements

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Action Alternative Purchaser Elements $/Unit Units Value

Minimum Deposit to National Forest Fund ($0.50)/mbf 38,005 ($19,003) Road Maintenance Deposits ($2.06)/mbf 38,005 ($78,290) Brush Disposal Deposits – Burn Piles ($26)/acre 256 ($6,656)

Total FS Required Deposits ($103,949) Total Sale Net Value $110,004 Total Sale Net Value per MBF $2.90

The timber sale portion of the project is profitable to the sale purchaser and would yield revenue in excess of that needed to cover Forest Service required deposits.

Historically, timber values have increased in real dollars over time. Timber values have declined over the past year but have shown a slight increase recently with some instability. Fuel prices are another important variable that can fluctuate over short time periods. Fuel prices affect nearly all logging cost centers. These two elements, timber value and fuel costs, will have a strong influence on the revenue generated by this sale.

Depending upon the type of sale, revenue in excess of what is needed for the Forest Service elements listed above are either returned to the U.S. Treasury and a proportion of the receipts are redistributed to local county governments or retained for local stewardship projects. Other benefits to the economy are generated by providing timber products, employment from the implementation of the project and employment from processing and manufacturing the raw wood material.

Economic Measures The timber benefit, less competition factor, is $12,134,899. Costs total $12,024,895. Thus, the present net value is $110,004. The benefit to cost ratio is $1.01:1. Climate Change

Existing Condition A growing body of scientific evidence and climate modeling indicate that climate change is occurring. There is still substantial uncertainty at regional and sub-regional scales as to future climate and ecosystem responses, much less the interactions between them. Nevertheless, the Washington Climate Change Impacts Assessment (Littell et al. 2009) suggests that models generally agree on several key trends, including:

• April 1 snowpack will decrease by over 25% across the state by 2020, which will shift stream flow in sensitive watersheds;

• Increased summer temperatures and decreased summer precipitation are projected to double the area burned in wildfire by 2040;

• Rising stream temperatures will likely reduce the quality and extent of freshwater salmon habitat, discussed in detail on the next page.

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Some believe climate change is not occurring or that it is not human-caused. This document does not present arguments on any of these concepts, which are well documented elsewhere. This project was not designed to specifically mitigate or respond to potential climate change. This section addressed aspects on the forest’s ability to deal with climate change. This analysis will not attempt to quantify carbon emissions or sequestration.

This project involves thinning of plantations, thinning for forest health and habitat improvement including to develop late successional character in second-growth stands. These objectives are detailed further in the Purpose and Need and Vegetation sections of the EA. Rapidly growing forests are recognized as a means of carbon sequestration (FAO 2007).

Climate Change and Fisheries Climate change is likely to play an increasingly important role in determining the abundance of fish including ESA- listed species, and the conservation value of designated critical habitats, in the project area and larger Pacific Northwest region. These changes are likely to be recognizable in most of the Silver Creek planning area, which is thought to be in the elevation zone of influence of climate change. Low- elevation areas are likely to be more affected due to higher temperatures and reduced snowpack. Areas with elevations high enough to maintain temperatures well below freezing for most of the winter and early spring will be less affected.

During the last century, average regional air temperatures increased by 1.5°F, and increased up to 4°F in some areas. Warming is likely to continue during the next century as average temperatures increase another 3 to 10°F. Overall, about one-third of the current cold-water fish (e.g. trout and salmon species), habitat in the Pacific Northwest is likely to exceed key water temperature thresholds by the end of this century (USGCRP 2009).

Precipitation trends during the next century are less certain than for temperature but more precipitation is likely to occur during October through March and less during summer months, and more of the winter precipitation is likely to fall as rain rather than snow (ISAB 2007; USGCRP 2009). Where snow occurs, a warmer climate will cause earlier runoff so stream flows in late spring, summer, and fall will be lower and water temperatures will be warmer (ISAB 2007; USGCRP 2009).

In sensitive watersheds such as Silver Creek, higher winter stream flows increase the risk that peak flows associate with higher magnitude winter floods in will damage spawning redds and wash away incubating eggs. Earlier peak stream flows will also flush some young salmon and steelhead from rivers to estuaries before they are physically mature, increasing stress and the risk of predation. Lower stream flows and warmer water temperatures during summer will degrade summer rearing conditions, in part by increasing the prevalence and virulence of fish diseases and parasites (USGCRP 2009). Other adverse effects are likely to include altered migration patterns, accelerated embryo development, premature emergence of fry, variation in quality and quantity of tributary rearing habitat, and increased competition and potential predation risk from warm-water, non-native species (ISAB 2007).

The earth’s oceans are also warming, with considerable inter-annual and inter-decadal variability relative to historic trends (Bindoff et al. 2007). Historically, warm periods in the coastal Pacific Ocean have coincided with relatively low abundances of salmon and steelhead, while cooler ocean periods have coincided with relatively high abundances (Scheuerell and Williams 2005; USGCRP 2009; Zabel et al. 2006). Ocean conditions adverse to salmon and steelhead may be more likely under a warming climate (Zabel et al. 2006).

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Effects

No Action As no vegetation manipulation would occur and no burning would take place, current carbon sequestration rates would remain similar, and no additional carbon would be released into the atmosphere. The No Action alternative would not result in additional carbon emissions from vehicles or burning, and would result in retention of carbon in relatively slow-growing or stagnated trees. Natural mortality that occurs would be retained on-site, unless wildfire or other disturbance occurs to consume trees or move them off-site.

Proposed Action This project is not likely to have direct localized effects on climate. The discussion of a project’s effect on climate change is inherently indirect and cumulative because the effects occur at a different time and place, and because the scale of the discussion is global. Since it is not reasonable to measure a project’s global impact, the discussion here focuses on key elements of forest management discussed in the scientific literature.

For this proposal, the following actions have the potential to affect carbon emissions or sequestration:

• Thinning to enhance health of the residual stand would result in trees that are better able to withstand stresses such as drier summer conditions (Millar et al. 2007)

• Variable density thinning with skips and gaps and retention of minor species would result in stands that are resilient and better able to respond to whatever changes come in the future (Millar et al. 2007);

• Fossil fuel would be used by equipment such as saws, tractors, skyline yarders, log trucks, and helicopters. It would possible for some of this equipment to use biofuels if available and priced competitively.

• Excess logging debris at landings and along major roadways would be burned on site in piles, releasing carbon into the atmosphere. Residual and natural fuel accumulations that do not present a wildfire hazard would be left in units to decompose naturally, which would release carbon more slowly into the soil and atmosphere.

In summary, the Proposed Action would result in some carbon sequestration and some carbon emissions. The vegetation treatments in the Proposed Action are intended to promote forest health and resiliency by creating conditions that allow stands and riparian areas to better respond and adapt to future climate change. In addition, closure and stabilization of roads, repair of existing roads, riparian down wood and in-stream treatments, and rehabilitation of dispersed recreation sites will all serve to improve riparian resistance and resilience to extreme precipitation events that may occur due to climate change.

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Other Environmental Consequences and Required Disclosures This section addresses those effects for which disclosure is required by NEPA regulations, Forest Service policy or regulation, Executive Order, or other laws and direction covering environmental analysis and documentation. In some cases, the information found here is also located elsewhere in the document.

Conflicts with other Plans, Policies, or Other Jurisdictions This project would not conflict with any plans or policies of other jurisdictions, including Tribes and neighboring public and private landowners. This project would not conflict with other policies, regulations, or laws, including the Clean Water Act, Endangered Species Act, National Historic Preservation Act, Magnuson-Stevenson Fishery Conservation and Management Act, and Clean Air Act. Other potential conflicts with plans, policies, or other jurisdictions are discussed below.

Environmental Justice Executive Order 12898 (February 11, 1994) directs federal agencies to focus attention on the human health and environmental condition in minority and low-income communities. The purpose of the Executive Order is to identify and address, as appropriate, disproportionately high and adverse human health or environmental effects on minority and low-income populations. While the sale of National Forest timber and restoration work could create or sustain jobs and provide consumer goods, neither of the alternatives would have disproportionately high or adverse human health or environmental effect on minority and low-income populations. The proposed action, including all vegetation management, connected actions, and restoration activities, may provide an increased benefit to diverse public entities and businesses.

Treaty Resources and Reserved Indian Rights There will be no impacts on American Indian social, economic, of subsistence rights due to this project. No impacts are anticipated related to the American Indian Religious Freedom Act. Tribes contacted regarding this Proposed Action are listed on the final page of this document.

Wetlands and Floodplains The known wetlands in the Silver Creek Thin project area will not be affected or will benefit because they would be sufficiently buffered from any vegetation management activities except for those specifically designed to improve wetland characteristics. Additional project design measures to protect streams, wetlands, and water quality will be built into treatment activities as described in the Proposed Action and Project Design Criteria, EA pages 12-41. Therefore, there will be no effect on wetlands and floodplains.

Unique Characteristics of the Area There are no parklands, farmlands, rangelands, wildernesses, potential wildernesses (PWAs), inventoried roadless areas (IRAs), unroaded areas, research natural areas, wild and scenic rivers, or ecologically critical areas within the Silver Creek Thin project area. Therefore, none of these features would be affected by the prosposed action. A map and complete description of land use allocations and appropriate uses is on page 10.

Air Quality and Sensitive Airsheds Ambient air quality is defined by the Clean Air Act of 1970 as the air quality anywhere people have access, outside of industrial site boundaries. Ambient air quality standards are designed to protect human health, welfare, and environmental quality. Air resource management includes any activity to anticipate, regulate, or monitor air pollution, air pollutant emissions, ambient air quality, or the effects of air pollution resulting from fires or fire management. The Clean Air Act requires the Environmental

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Protection Agency (EPA) to set National Ambient Air Quality Standards (NAAQS) and thresholds for criteria pollutants to control pollution and protect public health, safety, and welfare. Furthermore, the Clean Air Act establishes state-level responsibilities for preventing and controlling air pollution. Emissions from forest burning in Washington are regulated by the Washington Clean Air Act (RCW 70.94, 1991) and the Department of Natural Resources Smoke Management Plan (1998). Activities that include burning will follow guidelines in the Best Smoke Management Practices publication issued by the USDA Forest Service and USDA Natural Resources Conservation Service (O’Neill et al., 2011) to minimize the impacts of smoke. Guidelines include evaluating smoke dispersion, monitoring the effects of smoke on air quality, communicating with the public, considering emissions reduction techniques, and sharing the airshed by coordinating prescribed fire activities with adjacent landowners.

Sensitive Airsheds The Clean Air Act identifies three classes of airsheds (I-III). Increases in sulfur dioxide and particulate matter concentrations are highly restricted in Class I airsheds (FSM 5280). Wilderness areas that were designated prior to 1977 and exceed 5,000 acres are classified as Class I airsheds. Wilderness areas designated after 1977 are typically Class II airsheds. Sensitive airsheds that could be affected by debris burning in Silver Creek Thin are listed below. No non-attainment areas exist in the vicinity of the Silver Creek planning area.

Sensitive Area Sensitivity Classification Distance and Direction from Project (approx. distance from nearest stand)

Goat Rocks Wilderness Class II 15 miles E and SE Mount Rainier NP Class I 8 miles N

Potential or Unusual Expenditures of Energy The no-action alternative would not require any expenditure of fuel or energy. The Proposed Action would require expenditures of fuel for workers to access the project area, use power equipment, and to conduct logging and restoration activities. Jet fuel for helicopter operations would also occur where economically viable to do so. Overall, the proposed action would not result in any unusual expenditure of fuel.

Irreversible and Irretrievable Commitments of Resources Irreversible commitments of resources are those that are forever lost and cannot be reversed. Irretrievable commitments of resources are considered those that are lost for a period of time, and in time, can be replaced. No irreversible or irretrievable commitments of resources are expected to occur due to implementing the proposed action.

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Agencies, Tribes, and other Entities Consulted The Forest Service also invited several Federal, State, and tribal entities to engage in informal or formal comment, discussion, and/or consultation on this EA. Indian Tribes In compliance with 36 CFR 800.3(f), initiation of the NHPA Section 106 process included notification to four federally-recognized tribes, including the Cowlitz Indian Tribe, Squaxin Island Tribe, Nisqually Indian Community, and the Yakama Nation. Notification letters were sent on June 9, 2014 to the designated cultural resources program manager for each of the Tribes with an invitation to consult regarding the proposed project. No decision on the Silver Creek Thin project will be made until tribal consultation has concluded. Washington State Historic Preservation Office A copy of the heritage survey report was also submitted to the Washington State Historic Preservation Office (SHPO). Prior to a decision being made, the Forest Service must receive concurrence with the survey report and findings from the State Archaeologist on behalf of SHPO. US Fish and Wildlife Service Per regulations on interagency cooperation pursuant to Section 7 of the Endangered Species Act (1973), as amended, the Forest Service submitted a Wildlife Biological Assessment (BA) to the Department of Interior - US Fish and Wildlife Service (FWS) on August 31, 2015 to initiate formal consultation for the Silver Creek Thin proposed action. The following determinations were submitted: May Affect, Not Likely to Adversely Affect gray wolf; May Affect, Likely to Adversely Affect marbled murrelet (MAMU); May Affect, Likely to Adversely Affect northern spotted owl (NSO); May Affect, Likely to Adversely Affect Critical Habitat for marbled murrelet; May Affect, Likely to Adversely Affect Critical Habitat for northern spotted owl.

A Fisheries Biological Assessment was also submitted to FWS with a determination of No Effect for Columbia River Bull Trout (Salvelinus confluentus).

FWS responded to the BA with a Biological Opinion for the Silver Creek Thin project on January 29, 2016 with the following opinions: Not Likely to Jeopardize marbled murrelet and northern spotted owl; Not Likely to Adversely Modify designated critical habitat for marbled murrelet and northern spotted owl. FWS noted that the Silver Creek Thin Proposed Action incorporates conservation measures sufficient to minimize the impact of incidental take on the marbled murrelet; no incidental take is anticipated or exempted for the northern spotted owl. The Forest Service will comply with Terms and Conditions, which implement Reasonable and Prudent Measures required by FWS. Conservation Measures that were recommended in the BO will be considered by the Responsible Official in making a final decision on this project.

A separate concurrence finding was included with the Biological Opinion for a May Affect, Not Likely to Adversely Affect for endangered gray wolf. National Marine Fisheries Service The Forest Service submitted a Fisheries Biological Assessment (BA) to NOAA National Marine Fisheries Service (NMFS) on August 21, 2015 with determinations for listed fish species and their habitat as follows: May Affect, Likely to Adversely Affect for Lower Columbia River (LCR) steelhead trout

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(Oncorhynchus mykiss), LCR Chinook salmon (O. tshawytscha), and LCR Coho salmon (O. kisutch); May Affect: Essential Fish Habitat; May Effect, Likely to Adversely Affect Critical Habitat for Lower Columbia River (LCR) steelhead trout (Oncorhynchus mykiss) and LCR Chinook salmon (O. tshawytscha).

A Biological Opinion was returned to the Forest Service by NMFS on May 13, 2016, concluding that the Silver Creek Thin Proposed Action is not likely to jeopardize the continued existence of LCR Coho salmon, LCR Chinook salmon, or LCR steelhead and that the proposed action is not likely to adversely modify critical habitat for these species, and providing two non-discretionary reasonable and prudent measures along with terms and conditions for implementing them, all of which will be incorporated into project implementation. The BO further discusses effects to Pacific Coast Salmon Essential Fish Habitat and provides two conservation recommendations to protect, avoid, or minimize adverse effects to EFH. Conservation recommendations in the BO will be considered by the Responsible Official in making a final decision on this project.

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Appendix A: Issues Raised During Scoping

Scoping Comment Received Interdisciplinary Team Discussion Theme

Roads

I very strongly recommend 1) The crossing of the East The team discussed the subject of a potential crossing of East Fork Reconstruction / Economics Fork of Silver Creek be replaced, 2) But only with a low Silver Creek at length due to a number of factors, including the high / Flood Hazard / Historic removable bridge that, with its piers, would be public interest in restoring access to the forest on FR 47; a concern Information removed through winters. (several attachments and for the economic and logistical feasibility of hauling timber from the additions to scoping letter were also received detailing subwatershed without a crossing at this location; and, the potential the history of the 47 road, the previous crossings, and ecological and human impacts of placing another structure that could history of right of ways in that area) catastrophically fail in the path of flood debris and impact downstream communities. The team agreed there is no simple The great justification for constructing the difficult and solution to this issue and so the deciding official requested a expensive seven mile road from Randle into the upper preliminary economic analysis to determine the cost of constructing a Silver Creek drainage was recognized- that is why the variety of types of crossings (including a temporary bridge) at this extraordinary effort and expense was expended to location to inform the economic analysis of the project. An economic build the road in the late 1960's. analysis will be included in the EA that will include the anticipated haul cost. In addition, the cost estimates for types of crossings that A) Access to this area from the Cowlitz Valley Ranger would be feasible at this location will be discussed whether or not it is Station administrative office via this road is very, very included as a part of the proposed action or alternative. much shorter than by any alternative route.

B) Without this road, haul of forest products would require that the haul expensively lift the products over mountain passes of 3,000 ft. or higher elevation and over much longer roads.

C) In full protection of the environment downstream, most especially of the residents, homes and other human improvements downstream, the crossing structure must not increase the likelihood or impact of

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Scoping Comment Received Interdisciplinary Team Discussion Theme

any flood or landslide event in the East Fork of Silver Creek.

D) The low removable bridge will be very much less expensive to construct than the $5 million bridges suggested. The seasonal removal of the bridge and piers should be easy and inexpensive by just the Forest Service road crew. Either a railroad flat car bridge (lightweight, so preferable) or an Army Bailey Bridge is suggested, with lightweight removable steel ramps and piers at each end. If a Bailey Bridge is used, the Army might handle its construction and seasonal removal as an exercise for low cost. To me, considering a multi-million-dollar bridge here is grotesquely unreasonable- East Fork of Silver Creek is just “not that big of a deal.”

Any action on the existing log jam and landslide debris The team discussed a project at this location and concurred that Flood hazard there (at FR 47 crossing with East Fork Silver Creek) disturbing or dislodging the log jam and debris at this crossing would should be very carefully considered. Removal should not be prudent. be done only if it is certain to decrease the likelihood or impact of a future event. My feeling is that careful consideration would conclude that it should not be disturbed.

I suggest the Bin Wall retaining walls at MP 5 be Thank you for sending this valuable historic information. If this section Historic Information inspected by an engineer familiar with them, perhaps of road becomes a candidate for use in the proposed action, the by someone from the successors to the Armco retaining walls will be inspected (and we will send you some manufacturer. pictures!).

Opportunities to invest in this infrastructure through the The team recognizes the importance of providing a system of road Access / Maintenance maintenance and improvement of systems roads infrastructure that will support a variety of forest uses but we are also

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Scoping Comment Received Interdisciplinary Team Discussion Theme

should be evaluated. This maintenance can lead to mandated to respond to existing (and declining) road maintenance reduction and elimination of potential sediment delivery budgets, and of course the human and ecological risks caused by the sources, while maintaining access for the various road system. Timber projects are one way to leverage additional users. funds to provide critical upkeep and maintenance of roads to address resource damage and safety issues, and the team will seek to produce a balanced access management proposal in this project.

The use of new temporary roads and existing non- The interdisciplinary team is seeking access management solutions Temporary roads system roads will help to reduce logging costs. When for efficient harvest of timber while still minimizing the extent of new BMPs are used, these roads can be relatively low disturbance in the project area and responding to soil and geologic standard roads and then decommissioned as planned. instability in the Silver Creek area.

Include an analysis of effects of temporary roads and The effects of any road construction or reconstruction (temporary and Effects road reconstruction proposed and the economic and system) will be analyzed and disclosed in the EA. The IDT typically ecological tradeoffs of individual road segments. reviews every candidate stand as a group, with the line officer present, to make clear the economic and ecological tradeoffs being made in the context of vegetation and/or road treatments proposed. These “stand by stand” discussions will be documented and feed into the analyses disclosed in the EA.

The scoping letter proposes to construct an The EA will disclose any proposed road construction or Road construction undisclosed amount of road. This violates the law. reconstruction. It is essential for IDT specialists to have site-specific road information to conduct their analyses and make determinations with a reasonable degree of confidence. At the time of the scoping letter, exact road segments and locations were not established, as the proposed action was still being refined.

Roads damage the proper ecological functioning of the We acknowledge that roads can cause impacts to natural resources, Effects natural resources in a forest (numerous views and and these will be analyzed and disclosed in the EA. Any temporary citations opposing forest road construction are roads needed for the proposed action would be closed and stabilized following use for harvest. The team is also looking at additional roads

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Scoping Comment Received Interdisciplinary Team Discussion Theme

attached to this assertion); temp roads should be to close and stabilize in the project area to reduce risk to natural obliterated after use resources.

Increase number of miles of road to close and stabilize Currently the Forest Service is unable to fully fund the maintenance Decommissioning or decommission in areas that are have sensitive of all existing roads on the Forest. Lack of road maintenance poses habitats or where roads are having significant effects environmental and safety risks. It is important to address these to water quality in the project area issues through decommissioning or closure and stabilization, where appropriate, such as where future management activities are not expected to occur. The line officer has asked the team to consider only closure and stabilization, not decommissioning, based on public and interdisciplinary input. A preliminary list of roads to propose for closure is being derived from a variety of criteria based on known future management needs, aquatic and terrestrial risk posed by the road, and feasibility to analyze within the scope of this project.

Vegetation Management / Silvicultural Prescription

Logging “plunders and desecrates the land” (numerous The thinning prescriptions proposed will be consistent with direction Effects views and citations opposing timber harvest are provided in the NWFP and Forest Plan for Late Successional attached to this assertion) Reserve and Matrix, are consistent with the National Forest Management Act, and are based on a synthesis of established silvicultural science. We understand that public perception of timber harvest is controversial; however, there is a solid scientific foundation for use of thinning in this region to both enhance ecological values and provide economic benefit.

Discuss what resources or conditions will be “restored” The Purpose and Need for commercial harvest of timber is clearly Effects by logging the forest. Timber sales should not be stated to be partially for the economic benefit of the community. called “restoration projects” (numerous views and Where commercial harvest is proposed and also benefits some citations opposing logging are attached to this request aspect of forest structure, composition, and function, it will be and assertion). disclosed and explained in the EA. Other restoration projects that

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Scoping Comment Received Interdisciplinary Team Discussion Theme

might be proposed will be explained in the EA to detail their potential consequence or benefit on ecosystem health.

Maximize acres treated in this planning area. 3500 The acres proposed for treatment in the planning area will represent Area treated / LSR acres is only about 50% or less of Silver Creek a variety of factors including those you mention such as stand age, subwatershed. Particularly treating LSR before they management allocation, future production and management activities reach 80 years and maintaining future production of in the area, access, feasibility, and a suite of natural resource Matrix lands. considerations that must be given in any stand. It is also important to note that approximately 30% of the Silver Creek subwatershed is private land, and outside of Forest Service jurisdiction.

To meet Purpose and Need, make treatments The team appreciates the desire to make the project commercially Logging systems / commercially viable through selection of appropriate viable in all aspects (vegetation management, restoration, etc.). Economics harvest systems and temp/system road work to access harvest units. Suggestions include: Maximize use of The line officer has identified a logging systems specialist who will be ground-based harvesting and yarding to enhance part of the IDT in order to bring “implementation savvy” to the commercial viability; Downhill yarding in a thinning will discussion of feasibility on any vegetation treatments proposed in this be less expensive and should have less residual stem project. In addition, contracting officers and administrators participate damage with a wider spacing; Maximizing volume per during the planning process to help provide insight into the tradeoffs acre removal for helicopter units can lower the associated with selecting one harvest system over another. It is harvesting cost/mbf. This can also reduce the need to important for the IDT to be aware possible harvest systems in a given return for additional removals in the near term when stand to be able to conduct their analyses and make determinations volume per acre may not be substantial enough to with a reasonable degree of confidence. support helicopter operations.

Consider hardwood removals where appropriate to The team will investigate hardwood removal opportunities in the Hardwoods / Economics support hardwood processors infrastructure. planning area. The IDT will investigate where there may be Investigate opportunities to convert hardwoods to opportunities to use commercial or non-commercial vegetation conifer in riparian reserves. treatments in Riparian Reserves to accomplish restoration objectives, while maintaining consistency with Aquatic Conservation Strategy Objectives.

226 Silver Creek Thin EA January 2017

Scoping Comment Received Interdisciplinary Team Discussion Theme

The thinning prescription appears to be well thought The thinning prescriptions proposed will be consistent with direction Habitat / Fire Hazard / out but it is important to maintain sufficient canopy provided in the NWFP and Forest Plan for Late Successional Climate Change cover to keep the forest soils and underbrush moist Reserve and Matrix, are consistent with the National Forest and cool, and keep streams cool, particularly as our Management Act, and are based on a synthesis of established summers get warmer and drier. Heavy thinning also silvicultural science. The effects on understory vegetation, soils, fire, increases fire danger by allowing more drying of stream temperatures, and many other resources will be discussed in underbrush and soils. We also need to leave trees the in the EA. standing for future generations’ benefit. Wherever thinning is proposed, there will be a plan to deal with slash that may contribute to fire hazard.

Supportive of thinning in crowded plantation stands of Stands (plantations or naturally regenerated) evaluated for Plantations vs. Naturally 40-80 years only. Avoid thinning in older, naturally silvicultural treatment in this project will be reviewed and analyzed to Regenerated Stands regenerated stands. determine appropriate prescriptions based on their management objectives (as described in the NWFP and Forest Plan), natural resource concerns (including riparian areas, old-growth or legacy features, special species or habitats), and practical considerations (economic value, road access). The majority of stands initially identified in the project area are indeed plantations, but if there are opportunities to meet the purpose and need for the project in naturally regenerated stands while maintaining “natural” characteristics and protecting resources, the team is directed by the deciding official to do so.

Create larger openings in stands to stimulate forage The team will investigate opportunities, where appropriate, to create Early Seral species for ungulates forage openings in the project area. It is unclear what would be a “larger” opening (not specified in the letter received).

Urge that early seral openings are kept small and The team is not sure what is meant by “traditional clearcut” because Early Seral consideration is given to mimic natural disturbance this type of harvest varies dramatically based on land ownership and (leaving legacy features such as snags and downed management objectives. The goal for early seral openings in this project would be to highlight and retain complexity where it exists in

227 Cowlitz Valley Ranger District

Scoping Comment Received Interdisciplinary Team Discussion Theme

wood) to have a more modest prescription than stands that are appropriate to harvest in this manner. Project design traditional clearcuts measures will be included in the proposal to set size limits and provide for protection of important legacy features and species.

Implement a monitoring plan to assess effectiveness Monitoring for any aspect of the project will be discussed by the team Early Seral and effects of early seral treatments on such aspects and disclosed as part of the proposed action (project design criteria). as vegetation recruitment, understory regrowth, The items you identify would provide useful information for future invasive species recruitment, use of area by similar projects on the North Zone and could be relevant to other herbivores, and edge effects on surrounding forest Forests.

I have NO issues with regen harvesting as long as The team will see what opportunities exist for regeneration harvest in Regeneration harvest you're not on super-steep slopes and you're at least a the planning area that are consistent with management direction and couple tree lengths away from Class I and Class II still allow protection of Riparian Reserves and steep or unstable streams. slopes.

Thin more heavily overall than what is typical in LSR The thinning prescriptions proposed are consistent with direction LSR particularly in stands 60 or over since it is likely they provided in the NWFP and Forest Plan for Late Successional will not have another entry. Reserve and Matrix, are consistent with the National Forest Management Act, and are based on a synthesis of established silvicultural science. Timber production for economic benefit is only one goal of the Silver Creek Thin project; ultimately, the purpose in LSR is to help stands develop more quickly into “old growth” stands.

FS should include prescription to produce snag trees The vegetation prescription must be consistent with developing late Endangered Species for marbled murrelet habitat and leave areas with successional characteristics inside LSR portions of the project area. important habitat for murrelet outside any gaps Project design criteria for improving wildlife habitat and protecting created. marbled murrelet critical habitat and limiting disturbance to potential nesting murrelets will be included in the proposed action. Marbled murrelet is an important wildlife concern in the Silver Creek Thin area, and effects on the murrelet will be evaluated and disclosed to

228 Silver Creek Thin EA January 2017

Scoping Comment Received Interdisciplinary Team Discussion Theme

the Fish and Wildlife Service through a Biological Assessment and Level 1 consultation process.

Concerned about proposal to thin in plantations near Project design criteria for improving wildlife habitat and protecting Endangered Species historic Northern Spotted Owl sites and in NSO critical NSO critical habitat and limiting disturbance to potential nesting habitat. FS activities should not add to pressure on spotted owls will be included in the proposed action. Effects on the spotted owls or adversely modify their habitat. NSO and its critical habitat will be evaluated and disclosed to the Fish and Wildlife Service through a Biological Assessment and Level 1 consultation process.

Avoid thinning in Riparian Reserves (outside a Width of the Riparian Reserves and of the “no harvest” buffer (if Riparian Reserves minimum 100 foot buffer) to support ACS objectives different) will be discussed by the IDT. The no-commercial harvest and avoid impacts to 303d listed Silver Creek and buffer for class I-IV streams will be clearly articulated in the proposed federally listed salmonids in the Upper Cowlitz action (project design criteria) and the team will seek to not prevent watershed. Leave any trees cut in Riparian Reserves attainment of Aquatic Conservation Strategy Objectives with the onsite. selected buffers. The IDT will investigate where there may be opportunities to use commercial or non-commercial vegetation treatments in Riparian Reserves to accomplish restoration objectives, while maintaining consistency with Aquatic Conservation Strategy Objectives.

Two tree lengths should be plenty of buffer for Class I Width of the Riparian Reserves and of the “no harvest” buffer (if Riparian Reserves and Class II streams. different) will be discussed by the IDT. The no-commercial harvest buffer for class I-IV streams will be clearly articulated in the proposed action (project design criteria) and the team will seek to not prevent attainment of Aquatic Conservation Strategy Objectives with the selected buffers.

There's no reason to NOT thin in riparian zones if the The IDT will investigate where there may be opportunities to use Riparian Reserves areas are overcrowded with Douglas Fir - open them commercial or non-commercial vegetation treatments in Riparian

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Scoping Comment Received Interdisciplinary Team Discussion Theme

up and allow some space for Western Red Cedar and Reserves to accomplish restoration objectives, while maintaining Big Leaf Maple and other species. consistency with Aquatic Conservation Strategy Objectives.

Economics

Supportive of second bullet in Purpose and Need. The Most of the IDT lives near the planning area in the community of Purpose and Need economic benefits created in the local communities will Randle, WA, and directly understands the importance of this and serve to help support this and future projects by similar projects to the livelihoods of the community. Infrastructure helping to secure the existing forest industry needed to support this project will be considered throughout the infrastructure. This infrastructure not only includes the analysis. milling facilities, but also the logging, trucking, road construction, and road maintenance operators. Additionally the secondary jobs in the communities depend on this economic activity for their success.

Consider expanding operating windows to the Winter closures and other timing restrictions will be required for this Operating restrictions maximum practically allowed, including options for project to limit disturbance to endangered species (northern spotted winter logging operations, to make for a more owl, marbled murrelet) and other wildlife. Wet season operation will economical thinning project. only be permitted with implementation of specific mitigation measures and monitoring of soil, water quality, and weather indicators to determine whether mitigations are effective. These measures are considered integral to any harvest program to ensure compliance with Clean Water Act, Endangered Species Act, and other laws. Economics are only one facet of the purpose and need of the project, and a variety of resource concerns must be considered in implementation.

Include a local market lumber analysis in the EA or An economic analysis will be included in the EA as well as disclosure Economic analysis DEIS that includes: of the communities and business sectors potentially affected by the proposal.

230 Silver Creek Thin EA January 2017

Scoping Comment Received Interdisciplinary Team Discussion Theme

1) the name(s) of the communities and mills that need the forest products,

2) the current volume under contract for these mills and volume in the log-yard,

3) how you became aware of the mill’s need for volume,

4) other tourist dependent businesses in these communities (motels, restaurants etc.) that could be harmed by more logging in the area,

5) the effect to the financial viability of the community and mill if this sale isn’t purchased by the local mill, and

6) measures that will be taken to assure mills outside the local area will not purchase the Silver Creek timber sale. NEPA

Nowhere in the organic Act or any other law or USFS The management direction, policy, and other guidance that are the Purpose and Need policy does it state that removing trees to feed lumber foundation for the purpose and need will be discussed in the EA. mills is a legitimate reason to log (and damage) public land.

The scoping letter is silent on monitoring. Read 40 The EA will discuss any monitoring that will be required or Monitoring CFR 1505.3(d) And include a monitoring plan in the recommended as part of the proposed action and its objective. This EA (letter includes a list of specific items to include in had not been identified at the time of scoping. 40 CFR 1505.3(d) monitoring plan) applies specifically to the requirement for monitoring of implementation of decisions documented in a Record of Decision

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Scoping Comment Received Interdisciplinary Team Discussion Theme

(ROD) and analyzed in an Environmental Impact Statement (EIS). An Environmental Assessment (EA), with a documented Decision Notice (DN) may also include monitoring but it is not required except in implementation of adaptive management proposal (see 36 CFR 220.7(b)(2)(iv)).

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Appendix B: Interdisciplinary Team Members Name Specialty Aldo Aguilar Soil Resources Andrea Durham Recreation Kevin Flores Heritage and Cultural Resources Jennifer Harris Fire and Fuels John Jakubowski Wildlife Biology Hunter Kashdan Logging systems Brad Krieckhaus Botany and Invasive Species Mike McConnell Hydrology Sarah Rockey Roads and Engineering Kevin Senderak Silviculture and IDT leader Erica Taecker NEPA and IDT leader Ken Wieman Fish Biology

Additional participation and review by: Carol Chandler –Wildlife

Joe Gates – Silviculture

Ronelle Goens – Timber Sale Administration

Baker Holden – Fisheries

Jessica Hudec – Fire Ecology

Kraig Kidwell – Timber Sale Administration/Contracting

Crista O’Conner - Botany

Dave Olson – Natural Resources

Paul Smale – Hydrology/Aquatics

John Squires – Pinchot Partners

Ruth Tracy – Watershed Resources Jamie Tolfree – Pinchot Partners

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Appendix C: Transportation System Report Introduction The data for the Silver Creek Thin transportation report were collected through on the ground inspection of roads and culverts within the analysis area. Road maintenance objective levels based on the Forest Plan were the baseline to determine if roads within the analysis area are meeting the objective level needs. Road density maps, known culvert locations, existing road log reports, and analysis area maps all derived from corporate databases helped identify and verify road system items. Road density was calculated using Geographical Information System data by dividing the road miles within the sub-watershed by the total area of the sub-watershed.

Confirmation of road system items was done through a field verification process, where every listed road system item within the analysis area was verified. Unclassified roads, additional culverts, road closure effectiveness, and road reconstruction/maintenance needs were also identified during the field verification process. Existing Condition The road system in the Silver analysis area is serving three users. The most frequent use of this road system is for recreational purposes. The second is for commercial harvest of special forest products. The third road user of the Silver analysis area is through resource managers and their project personnel monitoring and carrying out prescriptions associated with their resource.

At this time, the overall condition of the Silver analysis area road system is fair to poor. Some portions of the existing road system is experiencing erosion, surface damage due to outdated construction/design practices, failed culverts and lack of road maintenance and or permanent erosion control measures. Some road sections have roadside vegetation due to the minimal road maintenance. Select maintenance and reconstruction of problem areas will need to occur to remedy the existing condition.

Currently there are approximately 15 miles of closed roads and 82 miles of open roads within the Silver analysis area. These roads are listed below by road number, operational maintenance level, and miles. Transportation System The major access routes in the Silver Creek area consists of the Forest Service Roads (FR) 4700000, 8500000, 7500000 roads, all of which are ML 2 and provide access to the area. Beyond these major access routes, the roads stay at a ML 2 and become ML 1. Some ML 2 roads have been managed at their current level while others have not been. All ML 1 roads are managed at their current level. All the routes provide a variety of surface types. There is no private land access within the planning area, but the road system does provide access to private lands outside of the forest boundary.

Most of the roads within the area are in maintenance level 2 status. The majority of these roads are drivable; however some have experienced considerable damage during the 2011 flood event and are in need of reconstruction and maintenance. Level 2 roads that are not currently drivable that will be drivable after the sale include sections of the 7500000, 4700135 and the 7561000.

234 Silver Creek Thin EA January 2017

Level 2 roads that will be treated as Level 1 roads include: 4778000, 4778011, 7561018 and 8500108.

The majority of the maintenance level 1 roads are effectively closed, however most have few or no drainage features in place. Some road surface erosion is occurring. Most of the maintenance level 1 roads within the Silver planning area were closed by placing berms at the beginning of the road. Typically, these roads are not being used by vehicles and subsequently have grown over with grass and some small trees. Except for an occasional cut bank failure and rutting, they are in good condition, and in many cases have closed themselves.

Within the project area, the majority of roads have varying degrees of drainage problems. Typically, these problems are a result of inadequate drainage design, and a general lack of maintenance. Most roads have not been maintained since the flood event and in some cases the last timber sale activity.

Table 55. Summary of Existing Roads and Management Level Status in Silver Creek Thin Project Area

Road # OPML Treated Miles 4700174 1 - BASIC CUSTODIAL CARE (CLOSED) 2.85 4778012 1 - BASIC CUSTODIAL CARE (CLOSED) 0.80 4778042 1 - BASIC CUSTODIAL CARE (CLOSED) 0.43 4778043 1 - BASIC CUSTODIAL CARE (CLOSED) 2.9 4778045 1 - BASIC CUSTODIAL CARE (CLOSED) 0.39 4778046 1 - BASIC CUSTODIAL CARE (CLOSED) 0.1 4778628 1 - BASIC CUSTODIAL CARE (CLOSED) 0.20 4778630 1 - BASIC CUSTODIAL CARE (CLOSED) 0.10 6353032 1 - BASIC CUSTODIAL CARE (CLOSED) 0.16 7500051 1 - BASIC CUSTODIAL CARE (CLOSED) 0.32 7500064 1 - BASIC CUSTODIAL CARE (CLOSED) 1.40 7500065 1 - BASIC CUSTODIAL CARE (CLOSED) 0.12 8500110 1 - BASIC CUSTODIAL CARE (CLOSED) 1.00 8500111 1 - BASIC CUSTODIAL CARE (CLOSED) 0.64 8500606 1 - BASIC CUSTODIAL CARE (CLOSED) 0.35 8500652 1 - BASIC CUSTODIAL CARE (CLOSED) 0.30 8511018 1 - BASIC CUSTODIAL CARE (CLOSED) 0.40 8522000 1 - BASIC CUSTODIAL CARE (CLOSED) 1.83 SUBTOTAL 14.29

4700000 2 - HIGH CLEARANCE VEHICLES 7.33 4700135 2 - HIGH CLEARANCE VEHICLES 1.00 4700178 2 - HIGH CLEARANCE VEHICLES 0.20 4700184 2 - HIGH CLEARANCE VEHICLES 1.00 4740000 2 - HIGH CLEARANCE VEHICLES 3.02 4740015 2 - HIGH CLEARANCE VEHICLES 0.80 4745000 2 - HIGH CLEARANCE VEHICLES 3.90 4773000 2 - HIGH CLEARANCE VEHICLES 3.40 4778000 2 - HIGH CLEARANCE VEHICLES 1 4778011 2 - HIGH CLEARANCE VEHICLES 0.70 6300000 2 - HIGH CLEARANCE VEHICLES 3.50

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Road # OPML Treated Miles 7500000 2 - HIGH CLEARANCE VEHICLES 5.8 7561000 2 - HIGH CLEARANCE VEHICLES 1.30 7561018 2 - HIGH CLEARANCE VEHICLES 0.10 7561021 2 - HIGH CLEARANCE VEHICLES 0.20 8500000 2 - HIGH CLEARANCE VEHICLES 15.70 8500108 2 - HIGH CLEARANCE VEHICLES 0.71 8500146 2 - HIGH CLEARANCE VEHICLES 0.55 8511000 2 - HIGH CLEARANCE VEHICLES 1.64 SUBTOTAL 51.85

4700000 2- HIGH CLEARANCE VEHICLES 9.77 5200000 3 - SUITABLE FOR PASSENGER CAR 2.51 8500000 2- HIGH CLEARANCE VEHICLES 6.50 SUBTOTAL 18.78 Road Reconstruction and Maintenance Some roads used for timber sale operations will be reconstructed to meet current traffic service level standards. Road maintenance includes maintaining drainage structures, blading and shaping the roadway, adding some additional surfacing rock and clearing logs and brush from roads. Specific activities include:

• Reconstruct shoulder and replace culvert of Forest Road (FR) 8500000 at milepost 13.0. • Reclaim asphalt from mileposts 0 to 6.5 of Forest Road 8500000 and from mileposts 10.3 to 17.1 of Forest Road 4700000. Asphalt will be pulverized and reclaimed to the full depth of asphalt and approximately 6” of existing crushed base rock under the asphalt for the entire width of asphalt sections including turnouts and curve widening. It will be blended in place so that the resulting blend is 50% pulverized asphalt and 50% crushed aggregate. Blend will be graded and compacted. Where we cannot recover enough crushed base rock from the existing road to produce a 50%/50% blend, additional crushed rock will be added to produce the designed mix. Asphalt reclamation will not occur within 200’ of any stream crossing or nearest cross drain, whichever is less. Asphalt removal will occur inside the buffer areas. • Blasting and crushing of rock at St. Regis (FR 7500000) and Boundary (FR 4740015) quarries for road fill and surfacing. If St. Regis rock pit cannot be developed, a commercial source will be used for maintenance and reconstruction purposes in the FR 7500000 corridor. • Replace washed-out culverts at mileposts 0.00, 0.48, 0.77 and 1.52 of FR 4700174. • Install temporary bridge where FR 4778043 crosses Willie Creek at milepost 0.2, repair washout with culvert at milepost 0.3 and unbury culvert at milepost 2.2. Reconstruct road junction with FR 4778042 for bridge delivery and installation. • Repair washout with culvert at milepost 0.15 of FR 4778045. • Repair washouts with culverts on FR 4778046. • Repair embankment at milepost 0.48 of FR 7500064, remove slide, unbury culvert at milepost 0.97, and unbury culvert at milepost 1.09. • Install culverts at mileposts 0.01, 0.45, 0.87 and 1.3 of FR 8522000. • Remove slough at milepost 4.7 of FR 4700000. • Deep patch repair between mileposts 10.58 and 16.12 of FR 4700000.

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• Realignment at milepost 16.12 and 16.2 with embankment repair at milepost 16.15 of FR 4700000. • Reconstruct length of FR 4700135 including ditch, shoulder, surface, embankment repair and blasting near terminus. • Reconstruct length of FR 4700184 including ditch, shoulder, surface and embankment repair. • Reconstruct length of FR 4740015 including ditch, shoulder, and surface and cross drain installation. • Reconstruct FR 4745000 between mileposts 0 and 1.2 including ditch, shoulder, surface and embankment repair. • Reconstruct FR 4773000 at milepost 0.1 including ditch, shoulder, surface and embankment repair. • Reconstruct FR 4778000 including ditch, shoulder and surface repair between milepost 0.08 and 0.91. • Repair washouts and replace culverts at milepost 0.39, 0.42, 0.46, 0.87 and 0.91 of FR 4778000. • Reconstruct length of FR 4778011 including ditch, shoulder and surface repair and culvert replacement at mileposts 0.56 and 0.6. • Reconstruct length of FR 6300000 including ditch, shoulder, surface repair and culvert replacement. • Repair washouts and replace culverts at mileposts 4.8 and 5.5 of FR 7500000. Reconstruct roadway at MP 1.8 and 2.3 including ditch, shoulder, surface and embankment repair. • Un-bury culvert at milepost 1.08 and repair washouts and replace culverts at mileposts 1.25 and 1.3 of FR 7561000. • Reconstruct FR 8511000 including ditch, shoulder, surface and embankment repair. • Construct approximately 7.41 miles of new, temporary road and re-open approximately 7.43 miles of existing non-system road. All temporary roads will be closed and returned to a more natural state after all harvest activities have been completed. • Maintain about 85 miles of system road; includes ditch line and drainage structure cleaning, brushing, blading and shaping the roadway, as well as adding some additional surfacing rock and clearing logs and danger trees from the roads where necessary.

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Table 56. Pre- and Post-harvest Road Reconstruction and Maintenance Summary for Silver Creek Thin

Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance GRAVEL AND NATIVE SURFACE ROADS

4700174 0-2.85 Washout repairs MP 0.0, 0.48 & Perform prehaul maintenance including Perform posthaul maintenance Road very difficult to find 1.52. Culvert replacements needed remove and end haul material roadside including roadside brushing, large washouts. Berm. at washouts and old log culvert at brushing, surface rock, blading, ditch and logging out, blading and drainage 0.77. Stream running along road. drainage structure and logging out maintenance as needed (T839) Temporary road construction of maintenance as needed. (T813, T-832, Intersection @ 4700 junction by pass T839) first crossing.

4778012 0-.8 Perform prehaul maintenance including Perform posthaul maintenance No culvert scour or water on remove and end haul material roadside including roadside brushing, roadway. Good road. Log out brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

4778042 0.17-0.6 Intersection reconstruction if want to Perform prehaul maintenance including Perform posthaul maintenance Drivable to intersection of the haul out the 85. remove and end haul material roadside including roadside brushing, 4778043. Needs surface rock brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

4778043 0-2.9 Replace bridge at Willie Creek MP Perform prehaul maintenance including Perform posthaul maintenance Berm at previous bridge 0.2 with temporary bridge, was 44' remove and end haul material roadside including roadside brushing, location. Bridge removed. long x 22' wide deck or reroute road brushing, surface rock, blading, ditch and logging out, blading and drainage Impassable at bridge upstream. Washout need culvert drainage structure and logging out maintenance as needed (T839) location. Some areas could installations. Debris flows along road. maintenance as needed. (T813, T-832, be passable, hard pack soil, T839) some gravel. 5 sites where debris sloughing on roadway. Very brushy. Washout MP 0.3 4778045 0-.39 MP 0.15 Washout 20' x 5' x 40'. Need Perform prehaul maintenance including Perform posthaul maintenance Impassable. Heavy culvert installations. remove and end haul material roadside including roadside brushing, waterbarring, log out, brushing, surface rock, blading, ditch and logging out, blading and drainage vegetation in roadway. Minor drainage structure and logging out maintenance as needed (T839) sloughing. Very brushy. maintenance as needed. (T813, T-832, Washout at MP 0.15 T839)

238 Silver Creek Thin EA January 2017

Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 4778046 0-.1 Need culvert installations. Perform prehaul maintenance including Perform posthaul maintenance Somewhat passable, very remove and end haul material roadside including roadside brushing, brushy. Minor sloughing. Only brushing, surface rock, blading, ditch and logging out, blading and drainage needing road to MP 0.1. drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

4778628 0-.2 Perform prehaul maintenance including Perform posthaul maintenance Good Road remove and end haul material roadside including roadside brushing, brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

4778630 0-0.1 Perform prehaul maintenance including Perform posthaul maintenance Good Road remove and end haul material roadside including roadside brushing, brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

6353032 0.34-0.5 Perform prehaul maintenance including Perform posthaul maintenance Is at the end of the 4700174. remove and end haul material roadside including roadside brushing, Did not see that section brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

7500051 0-0.32 Perform prehaul maintenance including Perform prehaul maintenance Good road, brushy, could use remove and end haul material roadside including roadside brushing, some rock brushing, surface rock, blading, ditch and surface rock, blading, ditch and drainage structure and logging out drainage structure and logging maintenance as needed. (T813, T-832, out maintenance as needed. T839) (T813, T839)

7500064 0-1.4 Embankment Repair 12' long x 3' Perform prehaul maintenance including Perform posthaul maintenance Road sloughed at MP 0.48. wide x 5' deep MP 0.48. Slide on remove and end haul material roadside including roadside brushing, Good roadbed. Brushy. road 21' long x 3' high x full width of brushing, surface rock, blading, ditch and logging out, blading and drainage road MP .97 approx. 33 CY of drainage structure and logging out maintenance as needed (T839) material to remove. maintenance as needed. (T813, T-832, T839)

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Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 7500065 0-.12 Perform prehaul maintenance including Perform posthaul maintenance Good road no washouts. remove and end haul material roadside including roadside brushing, Brushy. brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

8500110 0-1.0 Perform prehaul maintenance including Perform posthaul maintenance Passable but very brushy. remove and end haul material roadside including roadside brushing, brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

8500111 0-0.64 Perform prehaul maintenance including Perform posthaul maintenance Good road, hard pack with remove and end haul material roadside including roadside brushing, gravel. Brushy. Alder growing brushing, surface rock, blading, ditch and logging out, blading and drainage on roadway after first 300 drainage structure and logging out maintenance as needed (T839) feet. Unpassable. Plugged maintenance as needed. (T813, T-832, culvert at channel. T839)

8500606 0-0.35 Perform prehaul maintenance including Perform posthaul maintenance Unpassable. Vegetation in remove and end haul material roadside including roadside brushing, roadway full grown in. brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

8500652 0-0.3 Perform prehaul maintenance including Perform posthaul maintenance Stump at intersection and remove and end haul material roadside including roadside brushing, slope of road impassable. brushing, surface rock, blading, ditch and logging out, blading and drainage Rutting occurring. drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

8511018 0-0.4 Perform prehaul maintenance including Perform posthaul maintenance Passable with small vehicle. remove and end haul material roadside including roadside brushing, Staring to brush in. brushing, surface rock, blading, ditch and logging out, blading and drainage drainage structure and logging out maintenance as needed (T839) maintenance as needed. (T813, T-832, T839)

240 Silver Creek Thin EA January 2017

Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 8522000 0-1.83 Culvert Installations 18" x 30' long Perform prehaul maintenance including Perform posthaul maintenance Impassable. Need base and MP 0.01, 0.45, 0.87 and possibly 1.3. remove and end haul material roadside including roadside brushing, surface rock. Ditch needs to Road slumping lots of drain dip. brushing, surface rock, blading, ditch and logging out, blading and drainage be reestablished. Log out, Intersection reconstruction at jcn with drainage structure and logging out maintenance as needed (T839) heavy brush cannot do 7473 if do not want to use the maintenance as needed. (T813, T-832, mechanical. Bankfull at 4773000. Intersection reconstruction T839) crossings 6', 3', 4', 2'. Do not of 85 if want to haul out the 47. have to be bankfull if pulling before wet season. At MP 0.87 need to install culvert water running down road (1st switch back). After haul pull 0.87 culvert and have stream cross road and dissipate. 4700000 3-10.33 Slough removal MP 4.7. Perform prehaul maintenance including Perform posthaul maintenance Surface Rock needed MP4.7- roadside brushing, surface rock, blading, including roadside brushing, 9.6. Reconstruction is several ditch and drainage structure maintenance blading and drainage places. as needed. (T811, T813, T831, T834, maintenance as needed. (T811, T836, T842) T-836, T-854)

4700135 0-1.0 Major Roadway Reconstruction. Perform prehaul maintenance including Perform posthaul maintenance Impassable. Major rutting, Includes ditch, shoulder, roadbed roadside brushing, surface rock, blading, including roadside brushing, small berm at beginning of and surface repair. FP-03 303 Road ditch and drainage structure and logging blading and drainage road, minor road repair. Has Reconditioning. Embankment repair, out maintenance as needed. (T811, T813, maintenance as needed. (T811, good base rock, needs 10-20 CY of material needed. Narrow T831, T834, T836, T842, T851) T-836, T-854) surface rock. Log out. Heavy at end of road BLASTING may be brushing cannot do necessary. mechanical brushing too much. 4700178 0-0.2 Perform prehaul maintenance including Perform posthaul maintenance Impassable, brushy. Quarry roadside brushing, surface rock, blading, including roadside brushing, near end of road. ditch and drainage structure and logging blading and drainage out maintenance as needed. (T811, T813, maintenance as needed. (T811, T831, T834, T836, T842, T851) T-836, T-854)

4700184 0-1.0 Minor Roadway Reconstruction. Perform prehaul maintenance including Perform posthaul maintenance Has asphalt apron, open. Log Includes ditch, shoulder, roadbed roadside brushing, surface rock, blading, including roadside brushing, out, surface, blading, culvert and surface repair. FP-03 303 Road ditch and drainage structure and logging blading and drainage cleaning, ditch line cleaning, Reconditioning. Embankment repair, out maintenance as needed. (T811, T813, maintenance as needed. (T811, drivable to jcn of 185, need to 5 CY of material needed. T831, T834, T836, T842, T851) T-836, T-854) remove logs after that. Minor fill needed 5CY.

241 Cowlitz Valley Ranger District

Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 4740000 0-3.02 Perform prehaul maintenance including Perform posthaul maintenance Good condition B,BL, DL roadside brushing, surface rock, blading, including roadside brushing, ditch and drainage structure maintenance blading and drainage as needed. (T811, T813, T831, T834, maintenance as needed. (T811, T836, T842) T-836, T-854)

4740015 0-0.8 Minor roadway reconstruction of Perform prehaul maintenance including Perform posthaul maintenance Rutting occurring, water roadbed, shoulder and ditch. Cross roadside brushing, surface rock, blading, including roadside brushing, running along road from drain and drivable dip installations ditch and drainage structure and logging blading and drainage surface water run-off. needed. out maintenance as needed. (T811, T813, maintenance as needed. (T811, T831, T834, T836, T842, T851) T-836, T-854)

4745000 0-3.9 Minor roadway reconstruction of Perform prehaul maintenance including Perform posthaul maintenance Heavy brush, log removal. roadbed, shoulder and ditch, roadside brushing, surface rock, blading, including roadside brushing, Around MP 0.2 plugged bedrock. ditch and drainage structure and logging blading and drainage culvert. out maintenance as needed. (T811, T813, maintenance as needed. (T811, T831, T834, T836, T842, T851) T-836, T-854)

4773000 0-3.4 Minor roadway reconstruction of Perform prehaul maintenance including Perform posthaul maintenance Water along road from roadbed, shoulder and ditch at MP roadside brushing, surface rock, blading, including roadside brushing, plugged culvert at first turn. 0.1 where culvert is plugged. ditch and drainage structure and logging blading and drainage Ditch is heavily trenched out maintenance as needed. (T811, T813, maintenance as needed. T831, T834, T836, T842, T851) Reinstall waterbars. (T811, T- 836, T-854) 4778000 0-1.0 Major Roadway Reconstruction Perform prehaul maintenance including Perform posthaul maintenance Saturated roadbed, Includes ditch, shoulder, roadbed remove and end haul material, roadside including roadside brushing, waterbarring, log out, and surface repair. FP-03 303 Road brushing, surface rock, blading, ditch and blading and drainage vegetation in roadway. Debris Reconditioning. Road fill failure 100 + drainage structure and logging out maintenance as needed. sloughing on roadway. feet. Road has several washouts maintenance as needed. (T811, T813, Reinstall waterbars. (T811, T- Culvert plugged. Some areas needing culvert installations. Road is T831, T834, T-832 T839, T842, T851) 836, T-854) of hard pack road. Need base rutting and several slumps. and surface material. Reconstruction of intersection @ 47 junction

4778011 0-0.7 Major Roadway Reconstruction. Perform prehaul maintenance including Perform posthaul maintenance Impassable. Road needs to Includes ditch, shoulder, roadbed roadside brushing, surface rock, blading, including roadside brushing, be reestablished. Major and surface repair. FP-03 303 Road ditch and drainage structure and logging blading and drainage logging out, brushing, surface Reconditioning. 2 log bunk culverts out maintenance as needed. (T811, T813, maintenance as needed. and base material. Hard to 10' down x 3' wide & 6' down x 4' T831, T834, T839, T842, T851) Reinstall waterbars. (T811, T- even tell where road is. wide. 836, T-854)

242 Silver Creek Thin EA January 2017

Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 6300000 12.3-15.8 Temporary road construction of Perform prehaul maintenance including Perform posthaul maintenance Fair road, gravel. Passable. Intersection @ 63 and 47 junction. roadside brushing, surface rock, blading, including roadside brushing, Needs maintenance. Minor Repair and replace damaged culverts ditch and drainage structure maintenance blading and drainage brushing. as needed. (T811, T813, T831, T834, maintenance as needed. T836, T842) Reinstall waterbars. (T811, T- 836, T-854) 7500000 0-5.8 Major Washout MP 4.8 approx. 30' Perform prehaul maintenance including Perform posthaul maintenance Drivable good road could use long x 30' deep x 20' wide. Culvert roadside brushing, surface rock, blading, including roadside brushing, some surface rock and Replacement 36" x 40'. Could ditch and drainage structure maintenance blading and drainage brushing. develop St. Regis Quarry MP 3.9 as needed. (T811, T813, T831, T834, maintenance as needed. 7500 for backfill material. Washouts T836, T842) Reinstall waterbars. (T811, T- past 7561 jct: MP 5.9 25' long x 25' 836, T-854) deep x 20' wide, MP 5.5 40' long x 10' deep x 10' wide with 24" x 40' culvert replacement. Roadway Reconstruction includes ditch, shoulder, roadbed and surface repair MP 1.8 and 2.3 7561000 0-1.3 . Washouts: MP 1.25 16' long x 16' Rutting: MP 1.3 11' long x 5' wide x 2' Perform posthaul maintenance Rutting and washouts wide x 8' deep culvert replacement deep, MP 0.65-1.08' 1' deep, MP 1.08 30' including roadside brushing, occurring on road. Roadbed 24" x 40'. MP 1.08 1'x2'x30' Culvert long x 1' deep x 2' wide. Perform prehaul blading and drainage stable. Replacement 24" x 40'. MP 1.3 maintenance including roadside brushing, maintenance as needed. 2'x5'x11' and rut 2'x2'x60'. MP 1.08- surface rock, blading, ditch and drainage Reinstall waterbars. (T811, T- 0.65 1' rut in road. structure maintenance as needed. (T811, 836, T-854) T813, T831, T834)

7561018 0-0.1 9 Washouts: MP 0.1 - 3' long x 8' Perform prehaul maintenance including Perform posthaul maintenance Impassable, several deep x 2' wide, MP 0.17 - 20' long x roadside brushing, surface rock, blading, including roadside brushing, washouts. 12' deep x 20' wide with 24" x 40' ditch and drainage structure maintenance blading and drainage culvert replacement, MP 0.27 5' deep as needed. (T811, T813, T831, T834, maintenance as needed. x 12' wide extending 90' along length T839, T842) Reinstall waterbars. (T811, T- of road, MP 0.33 40' long x 15' deep 836, T-854) x 15' wide, MP 0.35-0.4 Road completely washed out, MP 0.47 40' long x >30' deep x 15' wide 24" x 40' culvert install. MP 0.47-0.51 3' wide x 3' deep 24" x 40' culvert replacement, water running along road way. MP 0.59 >20' deep x 20' long x 4' wide. MP 0.7 6' deep x 15' long x 3' wide

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Road # MP's Pre-harvest treatment- Pre-harvest treatment-Maintenance Post-harvest treatment- Field Notes Reconstruction Maintenance 7561021 0-0.2 Perform prehaul maintenance including Perform posthaul maintenance roadside brushing, surface rock, blading, including roadside brushing, ditch and drainage structure maintenance blading and drainage as needed. (T811, T813, T831, T834, maintenance as needed. (T811, T836, T842) T-836, T-854)

8500000 6.5-22.2 Reconstruction road shoulder Perform prehaul maintenance including Perform posthaul maintenance Large rock needs to be washout MP 13.0, possible culvert roadside brushing, surface rock, blading, including roadside brushing, removed from road. Reclaim replacement. ditch and drainage structure maintenance blading and drainage asphalt. Good Road. Could as needed. (T811, T813, T831, T834, maintenance as needed. (T811, be brushed. MP 9.37 needs T836, T842) T-836, T-854) some base and surface material. 8500108 0-0.71 May need to install culverts. Perform prehaul maintenance including Perform posthaul maintenance Drivable. Logs across road, roadside brushing, logging out, surface including roadside brushing, brushy. Crosses 2 channels rock, blading, ditch and drainage structure blading and drainage possibly 6. maintenance as needed. (T811, T813, maintenance as needed. (T811, T831, T834, T839, T842, T851) T-836, T-854)

8500146 0-0.55 Perform prehaul maintenance including Perform posthaul maintenance Gravel road. Passable for roadside brushing, surface rock, blading, including roadside brushing, high clearance vehicle. ditch and drainage structure maintenance blading and drainage as needed. (T811, T813, T831, T834, maintenance as needed. (T811, T836, T842) T-836, T-854)

8511000 0-1.64 Minor Roadway Reconstruction of Perform prehaul maintenance including Perform posthaul maintenance Good road, gravel. Passable. roadbed, shoulder and ditch. Road roadside brushing, surface rock, blading, including roadside brushing, Minor brushing. slumping, ditch higher than road ditch and drainage structure maintenance blading and drainage need to build up road with base and as needed. (T811, T813, T831, T834, maintenance as needed. (T811, surface material.. T836, T842) T-836, T-854)

244 Silver Creek Thin EA January 2017

ASPHALT ROADS 4700000 0-3, 10.33- Reclaim Asphalt MP 10.33-17.1. Deposit and Brushing Deposit Paved section of road. 17.1 Deep patch repair: MP 10.58,13.5,13.6,13.8,13.69,14.18,14. 68,14.78,16.12. Road Realignment MP 16.12 cut into bank 85' long x 6' wide x 30' high. Road Fill MP 16.15 take cut material from 16.12 and place in embankment. Road Realignment MP 16.2 cut into bank 50' long x 10' wide x 15' high. If hauling towards Randle there are 2 washouts MP 17.67 &17.68 with culvert replacement 1-48" 1-24". Slide Removal MP 17.7. Massive washout East Fork Silver Creek 20'x13' squashed pipe.

5200000 18.59- Deposit and Brushing Deposit Paved section of road. 21.10 8500000 0-6.5 Reclaim Asphalt MP 0.0-6.5 Deposit and Brushing Deposit Paved section of road.

245 Cowlitz Valley Ranger District

Appendix D: East Fork Silver Crossing Economic Analysis The Forest Service received numerous comments concerning the crossing at East Fork Silver Creek. The Forest Service recognizes the importance of maintaining access to the Forest for commercial and personal interests. The Forest Service studied the cost, benefits, and risks of various ways to replace the crossing and determined that the potential for further disturbance to an already unstable area and the possible adverse effects to natural resources and the community (homes, businesses, people, etc.) downstream were not outweighed by the potential economic benefits of reconstructing a crossing at this location.

An economic analysis was completed that examined several options based on crossing costs and the difference between hauling timber up Forest Road (FR) 47 towards Packwood verses hauling down FR 47 towards Randle.

Scenario one: If a crossing already existed at East Fork of Silver Creek, the Appraisal cost for hauling out the timber in the Silver Planning area would be $1,215,887.68.

Scenario two: Without replacing a crossing at East Fork of Silver Creek, the Appraisal cost for hauling out the timber in the Silver Planning area would be $1,488,092.64.

The haul cost is estimated based upon round trip minutes and round trip miles for both scenarios. The difference in haul cost for these two scenarios was $272,205.00; in other words, it will cost this much more to haul timber for the entire Silver Creek Thin project if the East Fork of Silver Creek crossing is not fixed. The cost to fix East Fork of Silver would need to be near or under this amount to justify fixing it to haul timber.

Several crossing options were evaluated for cost. The crossing options included:

Description Total Permanent Custom Bridge - 300 foot span $1,600,000.00 Permanent Modular Bridge - 300 foot span $1,185,000.00 Permanent Modular Bridge - 200 foot span $815,760.00 Modular Bridge Rental for 6 months - 300 foot span $521,000.00 Modular Bridge Rental for 6 months - 200 foot span $402,760.00 Temporary Bridge - 80 foot span, Forest Service owned $989,100.00 Road Realignment $523,770.00

Modular bridges are also known as (but are not limited to) Acrow, Bailey and/or EZ prefabricated steel bridges. A temporary railroad flatcar-type bridge was not analyzed because Forest Service direction does not allow installation of such a structure: FSM 7722.035 “Use of railroad flatcars as NFS road bridges is prohibited.”

246 Silver Creek Thin EA January 2017

Road realignment reconnaissance occurred 200-300 feet upstream of the old crossing and cost was estimated. In addition to the estimated cost exceeding the benefit of hauling down this road, other concerns emerged immediately such as a high level of instability/unstable soils in this area that could threaten any type of crossing and thus downstream communities and natural resources. In addition, the likely “best” location of a realignment would have to occur in close proximity to a major log jam, within Riparian Reserves and old growth stands, causing major effects to various natural resources and habitats during construction. In addition, it would seriously threaten the natural and human communities downstream when and if the crossing failed due to instability.

247 Cowlitz Valley Ranger District

Appendix E: Landscape Analysis

Figure 28. Year of origin (age class) for stands in the Silver Creek planning area. All stands proposed for harvest are shown as less than 80 years old except stands 9038 (dropped from proposed action) and 9053.

248 Silver Creek Thin EA January 2017

Table 1D. Breakdown of treatment acres by watershed and year of origin Total Total Total Total Total Tx ac Tx ac Tx ac Tx ac Tx ac NF NF NF NF NF % Tx % Tx %Tx %Tx %Tx NF Tx % Tx % Tx 1975- 1935- 1895- 1815- 0- 1975- 1935- 1895- 1815- 0- 1975- 1935- 1895- 1815- 0- Watershed Acres Acres Acres total NF 2014 1974 1934 1894 1814 2014 1974 1934 1894 1814 2014 1974 1934 1894 1814

Silver Creek 32011 22638 3526 11 15 643 2738 50 50 0 7001 5468 208 2589 7881 9 50 24 2 0.000

• 1975-2014 is < 40 years old • 1935-1974 is 40-79 years old • 1895-1934 is 80-119 years old • 1815-1894 is 120-199 years old • 0-1814 is ≥ 200 years old

Summary of Landscape Year of Origin All proposed treatment acres fall within the Silver Creek subwatershed (6th field, Figure 28). Table 1D above lists number of acres in the watershed, number of acres in the watershed that are on National Forest land, number of acres proposed for treatment (Tx), percentage of the total watershed represented by proposed treated acres, percentage of the watershed on National Forest land represented by proposed treated acres, proposed treated acres by year of origin/age group, total number of National Forest acres in the watershed in each age group, and percentage of acres in each age group on National Forest land proposed for treatment. Fifteen percent of the Silver Creek subwatershed that falls on National Forest land is proposed for treatment (11% of the entire subwatershed), including 50% of stands aged 40-79 years old on National Forest land.

Fourth or fifth field watersheds are more appropriate scales of analysis for the vegetation types present, given respective natural disturbance regimes. Silver Creek subwatershed falls within the Upper Cowlitz subbasin (4th field) and the Middle Cowlitz watershed (5th field). The Upper Cowlitz subbasin is 656,140 acres, and the Middle Cowlitz watershed is 97,088 acres. Proposed treatment acres equate to 0.5% of the Upper Cowlitz subbasin and 3.6% of the Middle Cowlitz watershed, a very small portion of total land.

The spatial arrangement of stands and proximity of treatments to old stands, young stands, and riparian or wildlife corridors might offer more ecological significance than simply number of acres treated in each age class in a watershed. All stands proposed for treatment are plantations, but how these stands fit into the landscape before they were plantations is worth considering.

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Summary of Seral Stage Analysis and Deviation from Historic Reference Figure 29 shows that nearly all of the stands proposed for treatment are seral stage B, mid-seral closed, as one might expect of plantations ready for thinning. Figure 30 shows the relative abundance of the seral stages with respect to reference conditions for vegetation types present. (Note: 5th field watershed boundaries are displayed, but analyses were done primarily at the 4th field watershed level for the vegetation types affected by the thinning.) In nearly all stands proposed for treatment, seral stage B, which is the current condition of the stands proposed for treatment, is abundant or overrepresented. So, from an ecological perspective, the goal of treatment could be to reduce the amount of this overrepresented or abundant seral stage by converting the stands to a seral stage that is underrepresented on the landscape. Late-seral closed is most lacking in terms of reference conditions in the watersheds where treatment is proposed. If the objectives of the thinning were ecologically driven, one could propose to thin abundantly- represented mid-seral closed stands to encourage growth and canopy layering that will facilitate the recruitment of underrepresented late-seral closed stands.

Seral stage A (early seral) is slightly underrepresented (4% vs. historical 5%) in the North Pacific Maritime Mesic-Wet Douglas-fir/Western Hemlock forest type (representing much of the project area) on National Forest land. A single percentage point can be accounted for by natural disturbance variability; moreover, the amount of early seral forest on adjacent lands, the connectivity of early seral forest among lands, and the overall quality of habitat provided by early seral forest are of more concern than simply number of acres. Private lands adjacent to the National Forest near Silver Creek planning area have been heavily harvested. Habitat conditions on those lands are unknown. Factors including snag abundance, height, and condition; coarse woody debris abundance, length, and condition; and shrub and herb richness need to be considered to assess habitat quality on both private and national forest lands. Analyses shared here are limited to forest composition and structure and do not include any factors of habitat quality.

Table 2D lists the numbers of acres in each seral stage for each vegetation type present in a watershed. Watershed boundaries were clipped to the National Forest boundary so influences of land management on private lands would not alter results. These data help determine the number of acres necessary to treat in order to affect the quantity and distribution of a seral stage on the greater landscape.

250 Silver Creek Thin EA January 2017

Figure 29. Seral stages in the Silver Creek planning area. A= early seral; B=mid seral closed; c= mid seral open; D= late seral open; E= late seral closed.

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Figure 30. Relative amounts of seral stages present in the Silver Creek planning area

252 Silver Creek Thin EA January 2017

Table 2D. Vegetation types (BpS) in three 5th field watersheds where treatments are proposed are broken down into seral stages (S class). Number of acres in each seral stage, current percentage of the vegetation type in each seral stage, and reference percentage are listed. S class S class BpS Percent Percent HUC_8 HUC_8 Name HUC_10 HUC_10 Name Model BpS Name LABEL CLASS Acres Current Reference East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland A similar 38 7 10 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland B over rep 262 48 20 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland C similar 24 4 5 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland D trace 10 2 15 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland E similar 216 39 50 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland No Info -99 2 East Cascades Mesic Montane Mixed- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110180 Conifer Forest and Woodland Rock -99 12 North Pacific Maritime Dry-Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110370 Douglas-fir-Western Hemlock Forest A over rep 4 7 5 North Pacific Maritime Dry-Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110370 Douglas-fir-Western Hemlock Forest B over rep 34 61 15 North Pacific Maritime Dry-Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110370 Douglas-fir-Western Hemlock Forest C 0 5 North Pacific Maritime Dry-Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110370 Douglas-fir-Western Hemlock Forest D 0 15 North Pacific Maritime Dry-Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110370 Douglas-fir-Western Hemlock Forest E under rep 18 32 60 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland A trace 44 7 95 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland B abundant 236 37 5 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland C abundant 60 9 0 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland D abundant 34 5 0 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland E abundant 270 42 0 North Pacific Maritime Mesic 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110380 Subalpine Parkland No Info -99 4

253 Cowlitz Valley Ranger District S class S class BpS Percent Percent HUC_8 HUC_8 Name HUC_10 HUC_10 Name Model BpS Name LABEL CLASS Acres Current Reference North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest A under rep 386 4 5 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest B over rep 7394 68 15 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest C trace 184 2 5 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest D trace 46 0 5 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest E under rep 2920 27 70 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest No Info -99 56 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest Rock -99 36 North Pacific Maritime Mesic-Wet 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110390 Douglas-fir-Western Hemlock Forest Water -99 12 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet A abundant 2228 5 1 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet B abundant 24918 53 5 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet C over rep 3227 7 5 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet D trace 667 1 4 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet E under rep 16101 34 85 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet No Info -99 226 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet Rock -99 46 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110411 Forest- Wet Water -99 276 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric A similar 1705 8 15 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric B over rep 8699 41 25 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric C under rep 1035 5 15 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric D over rep 1669 8 5 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric E similar 8120 38 40 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric No Info -99 50 254 Silver Creek Thin EA January 2017 S class S class BpS Percent Percent HUC_8 HUC_8 Name HUC_10 HUC_10 Name Model BpS Name LABEL CLASS Acres Current Reference North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric Rock -99 1047 North Pacific Mountain Hemlock 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110412 Forest- Xeric Water -99 6 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest A over rep 1161 4 1 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest B abundant 19207 64 4 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest C abundant 1413 5 1 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest D trace 172 1 2 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest E trace 7992 27 92 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest No Info -99 100 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest Rock -99 28 North Pacific Mesic Western Hemlock- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0110420 Silver Fir Forest Water -99 2 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest A trace 1507 4 15 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest B over rep 22450 61 20 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest C similar 1237 3 5 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest D trace 302 1 10 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest E under rep 11139 30 50 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest No Info -99 178 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest Rock -99 58 North Pacific Dry-Mesic Silver Fir- 17080004 Upper Cowlitz 1708000403 Middle Cowlitz 0111740 Western Hemlock-Douglas-fir Forest Water -99 16

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Appendix F: Response to Comments Received on the Preliminary EA NOTE: All page numbers refer to the December 2015 Preliminary EA.

Number Theme Comment Response

Commenter: Alice Hack

1-1 Supportive Planned commercial timber harvest, road maintenance, Thank you for your comment. comment and reconstruction have been well thought through.

1-2 Vegetation – Future planning should include growth of alder trees to Red alder has a unique niche across the landscape and has an Silvicultural help prevent root disease in Douglas fir trees and important role in creating diversity, minimizing root disease and prescription provide soil the necessary nitrogen. enriching soil productivity. The current proposal will only remove red alder where trees exist in excess of meeting these needs. See the PDC 1.4 on page 19 of the EA.

1-3 Vegetation – Trees need time to grow to be a desirable product. The current proposal seeks to provide timber of desirable size and Silvicultural Currently most trees are being harvested at immature quantities that are agreeable to purchasers. How the timber is prescription size resulting in poor grade lumber which is causing marketed and to what degree of quality, however, is left up to the inferior construction. purchaser to determine and is reflected in their bid price. From a timber product standpoint, a lot of mills do not have the capabilities to process larger trees at their mill and will only pay half the normal log price for an oversized log; mills that would be able to process larger logs are too far away (excessive haul costs) and/or are export mills, and FS does not allow export of our unprocessed logs. Also, our projects are primarily thinning from below (cutting the smaller trees and leaving the larger).

1-4 Transportation Since we had an extremely dry year until this month, The team appreciates the commenter’s concerns about recent system some plans may become emergencies - culverts, road (December 2015) flood events on the district. Currently there are no maintenance, unstable hillsides. With these torrents of proposed changes to the Proposed Action for Silver Creek Thin rain, we could be facing many unseen complications. related to the transportation system due to this flooding. In addition, road maintenance, reconstruction, and other transportation and restoration activities proposed in this project are intended in part to make the road system more resistant to failures during future flood events (EA pp. 9-13).

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Commenter: Pete Krabbe

2-1 Transportation I agree that USFS grounds north of Randle should be Appendix D was added to the EA to address this issue in more detail. accessible from Randle, East Lewis Co. mills and Please also refer to page 41 in the EA. system loggers need the work…. We don't need less access to the forest but more!

2-2 Project Design Let the loggers have access when weather permits and Project Design Criteria (particularly section 6, EA pages 27-35) specify acceptable conditions for logging operations to protect soil and water Criteria - removed when it starts raining. resources in compliance with the Forest Plan Standards and Guides Aquatics and Best Management Practices. Thresholds for precipitation and soil moisture and erosional features are among the indicators identified. Weather dependent features including depth of frost and snow pack are also critical component of acceptable logging operation conditions.

Commenter: William Truitt

3-1 Transportation I recommend that non-traditional options for accessing Appendix D was added to the EA to address this issue in more detail. the forest be explored. [letter includes description of Please also refer to page 41 in the EA. It is important to note that a system bridges that can be raised with cables during high water cable bridge would be more costly than several other crossing options months then are lowered into place when flood hazard is evaluated in Appendix D. reduced in the spring].

Commenter: Dean Lawrence

4-1 Transportation Has anyone looked at the option of building a new Our engineers conducted a preliminary analysis and field crossing [over East Fork Silver Creek on FR 47] by reconnaissance of a realignment upstream as the commenter system moving crossing upstream by 200-300 feet? It seems suggested. Appendix D was added to the EA to address this issue in you could begin the road on the Randle side and follow more detail. Please also refer to page 41 in the EA. the edge of the 2006 slide until you get to the creek then use a metal pipe arch about 14 feet wide and 8 feet high which would leave minimal amount of fill to complete the crossing, with some excavation to tie into the existing road on the east side of the creek.

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Commenter: John Squires

5-1 Riparian Buffers When reading the EA I did not see the methodology or Please see section 6 of the PDC in the EA (pages 27-35). The assumptions made when creating inner riparian buffers interdisciplinary planning process included a limiting factor assessment for class 3 streams and 100 feet for class 4 streams. for water and soil related issues, which determined final buffer Some clarification for such large inner riparian buffers designations. The Forest Plan as amended by the Northwest Forest would be appreciated Plan (NWFP ROD. Pg B-10) provides the context for considerations the IDT made in developing the buffers. Considerations included: Unstable slopes, channel stability, active mass wasting (landslides) and debris flows, site-specific soils data which was pre-reviewed on GIS or from photo interpretation and then verified in the field. (See EA pages 48-50, 55-58, 151-152, and 170-171 for more discussion). EA page 171 (Table 42) summarizes the channel stability measured within the analysis area and confirms a high percentage of Class III and IV streams are at risk of stability. We chose to standardize the buffer widths to simplify and add efficiency to the planning and layout process.this EA As a result, 100 feet buffer widths were used universally.

5-2 Riparian Buffers The EA states: “Also, in Rashin Edward B. et al. We concur that 10 meter buffer is typically effective at filtering surface indicated that a 10 meter setback for ground disturbance soil movement transported on the forest floor. However, Rashin’s can be expected to prevent sediment delivery to stream conclusions are specific to surface soil movement and do not from about 95% of harvest related erosion features. universally apply to management of unstable slopes or the Silver Incorporating appropriate ‘“No Harvest”’ buffer widths Creek Thin sediment transport functions. We do follow Rashin et al.’s around riparian areas in a harvesting unit will ensure logic and factor in other riparian functions as stated, “wider setbacks transported sediments filter out onto the forest floor and for ground disturbing activities may be advisable on portion of harvest limit the movements of sediment from reaching nearby sites where steep inner gorges along streams extend beyond 10 water bodies.” Given the FS own documentation, 150 meters. Other long-term functions of riparian zones, such as feet of no harvest buffer seems excessive and maintenance of stream temperature and large woody debris regimes, inconsistent with your own science. should also be considered in the design of stream buffers.” Riparian no-harvest buffers minimize disturbance on unstable slopes in order to avoid reducing soil strength and potentially subsequent landslides. Field reconnaissance and Forest soil mapping along with Watershed Analysis was used to identify areas of instability or geological hazardous zones. Many areas with 150-foot buffers were documented as active mass movement, torrent scours, or debris slides. Further, our prescription was also driven by the strong empirical evidence of the erosional features linked to past land management practices (EA pages 48-50, 55-58, 151-152, and 170-171). Continued management on relatively recent clearcut streamside buffers was viewed as likely to move the riparian reserve in a trajectory contrary to ACS objectives. Surface soil movement referenced in the comments was less of a concern than the deep-seated mass wasting. Surface soil movement

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values do vary based on a number of factors (slope, roughness, moisture, soil type) for typical harvest related overland soil movement. We generally agree that in some instances a large percentage of surface soil movement may be contained in 10 meters. We believe the buffer prescribed in this proposal is necessary to contain surface soil movement.

5-3 Riparian Buffers [EA] Page 152 under microclimate the FS uses “Streams Streams do influence microclimate as stated in the EA. Several in riparian reserves influence air temperature and authors agree timber harvest effects to microclimate may be mitigated humidity and create microclimate gradients extending with 10-20 meter buffers. However, as a rule slope stability, not laterally from streams (Olsen, et al. 2007). The FS has microclimate was a primary concern to establishment of these no failed to use more up to date studies. The Olson Density harvest buffers. Approximately 780 acres of buffers are in the best Management Riparian Buffer study 2014 is the only interests of protecting unstable and potentially unstable areas, which study of the combined effects of alternative forest are designated as riparian reserves by Northwest Forest Plan. See designs and riparian buffers and the best available discussion on unstable soils, landslide zones and buffers in the EA science and apparently the FS failed to use that science. pages 48-50, 55-58,. This study indicates that commercial thinning is consistent with Aquatic Conservation strategy/ ACS with much smaller inner riparian reserves than this EA proposes.

5-4 Riparian Buffers The other best available science concerning inner We understand that the spatial scale at which the ACS objectives were riparian zones and the ACS is Olson’s Forest Ecology intended to be attained was an ardently contested issue and ruled on and Management 2014 which I have included the in the courts (PCFFA v. NMFS). Previously, in Pacific Coast Fed. Of conclusions below verbatim [see Squires comment letter Fishermen’s Assn. v. Natl. Marine Fisheries Service, 265 F.3d 1028 page 3]…I would urge the adoption of the strategy (9th Cir. 2001)(PCFFA II, IV), the United States Court of Appeals for proposed by Olson in her conclusion of her study Forest the Ninth Circuit ruled that because the evaluation of a project’s Ecology and Management study 2014. Quoting Olson’s consistency with the long-term, watershed level ACS objectives could study, “The aquatic conservation strategy of the NFP is a overlook short-term, site-scale effects that could have serious regional approach to retain aquatic-dependent consequences to a listed species, these short-term, site-scale effects resources, and its objectives were intended to be must be considered. Memorandum EMS TRANSMISSION 05/24/2007, attained at larger spatial scales, with periodic BLM-Instruction Memorandum No. OR-2007-060 addresses actions unfavorable conditions within any particular watershed needed to respond to the rulings of PCFFA IV and PCFFA II. In (Reeves et al., 2006). Hence a calculated risk such as making the ACS consistency finding and to be guided by PCFFA II, implementing a 6- to 15-m riparian buffer at a stream the decision maker must: 1. Review projects against the ACS reach with upland restoration forestry, especially when objectives at the project or site scale, rather than only at the watershed other stream reaches within the drainage are managed scale. This review can be accomplished through cumulative effects more conservatively to hedge uncertainties, seems analyses (e.g., by evaluating the incremental effect of the project consistent with current policy for federal lands within the added to the existing condition, and the effects of other present and NFP area.” This describes exactly how management will reasonably foreseeable future actions) on watershed conditions; 2. occur in the future on lands covered by Silver Creek Thin Evaluate the immediate (short-term) impacts, as well as long-term EA. In the foreseeable future we will not harvest old impacts of an action; 3. Provide a description of the existing watershed growth in riparian buffers or any other older stands so condition, including the important physical and biological components

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these stands will only improve in their functions. The FS of the 5th field watershed; 4. Provide written evidence that the decision should adopt this strategy and by doing so address the maker considered relevant findings of watershed analysis. The courts requirement of the ACS to “restore” instead of noted the framers of the ACS disagreed on spatial context of the maintaining degraded habitats that your own EA states strategy and ruled in favor of the plaintiff in this landmark decision. are at “unacceptable risk” which is what this proposal There is a long history of industrial forest land management in the does. Silver Creek subwatershed (EA page 43-44, 50-52, 77). There is reasonable evidence to suggest that the portions of the Silver Creek subwatershed currently in non-federal ownership will be managed with relatively short rotation, clearcut logging. Matrix of pathway indicators ranks several baseline indicators at “unacceptable risk” for a variety of reasons. This Proposed Action takes some proactive measures to address degraded habitats not only through vegetation management but also through active restoration proposals (EA pp. 13-18). Road closures, riparian non-commercial treatment, and instream channel restoration are among the proposed actions, which are expected to move the baseline indicators in a positive trajectory. The element of time will be our ally in many circumstances. Many (riparian) stands are relatively young and underdeveloped. Further, there is strong evidence of ongoing disturbance where stands are dominated by alder. Passive restoration or deferring harvest for a rotation is expected to help rebuild long-term soil productivity and sustain watershed ecological functions.

5-5 Riparian Buffers The EA should also look at “ Alternative Riparian Buffer Our response is here is similar to that for comment 5-2 addressing Strategies for Matrix Lands of BLM Western Oregon Rashin’s study. The Reeves et al conclusions do not universally apply Forests That Maintain Aquatic Ecosystem Values to management of unstable slopes as per the Silver Creek Thin January 23, 2013 Gordon H. Reeves1 , Brian R. sediment transport functions. We agree with some aspect of Reeve’s Pickard2, K. Norman Johnson3,4” which indicate 100 conclusion regarding variable widths (page 48): “….based on stream feet for fish bearing and 50 feet for non -fish bearing segment importance; the variable-width buffer is better for both fish streams. and timber harvest because it enables managers to target where buffers will do the most good for fish while increasing the proportion of the buffer that also has timber production goals.” Larger buffer size would be required in more unstable areas or in areas that require greater protection to downstream water quality such as 303(d) listed streams for water temperature. See also response to comment 5-6 below as well as NWFP ROD B-10.

5-6 Riparian Buffers The FS should look at Rashin, E., C. Clishe, A. Loch and We agree that 30-foot buffers may be sufficient in some settings to J. Bell. 2006. Effectiveness of timber harvest practices meet the intent of ACS objectives. However, the NWFP ROD B-10 for controlling sediment related water quality impacts. asserts that multiple variables factor into efficacy of riparian reserve Journal of the American Water Resources Association. buffer. The ACS covers a wide array of ecological functions and Paper No. 01162 which indicates 30 foot buffers are processes. NW Forest Plan guidelines requires that we find appropriate and don’t violate ACS.

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consistency with all factors. Please also refer to responses for comments 5-1 through 5-11.

5-7 Riparian Buffers On page 162 the EA states: ”Other studies suggest of 45 Microclimate is among several considerations with respect to riparian m (150 ft.) on each side of stream with 70 to 80% management. It is our professional judgement that prescribed buffers overstory coverage (predominately Douglas-fir and will adequately protect the streams on NFS lands. Maintaining stream western hemlock to help maintain a natural riparian temperature is another objective of riparian management. Of particular microclimate environment along the streams adjacent to concern in the Silver Creek project area are channel reaches currently clear cuts in areas of moderate to steep slopes in excess of State water quality standards for stream temperature. Our (Brosofske, et al, 1997). This is seemed to be used to riparian harvest prescription was in part influenced by the large refute the previous citation: “Proper microclimate is a portions of the subwatershed currently managed as industrial forest crucial part of riparian reserves function on maintaining lands. While we do not have control over non-NFS lands, we assumed moisture and temperature. With minimum buffer widths these lands would continue to be intensively managed and likely to be of 45 to 75 feet, air temperatures within 30 feet of source areas of water warming. We agree that level of overstory streams have shown to be little affected by upslope retention is a contributing factor in maintaining site scale microclimate. thinning (Mazza, 2009). “ The Brosofske 1997 study Please also refer to discussion of microclimate and stream clearly refers to “streams adjacent to clearcuts” so I am temperatures in the EA pp. 78, 148-153, 155-156, 160, 164. confused why this study should be applicable to this thinning project and should be deleted which seems to leave you with the Maaza 2009 study which indicates buffers of 45- 75 feet. I could find nowhere in the document where the FS cited a study that indicated buffers should be larger than 45 feet except for the Brosofske study which has to do with clear cuts. The FS should follow their own citations and analyze a alternative that is consistent with the studies they cite.

5-8 Riparian Buffers On pages 151-152 the EA states “Summer stream We agree that 30-foot buffers may be sufficient in some settings to temperature is approximated based upon change in the meet the intent of ACS objectives. However, the NWFP ROD B-10 primary shade zone area of (minimum) 60 feet on each asserts that multiple variables factor into efficacy of riparian reserve side of a stream channel that is 20 feet wide or less. buffer. The ACS covers a wide array of ecological functions and Studies have shown that maximum shading ability is processes. NW Forest Plan guidelines requires that we find reached within a width of 80 feet and that 90% of that consistency with all factors. Please see responses for comments 5-1 maximum is reached within 55 feet (USDA Forest to 5-11 for more discussion on the considerations that informed the Service and BLM, 2010). Once effective shade buffer widths. decreases below 80% (220 Basal Area) it will begin to have an effect on increasing water temperature (USDA Forest Service and BLM, 2010).” This seems to indicate shade would not be an issue if the inner no treatment/restoration riparian zones for class 3 and 4 streams were 50 feet instead of 100-150 feet.

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5-9 Riparian Buffers The proposed action states to: “Actively manage and The interdisciplinary planning process included a limiting factor restore Riparian Reserves in the Lynx Creek and Silver assessment for water and soil related issues, which determined final Creek drainages to promote large tree structure and buffer designations (EA pages 27-35). The Forest Plan as amended riparian vegetation development using commercial and by the Northwest Forest Plan (NWFP ROD. Pg B-10) provides the noncommercial variable density thinning techniques context for considerations the IDT made in developing the buffers. (Middle Cowlitz Watershed Analysis, pp. 6-2 to 6-4). This Considerations included: Unstable slopes, channel stability, active will help control stocking and acquire vegetation mass wasting (landslides) and debris flows, site-specific soils data characteristics needed to attain Aquatic Conservation which was pre-reviewed on GIS or from photo interpretation and then Strategy objectives (NWFP ROD, pp. B-11, C-31 and C- verified in the field. (See EA 48-50, 55-58, 151-152, and 170-171 for 32).” This proposed action clearly doesn’t restore most more discussion). EA page 171 (Table 42) summarizes the channel of the acres in riparian reserves because class 3 and 4 stability measured within the analysis area and confirms a high streams have a no restoration buffers of 100-150 feet percentage of Class III and IV streams are at risk of stability. Sensitive and leave them at their present state of “unacceptable wildlife such as salamander species also benefit from riparian buffers risk”. In fact the EA states on page 175: “Riparian (EA page 125-126). We chose to standardize the buffer widths to reserves will be slow to attain Aquatic Conservation simplify and add efficiency to the planning and layout process. As a Strategy objectives (under this proposed action). Stand result, 100 feet buffer widths were used universally. Further, several structure and diversity will be underdeveloped. Riparian restoration projects are specifically in the proposed action to develop stands in the analysis area will be typically undersized riparian structure and habitat and promote large wood in strategic and ineffective at contributing LW in the short-term. The stream reaches (EA p. 13). dominant Grass/Pole seral stage may persist for several decades. Recruitment of large wood will be delayed, commensurate with riparian stand development.” Given this statement why doesn’t this proposed action address this issue by thinning within 45 feet of any class 3 or 4 stream which would have the attainment of large wood greatly accelerated instead of the proposed action which delays the benefits of large wood in streams? This proposed action maintains most of the riparian reserves that are functioning at “unacceptable risk” in that state for hundreds of years until a stand replacing fire comes though allowing natural regeneration. For example cedar is a very critical species because of it long life, large size and ability to create large wood for a long time critical to fish species to have growing in riparian areas. There are few if any cedars or any tree species diversity in these old clear cuts and the ACS requires the FS to “restore species diversity” in riparian reserves and instead the FS chose’s to maintain riparian reserves in their present degraded state with no hope of species diversity coming in naturally because the planted Doug Fir has such a head start that other species have no hope of surviving and growing to maturity in their shade. These large dense stands of Douglas fir/ DF also prohibit the dispersal of the Northern Spotted Owl/ NSO making it

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more difficult for the species to survive because they can’t fly though these thick stands. Since the FS is not significantly reducing the density in these stands of riparian reserves it will have a negative effect on the NSO for decades to come. Again the ACS requires the FS to “restore” and this proposed action doesn’t do that but instead takes the easy no management option of doing nothing that allows the dispersal of the NSO to be hindered and the significant delay in attainment of late successional characteristics in these stands that are critical for the survival of the NSO.

5-10 Riparian Buffers I can only assume that the decision to leave such large The interdisciplinary planning process included a limiting factor buffers on class 3 and class 4 streams is the fear that assessment for water and soil related issues, which determined final such benign treatments such as thinning somehow buffer designations (EA pages 33-40). The Forest Plan as amended violate ACS even though the best available science by the Northwest Forest Plan (NWFP ROD . Pg B-10) provides the doesn’t indicate it would. In fact the studies used in the context for considerations the IDT made in developing the buffers. EA as noted previously indicate riparian no harvest/no Considerations included: Unstable slopes, channel stability, active restoration buffers could be smaller, somewhere mass wasting (landslides) and debris flows, site-specific soils data between 20 and 50 feet. This EA fails to meet its own which was pre-reviewed on GIS or from photo interpretation and then stated purpose and need statements and needs to verified in the field. (See EA pages 48-50, 55-58, 151-152, and 170- modify the proposal to do so. This seems to not be 171 for more discussion). EA page 171 (Table 42) summarizes the intellectually dishonest since in the Nisqually EA there channel stability measured within the analysis area and confirms a was a project analyzed that was determined not to high percentage of Class III and IV streams are at risk of stability. violate ACS called the Riparian and Instream Sensitive wildlife such as salamander species also benefit from Restoration project. That project has the treatment of riparian buffers (EA page 125-126). We chose to standardize the 250 acres in inner riparian areas creating 147 stream buffer widths to simplify and add efficiency to the planning and layout structures along 7.4 miles of streams some of which are process. As a result, 100 feet buffer widths were used universally. fish bearing streams. The project would be PDC 1.16, on page 21 of this document, indicates the buffer widths noncommercial thinning of the inner riparian areas to not used for each stream class exceed 35% relative density removing trees 12- 28 inches DBH. The project would install instream log The restoration projects involving riparian and instream disturbance structures in cluster of 2-12 logs. The logs would be would be subject to several design criteria and mitigations to prevent hauled up to 200 feet and put in the stream by water quality issues during implementation (EA, PDC sections 8 and hoe/loader, excavator, skidder, dump truck and a truck 9). The Fisheries section of the EA discloses the beneficial and all working in riparian area with some of this big adverse, short-term and long-term effects of the Proposed Action, equipment by necessity entering the creeks floodway. restoration projects, and associated design criteria and buffers on How these activities impacts which are substantial would listed fish and ACS objectives in the EA (173-189). not violate ACS while commercial thinning between 45- 150 feet from a stream does seems intellectually dishonest. The no harvest buffers in the Nisqually Thin EA were 30 to 60 feet on intermittent streams which is consistent with the best available science. The science

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you use in your EA as noted previously indicate 30 to 60 feet no harvest buffers don’t violate ACS but actually “restore” some of the nine indicators of the ACS so to be intellectually honest you should follow your science.

5-11 Riparian Buffers The FS should use the studies I have provided as well The interdisciplinary planning process included a limiting factor as their own and alter their inner riparian no harvest/ no assessment for water and soil related issues, which determined final restoration area to 45 feet (unless site specific analysis buffer designations (EA pages 27-35). The Forest Plan as amended indicates differently) and commercially thin in these by the Northwest Forest Plan (NWFP ROD. Pg B-10) provides the areas from 45 to 150 feet. The inner riparian zone context for considerations the IDT made in developing the buffers. should also be thinned to a relative density of 35% Considerations included: Unstable slopes, channel stability, active similar to the Riparian and Instream Restoration Project. mass wasting (landslides) and debris flows, site-specific soils data Wood could be removed commercially or left on site. which was pre-reviewed on GIS or from photo interpretation and then There should also be created a number of gaps (Olson’s verified in the field. (See EA pages 48-50, 55-58, 151-152, and 170- recommendation on field trip this summer) that could 171 for more discussion). EA page 171 (Table 42) summarizes the then be replanted with cedar and other appropriate channel stability measured within the analysis area and confirms a species to create tree species and shrub diversity. This high percentage of Class III and IV streams are at risk of stability. is consistent with the best available science which Sensitive wildlife such as salamander species also benefit from indicates these activities would not violate ACS and riparian buffers (EA page 125-126). We chose to standardize the certainly have fewer impacts than the Riparian and buffer widths to simplify and add efficiency to the planning and layout Instream Restoration Project analyzed in Nisqually EA. process. As a result, 100 feet buffer widths were used universally. PDC 1.16, on page 21 of this document, indicates the buffer widths used for each stream class Further, several restoration projects are specifically in the proposed action to develop riparian structure and habitat and promote large wood in strategic stream reaches (EA p. 13).

5-12 Vegetation – I must applaud the FS for including some early seral A seral stage analysis was done for the biophysical settings Early Seral treatments although only 176 acres of the 3032 acres (vegetation types) in the Middle Cowlitz Watershed and on NFS land analyzed for treatment is certainly not enough. While by the Gifford Pinchot Forest Ecologist in December 2014. It was there is early seral habitat available it is not quality early inadvertently omitted from the Preliminary EA but now appears as seral habitat and is quickly growing out of that stage. Appendix E. This analysis partially informed the location and amount Combined with the fact that there won’t be any of early seral habitat enhancement treatments planning in the Silver treatments for decades in this watershed, early seral Creek project. The following is an excerpt from that analysis: "Seral habitat must be created now or in 30-50 years there will stage A (early seral) is slightly underrepresented (4% vs. reference be a larger deficit. Nowhere in the EA do I see an condition of 5%) in the North Pacific Maritime Mesic-Wet Douglas- analysis of how far out of the historic range of natural fir/Western Hemlock forest type (representing much of the project variability FS lands below 3500 feet are. There is no area) on National Forest land. A single percentage point can be analysis of even presence or absence of early seral accounted for by natural disturbance variability. The amount of early dependent species whose numbers are decreasing seral forest on adjacent lands, the connectivity of early seral forest regionally and are headed for listing. I would urge the FS among lands, and the overall quality of habitat provided by early seral to look at the study Biological Associates of Early Seral forest are of more concern than simply number of acres. Private lands preforests in the Pacific Northwest: Swanson et al. adjacent to the National Forest near Silver Creek planning area have

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2014.This documents a number of early seral species been heavily harvested. Habitat conditions on those lands are that are in decline and in need of early seral habitat. Also unknown. Factors including snag abundance, height, and condition; look at Early Seral Forest in the Pacific Northwest, coarse woody debris abundance, length, and condition; and shrub and Swanson 2012. Swanson notes that the larger the herb richness need to be considered to assess habitat quality on both disturbance that creates early seral habitat the better private and national forest lands. Analyses shared here are limited to and the longer this habitat will persist. The FS needs to forest composition and structure and do not include any factors of analyze the cumulative impacts to these species in peril habitat quality. “Thus, findings indicate no lack of early seral habitat on over the next 30 years as their habitat leaves the early NFS lands in the Douglas-fir/western hemlock forest type of the Middle seral stage and how this may lead to their extinction. Cowlitz watershed based on forest structure and composition. However, you are correct to note that the quality of such habitat was not specifically analyzed on NFS or adjacent lands. Past harvest practices suggest that current early seral habitat might be lacking in quality components; however, without more information on habitat quality across land ownerships and among seral stages, we cannot knowledgeably and in good conscience prescribe early seral habitat enhancement at the potential expense of other habitat types. Furthermore, treatments are limited to thinning stands younger than 80 years old in the Late Successional Reserve (LSR) allocation. Regeneration harvest (early seral enhancement) conflicts with the management direction of LSR (EA, p. 4).

5-13 Vegetation – The EA states in the “needs” statement that there is a A seral stage analysis was done for the biophysical settings Early Seral “lack of early seral habitat”. While there are some early (vegetation types) in the Middle Cowlitz Watershed and on NFS land seral treatments there are none above 3500 feet. The by the Gifford Pinchot Forest Ecologist in December 2014. It was fire interval at higher elevation is more frequent and after inadvertently omitted from the Preliminary EA but now appears as over a hundred years of fire suppression has caused a Appendix E. departure from historic conditions. Moreover there will be no vegetation management for the next 30 years The majority of forest types in the Silver Creek planning area above causing the departure from historic conditions to only and below 3500 feet are characterized by long (100-300 year) or very worsen as young plantations mature quickly out of early long (300+ year) fire regimes (Agee 1993). Fire suppression has only seral habitat. To adequately manage conditions in the been affecting western forests for approximately 100 years. We cannot future some vegetation treatment needs to be taken now assume departure from historic conditions because fire suppression so in 30-50 years site conditions will be within the range has been occurring for only a single fire return interval in the driest of natural variability. I urge that this EA analyze what the vegetation types present in the planning area. Even in another 50 need will be for early seral habitat 30-50 years from now years, most of the forest types present will still be within their natural above 3500 to be within the historic range of variability. . range of variability regarding fire frequency. If the trajectory we are on now indicates there will be a Stands above 3500 feet in the Matrix allocation are in a Management deficit of early seral habitat then treatments need to be Area Category where timber production is the primary objective. included in this EA to ensure that above 3500 feet early Stands in this category cannot be regeneration harvested until they seral habitat will be in its historic range of variability. have met Culmination of Mean Annual Increment (CMAI) as dictated These treatments should be like Veta and Pinto sales. I by NFMA (EA, PDC 1.9, and page 80-81). Mean annual increment is am sure after analysis we will find that they are out of the average annual growth of a stand, which culminates when it their historic range of natural variability or will be soon

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based on local and indigenous knowledge. The EA reaches its maximum rate of growth. The District Ranger did not want seems to assume it will be in the historic range of to propose treatment in stands older than 130 years which left only variability by not treating these areas and I question that stands under 60 years old available for the project as there were no assumption since I have seen no analysis in EA to stands between ages 60 and 130. The stands less than 60 years old indicate it will be. I urge that that a new alternative be have not yet met the CMAI requirement and therefore can only be created that addresses early seral habitat above 3500 thinned according to NFMA. feet and be analyzed.

5-14 Wildlife The FS should look at : “Butterflies and Moths of PNW According to the referenced Butterflies of Moths of PNW Forests and forests and Woodlands: Rare, Endangered and Woodlands, Miller and Hamilton, 2007, "Many of the taxa covered in Vegetation – Management Sensitive Species, Miller and Hamilton this book reveal present day patterns in distribution that appear to be Early Seral 2007 to understand the number and types of species remnants of the species range that historically (centuries to millennia) that are at risk of going away if more quality early seral was more widely distributed. The current diminished ranges contracted habitat is not created. To create more quality early seral naturally to very small populations within isolated refugia along the habitat early seral treatments should be considered on West Coast prior to European settlement of North America. cable ground and the total early seral acreage should be Subsequent to the natural contraction of these species ranges, at least 800 acres. At the very least early seral adverse human-related effects on the quality and quantity of remaining treatments should occur where the ground is ground suitable habitat resulted in fragmentation of the populations, thus based logging. Unit 21 which is 14 acres of early seral placing them on the brink of extinction. Four issues are responsible for should be 30, unit 28 should from 59 to 80; unit 29 the fragmentation and decline among these populations: 1) loss of proposes 33acres should be 43 and unit 37 propose 18 habitat to urban and agricultural development; 2) logging of mature should be 28. Unless the FS starts creating more quality forests; 3) the controlled management of natural disturbances such as early seral habitat now in a few decades it will be almost wildfires, and; 4) the introduction of tall-growing exotic grasses and nonexistent and early seral dependent species will be brush that compete with and displace native vegetation, including the listed as threatened or endangered and could go extinct. food plants required by the larvae of many butterfly species.." Please analyze this alternative where these actions are Therefore, citing this reference as an argument for creating early seral taken and how these treatments will impact early seral habitat in a forested environment does not logically examine the species in decline or peril. factors leading to Lepidoptera population declines. The 2 factors causing decline of Pacific NW native moths and butterflies cited above that are relevant to Silver Creek would be #2, logging of mature forests, and #3, control of natural disturbance events such as fire. To argue that by not creating clearcuts that are artificial early seral habitat that does not persist on the landscape for more than 2 or 3 decades given the rapid rate of conifer growth in the Pacific Northwest, would cause the extinction of native moths and butterflies, is ignoring the habitat requirements of these species that in some cases, such as the Johnson's hairstreak butterfly (Region 6 sensitive) feed on dwarf mistletoe and require conifer canopy as habitat. According to Miller and Hamilton, "management practices that would benefit this species need to promote the maintenance of mature and old-growth conifer forests at middle to low elevations on the west slope of the Cascade would be to increase the length of time in the harvest rotation of mature true fir forests along the summit of the Cascade Mountains".

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Other Region 6 sensitive species, such as the mardon skipper butterfly, require dry meadow habitat that would not be created in an early seral forest opening because the seed source for the required grasses, such as fescue, would not be present in the soil and therefore would not be produced by removing the conifers. The Gifford Pinchot Land and Resources Management Plan, as well as Regional Guides, establish the maximum size and dispersal of created openings in accordance with the legal requirements and provisions in the National Forest Management Act (EA, pp. 80-81). These standards and guidelines limit the size of created openings to 60 acres in the Western Hemlock Working Group and 40 acres in the Pacific Silver Fir Working Group and elsewhere. Virtually all of the proposed created openings in the project proposal are located in the Pacific Silver Fir Working Group (EA Table 1 and Table 6). Additionally, the standards and guidelines require that logical harvest unit(s) remain between existing created openings (EA PDC 1.9). These constraints, combined with other factors such as buffers for riparian habitat, terrestrial habitat, unstable soils and visuals have all played a role in developing the shape, size and dispersal of created openings in the project proposal.

5-15 Transportation I also have concerns about the roads that are being There are currently many miles of road in Silver Creek, which are not system proposed for closure. Road 7561018 has been rated as accessible due to failure nor have been for a decade or more. This “moderate access need” and shouldn’t be closed project would actually improve or re-establish access on system roads because of future access needs for harvest in the matrix. (see EA page 15 and Appendix C). No roads are proposed to be Road 4778011 will “have to reconstruct length of FR decommissioned (completely removed from the National Forest road 4778011 including ditch, shoulder and surface repair and system) as stated in the Proposed Action. Further, closure and culvert replacement at mileposts 0.56 and 0.6.” To stabilization does not foreclose the opportunity to use the road for spend tens of thousands of dollars to repair a road and future management, and no roads currently open are proposed for then to decommission it seems an unwise use of dollars. closure in this project. We are challenged to strike a balance between Since its closure is justified for wildlife security the costs of maintaining roads, providing public and administrative access cheaper option would be to gate it. Road 4700213 the and sustaining ecological function across the landscape (both aquatics need is rated moderate and since the reason for closure and terrestrial). The current degraded nature of the NFS road system is wildlife security a gate permanently locked would be is a pressing concern for many facets of resource management. We most cost effective. Road 7500047, 7500048, 4700049 have a development of road infrastructure, which far outreaches our and 7500002 have high access needs and should not be capacity to conduct regular maintenance necessary to sustain both closed. Road 8500108 has a high access need and suitable driving conditions and help safeguard against chronic and moderate aquatic and low terrestrial risk and shouldn’t catastrophic failure. Part of our road strategy is to bring our road be closed because there is no pressing ecological risks system into proportion of our current and expected fiscal capacity to and because of the “high access need”. Let us not make maintain. While there is an upfront investment in closing and stabilizing another 7708 mistake where we closed the road a few roads, we believe that in the long-term, we are money ahead by years ago and are now going to be spending tens of proactively closing roads and preserving much of the road matrix for thousands of dollars to reopen it. future use. Among our goals for this planning area was to sustain current net levels of public access to the extent practical. Roads which

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provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so, we found that several roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance.

Commenter: Pinchot Partners

6-1 Vegetation – During scoping for Silver, the Pinchot Partners provided Many factors were considered regarding huckleberry enhancement in Early seral, comments on restoration projects, at your request. Our the Silver Creek planning area. Direction and guidelines are provided Huckleberry primary concern was to restore huckleberry habitat by Gifford Pinchot Land and Resource Management Plan, the enhancement within the Silver Creek area as huckleberry restoration is Northwest Forest Plan, the National Forest Management Act (NFMA), a priority for the Pinchot Partners... We do not feel and line officer sideboards (please see EA pages 4-5, 80-81). Further huckleberry restoration was adequately addressed in the consideration was given to plant associations where we are most likely draft EA. Huckleberries are noted only nine times in the to be successful, forest structure condition class, access, tribal uses, 247 page draft EA, mostly in the plant associations social values, and competing priorities. table... If a prior historical conditions analysis had been performed, undoubtedly, huckleberry areas would hae Additionally, a seral stage analysis was done for the biophysical been documented as being prevalent in the upper settings (vegetation types) in the Middle Cowlitz Watershed and on elevations of the Silver area and received more analysis. NFS land by the Gifford Pinchot Forest Ecologist in December 2014. It Huckleberries are noted as a special forest product of was inadvertently omitted from the Preliminary EA but now appears as interest to forest visitors on page 195 of the draft EA... Appendix E. we encourage you to be more inclusive of multiple social values of interest to forest visitors in the analysis and give more attention to huckleberries and huckleberry habitat.

6-2 Correction We also noticed an error on page 12 of the preliminary The EA has been corrected to reflect the role of the Pinchot Partners EA. It notes that the Forest Service hosted a public in coordinating and hosting the public meeting. Apologies for this error, meeting on November 12, 2014. That meeting was co- and thank you for your outreach and support efforts! hosted with the Pinchot Partners. We worked with Erica Taecker to develop the flyer, send out press releases, post notices and we provided food in order to encourage community members to attend.

Commenter: Ron Pfeifer

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7-1 Transportation I only have one substantial comment and that concerns Appendix D was added to the EA to address this issue in more detail. system one of the “Alternatives Considered, but Eliminated from Please also refer to page 41 in the EA. Detailed Study”. My specific concern is about the “Alternative to Reconstruct FR 47 Crossing at East Fork Silver Creek”. I have seen that blown out crossing, and it is certainly a mess and a complicated situation. I’m not an engineer, hydrologist, soil scientist, geologist or district ranger, so I won’t pretend that I know the correct solution to that problem. My concern is that the EA does not provide the public with nearly enough information to judge whether, in fact, such an alternative is economically viable, especially if it were only a temporary crossing constructed to minimum specification and used only for timber haul during the project. In my opinion, you should be providing the public (in a transparent way; e.g. in the appendix) with all the assumptions and data used in the preliminary analysis by which you decided that any reconstructed crossing of the creek is not economically viable. Commenter: Kathy Heimbigner

8-1* Transportation I do believe it would be beneficial for the 47 road to be Appendix D was added to the EA to address this issue in more detail. system restore as much as possible - for numerous reasons. We Please also refer to page 41 in the EA. had always enjoyed the capability to drive up into the forest on that road - in fact, my husband drove up there early in the morning of May 18, 1980 and saw the beauty of the mountain just before Mt St Helens erupted! *Note* comment does not have standing for objection because it was submitted after comment period closed.*

8-2* Public safety, I do have a concern for Silver Creek itself, its health and The IDT developed the Proposed Action not only to provide revenue to Social impacts riparian abilities in addition to the folks of the valley the local economy through timber sales, but also to address many of affected by the flooding. I would welcome any efforts to the very issues the commenter has raised related to riparian health improve on these matters. and public safety. Please see Appendix D for more detailed *Note* comment does not have standing for objection discussion. because it was submitted after comment period closed.*

8-3 Public safety, Summary of oral comments provided during comment The IDT developed the Proposed Action not only to provide revenue to social impacts period: the local economy through timber sales, but also to address many of Multiple flood events over decades have scoured away the very issues the commenter has raised related to riparian health portions of this [Heimbigner’s] property on Silver Creek. and public safety. Please see Appendix D for more detailed In every flood event, more debris is deposted and more discussion.

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land is eroded/shifted onto and away from the property. Logs and debris upstream of the East Fork Silver Creek crossing of The net loss of land from this property is estimated to be FR47 will not be directly impacted or moved by this project. However, 1 acre since 1975. an alternative to reconstruct a crossing or bridge at that location was Federal funds have supported bank revetments on the not fully analyzed in part due to the risk of another catastrophic failure [Heimbigner] property in the past after floods, but not of a crossing, which would have the potential to more severely impact always and not easily. downstream communities than logs and debris alone. Please see the Very concerned that logs and debris still upstream will Appendix D for more about the evaluation done for a potential continue to come down during flood events, modifying crossing. her [Heimbigner] property and affecting the local community.

8-4 Transportation, Supportive of community's interest in constructing even Appendix D was added to the EA to address this issue in more detail. ; social impacts a temporary "Bailey bridge" on FR 47 over the East Fork page 41 in the EA also addresses this. Silver Creek to allow access to the forest.

Commenter: Gifford Pinchot Task Force

9-1 Riparian buffers Many Riparian Reserves are short of dead wood due to The proposed project would commercially thin approximately 300 past and ongoing logging, roads, and fire suppression. In acres within the outer riparian reserve buffers, no closer than 100 feet the Silver Creek project area, there are multiple streams to streams (see PDC 1.16 for buffer widths) and maintain with poor large woody debris and poor pool per mile approximately 1,300 acres of "no harvest" within the inner riparian ratings. Natural processes of stand growth and mortality reserves (see discussion of how inner reserve widths were determined will correct this shortage, whereas thinning could capture in responses to comments 5-1 to 5-11). Therefore, while some of the and export mortality and reduce and delay recruitment of research cited may show that the long-term result of thinning is fewer wood to both streams and uplands within Riparian large diameter trees and slower recruitment of small diameter snags Reserves. This is not a minor short-term effect, but (as discussed in the EA beginning on page 134 in the cavity excavator rather a significant long-term effect. Such effects are section, see suppression mortality discussion), much other research inconsistent with the Aquatic Conservation Strategy would show that thinning does produce larger diameter trees (Chan et which prohibits logging in Riparian Reserves unless it is al, 2006). Therefore, while there may be some validity to the argument needed to meet objectives, and requires that that thinning would produce fewer small diameter snags and less management actions “maintain” and "not retard" ACS down wood, the effects of the proposed treatments would only occur objectives, including dead wood. Any purported benefits on 300 acres, and would occur in generally in young, managed of riparian thinning must be weighed against the plantations that are not currently providing substantial amounts of potential adverse effects on dead wood recruitment. dead wood habitat for amphibians, mollusks, lichen and fungi that are A recent interagency study assessed the potential typically associated with late successional stands. Therefore, given the ecological outcomes of riparian thinning in relation to small area affected and the age of these stands, thinning 300 acres of ACS objectives, noting that riparian thinning “can reduce outer riparian reserves within the approximately 30,000 acre the future supplies of snags and large dead down and watershed, will not have a substantial impact to dead wood habitat in decomposing wood on the forest floor and in aquatic the Silver Creek watershed and the species that are associated with systems,” potentially retarding attainment of ACS dead wood habitat. See cavity excavator section in EA, page 134-137 objectives #8 and #9. See Spies et al 2013 at 27. for project effects to cavity excavators. Dead wood is important to both aquatic and terrestrial purposes of Riparian Reserves. As such, the EA cannot just focus on recruitment of wood to streams, but must

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also address the need to recruit optimal levels of snag and dead wood to meet the needs of terrestrial wildlife (e.g. primary cavity excavators, secondary cavity users, amphibians, mollusks, lichen, fungi), which were intended to be benefited by Riparian Reserves. In addition, dead wood of all sizes is important to streams and riparian function. In small streams, small wood can even perform the ecological and hydrological functions normally thought to require large wood. If the goal of logging is to create large trees faster, the NEPA analysis should document the size, gradient, and other characteristics of streams adjacent to each logging area and determine the size of wood that can serve key ecological and hydrological functions, then disclose the effects of logging relative to those relevant wood sizes. In another recent long-term study, an unthinned stand had far more large diameter live trees than a thinned stand decades later, as described below. According to a position paper by Kim Kratz, Director of the National Marine Fisheries Service (NMFS) Oregon State Habitat Office: “Thinning accelerated the development of large diameter trees by about 20 years such that there were more live trees > 18” dbh in the two decades following thinning, relative to the unthinned stand, but this advantage was short-lived. Three decades after thinning, there were more live trees > 18” dbh in the unthinned stand and five decades after thinning there were twice as many live trees >18” dbh in the unthinned stand relative to the thinned stand. A similar trajectory was observed for the live trees > 24” dbh.” Kim Kratz, Ph.D., Issue Paper for Western Oregon. NMFS, Oregon State Habitat Office. 7- 23-2010. Appendix 1 at 38. The NMFS position paper assessed whether heavy thinning of riparian conifer forests leads to more instream wood and concluded that “an unthinned stand will produce a higher number of both live and dead trees across a range of diameter classes and will produce far more dead wood over a much longer time frame relative to a heavily thinned stand. A strategy of thinning to accelerate the development of a few healthy, large-diameter trees does not translate into more large wood in streams. ” Kratz at 4 (emphasis added). Kratz also states: In regards to stream habitat, many of the negative impacts created by the existing riparian thinning proposals could be largely

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avoided with wider no-thin buffers (e.g., see Appendix 1) and removing far fewer trees during thinning operations. In examining forest thinning proposals designed to accelerate the development of late successional forest conditions and restore instream fish habitat, NMFS is finding that, in many cases, they are likely to do neither. Kratz at 8 (emphasis added). According to the Silver Creek EA, thinning in Riparian Reserves under the proposed action will result in “[t]he growth of trees both in height and girth [which] will improve shade in the long- term and provide future recruitment of large wood to the forest floor and/or to the actual stream itself.” EA at 81. However, as illustrated above, recent studies have shown the opposite effect over the longer term.Pollock and Beechie also emphasize uncertainty in the response of particular species to treatments that attempt to recreate associated habitat structures, as well as the possibility of neglecting other important features that a species needs. For example, “attempts to restore spotted owl habitat by heavily thinning to accelerate the development of large diameter nesting trees could actually delay spotted owl recovery by reducing production of the large down wood utilized by the species it preys upon.” Pollock and Beechie 2014 citing Forsman et al., 1984; Carey, 1995; North et al., 1999.In order to retain options for recruitment of large wood in degraded stream systems, scientific recommendations include retention of trees >12” dbh. Removal of trees from riparian zones may delay the recovery of fish habitat. At a minimum, the largest trees (that is, those > 12 inches in diameter at breast height) should be left in riparian areas for future sources of in-stream wood. This would apply to all streams, as recommended by Anderson and others (1992). Smaller trees could be removed as part of a program for riparian vegetation restoration. Gordon H. Reeves and Fred H. Everest. 1994. REDUCING HAZARD FOR ENDANGERED SALMON STOCKS. in Everett, Richard L., comp. 1994. Restoration of stressed sites, and processes. Gen. Tech. Rep. PNW-GTR-330. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station.

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9-2 Riparian buffers In addition to questioning the merits of riparian thinning There is no commercial thinning proposed in the inner riparian in terms of dead wood, snag recruitment, and other key reserves, which are defined in the by EA PDC 1.16 and explained in riparian habitat structures, we have concerns about the much further detail in the response to comments 5-1 through 5-11 proposal to pre-commercially thin inner Riparian along with EA references in those responses. Reserves due to potential effects on water quality from Project design criteria specific to pre-commercial thinning proposed in lack of stream shade and sedimentation (sedimentation this project have been added to the Silver Creek Thin EA PDC as will be further addressed in the roads section herein). section 10. These are the same PDC, which apply to other pre- While we are not opposed to some hand felling and commercial thinning projects across the forest and have been leaving of trees in riparian areas for habitat restoration in successful at ensuring minimum stocking to meet land management dense, young plantation stands, we do not support objectives as well as protecting aquatic and wildlife habitat, water thinning right up to stream edges without sufficient no quality, and ensuring compliance with the Forest Plan, as amended, cut buffers. as well as Clean Water Act and other laws, policies, and regulations. First, there is some confusing and misleading information in the EA. On the one hand, the Forest Service asserts that thinning up to 20 feet from streams will be sufficient to ensure sufficient stream shade and protect the fragile microclimate (indicating that thinning will occur up to 20 feet from stream edges). See EA at 158-162. Yet, when evaluating microclimate and stream temperature, the Forest Service states that there will be minimal effects because buffer widths are 60-300 feet. In the microclimate section, it appears that the full analysis of effects focuses solely on thinning in outer reserves, despite the prescription to also thin the inner reserves. See EA at 162. The Forest Service must assess the impacts of allowing thinning in inner Riparian Reserves on stream temperature and microclimate, and provide additional details on the specific thinning prescription for inner reserves in the EA. Further, this proposal covers a large area with varying degrees of slope angles, stream orientations, densities, and species diversities, so there is a wide range of variability in effects. There are multiple studies concluding that thinning in Riparian Reserves—both inner and outer reserves—can increase stream temperatures beyond a level that supports healthy aquatic and riparian ecosystems, which could potentially retard attainment of ACS Objective #4 and contributing to water quality standard violations. See Spies et al at 26. The NMFS position paper referenced above also discusses riparian buffers in more detail and questions the modeling that the Forest Service and Bureau of Land Management are using to determine minimum riparian buffer widths to

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ensure sufficient stream shade. See Kratz at 14-20. NFMS in part does this due to generalizations made in determining stream buffers, which do not account for variable parameters like stream orientation or sinuosity. Kratz at 17-18. The Forest Service must also ensure that there are sufficient buffers to protect stream shade and microclimate in this proposal due to the presence of federally listed fish populations, including Chinook, Coho, and steelhead, in the project area. Anadromous fish populations require cool water throughout all of their life stages and no cut buffers are essential to ensure sufficient stream shade. "Stream temperatures are significantly influenced by shading from streamside forests (e.g., Brown 1970, Brown and Krygier 1970, Brazier and Brown 1973). Recent field evidence in Bristish Columbia showed that stream temperature was 3°C higher with a forested buffer of 33 feet wide than in the forested control site, and 1.6°C higher with a 98 foot forested buffer. By contrast, a recent modeling effort showed that, on average, a 90 foot forested buffer in Oregon forests was likely to keep the temperature increase less than 0.3°C (upper 95% confidence interval 0.6°C, based on modeled stream temperature using Ripstream, Groom et al. 2011). This suggests that stream temperatures may still not be protected in many reaches even with a 90 foot buffer." Timothy Beechie letter to OR Board of Forestry, July 21, 2015.In addition, according to the EA, there are three identified 303(d) listed stream segments for water temperature in the project area: Silver Creek, Lake Creek, and Lynx Creek. The EA must indicate the extent of water quality impairment and must disclose the direct and cumulative impacts. The Clean Water Act does not permit de minimus degradation of water quality, especially on streams that are already impaired. 33 U.S.C. § 1323(a)(2)(C).

9-3 Riparian buffers The ACS objectives of the NWFP also require the Forest See EA on page 126-128 for disclosure of effects to Van Dyke’s Service to “[m]aintain and restore spatial and temporal salamander and other amphibians. It is not practical to designate connectivity within and between watersheds.” See ACS Riparian Reserves across ridges given that they are, by definition, Objective 2. Riparian Reserves function as connectivity located within variable distances from stream channels that typically corridors and provide habitat to sensitive wildlife species do not start at the ridgeline and generally are not even evident until like the Van Dyke’s salamander. We recommend that some distance from the ridges where groundwater appears at the

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the Forest Service consider extending the riparian surface. Therefore, they usually cannot be defined to the top of the buffers across key ridgetops in order to provide ridgeline. Also, very few proposed treatment units abut a ridgeline interbasin connectivity for amphibians and other species. therefore no riparian buffers within units are located near a ridge. However, we acknowledge that the function of riparian reserves in the Northwest Forest Plan is to provide connectivity on the landscape for semi-terrestrial riparian associated species, including salamanders, especially within the Matrix land designation. Consistency of this project with ACS objectives (including number 2) is addressed in the EA at p.187.

9-4 Riparian buffers For all of the above reasons, the Task Force There is no commercial thinning proposed in the inner Riparian recommends that the Forest Service refrain from Reserves, which are defined in the EA by PDC 1.16 and discussed in thinning in the inner portion of Riparian Reserves within much further detail in the response to comments 5-1 through 5-11 the Silver Creek project area or at least limit thinning to along with EA references in those responses. very young, high density stands on gentle slopes beyond Project design criteria specific to pre-commercial thinning proposed in the 100 foot zone where most shade and woody debris this project have been added to the Silver Creek Thin EA PDC as recruitment is generated. We recommend maintaining section 10. These are the same PDC which apply to other pre- nocut buffers of at least 130 feet for perennial fish- commercial thinning projects across the forest and have been bearing streams in the entire project area and successful at ensuring minimum stocking to meet land management maintaining full Riparian Reserve widths if any early objectives as well as protecting aquatic and wildlife habitat, water seral prescriptions are retained in matrix. We also quality, and ensuring compliance with the Forest Plan, as amended, recommend retention of trees >12” dbh in fish-bearing as well as Clean Water Act and other laws, policies, and regulations. streams, and that trees cut in Riparian Reserves remain on site. In addition, we recommend that only standard thinning be conducted in Riparian Reserves. Lastly, we would like clarification on thinning limitations for the pre- commercial prescription in inner Riparian Reserves.

9-5 Transportation The Task Force is very supportive of the road closures The Proposed Action related to the use and disposition of system and system and stabilization proposed in the EA to address non-system roads responds to a variety of factors raised during terrestrial and aquatic risks. However, as highlighted in internal and external scoping and analysis disclosed in this EA. There our scoping comments, we are concerned about the are currently many miles of road in Silver Creek, which are not effects of road construction, reconstruction, and landings accessible due to failure nor have been for a decade or more. We are in this proposal, especially due to soil instability issues challenged to strike a balance between costs of maintaining roads, and landslide occurrences in the project area (note that providing public and administrative access and sustaining ecological Figure 9 on slope stability is missing on p. 69). The EA function across the landscape (both aquatics and terrestrial). Stability states that there will be reconstruction of 64.1 miles of concerns in the project area factored greatly into the overall Proposed level 2 roads and 14.51 miles of level 1 roads; 7.4 miles Action as well as Project Design Criteria required for accomplishing of new temporary roads; 855 landings; and 22 stream any roadwork (EA p. 13, PDC sections 6 and 7, Appendix C). The crossings in the Silver Creek thin proposal. We are effects of the Proposed Action related to soils and slope stability are particularly concerned with the proposal to build or discussed on pages 63-70. The current degraded nature of the NFS rebuild stream crossings, create new temporary roads, road system is a pressing concern for many facets of resource reconstruct temporary roads, and reopen management. We have a development of road infrastructure, which far decommissioned roads. We are also disappointed that outreaches our capacity to conduct regular maintenance necessary to

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the draft EA fails to include a map with clearly marked sustain both suitable driving conditions and help safeguard against locations of new stream crossings, which should be the chronic and catastrophic failure. Part of our road strategy is to bring minimum information presented to the public through our road system into proportion of our current and expected fiscal NEPA. [multiple references in EA are provided indicating capacity to maintain. Among our goals for this planning area was to the reasons for GPTF's concerns related to ESA fish, sustain current net levels of public access to the extent practical. water quality, wildlife, sensitive habitats) Roads which provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so, we found that several roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance. The effects species of proposed changes to the transportation are analyzed and disclosed in this EA. Road reconstruction needs, including stream crossings, is listed in tabular and narrative form in Appendix C of the EA. In addition, known streams are shown in their proximity to roads in the project area in the Proposed Action, Figures 3-8 in the EA. Figure 9 erroneously appeared in the Index of Figures in the Preliminary EA due to a hyperlink placed on the text (no figure 9 exists). The index listing has been corrected in the updated EA.

9-6 Project Design In addition, we are concerned about mitigation measure The Gifford Pinchot National Forest is following National and Regional Criteria – Water 6.20, which allows off-season logging with approval from guidelines for staffing and is currently fully staffed in Sale quality and ACS a sale administrator. Off-season logging can result in Administration. The Forest also complies with monitoring protocols, as sedimentation and related water quality and ACS well as random and routine compliance checks before, during, and violations. We do not believe that the Forest Service is after harvesting activities. Reconstruction, maintenance, and other adequately staffed to sufficiently monitor sites to ensure restoration activities and associated PDC included in this proposal are violations do not occur. designed to repair or restore the sites that currently do not or may not meet ACS objectives prior to haul activities.

9-7 Temporary roads We also request that new temporary roads or road The Forest Service endeavors to minimize the amount of temporary reconstruction be minimized, especially where the roads road construction while also meeting the diverse economic and could adversely impact listed fish habitat or result in ecological objectives for a timber project. Temporary road construction other harmful aquatic or terrestrial impacts. There is is often needed to access the whole stand without skidding or yarding clear evidence that temporary roads are anything but across streams, which are more detrimental to the health of that temporary and that, oftentimes, their existence and stream than building a temporary road. subsequent impact continues in perpetuity. Temporary Temporary roads are located far enough away from stream channels roads can detrimentally affect stream health, as well as for them to deliver any sediment. Page 163-165 in the EA under habitat for Northern Spotted Owl and a variety of Objective 4 of the ACS states, "Proximity of temporary roads to stream regional species. They can also result in the compaction channels is limited which would allow sediment to be filtered through

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of soil, alteration of the forest microclimate, alteration of the forested vegetated floor prior to entering stream channels. the flow of water in the stand, erosion, sedimentation, Sediment delivery would not result in a measureable increase in and increased peak flows of nearby streams. stream sediment deposition." Project Design Criteria and Mitigation Measures table sections 6 and 7 describe measures reduce the risk of erosion and any sediment delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams during off-season logging operations by following a timing restriction so as not to log during wet weather conditions which can be measured objectively (#6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (#6.15). Effects of these activities on sediment delivery are disclosed in the EA at 150.

9-8 Transportation We also encourage the agency to increase the number The team endeavored to use the 2002 Roads Analysis and field data system of miles designated for closure and stabilization or to identify roads to close and stabilize through the Silver Creek Thin decommissioning in areas that are sensitive habitats or project considering ecological risk factors including those asserted by where roads have significant impacts on water quality the commenter. Roads which provide access to multi-purpose (public within the project area. identified) location(s) were prioritized to maintain on the active road system. We are challenged to strike a balance between costs of maintaining roads, providing public and administrative access and sustaining ecological function across the landscape (both aquatics and terrestrial). Stability concerns in the project area factored greatly into the overall Proposed Action as well as Project Design Criteria required for accomplishing any road work, including closure and stabilization (EA p. 13, and PDC sections 6 and 7, Appendix C).

9-9 Transportation In addition, in our scoping comments, we requested that The analysis of trade-offs as you suggest is typically done through the system, an analysis of temporary roads and road reconstruction interdisciplinary development and refinement of the proposed action, Ecosystem and the economic and ecological tradeoffs of individual as well as in discussion of project design criteria and mitigation services road segments be conducted. However, we do not see measures. These discussions and notes are contained within the this analysis in the EA. It is critical that the EA evaluate project record and summarized where appropriate in the EA. the costs of road reconstruction and thinning versus the There were multiple methods and procedures followed for identifying benefits, like ecosystem services, that the forest can environmental amenities and values and effects to them in the EA provide. (pp.43-210). These included deriving the project need from the Gifford Pinchot National Forest Land and Resource Management Plan, Middle Cowlitz Watershed Analysis, landscape-scale assessments, best available science, and local resource data collected. These sources also provided information about an array of difficult-to-quantify environmental amenities and values, such as recreation, visual quality, and climate change. While not depicted in quantitative form for every resource (i.e. many values, such as the amenity value of being able to access the forest for recreation benefit), the costs and benefits of roadwork are

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disclosed in the EA in terms of effects to a variety of ecological, economic, and social resources.

9-10 Wildlife – The Task Force is concerned about the proximity of A biological assessment for project effects to northern spotted owl Endangered some of the plantation units to NSO suitable habitat and (NSO) and marbled murrelet (MAMU), both Endangered Species Act Species Act the impacts of thinning within NSO critical habitat. Right (ESA) listed species, was prepared and reviewed by the US Fish and now, with the negative impact that barred owls are Wildlife Service (the Service). The Service responded with a biological having on spotted owls and the potential uplisting of the opinion (BO) for the Silver Creek Thin project. According to the BO, NSO to endangered status, the Forest Service should be the Silver Creek Thin project is "not likely to jeopardize the continued cautious that timber harvest activities do not add to the existence of the northern spotted owl." The Fish and Wildlife Service pressure on spotted owls, or directly harm or adversely made the same conclusion in the BO for MAMU. The BA/BO process modify their critical habitat. [references to ESA listing is followed to ensure that federal actions due not jeopardize the and EA NSO analysis are provided in the comment as continued existence of ESA listed species and as such are compliant rationale for GPTF's concern]... To avoid detrimental with the ESA. The EA discusses at length the effects of the inclusion effects to NSO and potential violations of the ESA, as of Unit 29 regarding the loss of NSO foraging and MAMU potential well as impacts to marbled murrelet habitat and listed nesting habitat. See MAMU and NSO sections of this EA. Effects fish (note new temporary road and stream crossings analysis includes potential disturbance along old growth edge within the unit), we request that the Forest Service drop (potential NSO and MAMU nesting habitat), potential for increase in unit 29E from this proposal. We are also concerned negative competitive interactions with barred owls, as well as effects to about regeneration harvest in unit 37E, as it is critical habitat. These effects are fully disclosed in the EA, as well as immediately adjacent to suitable NSO habitat. We would known species occurrence within the project area. like to see unit 37E dropped for that reason and others described in the early seral section below.

9-11 Wildlife – Similar to our discussion in the NSO section above, the The concern over the inclusion of Unit 29 is noted and addressed in Endangered Task Force is very concerned about the inclusion of unit the previous response. Surveys for marbled murrelet occupancy in the Species 29 in this proposal due to potential direct impacts on unit will be conducted prior to inclusion of this unit within a timber sale marbled murrelets, and requests that the unit be contract. At this point marbled murrelets are not known to occur in dropped. We are also concerned about the likely to Silver Creek although suitable nesting habitat is present. Surveys were adversely affect determinations for marbled murrelets conducted in this area in the 1990's for a timber sale and none were and their designated critical habitat, considering both the detected then. Though Unit 29 is suitable nesting habitat, it is not individual impacts of this project and the cumulative within designated critical habitat for marbled murrelet. The proposed impacts when combined with the Nisqually Thin and project does not include older stands, the oldest one being Unit 29, 85 other logging projects occurring on adjacent lands. We years, containing legacy features from an older stand. EA PDC 1.15 are also concerned that no marbled murrelet surveys includes retaining legacy features within units if they are found with have been completed in the project area in many years. treatment units. There is also an operating season restriction for We request that the Forest Service protect older stands helicopter yarding where it may occur near potential nesting stands for throughout the project area and consider adjusting marbled murrelet and spotted owl to limit that activity to outside of the helicopter logging method prescriptions, shifting the nesting season. boundaries of those helicopter logging units away from suitable nest sites, or dropping those units altogether.

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9-12 Vegetation – The ecological analysis of current versus historical seral stage Early Seral, structure in the Silver Creek watershed is displayed Figure 17 in the Wildlife EA in the deer and elk section and was added to the EA as Appendix E. This analysis reveals that the watershed is currently at 4% early seral versus an historical estimate of 5% that would typically be in an early seral structure given the climate, plant association, fire frequency interval, etc. Swanson 2012 (pg. 71, 139 in EA) is also referenced in the deer and elk section with a discussion of the importance of early seral habitat to a number of species. Historically natural wildfire would have played the most important role of all of the natural disturbance events in the creation of early seral habitat in the Pacific Northwest. Currently the GP does not have a natural fire policy and large-scale fires have generally been infrequent over the past 100 years of fire suppression. See EA, fire ecology section. Past regeneration harvest on a large scale has created artificially large areas of early seral that is no longer the case given current land management practices. As noted in the EA on page 139, records from Mt. Rainier National Park indicate low elk numbers there until the 1950’s when the elk population increased significantly. This coincided with logging activities outside of the park that increased the carrying capacity on elk winter ranges by increasing forage production of grasses and shrubs. Intensive logging, generally in the form of clear cutting, greatly changed the character and structure of the forests outside of the park, resulting in a patchwork of second and third generation stands. As National Forest land was logged creating more open and favorable habitat for elk, The Task Force is opposed to the prescription of many large groups of elk remained outside of the park year-round and regeneration harvest to create early seral habitat are now considered resident elk. Many of these resident elk remain because it typically replicates a clearcut, which has long below 3,000 feet for the entire year, while other migratory elk still move lasting detrimental impacts to soil health, water quality, into alpine meadows during summer and return to the lower valleys in and wildlife. We believe that the purpose and need for winter. Therefore, past harvest practices have greatly altered the early seral habitat to create deer and elk forage is movement patterns and habitat use of the South Rainier elk herd on unreasonable and without scientific support. In scoping, the forest. However, asserting that the continued loss of early seral we requested an assessment illustrating the need to habitat over the next 30 years will lead to the extinction of deer, elk create more early seral habitat for deer and elk in this and other species that are associated with early seral habitat is area, but see no evidence that any assessment was speculative and not supportable, given that none of these species is conducted. [Rationale including maps generated by currently listed under ESA. The species that are more likely to go GPTF are in comment letter to support comment that EA extinct in the next 30 years are those that are associated with late fails to consider amount of early seral habitat on successional habitat. The project proposes a modest amount (176 adjacent private and state lands; as well as concern for acres) of early seral habitat creation in deer and elk winter range that regeneration harvest in NSO and MAMU habitat esp. would contribute to an increase in forage for deer and elk, but only for unit 29E] a short period of approximately 20 to 30 years.

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9-13 Vegetation – We are also concerned about other units that contain The effects to sensitive soils, wildlife, and listed fish, and sensitive Regeneration unstable soils, significant biological diversity, and/or are habitat for the units proposed for regeneration harvest (“E”) are harvest in proximity to listed fish habitat, including units 38E, disclosed in the EA (pp. 44-191), Consistency with Forest Plan 37E, and 28E. For instance, “Unit 38 would have the standards and guidelines is stated on page 66, 70, 71, 77-78, 81, 88- highest amount of new [soil] disturbance as described in 89, 95, 125, 466-190). the proposed action, up to approximately 14.7 percent The commenter’s survey data have not been provided to the Forest soil disturbance due to construction of a new helicopter Service so there is no way to assess their technical adequacy, landing in a relatively small unit, 8 acres gross (Table incorporate them into this analysis, or know whether they complement 10).” EA at 63. Unit 38E also contains substantial or deviate from the data collected by FS staff according to stand exam, diversity and older stands of trees, as documented in the wildlife, soils, or other survey protocols. The EA discloses potential Task Force’s surveys in July 2015, and is in close effects of regeneration harvest on these resources. proximity to listed fish habitat. Similarly, we are In addition, PDC 1.15 was specifically developed in order to retain concerned about regeneration harvest in unit 37E. The legacy features in the stands cited by the commenter. If older trees are Task Force also surveyed that unit in July and found with early seral treatments, they will be excluded or buffered documented very sensitive soils, animal trails, extensive from harvest areas. burrows, high biological diversity, and significant large down wood. Unit 37E is also in close proximity to listed fish habitat, borders suitable marbled murrelet habitat and old growth stands, and contains a disproportionate amount of new stream crossings (13 of 22 in the project area). Unit 28E also contains some stands over 175 years old and would include multiple stream crossings in close proximity to listed fish habitat. Consequently, the Task Force requests that the Forest Service modify the proposal by dropping units 29E, 28E, 37E, and 38E and substitute thinning for regeneration harvest on the remaining matrix units. Commenter: Cowlitz Tribe 10-1 Vegetation – The EA does not address how the proposed action One of the needs of the project is to produce commercial yields of Matrix objectives meets the Matrix management objectives intent. wood and optimization of timber in Matrix lands (EA, p. 3-5).The [comment includes references from EA description of Desired Future Condition for Matrix lands is such that evidence of land Matrix objectives and proposed action thinning managed intensively for timber production and other commodities is treatments proposed] apparent (EA, p.73).Treatment units in Matrix will emphasize a traditional approach by thinning stands down to spatially uniform residual densities to ensure that overstory tree layers fully occupy the site and thus maintain timber production (EA, p. 75).Treatment units in Matrix would maintain a continued state of inter-tree competition while maintaining growth more at the stand level and less at the individual tree level. This would be consistent with the project’s Purpose and Need to produce commercial yields of wood and optimization of timber in Matrix lands (EA, pp. 75-76).

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10-2 Fire Ecology The EA also lacks a description of the historic watershed A seral stage analysis was done for the biophysical settings ecology.[references included from EA]. The EA does not (vegetation types) in the Middle Cowlitz Watershed and on NFS land provide adequate historic information to support the by the Gifford Pinchot Forest Ecologist in December 2014. It was statement that fire ecology does not need to be restored. inadvertently omitted from the Preliminary EA but now appears as Appendix E. The ecological analysis of current versus historical seral stage structure in the Silver Creek watershed is also displayed in Figures 17, 29, and 30 of this EA. This analysis reveals that the watershed is currently at 4% early seral versus an historical estimate of 5% that would typically be in an early seral structure given the climate, plant association, fire frequency interval, etc. Historically natural wildfire would have played the most important role of all of the natural disturbance events in the creation of early seral habitat in the Pacific Northwest. Currently the GP does not have a natural fire policy and large-scale fires have generally been infrequent over the past 100 years of fire suppression. See the fire ecology section of the EA.

10-3 Noxious weeds The EA notes that noxious weeds 'may or may not be In partnership with Lewis County, the Cowlitz Valley Ranger District is controlled depending on available funding" (pg 97). treating over 900 acres of priority invasive species each year (this is Noxious weeds present a real and considerable threat to an average of 3 years). About 20 invasive species are being controlled ecosystems as well as individual plant and animal in numerous locations across the district, including rock quarries, species. It is recommended that the Forest allocate roads and timber sale areas, and recreation areas. Extreme fire years funding towards invasive species removal, as a well can temporarily affect the budget for Forest Service programs such as known risk factor to long-term forest ecosystem health. invasive species. However, this would not typically affect the funding available for Lewis County to treat invasive species, and Lewis County does most of the actual control work on the Cowlitz Valley Ranger District.

10-4 Visuals, Tourism, Page 196 [of EA] notes that "most residents of these The Gifford Pinchot National Forest Land and Resource Management Economics towns depend on tourism to the area and the national Plan (LRMP) provides the basis for Scenery Management objectives; forest." However, on page 205, Lewis county had around The Forest Management Goal for Scenery is to provide natural- 15% of jobs in industries that relate to travel and tourism, appearing scenery from the high use (most important) recreation travel which is smaller than the national or state average. routes and use areas (p.IV-3 ). P.IV-22 further characterizes Scenery Creating visual buffers to accommodate tourism should as a resource and specifically directs that the visual management be laid out in a cost-benefit table, specific to the system (now known as Agriculture Handbook Number 701: Landscape watershed treated and the amount of expected tourism Aesthetics) is to be used in all resource programs to maintain high that would not use the forest area due to visual impacts. scenic quality. Specific viewsheds were identified through Forest Planning and can be viewed on p.IV-23 of the LRMP. Each viewshed was assigned a Visual Quality Objective, which is defined as categories of acceptable landscape alteration measured in degrees of deviation from the natural-appearing landscape. These categories range from no timber harvest (Preservation) to heavier timber harvest (Modification) and each Land Management Allocation in the LRMP has been assigned at least one of these categories. For example,

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Wilderness has a Visual Quality Objective of Preservation i.e. no timber harvest (p.IV-120), while Timber Production (also known as General Forest), has a Visual Quality Objective of Modification i.e. full timber harvest will be scheduled (p.IV-136). Typically, the Land Management Allocation of Visual Emphasis (p.IV- 98) has been assigned to the Viewsheds identified on p.IV-23 of the LRMP. It is understood that these viewsheds are the high use recreation travel routes, so management objectives are to manage for visual quality here. The Visual Quality Objective assigned is either Retention or Partial Retention, with specific direction for maintaining visual buffers, usually up to ½ mile, but can be further dependent on location. The goal for Visual Emphasis is to provide a visually natural or near-natural landscape as viewed from the designated travel route or use area.

10-5 Correction Cultural attributes in the watershed are noted [in the EA] Thank you for bringing this omission to our attention. The following to be "primarily associated with historic sites change has been made to the EA, page 190: Cultural attributes are (homesteads, farms, trails), livestock grazing and early primarily associated with traditional uses by the Cowlitz and Nisqually logging." (pg. 192). The Cowlitz people have cultural Tribes, including berry picking, foraging, and hunting. Other cultural values associated with berrying, foraging, hunting, and attributes associated with the area include historic sites (homesteads, other values. Evaluating the place value should include farms, and trails), livestock grazing, and early logging. the cultural values of the Cowlitz, or others peoples as apply in a specific area.

10-6 NEPA – During the Pinchot Partners discussion about the As the commenter states, Forest Service regulations now prevent Comment period proposed project, it was brought up a rule change, 36 extension of the comment period for EAs. The FS understands the CFR 218.25(iv) "Extension. The time period for the commenter’s frustration with holding a comment period during the opportunity to comment on a proposed project or activity holiday season; the timeframe was not intentional but it allowed the to be documented with an environmental assessment project to keep moving through the planning process. shall not be extended." The time period extension has historically allowed Forest Service staff, or concerned public citizens, the flexibility to lengthen the comment period for cause. In the case of Silver Creek Thin EA, the comment period opened immediately after Thanksgiving and closes just before the new year. At this time, many staff are taking vacations. An extension would have been welcome to improve our response detail.

10-7* Cultural The CRD (Cultural Resources Department) recommends An Inadvertent Discovery Plan is incorporated into every project resources an Inadvertent Discovery Plan be attached to the permit; contract where ground disturbance may occur. We have provided a we have included language for your consideration. copy of the Forest’s IDP to the tribe, which addresses these concerns.

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*Note* comment does not have standing for objection because it was submitted after comment period closed.*

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Commenter: Dave Bunting 11-1 Transportation I believe the decision to not rebuild the East Fork Appendix D was added to the EA to address this issue in more detail. system crossing is wrong. There are so many reasons that Please also refer to page 45 in the EA. justify rebuilding it, among them of course the huge and expensive effort we made to connect Silver Creek to Randle, and the cost need not be very much at all. [attachments provided: article with rationale which was published in the Highway Shopper newspaper out of Packwood, WA on December 9 2015; as well as letter Mr. Bunting sent promoting his interest local individuals explaining his rationale including economic efficiency and the safety for downstream residents that might be afforded by a temporary "railroad flatcar-type" bridge]. Commenter: American Forest Resource Council 12-1 Support, AFRC generally supports the Proposed Action as it best Thank you for your comment. Economics meets the purpose and need of the project. A key to accomplishing the goal of the purpose and need statement of this project is for the activity to be economically viable. The ability for both the commercial and non-commercial activities of this proposal to be accomplished, the project must economically viable. Factors affecting the economics of a project can include the selection of appropriate harvest systems to accomplish the stated goals, operating seasons that provide flexibility for the purchaser/operator, volume removals, and a suitable transportation infrastructure. We are pleased to see the Forest has taken many of these factors into consideration in this proposal.

12-2 Economics We are pleased to see the project allow ground based Thank you for your comment. mechanical harvesting on slopes up to 45% and we encourage the consideration of this in future projects. Mechanical harvesting has benefits economically, improved ability to protect residual trees during felling operations, and increased safety for harvesting personnel.

12-3 Logging systems AFRC would encourage the GPNF to assure the Helicopter logging is generally the last option the team considers for proposed 71 acres of helicopter logging cannot be accessing a stand after more conventional yarding methods have accessed with other more conventional yarding been ruled out due to resource concerns or inaccessibility. In most methods. In the absence of the ability to yard with cases, helicopter yarding is economically unfeasible when conducting systems other than helicopter, we would urge the Forest thinning of plantations, and helicopter availability during the typical

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to evaluate the best means of "packaging" these units operating season is decreasing with a longer and more active fire into future sales which make economic sense. season. The Forest Service does seek to package stands to be Spreading fixed "move in" costs over the maximum helicopter logged into sales where the majority of stands can be volume possible will aid in this effort. accessed with a cheaper logging system (ground based or skyline), or sales in which higher volume may be achieved over a smaller area, such as in regeneration harvests.

12-4 Limited The proposed project has LOP's for wildlife mitigation to limit Operating Period AFRC is encouraged and applauds the efforts the Forest disturbance impacts to ESA listed species. There are LOP's for big has undertaken in developing criteria/outcome based game winter range as well that usually are granted waivers given restrictions for operations outside the Normal Operating certain conditions are met. The winter range LOP includes units 17, Period (NOP) of July 1 to September 30. This has the 21, 30 and 38, so these could be waived under certain criteria. These potential to allow greater flexibility when scheduling units also have a early/late hours LOP for marbled murrelet nesting operations. When Limited Operation Periods (LOPs) are season from 4/1 to 9/23 which does not curtail logging activity considered, there are only 6 days for Units 17, 21, 30, 38 completely, only during the 2 hours after dawn and 2 hours before which have no LOP impacts. sunset time period. Therefore, there will likely be more than 6 days without LOP's to harvest these units.

12-5 Economics/ We are pleased to the see the winter logging option Thank you for your comment. Winter logging included to potentially allow the operator to operate under the guidelines identified in Objective 6.20 (pg 38). Assuming the project area is accessible during winter months, without significant snow plowing expense, winter operation can be very beneficial to prospective bidders. Generally, it is at this time of year when it is important to maintain economic activity by providing work for logging crews and a source of wood for mills to process.

12-6 Transportation AFRC is also pleased to see this project will work to Close/Stabilize treatments would not foreclose the option to reopen System improve the road infrastructure of the forest as needed these routes in the future, as the roads would remain on the National for timber haul...Regarding the FS 47 Road, we would Forest road system but would be closed to use as Management Level encourage the Forest Service as part of the "close and 1. Appendix D was added to the EA to address this economic stabilize" work proposed to not foreclose on the potential comment in more detail. Please also refer to page 45 in the EA. to re-construct and open this access route. Considering the amount of Matrix land allocation in the area, future access via this route may be advisable. There also appears, based on scoping comments, to be an interest in the local community for restoration of this access route. We did see reference in the scoping comments to an economic analysis which would be included in the EA. However, we did not see the detailed analysis referenced in the scoping comment reply.

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12-7 Daylighting We are disappointed to see the Forest decided to not The rationale for not pursuing an alternative to daylight roads is Roads pursue the road day-lighting alternative. The ability for disclosed in the EA at page 45. There may be opportunity to include day-lighted roads to dry quicker has benefits for such a proposal in future project areas where daylighting is more maintenance, longevity for the road surface, and consistent with resource objectives or by refining the criteria for which reduced sediment development from traffic. While we this tool might be proposed. understand concerns over daylighting a 20-foot-wide area (each side) along the road within Riparian Reserves could impact water quality and habitat, thinning in these areas, particularly overhanging deciduous trees, can help in addressing road surface conditions and length of time to dry. Additionally, we would point out that improving road conditions outside of Riparian Reserves will serve to further protect resources within the Riparian Reserve where the road passes through. Day-lighting within and near proposed harvest units can serve to help improve road drying times in those areas. While not system wide within the analysis area, we believe this work would incrementally improve road conditions and maintenance needs. On other ownerships we have seen significant impacts to road surfacing by non-logging related (i.e. recreational light vehicle) traffic during rain events. Portions of roads where day light could easily reach the running surface saw less impact from non-logging related traffic than those shaded most of the time.

12-8 Wildlife AFRC supports the inclusion of Unit 29 in this proposal. It is unlikely that marbled murrelets would be detected in Unit 29, but Based on Fig. 2 in the document, this unit is in Matrix the Northwest Forest Plan and the Biological Opinion received from land allocation and the proposed treatment is consistent the Fish and Wildlife Service requires in its Terms and Conditions that with the expectations of Matrix lands. Based on the MAMU surveys are conducted before harvest of suitable nesting information provided in the EA and work conducted by habitat can occur. other landowners in the vicinity we feel it is highly unlikely that surveys will show presence of marbled murrelets in this stand. This unit as with most of the rest of the Silver planning area proposed for management are on the edge of the 55 mile from marine waters range for use. We encourage the GPNF to continue with inclusion of this unit and evaluate all opportunities to offer this unit in a future sale project.

12-9 Riparian buffers AFRC would like to see greater effort now and in the Please see section 6 of the PDC in the EA (pages 33-40). The future of evaluating commercial opportunities to treat a interdisciplinary planning process included a limiting factor assessment wider area of the riparian reserves than what is currently for water and soil related issues, which determined final buffer proposed….It has been documented by many that most designations. The Forest Plan as amended by the Northwest Forest

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of the wood that naturally recruits to streams comes from Plan (NWFP ROD. Pg B-10) provides the context for considerations within the first 65 feet of the stream channel (Murphy the IDT made in developing the buffers. Considerations included: and Koski, 1989; McDade et al. 1990. Johnson et al. Unstable slopes, channel stability, active mass wasting (landslides) 2011). So if this is where the LWD is coming from then and debris flows, site-specific soils data which was pre-reviewed on thinning in this region would likely accelerate its GIS or from photo interpretation and then verified in the field. (see EA creation...It has also been documented that vegetated pages 52-54, 56-62, 171-172 for more discussion). EA page 172 buffers that are greater than 33 feet in width have been (Table 42) summarizes the channel stability measured within the shown to be effective at trapping and storing sediment analysis area and confirms a high percentage of Class III and IV (Rashin et al. 2006). Partial cutting down to one or two streams are at risk of stability. We chose to standardize the buffer conifers from intermittent and perennial stream channels widths to simplify and add efficiency to the planning and layout would accelerate the recruitment of LWD with minimal process. As a result, 100 feet buffer widths were used universally. impacts to sedimentation and stream temperature. We PDC 1.16, on page 21 of this document, indicates the buffer widths would like the GPNF to consider these trade-offs closely used for each stream class in the planning for this project and future projects to improve riparian conditions on the maximum amount of these reserves.

12-10 Riparian We would also like the Forest to consider including some The interdisciplinary planning process included a limiting factor treatments of the following pieces of scientific research into their assessment for water and soil related issues, which determined final analysis. Much controversy surrounding any type of buffer designations (EA pages 33-40). The Forest Plan as amended thinning in riparian reserves has surfaced, and we think by the Northwest Forest Plan (NWFP ROD. Pg B-10) provides the the following information would be useful in justifying the context for considerations the IDT made in developing the buffers. kinds of beneficial treatments the GPNF implements.[list Considerations included: Unstable slopes, channel stability, active of references and summary of pertinent findings included mass wasting (landslides) and debris flows, site-specific soils data in comment letter] which was pre-reviewed on GIS or from photo interpretation and then verified in the field. (see EA pages 52-54, 56-62, 171-172 for more discussion). EA page 172 (Table 42) summarizes the channel stability measured within the analysis area and confirms a high percentage of Class III and IV streams are at risk of stability. Sensitive wildlife such as salamander species also benefit from riparian buffers (EA page 127-128). We chose to standardize the buffer widths to simplify and add efficiency to the planning and layout process. As a result, 100 feet buffer widths were used universally for class 3 and 4 streams, wider for class 1 and 2. PDC 1.16, on page 21 of this document, indicates the buffer widths used for each stream class Further, several restoration projects are specifically in the proposed action to develop riparian structure and habitat and promote large wood in strategic stream reaches (EA p. 19).

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Commenter: Dick Artley 13-1 Temporary roads Logging road construction causes significant ecological The Forest Service endeavors to minimize the amount of temporary harm. Please analyze an action alternative in detail that road construction while also meeting the diverse economic and does not construct any new roads( temporary or ecological objectives for a timber project. Temporary road construction system).This would satisfy the P&N. Just as with No is often needed to access the whole stand without skidding or yarding Action, this alternative provides the public with the trade- across streams, which are more detrimental to the health of that off between the Proposed Action and an alternative with stream than building a temporary road. Temporary roads are located less volume and less environmental impact . . . far enough away from stream channels for them to deliver any especially to aquatic resources. [attachments and sediment. Page 165 in the EA under Objective 4 of the ACS states, references provided detailing agency past and present "Proximity of temporary roads to stream channels is limited which construction of roads Is extensive along with NEPA and would allow sediment to be filtered through the forested vegetated aquatic references] floor prior to entering stream channels. Sediment delivery would not result in a measureable increase in stream sediment deposition." Project Design Criteria and Mitigation Measures table sections 6 and 7 describe measures reduce the risk of erosion and any sediment delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams during off-season logging operations by following a timing restriction so as not to log during wet weather conditions which can be measured objectively (#6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (#6.15). Effects of these activities on sediment delivery are disclosed in the EA at 160-162. Some alternatives, including one to avoid any road construction, were not deemed reasonably feasible or viable, as disclosed and explained on page 45 of the EA. One action alternative was ultimately developed, and the team felt that no further alternatives would effectively balance resource objectives and multiple values across the landscape while also addressing the interests of the community.

13-2 Transportation Without exception, road construction and reconstruction The Proposed Action related to the use and disposition of system and system are activities that cause damage to some important non-system roads responds to a variety of factors raised during natural resources in the forest. New road construction is internal and external scoping and analysis disclosed in this EA. There particularly detrimental to aquatic and wildlife resources. are currently many miles of road in Silver Creek, which are not Chief Dombeck’s statement below supports this fact. accessible due to failure nor have been for a decade or more. We are challenged to strike a balance between costs of maintaining roads, providing public and administrative access and sustaining ecological function across the landscape (both aquatics and terrestrial). Stability concerns in the project area factored greatly into the overall Proposed Action as well as Project Design Criteria required for accomplishing any roadwork (EA p. 15-19, 33-42 PDC sections 6 and 7, Appendix C). The effects of the Proposed Action related to soils, wildlife, fisheries, and other resources are discussed on pages 47-215. The current

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degraded nature of the NSF road system is a pressing concern for many facets of resource management. We have a development of road infrastructure, which far outreaches our capacity to conduct regular maintenance necessary to sustain both suitable driving conditions and help safeguard against chronic and catastrophic failure. Part of our road strategy is to bring our road system into proportion of our current and expected fiscal capacity to maintain. Among our goals for this planning area was to sustain current net levels of public access to the extent practical. Roads which provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so we found that several roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance.

13-3 NEPA - Best The Administrative Procedures Act directs judges to set Given the experience and professional background of the scientists on available science aside an agency action if the court determines that the the team, we believe the analysis of effects disclosed in the EA was action is “arbitrary, capricious, an abuse of discretion, or based upon appropriate scientific literature, valid data, and otherwise not in accordance with law.” 5 U.S.C. § professional judgment. The EA discloses the measurable effects to 706(2)(A). A line-officer who ignores best-science and resources from pages 47 through 215, including data and summaries instead makes a Decision on weak, meager evidence from which effects determinations were drawn. Resources in which provided by people with financial interest in a sale being data or surveys are lacking were disclosed in the EA, and the potential sold (i.e. IDT members that represent timber and effects were estimated based on peer-reviewed science and engineering) is guilty of violating the APA. representative data sets.

13-4 NEPA – Public Include a new section that provides specific information The opportunity to provide input during scoping and comment periods Involvement listing the collaborative group member’s names and was offered to the general public via mail, email, and website, not affiliations. This specific information should include at exclusively to the collaborative group. The proposed action was least 1) each collaborative group member’s interest in developed from scoping feedback received, in writing, from a variety of the proposed sale, and 2) information describing how the sources and interests, including citizens and entities based outside the collaborative group member is any way linked somehow local area. The public meeting held during scoping was open to the to woods products. general public, as were field trips to the project area. Collaborative group concerns were not given more weight than those expressed by any other member of the public who chose to provide input.

13-5 NEPA - Please post your responses to public comments on this Comments and responses are in the updated EA as Appendix F and Comments online as well as maintaining a hardcopy in the Project will be posted separately online, in addition to kept in a hardcopy File. project file.

13-6 Economics Increases in National forest logging do not stabilize or Logging and employment in other timber related jobs are 10-12% of enhance the economic of small communities located the local economy (Census Bureau, 2011), considerably greater than

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near them. [excerpts from various sources cited in a the importance of this sector on employment nationally (Figure 23). research paper are included to support this comment]. While travel and tourism related employment accounts for around 15% Please describe why Dr. Power's research does not of local employment, this is similar to the national average, and is likely apply to the Gifford Pinchot National Forest. due in part to the presence of Mt. Rainier National Park in Lewis County as well as the adjacent district on the Wenatchee National Forest. The timber industry provides stability to the local workforce as a source of jobs that typically pay more than the service industry jobs associated with tourism.

13-7 Economics, Why do you reject the findings and conclusions of The Gifford Pinchot National Forest and adjacent public lands provide Recreation Undersecretary of Agriculture Jim Lyons and well many recreation opportunities. Please visit respected scientists? They all make the case that 1) http://www.fs.usda.gov/recmain/giffordpinchot/recreation. Logging and recreationists avoid areas that have been logged, and 2) employment in other timber related jobs are 10-12% of the local recreation-related revenues to local communities with economy (Census Bureau, 2011), considerably greater than the lumber mills is much more than the revenues generated importance of this sector on employment nationally (Figure 23). While by logging? travel and tourism related employment accounts for around 15% of local employment, this is similar to the national average, and is likely due in part to the presence of Mt. Rainier National Park in Lewis County as well as the adjacent district on the Wenatchee National Forest. The timber industry provides stability to the local workforce as a source of jobs that typically pay more than the service industry jobs associated with tourism.

13-8 NEPA – Purpose You reject the research conclusions of 241 Ph.D. The Purpose and Need for this and many projects on the Gifford and Need scientists quoted in [attachment of references provided Pinchot National Forest responds directly to the Gifford Pinchot with comment letter] who demonstrate how logging- National Forest Land and Resource Management Plan regarding related harm (and in a few cases destruction) is inflicted timber output and other resource goals and objectives. EA page 9. on multiple natural resources in and near the sale area. The effects of commercial thinning and other treatments in the Incredibly, you rely on the advice of 3 or 4 timber Proposed Action on various natural resources are disclosed in the EA, employees financially motivated to sell timber. You know pages 47-215. the log for community stability P&N statement appears in at least 80% of all timber sale NEPA documents. This has become the commonly used excuse by USFS line- officers to sell unneeded timber sales and you use it here.

13-9 Economics – If you were really concerned about local community The Forest Service determination to offer a timber sale under the Small Business stability and local job creation you would offer this sale Small Business Act is made in accordance with FS Timber Sale Administration as an SBA sale to prevent a large timber corporation Preparation Handbook 2409.18, which directs implementation of the from logging it using their own labor. This would prevent SBA regulations (Title 13 of 13 CFR 121). This occurs after the NEPA the logs from being hauled many miles to be processed process has occurred and a decision has been made to implement a at a mill far removed from the small communities you timber project. claim need economic help. Of course your motivation to Between 2003 and 2012, there were 36 commercial thin timber sales sell this timber sale has nothing to do with community across the Forest that were not part of stewardship projects, of which

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stability. We both know “local community stability” and half were allocated to companies that are registered with the Small “local job creation” is part of the USFS dishonest script Business Administration. None of the sales were sold below-cost. Over to trick the public into accepting tragic timber sales. half of the sales had 2-6 bidders and were sold for up to 3.5 times the advertised value. Timber harvest is not only proposed to benefit the local economy, as stated in the Purpose and Need (EA p.9). It is a land management tool to improve forest health and provide wildlife habitat. This project is expected to be harvested through several timber sales, over several years.

13-10 NEPA - Analyze at least 1 citizen generated alternative to the Section 102 [42 USC § 4332] (2) of the National Environmental Policy Alternatives Proposed Action in detail. Act states “all agencies of the Federal Government shall—…(E) study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of competing available resources.” (bold italics added for emphasis). Issues brought up during public and internal scoping and review were resolved through revising the silvicultural prescriptions and project design criteria, or through dropping units or portions of units, resulting in the one proposed action alternative rather than multiple alternatives to meet the purpose and need of this project. The project addresses restoration priorities to restore channel conditions to the extent possible given planning and implementation constraints. The restoration projects were vetted in public scoping and subject to the IDT process. Discussion of specific alternatives proposed but not fully analyzed appears in the EA on page 45.

13-11 Temporary roads At page 15 you propose to return your temporary roads The Forest Service endeavors to minimize the amount of temporary to a more natural state after use. As part of the timber road construction while also meeting the diverse economic and sale you propose to construct 7.41 miles of new road ecological objectives for a timber project. Temporary road construction you refer to as “temporary road” that will generate new is often needed to access the whole stand without skidding or yarding sediment. New roads produce 3 to 5 times more across streams, which are more detrimental to the health of that sediment than an existing road produces. There is no stream than building a temporary road. Temporary roads are located sediment analysis. How does the public know if the net far enough away from stream channels for them to deliver any sediment is reduced? Your proposal to return your sediment. Page 165 in the EA under Objective 4 of the ACS states, temporary roads to a more natural state will leave the "Proximity of temporary roads to stream channels is limited which road surface in place so you can access the cutting units would allow sediment to be filtered through the forested vegetated with less reconstruction costs the next time you log the floor prior to entering stream channels. Sediment delivery would not area. Links to science showing complete obliteration is result in a measureable increase in stream sediment deposition." more effective at reducing long-term sediment Project Design Criteria and Mitigation Measures table sections 6 and 7 generation than any other closure methods [provided in describe measures reduce the risk of erosion and any sediment comment letter]. delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams

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during off-season logging operations by following a timing restriction so as not to log during wet weather conditions which can be measured objectively (#6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (#6.15). Effects of these activities on sediment delivery are disclosed in the EA at 160-162.

13-12 NEPA - EIS Include the source literature for particularly relevant The commenter appears confused as to which project or NEPA science quotes contained in the Opposing Viewpoint document he is commenting on, since he refers to a "final EIS." The Attachments in the References section of the final EIS Silver Creek Thin project is documented in an EA. Further, the and cite the quotes contained in the attachments in the collection of quotes and sources provided by the commenter is offered body of the final EIS. Some adverse effects of project to support a general viewpoint and is not referenced to any particular activities described by scientists in the Attachments was finding, statement, or resource within this document. This makes it not mentioned in the final NEPA document EA, 40 CFR impossible to determine the intent and context of each quote as it 1500.2(f) because the Responsible Official was unable relates to our detailed analysis. Given the experience and professional to avoid or minimize any possible adverse effects upon background of the scientists on the analysis team, we believe the the quality of the human environment without knowledge specific references to scientific, professional and other literature found of the adverse effects. throughout this document demonstrate an appropriate and unbiased analysis.

13-13 NEPA - Effects Don’t overstate and/or exaggerate the timber sale’s The beneficial and adverse effects of the Silver Creek Thin, including benefits to the environment [list of references in EA of activities associated with timber harvest, roadwork, and restoration what will be restored is included in comment]. If it will projects, are disclosed in the EA pages 47-215. restore a resource tell the public why the resource needs improvement and how logging will restore it. Specifically, describe how subjecting the resources listed above that you claim will be restored to industrial equipment (skidders and tractors) weighing 16 tons with spinning wheels and tracks will restore them to resources that function properly again. Failure to do so will violate NFMA at Section 6 (g)(3)(E)(iii), 40 CFR 1500.1(c) and 40 CFR 1500.2(e) and (f).

13-14 NEPA – Best Include some source documents from the Opposing The collection of sources provided by the commenter is offered to available science Views Attachments [provided with comment letter] in the support a general viewpoint and is not referenced to any particular References section of the final EA. Also, cite some the finding or statement within this document. This makes it impossible to specific quotes related to the issue that are presented in determine the intent and context of each quote as it relates to our the source literature in the Opposing Views Attachments. detailed analysis. Given the experience and professional background The public deserves to be informed of this information so of the scientists on the analysis team, we believe the specific they can make an informed decision to support or references to scientific, professional and other literature found oppose the timber sale based on complete data. throughout this document demonstrate an appropriate and unbiased analysis.

13-15 NEPA – Best The Silver Creek sale will take away more undeveloped The collection of sources provided by the commenter is offered to available science national forest acres from the legacy the unborn kids of support a general viewpoint and is not referenced to any particular

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the future. A sample of the opposing views from the finding or statement within this document. This makes it impossible to Opposing Views Attachments is included below [44 determine the intent and context of each quote as it relates to our statements and Opposing Views attachment are detailed analysis. Given the experience and professional background included in comment letter]. Please meet with your IDT of the scientists on the analysis team, we believe the specific and discuss each science statement. references to scientific, professional and other literature found throughout this document demonstrate an appropriate and unbiased analysis. Commenter: Gary Stamper 14-1 Public Safety Will the plan support safety concerns of the citizens from The IDT developed the Proposed Action not only to provide revenue to the affected area? the local economy through timber sales, but also to address issues raised related to riparian health and public safety. Safety concerns specifically addressed include evaluating the safety and economic need for a crossing on FR 47 across the East Fork Silver Creek (EA pages 45-46 and Appendix D), as well as inclusion of project design criteria (PDC) to address hazardous fuels (EA p. 28).

14-2 Economics Is the agency being financially responsible to the citizens It is not clear in what respect this comment is related to the scope of and taxpayers who bear the burden of cost over-runs? the Silver Creek Thin project. However, economic costs and benefits, in addition to the environmental and social consequences of the project are disclosed in the EA (pp. 47-215). Appendix D specifically addresses the financial considerations to not reconstructing a crossing on FR 47 across East Fork Silver Creek.

14-3 Economics How does the project benefit the economy and The Silver Creek Thin project was driven in part by an identified need stakeholders, including but not limited to the timber to “Create a sustainable supply of timber and other forest products that industry, of East Lewis County? It is my hope that with will help maintain the stability of local and regional economies (NWFP sound decision making, this road project will bring more FEIS, p.S-4),” see the EA page 9. The economic context of Lewis jobs and opportunities for the residents and businesses County as well as analysis of the costs and benefits of the vegetation of the area impacted. management and associated roadwork are disclosed in the EA on pages 203-209.

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Appendix G. Response to Comments and Objections NOTE: All page numbers refer to the January 2017 EA.

NUMBER THEME COMMENT RESPONSE

Commenter: Alice Hack

1-1 Supportive Planned commercial timber harvest, road maintenance, Thank you for your comment. comment and reconstruction have been well thought through.

1-2 Vegetation – Future planning should include growth of alder trees to Red alder has a unique niche across the landscape and has an Silvicultural help prevent root disease in Douglas fir trees and important role in creating diversity, minimizing root disease and prescription provide soil the necessary nitrogen. enriching soil productivity. The current proposal will only remove red alder where trees exist in excess of meeting these needs. See PDC 1.4.

1-3 Vegetation – Trees need time to grow to be a desirable product. The current proposal seeks to provide timber of desirable size and Silvicultural Currently most trees are being harvested at immature quantities that are agreeable to purchasers. How the timber is prescription size resulting in poor grade lumber which is causing marketed and to what degree of quality, however, is left up to the inferior construction. purchaser to determine and is reflected in their bid price. From a timber product standpoint, a lot of mills do not have the capabilities to process larger trees at their mill and will only pay half the normal log price for an oversized log; mills that would be able to process larger logs are too far away (excessive haul costs) and/or are export mills, and FS does not allow export of our unprocessed logs. Also, our projects are primarily thinning from below (cutting the smaller trees and leaving the larger).

1-4 Transportation Since we had an extremely dry year until this month, The team appreciates the commenter’s concerns about recent system some plans may become emergencies - culverts, road (December 2015) flood events on the district. Currently there are no maintenance, unstable hillsides. With these torrents of proposed changes to the Proposed Action for Silver Creek Thin rain, we could be facing many unseen complications. related to the transportation system due to this flooding. In addition, road maintenance, reconstruction, and other transportation and restoration activities proposed in this project are intended in part to make the road system more resistant to failures during future flood events (EA pp. 9-12).

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Commenter: Pete Krabbe

2-1 Transportation I agree that USFS grounds north of Randle should be Appendix D was added to the EA to address this issue in more detail. accessible from Randle, East Lewis Co. mills and Please also refer to page 41 in the EA. system loggers need the work…. We don't need less access to the forest but more!

2-2 Project Design Let the loggers have access when weather permits and Project Design Criteria (particularly Section 6, pp. 27-35) specify acceptable conditions for logging operations to protect soil and water Criteria - removed when it starts raining. resources in compliance with the Forest Plan Standards and Guides Aquatics and Best Management Practices. Thresholds for precipitation and soil moisture and erosional features are among the indicators identified. Weather dependent features including depth of frost and snow pack are also critical component of acceptable logging operation conditions.

Commenter: William Truitt

3-1 Transportation I recommend that non-traditional options for accessing Appendix D was added to the EA to address this issue in more detail. the forest be explored. [letter includes description of Please also refer to page 41 in the EA. It is important to note that a system bridges that can be raised with cables during high water cable bridge would be more costly than several other crossing options months then are lowered into place when flood hazard is evaluated in Appendix D. reduced in the spring].

Commenter: Dean Lawrence

4-1 Transportation Has anyone looked at the option of building a new Our engineers conducted a preliminary analysis and field crossing [over East Fork Silver Creek on FR 47] by reconnaissance of a realignment upstream as the commenter system moving crossing upstream by 200-300 feet? It seems suggested. Appendix D was added to the EA to address this issue in you could begin the road on the Randle side and follow more detail. Please also refer to page 41 in the EA. the edge of the 2006 slide until you get to the creek then use a metal pipe arch about 14 feet wide and 8 feet high which would leave minimal amount of fill to complete the crossing, with some excavation to tie into the existing road on the east side of the creek.

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Commenter: John Squires

5-1 Riparian Buffers When reading the EA I did not see the methodology or Please see section 6 of the PDC in the EA (pages 27-35). The assumptions made when creating inner riparian buffers interdisciplinary planning process included a limiting factor assessment for class 3 streams and 100 feet for class 4 streams. for water and soil related issues, which determined final buffer Some clarification for such large inner riparian buffers designations. The Forest Plan as amended by the Northwest Forest would be appreciated Plan (NWFP ROD. Pg B-10) provides the context for considerations the IDT made in developing the buffers. Considerations included: Unstable slopes, channel stability, active mass wasting (landslides) and debris flows, site-specific soils data which was pre-reviewed on GIS or from photo interpretation and then verified in the field. (See EA pages 48-50, 55-58, 151-152, and 170-171 for more discussion). Table 42 summarizes the channel stability measured within the analysis area and confirms a high percentage of Class III and IV streams are at risk of stability. We chose to standardize the buffer widths to simplify and add efficiency to the planning and layout process. PDC 1.16 indicates the buffer widths used for each stream class.

5-2 Riparian Buffers The EA states: “Also, in Rashin Edward B. et al. We concur that 10 meter buffer is typically effective at filtering surface indicated that a 10 meter setback for ground disturbance soil movement transported on the forest floor. However, Rashin’s can be expected to prevent sediment delivery to stream conclusions are specific to surface soil movement and don’t universally from about 95% of harvest related erosion features. apply to management of unstable slopes or the Silver Creek Thin Incorporating appropriate ‘“No Harvest”’ buffer widths sediment transport functions. We do follow Rashin et al.’s logic and around riparian areas in a harvesting unit will ensure factor in other riparian functions as stated, “wider setbacks for ground transported sediments filter out onto the forest floor and disturbing activities may be advisable on portion of harvest sites where limit the movements of sediment from reaching nearby steep inner gorges along streams extend beyond 10 meters. Other water bodies.” Given the FS own documentation, 150 long term functions of riparian zones, such as maintenance of stream feet of no harvest buffer seems excessive and temperature and large woody debris regimes, should also be inconsistent with your own science. considered in the design of stream buffers.” Riparian no-harvest buffers minimize disturbance on unstable slopes in order to avoid reducing soil strength and potentially subsequent landslides. Field reconnaissance and Forest soil mapping along with Watershed Analysis was used to identify areas of instability or geological hazardous zones. Many areas with 150 foot buffers were documented as active mass movement, torrent scours, or debris slides. Further, our prescription was also driven by the strong empirical evidence of the erosional features linked to past land management practices (EA pages 48-50, 55-58, 151-152, 170-171). Continued management on relatively recent clearcut streamside buffers was viewed as likely to move the riparian reserve in a trajectory contrary to ACS objectives. Surface soil movement referenced in the comments was less of a concern than the deep seated mass wasting. Surface soil movement

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values do vary based on a number of factors (slope, roughness, moisture, soil type) for typical harvest related overland soil movement. We generally agree that in some instances a large percentage of surface soil movement may be contained in 10 meters. We believe the buffer prescribed in this proposal is necessary to contain surface soil movement.

5-3 Riparian Buffers [EA] Page 152 under microclimate the FS uses “Streams Streams do influence micro climate as stated in the EA. Several in riparian reserves influence air temperature and authors agree timber harvest effects to microclimate may be mitigated humidity and create microclimate gradients extending with 10-20 meter buffers. However, as a rule slope stability, not laterally from streams (Olsen, et al. 2007). The FS has microclimate, was a primary concern to establishment of these no failed to use more up to date studies. The Olson Density harvest buffers. Approximately 780 acres of buffers are in the best Management Riparian Buffer study 2014 is the only interests of protecting unstable and potentially unstable areas, which study of the combined effects of alternative forest are designated as riparian reserves by Northwest Forest Plan. See designs and riparian buffers and the best available discussion on unstable soils, landslide zones and buffers in the EA science and apparently the FS failed to use that science. pages 48-50, 55-58. This study indicates that commercial thinning is consistent with Aquatic Conservation strategy/ ACS with much smaller inner riparian reserves than this EA proposes.

5-4 Riparian Buffers The other best available science concerning inner We understand that the spatial scale at which the ACS objectives were riparian zones and the ACS is Olson’s Forest Ecology intended to be attained was an ardently contested issue and ruled on and Management 2014 which I have included the in the courts (PCFFA v. NMFS). Previously, in Pacific Coast Fed. Of conclusions below verbatim [see Squires comment letter Fishermen’s Assn. v. Natl. Marine Fisheries Service, 265 F.3d 1028 page 3]…I would urge the adoption of the strategy (9th Cir. 2001)(PCFFA II, IV), the United States Court of Appeals for proposed by Olson in her conclusion of her study Forest the Ninth Circuit ruled that because the evaluation of a project’s Ecology and Management study 2014. Quoting Olson’s consistency with the long-term, watershed level ACS objectives could study, “The aquatic conservation strategy of the NFP is a overlook short-term, site-scale effects that could have serious regional approach to retain aquatic-dependent consequences to a listed species, these short-term, site-scale effects resources, and its objectives were intended to be must be considered. Memorandum EMS TRANSMISSION 05/24/2007, attained at larger spatial scales, with periodic BLM-Instruction Memorandum No. OR-2007-060 addresses actions unfavorable conditions within any particular watershed needed to respond to the rulings of PCFFA IV and PCFFA II. In (Reeves et al., 2006). Hence a calculated risk such as making the ACS consistency finding and to be guided by PCFFA II, implementing a 6- to 15-m riparian buffer at a stream the decision maker must: 1. Review projects against the ACS reach with upland restoration forestry, especially when objectives at the project or site scale, rather than only at the watershed other stream reaches within the drainage are managed scale. This review can be accomplished through cumulative effects more conservatively to hedge uncertainties, seems analyses (e.g., by evaluating the incremental effect of the project consistent with current policy for federal lands within the added to the existing condition, and the effects of other present and NFP area.” This describes exactly how management will reasonably foreseeable future actions) on watershed conditions; 2. occur in the future on lands covered by Silver Creek Thin Evaluate the immediate (short-term) impacts, as well as long-term EA. In the foreseeable future we will not harvest old impacts of an action; 3. Provide a description of the existing watershed growth in riparian buffers or any other older stands so condition, including the important physical and biological components

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these stands will only improve in their functions. The FS of the 5th field watershed; 4. Provide written evidence that the decision should adopt this strategy and by doing so address the maker considered relevant findings of watershed analysis. The courts requirement of the ACS to “restore” instead of noted the framers of the ACS disagreed on spatial context of the maintaining degraded habitats that your own EA states strategy and ruled in favor of the plaintiff in this landmark decision. are at “unacceptable risk” which is what this proposal There is a long history of industrial forest land management in the does. Silver Creek subwatershed (EA page 43-44, 50-52, 77). There is reasonable evidence to suggest that the portions of the Silver Creek subwatershed currently in non-federal ownership will be managed with relatively short rotation, clearcut logging. Matrix of pathway indicators ranks several baseline indicators at “unacceptable risk” for a variety of reasons. This Proposed Action takes some proactive measures to address degraded habitats not only through vegetation management but also through active restoration proposals (EA pp. 13-18). Road closures, riparian non-commercial treatment, and instream channel restoration are among the proposed actions which are expected to move the baseline indicators in a positive trajectory. The element of time will be our ally in many circumstances. Many (riparian) stands are relatively young and underdeveloped. Further, there is strong evidence of ongoing disturbance where stands are dominated by alder. Passive restoration or deferring harvest for a rotation is expected to help rebuild long term soil productivity and sustain watershed ecological functions.

5-5 Riparian Buffers The EA should also look at “ Alternative Riparian Buffer Our response is here is similar to that for comment 5-2 addressing Strategies for Matrix Lands of BLM Western Oregon Rashin’s study. The Reeves et al conclusions do not universally apply Forests That Maintain Aquatic Ecosystem Values to management of unstable slopes as per the Silver Creek Thin January 23, 2013 Gordon H. Reeves1 , Brian R. sediment transport functions. We agree with some aspect of Reeve’s Pickard2, K. Norman Johnson3,4” which indicate 100 conclusion regarding variable widths (page 48): “….based on stream feet for fish bearing and 50 feet for non -fish bearing segment importance; the variable-width buffer is better for both fish streams. and timber harvest because it enables managers to target where buffers will do the most good for fish while increasing the proportion of the buffer that also has timber production goals.” Larger buffer size would be required in more unstable areas or in areas that require greater protection to downstream water quality such as 303(d) listed streams for water temperature. See also response to comment 5-6 below as well as NWFP ROD B-10.

5-6 Riparian Buffers The FS should look at Rashin, E., C. Clishe, A. Loch and We agree that 30 foot buffers may be sufficient in some settings to J. Bell. 2006. Effectiveness of timber harvest practices meet the intent of ACS objectives. However, the NWFP ROD B-10 for controlling sediment related water quality impacts. asserts that multiple variables factor into efficacy of riparian reserve Journal of the American Water Resources Association. buffer. The ACS covers a wide array of ecological functions and Paper No. 01162 which indicates 30 foot buffers are processes. NW Forest Plan guidelines requires that we find appropriate and don’t violate ACS.

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consistency with all factors. Please also refer to responses for comments 5-1 through 5-11.

5-7 Riparian Buffers On page 162 the EA states: ”Other studies suggest of 45 Microclimate is among several considerations with respect to riparian m (150 ft.) on each side of stream with 70 to 80% management. It is our professional judgement that prescribed buffers overstory coverage (predominately Douglas-fire and will adequately protect the streams on NFS lands. Maintaining stream western hemlock to help maintain a natural riparian temperature is another objective of riparian management. Of particular microclimate environment along the streams adjacent to concern in the Silver Creek project area are channel reaches currently clear cuts in areas of moderate to steep slopes in excess of State water quality standards for stream temperature. Our (Brosofske, et al, 1997). This is seemed to be used to riparian harvest prescription was in part influenced by the large refute the previous citation: “Proper microclimate is a portions of the subwatershed currently managed as industrial forest crucial part of riparian reserves function on maintaining lands. While we don’t have control over non-NFS lands, we assumed moisture and temperature. With minimum buffer widths these lands will continue to be intensively managed and likely to be of 45 to 75 feet, air temperatures within 30 feet of source areas of water warming. We agree that level of overstory streams have shown to be little affected by upslope retention is a contributing factor in maintaining site scale microclimate. thinning (Mazza, 2009). “ The Brosofske 1997 study Please also refer to discussion of microclimate and stream clearly refers to “streams adjacent to clearcuts” so I am temperatures in the EA pp. 78, 117-119, 150-152, 155-156, 160, 164. confused why this study should be applicable to this thinning project and should be deleted which seems to leave you with the Maaza 2009 study which indicates buffers of 45- 75 feet. I could find nowhere in the document where the FS cited a study that indicated buffers should be larger than 45 feet except for the Brosofske study which has to do with clear cuts. The FS should follow their own citations and analyze a alternative that is consistent with the studies they cite.

5-8 Riparian Buffers On pages 151-152 the EA states “Summer stream We agree that 30 foot buffers may be sufficient in some settings to temperature is approximated based upon change in the meet the intent of ACS objectives. However, the NWFP ROD B-10 primary shade zone area of (minimum) 60 feet on each asserts that multiple variables factor into efficacy of riparian reserve side of a stream channel that is 20 feet wide or less. buffer. The ACS covers a wide array of ecological functions and Studies have shown that maximum shading ability is processes. NW Forest Plan guidelines requires that we find reached within a width of 80 feet and that 90% of that consistency with all factors. Please see responses for comments 5-1 maximum is reached within 55 feet (USDA Forest to 5-11 for more discussion on the considerations that informed the Service and BLM, 2010). Once effective shade buffer widths. decreases below 80% (220 Basal Area) it will begin to have an effect on increasing water temperature (USDA Forest Service and BLM, 2010).” This seems to indicate shade would not be an issue if the inner no treatment/restoration riparian zones for class 3 and 4 streams were 50 feet instead of 100-150 feet.

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5-9 Riparian Buffers The proposed action states to: “Actively manage and The interdisciplinary planning process included a limiting factor restore Riparian Reserves in the Lynx Creek and Silver assessment for water and soil related issues, which determined final Creek drainages to promote large tree structure and buffer designations (PDC 1.16). The Forest Plan as amended by the riparian vegetation development using commercial and Northwest Forest Plan (NWFP ROD. Pg B-10) provides the context for noncommercial variable density thinning techniques considerations the IDT made in developing the buffers. Considerations (Middle Cowlitz Watershed Analysis, pp. 6-2 to 6-4). This included: Unstable slopes, channel stability, active mass wasting will help control stocking and acquire vegetation (landslides) and debris flows, site-specific soils data which was pre- characteristics needed to attain Aquatic Conservation reviewed on GIS or from photo interpretation and then verified in the Strategy objectives (NWFP ROD, pp. B-11, C-31 and C- field. (See EA 48-50, 55-58, 151-152, and 170-171 for more 32).” This proposed action clearly doesn’t restore most discussion). EA page 171 (Table 42) summarizes the channel stability of the acres in riparian reserves because class 3 and 4 measured within the analysis area and confirms a high percentage of streams have a no restoration buffers of 100-150 feet Class III and IV streams are at risk of stability. Sensitive wildlife such and leave them at their present state of “unacceptable as salamander species also benefit from riparian buffers (EA page risk”. In fact the EA states on page 175: “Riparian 125-126). We chose to standardize the buffer widths to simplify and reserves will be slow to attain Aquatic Conservation add efficiency to the planning and layout process. PDC 1.16, on page Strategy objectives (under this proposed action). Stand 21 of this document, indicates the buffer widths used for each stream structure and diversity will be underdeveloped. Riparian class Further, several restoration projects are specifically in the stands in the analysis area will be typically undersized proposed action to develop riparian structure and habitat and promote and ineffective at contributing LW in the short term. The large wood in strategic stream reaches (EA p. 13). dominant Grass/Pole seral stage may persist for several decades. Recruitment of large wood will be delayed, commensurate with riparian stand development.” Given this statement why doesn’t this proposed action address this issue by thinning within 45 feet of any class 3 or 4 stream which would have the attainment of large wood greatly accelerated instead of the proposed action which delays the benefits of large wood in streams? This proposed action maintains most of the riparian reserves that are functioning at “unacceptable risk” in that state for hundreds of years until a stand replacing fire comes though allowing natural regeneration. For example cedar is a very critical species because of it long life, large size and ability to create large wood for a long time critical to fish species to have growing in riparian areas. There are few if any cedars or any tree species diversity in these old clear cuts and the ACS requires the FS to “restore species diversity” in riparian reserves and instead the FS chose’s to maintain riparian reserves in their present degraded state with no hope of species diversity coming in naturally because the planted Doug Fir has such a head start that other species have no hope of surviving and growing to maturity in their shade. These large dense stands of Douglas fir/ DF also prohibit the dispersal of the Northern Spotted Owl/ NSO making it

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more difficult for the species to survive because they can’t fly though these thick stands. Since the FS is not significantly reducing the density in these stands of riparian reserves it will have a negative effect on the NSO for decades to come. Again the ACS requires the FS to “restore” and this proposed action doesn’t do that but instead takes the easy no management option of doing nothing that allows the dispersal of the NSO to be hindered and the significant delay in attainment of late successional characteristics in these stands that are critical for the survival of the NSO.

5-10 Riparian Buffers I can only assume that the decision to leave such large The interdisciplinary planning process included a limiting factor buffers on class 3 and class 4 streams is the fear that assessment for water and soil related issues, which determined final such benign treatments such as thinning somehow buffer designations (PDC 1.16). The Forest Plan as amended by the violate ACS even though the best available science Northwest Forest Plan (NWFP ROD. Pg B-10) provides the context for doesn’t indicate it would. In fact the studies used in the considerations the IDT made in developing the buffers. Considerations EA as noted previously indicate riparian no harvest/no included: Unstable slopes, channel stability, active mass wasting restoration buffers could be smaller, somewhere (landslides) and debris flows, site-specific soils data which was pre- between 20 and 50 feet. This EA fails to meet its own reviewed on GIS or from photo interpretation and then verified in the stated purpose and need statements and needs to field. (See EA 48-50, 55-58, 151-152, and 170-171 for more modify the proposal to do so. This seems to not be discussion). EA page 171 (Table 42) summarizes the channel stability intellectually dishonest since in the Nisqually EA there measured within the analysis area and confirms a high percentage of was a project analyzed that was determined not to Class III and IV streams are at risk of stability. violate ACS called the Riparian and Instream Restoration project. That project has the treatment of Sensitive wildlife such as salamander species also benefit from 250 acres in inner riparian areas creating 147 stream riparian buffers (EA page 125-126). We chose to standardize the structures along 7.4 miles of streams some of which are buffer widths to simplify and add efficiency to the planning and layout fish bearing streams. The project would be process. PDC 1.16, on page 21 of this document, indicates the buffer noncommercial thinning of the inner riparian areas to not widths used for each stream class Further, several restoration projects exceed 35% relative density removing trees 12- 28 are specifically in the proposed action to develop riparian structure and inches DBH. The project would install instream log habitat and promote large wood in strategic stream reaches (EA p. structures in cluster of 2-12 logs. The logs would be 13). hauled up to 200 feet and put in the stream by The restoration projects involving riparian and instream disturbance hoe/loader, excavator, skidder, dump truck and a truck would be subject to several design criteria and mitigations to prevent all working in riparian area with some of this big water quality issues during implementation (EA pages 42-43, PDC equipment by necessity entering the creeks floodway. sections 8 and 9). The Fisheries section of the EA discloses the How these activities impacts which are substantial would beneficial and adverse, short term and long term effects of the not violate ACS while commercial thinning between 45- Proposed Action, restoration projects, and associated design criteria 150 feet from a stream does seems intellectually and buffers on listed fish and ACS objectives in the EA (177-191). dishonest. The no harvest buffers in the Nisqually Thin EA were 30 to 60 feet on intermittent streams which is consistent with the best available science. The science

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you use in your EA as noted previously indicate 30 to 60 feet no harvest buffers don’t violate ACS but actually “restore” some of the nine indicators of the ACS so to be intellectually honest you should follow your science.

5-11 Riparian Buffers The FS should use the studies I have provided as well See response to Comment 5-10. as their own and alter their inner riparian no harvest/ no restoration area to 45 feet (unless site specific analysis indicates differently) and commercially thin in these areas from 45 to 150 feet. The inner riparian zone should also be thinned to a relative density of 35% similar to the Riparian and Instream Restoration Project. Wood could be removed commercially or left on site. There should also be created a number of gaps (Olson’s recommendation on field trip this summer) that could then be replanted with cedar and other appropriate species to create tree species and shrub diversity. This is consistent with the best available science which indicates these activities would not violate ACS and certainly have fewer impacts than the Riparian and Instream Restoration Project analyzed in Nisqually EA.

5-12 Vegetation – I must applaud the FS for including some early seral A seral stage analysis was done for the biophysical settings Early Seral treatments although only 176 acres of the 3032 acres (vegetation types) in the Middle Cowlitz Watershed and on NFS land analyzed for treatment is certainly not enough. While by the Gifford Pinchot Forest Ecologist in December 2014. It was there is early seral habitat available it is not quality early inadvertently omitted from the Preliminary EA but now appears as seral habitat and is quickly growing out of that stage. Appendix E. This analysis partially informed the location and amount Combined with the fact that there won’t be any of early seral habitat enhancement treatments planning in the Silver treatments for decades in this watershed, early seral Creek project. The following is an excerpt from that analysis: "Seral habitat must be created now or in 30-50 years there will stage A (early seral) is slightly underrepresented (4% vs. reference be a larger deficit. Nowhere in the EA do I see an condition of 5%) in the North Pacific Maritime Mesic-Wet Douglas- analysis of how far out of the historic range of natural fir/Western Hemlock forest type (representing much of the project variability FS lands below 3500 feet are. There is no area) on National Forest land. A single percentage point can be analysis of even presence or absence of early seral accounted for by natural disturbance variability. The amount of early dependent species whose numbers are decreasing seral forest on adjacent lands, the connectivity of early seral forest regionally and are headed for listing. I would urge the FS among lands, and the overall quality of habitat provided by early seral to look at the study Biological Associates of Early Seral forest are of more concern than simply number of acres. Private lands preforests in the Pacific Northwest: Swanson et al. adjacent to the National Forest near Silver Creek planning area have 2014.This documents a number of early seral species been heavily harvested. Habitat conditions on those lands are that are in decline and in need of early seral habitat. Also unknown. Factors including snag abundance, height, and condition; look at Early Seral Forest in the Pacific Northwest, coarse woody debris abundance, length, and condition; and shrub and Swanson 2012. Swanson notes that the larger the herb richness need to be considered to assess habitat quality on both disturbance that creates early seral habitat the better private and national forest lands. Analyses shared here are limited to

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and the longer this habitat will persist. The FS needs to forest composition and structure and do not include any factors of analyze the cumulative impacts to these species in peril habitat quality. “Thus, findings indicate no lack of early seral habitat on over the next 30 years as their habitat leaves the early NFS lands in the Douglas-fir/western hemlock forest type of the Middle seral stage and how this may lead to their extinction. Cowlitz watershed based on forest structure and composition. However, you are correct to note that the quality of such habitat was not specifically analyzed on NFS or adjacent lands. Past harvest practices suggest that current early seral habitat might be lacking in quality components; however, without more information on habitat quality across land ownerships and among seral stages, we cannot knowledgeably and in good conscience prescribe early seral habitat enhancement at the potential expense of other habitat types. Furthermore, treatments are limited to thinning stands younger than 80 years old in the Late Successional Reserve (LSR) allocation. Regeneration harvest (early seral enhancement) conflicts with the management direction of LSR (EA, pp. 4-5).

5-13 Vegetation – The EA states in the “needs” statement that there is a A seral stage analysis was done for the biophysical settings Early Seral “lack of early seral habitat”. While there are some early (vegetation types) in the Middle Cowlitz Watershed and on NFS land seral treatments there are none above 3500 feet. The by the Gifford Pinchot Forest Ecologist in December 2014. It was fire interval at higher elevation is more frequent and after inadvertently omitted from the Preliminary EA but now appears as over a hundred years of fire suppression has caused a Appendix E. departure from historic conditions. Moreover there will be no vegetation management for the next 30 years The majority of forest types in the Silver Creek planning area above causing the departure from historic conditions to only and below 3500 feet are characterized by long (100-300 year) or very worsen as young plantations mature quickly out of early long (300+ year) fire regimes (Agee 1993). Fire suppression has only seral habitat. To adequately manage conditions in the been affecting western forests for approximately 100 years. We cannot future some vegetation treatment needs to be taken now assume departure from historic conditions because fire suppression so in 30-50 years site conditions will be within the range has been occurring for only a single fire return interval in the driest of natural variability. I urge that this EA analyze what the vegetation types present in the planning area. Even in another 50 need will be for early seral habitat 30-50 years from now years, most of the forest types present will still be within their natural above 3500 to be within the historic range of variability. . range of variability regarding fire frequency. If the trajectory we are on now indicates there will be a Stands above 3500 feet in the Matrix allocation are in a Management deficit of early seral habitat then treatments need to be Area Category where timber production is the primary objective. included in this EA to ensure that above 3500 feet early Stands in this category cannot be regeneration harvested until they seral habitat will be in its historic range of variability. have met Culmination of Mean Annual Increment (CMAI) as dictated These treatments should be like Veta and Pinto sales. I by NFMA (EA, PDC 1.9, and page 77-78). Mean annual increment is am sure after analysis we will find that they are out of the average annual growth of a stand which culminates when it their historic range of natural variability or will be soon reaches its maximum rate of growth. The District Ranger did not want based on local and indigenous knowledge. The EA to propose treatment in stands older than 130 years which left only seems to assume it will be in the historic range of stands under 60 years old available for the project as there were no variability by not treating these areas and I question that stands between ages 60 and 130. The stands less than 60 years old assumption since I have seen no analysis in EA to indicate it will be. I urge that that a new alternative be

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created that addresses early seral habitat above 3500 have not yet met the CMAI requirement and therefore can only be feet and be analyzed. thinned according to NFMA.

5-14 Wildlife The FS should look at : “Butterflies and Moths of PNW According to the referenced Butterflies of Moths of PNW Forests and forests and Woodlands: Rare, Endangered and Woodlands, Miller and Hamilton, 2007, "Many of the taxa covered in Vegetation – Management Sensitive Species, Miller and Hamilton this book reveal present day patterns in distribution that appear to be Early Seral 2007 to understand the number and types of species remnants of the species range that historically (centuries to millennia) that are at risk of going away if more quality early seral was more widely distributed. The current diminished ranges contracted habitat is not created. To create more quality early seral naturally to very small populations within isolated refugia along the habitat early seral treatments should be considered on West Coast prior to European settlement of North America. cable ground and the total early seral acreage should be Subsequent to the natural contraction of these species ranges, at least 800 acres. At the very least early seral adverse human-related effects on the quality and quantity of remaining treatments should occur where the ground is ground suitable habitat resulted in fragmentation of the populations, thus based logging. Unit 21 which is 14 acres of early seral placing them on the brink of extinction. Four issues are responsible for should be 30, unit 28 should from 59 to 80; unit 29 the fragmentation and decline among these populations: 1) loss of proposes 33acres should be 43 and unit 37 propose 18 habitat to urban and agricultural development; 2) logging of mature should be 28. Unless the FS starts creating more quality forests; 3) the controlled management of natural disturbances such as early seral habitat now in a few decades it will be almost wildfires, and; 4) the introduction of tall-growing exotic grasses and nonexistent and early seral dependent species will be brush that compete with and displace native vegetation, including the listed as threatened or endangered and could go extinct. food plants required by the larvae of many butterfly species.." Please analyze this alternative where these actions are Therefore, citing this reference as an argument for creating early seral taken and how these treatments will impact early seral habitat in a forested environment does not logically examine the species in decline or peril. factors leading to Lepidoptera population declines. The 2 factors causing decline of Pacific NW native moths and butterflies cited above that are relevant to Silver Creek would be #2, logging of mature forests, and #3, control of natural disturbance events such as fire. To argue that by not creating clearcuts that are artificial early seral habitat that does not persist on the landscape for more than 2 or 3 decades given the rapid rate of conifer growth in the Pacific Northwest, would cause the extinction of native moths and butterflies, is ignoring the habitat requirements of these species that in some cases, such as the Johnson's hairstreak butterfly (Region 6 sensitive) feed on dwarf mistletoe and require conifer canopy as habitat. According to Miller and Hamilton, "management practices that would benefit this species need to promote the maintenance of mature and old-growth conifer forests at middle to low elevations on the west slope of the Cascade would be to increase the length of time in the harvest rotation of mature true fir forests along the summit of the Cascade Mountains". Other Region 6 sensitive species, such as the mardon skipper butterfly, require dry meadow habitat that would not be created in an early seral forest opening because the seed source for the required grasses, such as fescue, would not be present in the soil and therefore would not be produced by removing the conifers. The Gifford Pinchot

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Land and Resources Management Plan, as well as Regional Guides, establish the maximum size and dispersal of created openings in accordance with the legal requirements and provisions in the National Forest Management Act (EA, pp. 77-78). These standards and guidelines limit the size of created openings to 60 acres in the Western Hemlock Working Group and 40 acres in the Pacific Silver Fir Working Group and elsewhere. Virtually all of the proposed created openings in the project proposal are located in the Pacific Silver Fir Working Group (EA Table 6). Additionally, the standards and guidelines require that logical harvest unit(s) remain between existing created openings (EA PDC 1.9). These constraints, combined with other factors such as buffers for riparian habitat, terrestrial habitat, unstable soils and visuals have all played a role in developing the shape, size and dispersal of created openings in the project proposal.

5-15 Transportation I also have concerns about the roads that are being There are currently many miles of road in Silver Creek which are not system proposed for closure. Road 7561018 has been rated as accessible due to failure nor have been for a decade or more. This “moderate access need” and shouldn’t be closed project would actually improve or re-establish access on system roads because of future access needs for harvest in the matrix. (see EA pp. 9-12, Appendix C). No roads are proposed to be Road 4778011 will “have to reconstruct length of FR decommissioned (completely removed from the National Forest road 4778011 including ditch, shoulder and surface repair and system) as stated in the Proposed Action (EA p. 45). Further, closure culvert replacement at mileposts 0.56 and 0.6.” To and stabilization does not foreclose the opportunity to use the road for spend tens of thousands of dollars to repair a road and future management, and no roads currently open are proposed for then to decommission it seems an unwise use of dollars. closure in this project. We are challenged to strike a balance between Since its closure is justified for wildlife security the costs of maintaining roads, providing public and administrative access cheaper option would be to gate it. Road 4700213 the and sustaining ecological function across the landscape (both aquatics need is rated moderate and since the reason for closure and terrestrial). The current degraded nature of the NFS road system is wildlife security a gate permanently locked would be is a pressing concern for many facets of resource management. We most cost effective. Road 7500047, 7500048, 4700049 have a development of road infrastructure which far outreaches our and 7500002 have high access needs and should not be capacity to conduct regular maintenance necessary to sustain both closed. Road 8500108 has a high access need and suitable driving conditions and help safeguard against chronic and moderate aquatic and low terrestrial risk and shouldn’t catastrophic failure. Part of our road strategy is to bring our road be closed because there is no pressing ecological risks system into proportion of our current and expected fiscal capacity to and because of the “high access need”. Let us not make maintain. While there is an upfront investment in closing and stabilizing another 7708 mistake where we closed the road a few roads, we believe that in the long term, we are money ahead by years ago and are now going to be spending tens of proactively closing roads and preserving much of the road matrix for thousands of dollars to reopen it. future use. Among our goals for this planning area was to sustain current net levels of public access to the extent practical. Roads which provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so we found that several

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roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance.

Commenter: Pinchot Partners

6-1 Vegetation – During scoping for Silver, the Pinchot Partners provided Many factors were considered regarding huckleberry enhancement in Early seral, comments on restoration projects, at your request. Our the Silver Creek planning area. Direction and guidelines are provided Huckleberry primary concern was to restore huckleberry habitat by Gifford Pinchot Land and Resource Management Plan, the enhancement within the Silver Creek area as huckleberry restoration is Northwest Forest Plan, the National Forest Management Act (NFMA), a priority for the Pinchot Partners... We do not feel and line officer sideboards (please see EA pp. 4-6, 209-212). Further huckleberry restoration was adequately addressed in the consideration was given to plant associations where we are most likely draft EA. Huckleberries are noted only nine times in the to be successful, forest structure condition class, access, tribal uses, 247 page draft EA, mostly in the plant associations social values, and competing priorities. table... If a prior historical conditions analysis had been performed, undoubtedly, huckleberry areas would hae Additionally, a seral stage analysis was done for the biophysical been documented as being prevalent in the upper settings (vegetation types) in the Middle Cowlitz Watershed and on elevations of the Silver area and received more analysis. NFS land by the Gifford Pinchot Forest Ecologist in December 2014. It Huckleberries are noted as a special forest product of was inadvertently omitted from the Preliminary EA but now appears as interest to forest visitors on page 195 of the draft EA... Appendix E. we encourage you to be more inclusive of multiple social values of interest to forest visitors in the analysis and give more attention to huckleberries and huckleberry habitat.

6-2 Correction We also noticed an error on page 12 of the preliminary The EA has been corrected to reflect the role of the Pinchot Partners EA. It notes that the Forest Service hosted a public in coordinating and hosting the public meeting. Apologies for this error, meeting on November 12, 2014. That meeting was co- and thank you for your outreach and support efforts! hosted with the Pinchot Partners. We worked with Erica Taecker to develop the flyer, send out press releases, post notices and we provided food in order to encourage community members to attend.

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Commenter: Ron Pfeifer

7-1 Transportation I only have one substantial comment and that concerns Appendix D was added to the EA to address this issue in more detail. system one of the “Alternatives Considered, but Eliminated from Please also refer to page 41 in the EA. Detailed Study”. My specific concern is about the “Alternative to Reconstruct FR 47 Crossing at East Fork Silver Creek”. I have seen that blown out crossing, and it is certainly a mess and a complicated situation. I’m not an engineer, hydrologist, soil scientist, geologist or district ranger, so I won’t pretend that I know the correct solution to that problem. My concern is that the EA does not provide the public with nearly enough information to judge whether, in fact, such an alternative is economically viable, especially if it were only a temporary crossing constructed to minimum specification and used only for timber haul during the project. In my opinion, you should be providing the public (in a transparent way; e.g. in the appendix) with all the assumptions and data used in the preliminary analysis by which you decided that any reconstructed crossing of the creek is not economically viable.

Commenter: Kathy Heimbigner

8-1* Transportation I do believe it would be beneficial for the 47 road to be Appendix D was added to the EA to address this issue in more detail. system restore as much as possible - for numerous reasons. We Please also refer to page 41 in the EA. had always enjoyed the capability to drive up into the forest on that road - in fact, my husband drove up there early in the morning of May 18, 1980 and saw the beauty of the mountain just before Mt St Helens erupted! *Note* comment does not have standing for objection because it was submitted after comment period closed.*

8-2* Public safety, I do have a concern for Silver Creek itself, its health and The IDT developed the Proposed Action not only to provide revenue to Social impacts riparian abilities in addition to the folks of the valley the local economy through timber sales, but also to address many of affected by the flooding. I would welcome any efforts to the very issues the commenter has raised related to riparian health improve on these matters. and public safety. Please Appendix D for more detailed discussion. *Note* comment does not have standing for objection because it was submitted after comment period closed.*

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8-3 Public safety, Summary of oral comments provided during comment The IDT developed the Proposed Action not only to provide revenue to social impacts period: the local economy through timber sales, but also to address many of the very issues the commenter has raised related to riparian health Multiple flood events over decades have scoured away and public safety. Please see Appendix D for more detailed portions of this [Heimbigner’s] property on Silver Creek. discussion. In every flood event, more debris is deposted and more land is eroded/shifted onto and away from the property. Logs and debris upstream of the East Fork Silver Creek crossing of The net loss of land from this property is estimated to be FR47 will not be directly impacted or moved by this project. However, 1 acre since 1975. an alternative to reconstruct a crossing or bridge at that location was not fully analyzed in part due to the risk of another catastrophic failure Federal funds have supported bank revetments on the of a crossing, which would have the potentially to more severely [Heimbigner] property in the past after floods, but not impact downstream communities than logs and debris alone. Please always and not easily. see the EA page 41 and Appendix D for more about the evaluation Very concerned that logs and debris still upstream will done for a potential crossing. continue to come down during flood events, modifying her [Heimbigner] property and affecting the local community.

8-4 Transportation, Supportive of community's interest in constructing even Appendix D was added to the EA to address this issue in more detail. social impacts a temporary "Bailey bridge" on FR 47 over the East Fork Please also refer to page 41 in the EA. Silver Creek to allow access to the forest.

Commenter: Gifford Pinchot Task Force

9-1 Riparian buffers Many Riparian Reserves are short of dead wood due to The proposed project would commercially thin approximately 300 past and ongoing logging, roads, and fire suppression. In acres within the outer riparian reserve buffers, no closer than 100 feet the Silver Creek project area, there are multiple streams to streams (see EA PDC 1.16 for buffer widths) and maintain with poor large woody debris and poor pool per mile approximately 1,300 acres of "no harvest" within the inner riparian ratings. Natural processes of stand growth and mortality reserves (see discussion of how inner reserve widths were determined will correct this shortage, whereas thinning could capture in responses to comments 5-1 to 5-11). Therefore, while some of the and export mortality and reduce and delay recruitment of research cited may show that the long term result of thinning is fewer wood to both streams and uplands within Riparian large diameter trees and slower recruitment of small diameter snags Reserves. This is not a minor short-term effect, but (as discussed in the EA beginning on page 134 in the cavity excavator rather a significant long-term effect. Such effects are section, see suppression mortality discussion), much other research inconsistent with the Aquatic Conservation Strategy would show that thinning does produce larger diameter trees (Chan et which prohibits logging in Riparian Reserves unless it is al, 2006). Therefore, while there may be some validity to the argument needed to meet objectives, and requires that that thinning would produce fewer small diameter snags and less management actions “maintain” and "not retard" ACS down wood, the effects of the proposed treatments would only occur objectives, including dead wood. Any purported benefits on 300 acres, and would occur in generally in young, managed of riparian thinning must be weighed against the plantations that are not currently providing substantial amounts of potential adverse effects on dead wood recruitment. dead wood habitat for amphibians, mollusks, lichen and fungi that are typically associated with late-successional stands. Therefore, given the small area affected and the age of these stands, thinning 300 acres of

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A recent interagency study assessed the potential outer riparian reserves within the approximately 30,000 acre ecological outcomes of riparian thinning in relation to watershed, will not have a substantial impact to dead wood habitat in ACS objectives, noting that riparian thinning “can reduce the Silver Creek watershed and the species that are associated with the future supplies of snags and large dead down and dead wood habitat. See cavity excavator section in EA, page 134-139 decomposing wood on the forest floor and in aquatic for project effects to cavity excavators. systems,” potentially retarding attainment of ACS objectives #8 and #9. See Spies et al 2013 at 27. Dead wood is important to both aquatic and terrestrial purposes of Riparian Reserves. As such, the EA cannot just focus on recruitment of wood to streams, but must also address the need to recruit optimal levels of snag and dead wood to meet the needs of terrestrial wildlife (e.g. primary cavity excavators, secondary cavity users, amphibians, mollusks, lichen, fungi), which were intended to be benefited by Riparian Reserves. In addition, dead wood of all sizes is important to streams and riparian function. In small streams, small wood can even perform the ecological and hydrological functions normally thought to require large wood. If the goal of logging is to create large trees faster, the NEPA analysis should document the size, gradient, and other characteristics of streams adjacent to each logging area and determine the size of wood that can serve key ecological and hydrological functions, then disclose the effects of logging relative to those relevant wood sizes. In another recent long-term study, an unthinned stand had far more large diameter live trees than a thinned stand decades later, as described below. According to a position paper by Kim Kratz, Director of the National Marine Fisheries Service (NMFS) Oregon State Habitat Office: “Thinning accelerated the development of large diameter trees by about 20 years such that there were more live trees > 18” dbh in the two decades following thinning, relative to the unthinned stand, but this advantage was short-lived. Three decades after thinning, there were more live trees > 18” dbh in the unthinned stand and five decades after thinning there were twice as many live trees >18” dbh in the unthinned stand relative to the thinned stand. A similar trajectory was observed for the live trees > 24” dbh.” Kim Kratz, Ph.D., Issue Paper for Western Oregon. NMFS, Oregon State Habitat Office. 7- 23-2010. Appendix 1 at 38. The NMFS position paper assessed whether heavy thinning of

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riparian conifer forests leads to more instream wood and concluded that “an unthinned stand will produce a higher number of both live and dead trees across a range of diameter classes and will produce far more dead wood over a much longer time frame relative to a heavily thinned stand. A strategy of thinning to accelerate the development of a few healthy, large-diameter trees does not translate into more large wood in streams. ” Kratz at 4 (emphasis added). Kratz also states: In regards to stream habitat, many of the negative impacts created by the existing riparian thinning proposals could be largely avoided with wider no-thin buffers (e.g., see Appendix 1) and removing far fewer trees during thinning operations. In examining forest thinning proposals designed to accelerate the development of late-successional forest conditions and restore instream fish habitat, NMFS is finding that, in many cases, they are likely to do neither. Kratz at 8 (emphasis added). According to the Silver Creek EA, thinning in Riparian Reserves under the proposed action will result in “[t]he growth of trees both in height and girth [which] will improve shade in the long term and provide future recruitment of large wood to the forest floor and/or to the actual stream itself.” EA at 81. However, as illustrated above, recent studies have shown the opposite effect over the longer term. Pollock and Beechie also emphasize uncertainty in the response of particular species to treatments that attempt to recreate associated habitat structures, as well as the possibility of neglecting other important features that a species needs. For example, “attempts to restore spotted owl habitat by heavily thinning to accelerate the development of large diameter nesting trees could actually delay spotted owl recovery by reducing production of the large down wood utilized by the species it preys upon.” Pollock and Beechie 2014 citing Forsman et al., 1984; Carey, 1995; North et al., 1999.In order to retain options for recruitment of large wood in degraded stream systems, scientific recommendations include retention of trees >12” dbh. Removal of trees from riparian zones may delay the recovery of fish habitat. At a minimum, the largest trees (that is, those > 12 inches in diameter at breast height) should be left in riparian areas for future sources of in-stream wood. This would apply to all streams, as recommended by

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Anderson and others (1992). Smaller trees could be removed as part of a program for riparian vegetation restoration. Gordon H. Reeves and Fred H. Everest. 1994. REDUCING HAZARD FOR ENDANGERED SALMON STOCKS. in Everett, Richard L., comp. 1994. Restoration of stressed sites, and processes. Gen. Tech. Rep. PNW-GTR-330. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station.

9-2 Riparian buffers In addition to questioning the merits of riparian thinning There is no commercial thinning proposed in the inner riparian in terms of dead wood, snag recruitment, and other key reserves, which are defined in the EA by PDC 1.16 and explained in riparian habitat structures, we have concerns about the much further detail in the response to comments 5-1 through 5-11 proposal to pre-commercially thin inner Riparian along with EA references in those responses. Reserves due to potential effects on water quality from lack of stream shade and sedimentation (sedimentation Project design criteria specific to pre-commercial thinning proposed in will be further addressed in the roads section herein). this project have been added to the Silver Creek Thin EA PDC, pp. 37- While we are not opposed to some hand felling and 38. These are the same PDC which apply to other pre-commercial leaving of trees in riparian areas for habitat restoration in thinning projects across the forest and have been successful at dense, young plantation stands, we do not support ensuring minimum stocking to meet land management objectives as thinning right up to stream edges without sufficient no well as protecting aquatic and wildlife habitat, water quality, and cut buffers. ensuring compliance with the Forest Plan, as amended, as well as Clean Water Act and other laws, policies, and regulations. First, there is some confusing and misleading information in the EA. On the one hand, the Forest Service asserts that thinning up to 20 feet from streams will be sufficient to ensure sufficient stream shade and protect the fragile microclimate (indicating that thinning will occur up to 20 feet from stream edges). See EA at 158-162. Yet, when evaluating microclimate and stream temperature, the Forest Service states that there will be minimal effects because buffer widths are 60-300 feet. In the microclimate section, it appears that the full analysis of effects focuses solely on thinning in outer reserves, despite the prescription to also thin the inner reserves. See EA at 162. The Forest Service must assess the impacts of allowing thinning in inner Riparian Reserves on stream temperature and microclimate, and provide additional details on the specific thinning prescription for inner reserves in the EA. Further, this proposal covers a large area with varying degrees of slope angles, stream orientations, densities, and species diversities, so there is a wide range of variability in effects. There are multiple studies concluding that thinning in Riparian Reserves—

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both inner and outer reserves—can increase stream temperatures beyond a level that supports healthy aquatic and riparian ecosystems, which could potentially retard attainment of ACS Objective #4 and contributing to water quality standard violations. See Spies et al at 26. The NMFS position paper referenced above also discusses riparian buffers in more detail and questions the modeling that the Forest Service and Bureau of Land Management are using to determine minimum riparian buffer widths to ensure sufficient stream shade. See Kratz at 14-20. NFMS in part does this due to generalizations made in determining stream buffers, which do not account for variable parameters like stream orientation or sinuosity. Kratz at 17-18. The Forest Service must also ensure that there are sufficient buffers to protect stream shade and microclimate in this proposal due to the presence of federally listed fish populations, including Chinook, coho, and steelhead, in the project area. Anadromous fish populations require cool water throughout all of their life stages and no cut buffers are essential to ensure sufficient stream shade. "Stream temperatures are significantly influenced by shading from streamside forests (e.g., Brown 1970, Brown and Krygier 1970, Brazier and Brown 1973). Recent field evidence in Bristish Columbia showed that stream temperature was 3°C higher with a forested buffer of 33 feet wide than in the forested control site, and 1.6°C higher with a 98 foot forested buffer. By contrast, a recent modeling effort showed that, on average, a 90 foot forested buffer in Oregon forests was likely to keep the temperature increase less than 0.3°C (upper 95% confidence interval 0.6°C, based on modeled stream temperature using Ripstream, Groom et al. 2011). This suggests that stream temperatures may still not be protected in many reaches even with a 90 foot buffer." Timothy Beechie letter to OR Board of Forestry, July 21, 2015.In addition, according to the EA, there are three identified 303(d) listed stream segments for water temperature in the project area: Silver Creek, Lake Creek, and Lynx Creek. The EA must indicate the extent of water quality impairment and must disclose the direct and cumulative impacts. The Clean Water Act does not permit de minimus degradation of water quality,

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especially on streams that are already impaired. 33 U.S.C. § 1323(a)(2)(C).

9-3 Riparian buffers The ACS objectives of the NWFP also require the Forest See EA on pages 126-128 for disclosure of effects to Van Dyke’s Service to “[m]aintain and restore spatial and temporal salamander and other amphibians. It is not practical to designate connectivity within and between watersheds.” See ACS Riparian Reserves across ridges given that they are, by definition, Objective 2. Riparian Reserves function as connectivity located within variable distances from stream channels that typically corridors and provide habitat to sensitive wildlife species do not start at the ridgeline and generally are not even evident until like the Van Dyke’s salamander. We recommend that some distance from the ridges where groundwater appears at the the Forest Service consider extending the riparian surface. Therefore they usually cannot be defined to the top of the buffers across key ridgetops in order to provide ridgeline. Also, very few proposed treatment units abut a ridgeline interbasin connectivity for amphibians and other species. therefore no riparian buffers within units are located near a ridge. However, we acknowledge that the function of riparian reserves in the Northwest Forest Plan is to provide connectivity on the landscape for semi-terrestrial riparian associated species, including salamanders, especially within the Matrix land designation. Consistency of this project with ACS objectives (including number 2) is addressed in the EA, p. 163.

9-4 Riparian buffers For all of the above reasons, the Task Force There is no commercial thinning proposed in the inner Riparian recommends that the Forest Service refrain from Reserves, which are defined in the EA by PDC 1.16 and discussed in thinning in the inner portion of Riparian Reserves within much further detail in the response to comments 5-1 through 5-11 the Silver Creek project area or at least limit thinning to along with EA references in those responses. very young, high density stands on gentle slopes beyond the 100 foot zone where most shade and woody debris Project design criteria specific to pre-commercial thinning proposed in recruitment is generated. We recommend maintaining this project have been added to the Silver Creek Thin EA PDC as pp. nocut buffers of at least 130 feet for perennial fish- 37-38. These are the same PDC which apply to other pre-commercial bearing streams in the entire project area and thinning projects across the forest and have been successful at maintaining full Riparian Reserve widths if any early ensuring minimum stocking to meet land management objectives as seral prescriptions are retained in matrix. We also well as protecting aquatic and wildlife habitat, water quality, and recommend retention of trees >12” dbh in fish-bearing ensuring compliance with the Forest Plan, as amended, as well as streams, and that trees cut in Riparian Reserves remain Clean Water Act and other laws, policies, and regulations. on site. In addition, we recommend that only standard thinning be conducted in Riparian Reserves. Lastly, we would like clarification on thinning limitations for the pre- commercial prescription in inner Riparian Reserves.

9-5 Transportation The Task Force is very supportive of the road closures The Proposed Action related to the use and disposition of system and system and stabilization proposed in the EA to address non-system roads responds to a variety of factors raised during terrestrial and aquatic risks. However, as highlighted in internal and external scoping and analysis disclosed in this EA. There our scoping comments, we are concerned about the are currently many miles of road in Silver Creek which are not effects of road construction, reconstruction, and landings accessible due to failure nor have been for a decade or more. We are

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in this proposal, especially due to soil instability issues challenged to strike a balance between costs of maintaining roads, and landslide occurrences in the project area (note that providing public and administrative access and sustaining ecological Figure 9 on slope stability is missing on p. 69). The EA function across the landscape (both aquatics and terrestrial). Stability states that there will be reconstruction of 64.1 miles of concerns in the project area factored greatly into the overall Proposed level 2 roads and 14.51 miles of level 1 roads; 7.4 miles Action as well as Project Design Criteria required for accomplishing of new temporary roads; 855 landings; and 22 stream any road work (EA PDC sections 6 and 7, Appendix C). The effects of crossings in the Silver Creek thin proposal. We are the Proposed Action related to soils and slope stability are discussed particularly concerned with the proposal to build or on pages 44-66. The current degraded nature of the NSF road system rebuild stream crossings, create new temporary roads, is a pressing concern for many facets of resource management. We reconstruct temporary roads, and reopen have a development of road infrastructure which far outreaches our decommissioned roads. We are also disappointed that capacity to conduct regular maintenance necessary to sustain both the draft EA fails to include a map with clearly marked suitable driving conditions and help safeguard against chronic and locations of new stream crossings, which should be the catastrophic failure. Part of our road strategy is to bring our road minimum information presented to the public through system into proportion of our current and expected fiscal capacity to NEPA. [multiple references in EA are provided indicating maintain. Among our goals for this planning area was to sustain the reasons for GPTF's concerns related to ESA fish, current net levels of public access to the extent practical. Roads which water quality, wildlife, sensitive habitats). provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so we found that several roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance. The effects species of proposed changes to the transportation are analyzed and disclosed in this EA. Road reconstruction needs, including stream crossings, is listed in tabular and narrative form in Appendix C of the EA. In addition, known streams are shown in their proximity to roads in the project area in the Proposed Action, Figures 3-8 Figure 9 erroneously appeared in the Index of Figures in the Preliminary EA due to a hyperlink placed on the text on page 68 (no figure 9 exists). The index listing has been corrected in the updated EA.

9-6 Project Design In addition, we are concerned about mitigation measure The Gifford Pinchot National Forest is following National and Regional Criteria – Water 6.20, which allows off-season logging with approval from guidelines for staffing and is currently fully staffed in Sale quality and ACS a sale administrator. Off-season logging can result in Administration. The Forest also complies with monitoring protocols, as sedimentation and related water quality and ACS well as random and routine compliance checks before, during, and violations. We do not believe that the Forest Service is after harvesting activities. Reconstruction, maintenance, and other restoration activities and associated PDC included in this proposal are

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adequately staffed to sufficiently monitor sites to ensure designed to repair or restore the sites that currently do not or may not violations do not occur. meet ACS objectives prior to haul activities.

9-7 Temporary roads We also request that new temporary roads or road The Forest Service endeavors to minimize the amount of temporary reconstruction be minimized, especially where the roads road construction while also meeting the diverse economic and could adversely impact listed fish habitat or result in ecological objectives for a timber project. Temporary road construction other harmful aquatic or terrestrial impacts. There is is often needed to access the whole stand without skidding or yarding clear evidence that temporary roads are anything but across streams, which are more detrimental to the health of that temporary and that, oftentimes, their existence and stream than building a temporary road. subsequent impact continues in perpetuity. Temporary roads can detrimentally affect stream health, as well as Temporary roads are located far enough away from stream channels habitat for Northern Spotted Owl and a variety of for them to deliver any sediment. On p. 163 of the EA, Objective 4 of regional species. They can also result in the compaction the ACS states, "Proximity of temporary roads to stream channels is of soil, alteration of the forest microclimate, alteration of limited which would allow sediment to be filtered through the forested the flow of water in the stand, erosion, sedimentation, vegetated floor prior to entering stream channels. Sediment delivery and increased peak flows of nearby streams. would not result in a measureable increase in stream sediment deposition." Project Design Criteria and Mitigation Measures table sections 6 and 7 describe measures reduce the risk of erosion and any sediment delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams during off-season logging operations by following a timing restriction so as not to log during wet weather conditions which can be measured objectively (#6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (#6.15). Effects of these activities on sediment delivery are disclosed in the EA beginning on p. 154.

9-8 Transportation We also encourage the agency to increase the number The team endeavored to use the 2002 Roads Analysis and field data system of miles designated for closure and stabilization or to identify roads to close and stabilize through the Silver Creek Thin decommissioning in areas that are sensitive habitats or project considering ecological risk factors including those asserted by where roads have significant impacts on water quality the commenter. Roads which provide access to multi-purpose (public within the project area. identified) location(s) were prioritized to maintain on the active road system. We are challenged to strike a balance between costs of maintaining roads, providing public and administrative access and sustaining ecological function across the landscape (both aquatics and terrestrial). Stability concerns in the project area factored greatly into the overall Proposed Action as well as Project Design Criteria required for accomplishing any road work, including closure and stabilization (EA PDC sections 6 and 7, Appendix C).

9-9 Transportation In addition, in our scoping comments, we requested that The analysis of trade-offs as you suggest is typically done through the system, an analysis of temporary roads and road reconstruction interdisciplinary development and refinement of the proposed action,

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Ecosystem and the economic and ecological tradeoffs of individual as well as in discussion of project design criteria and mitigation services road segments be conducted. However, we do not see measures. These discussions and notes are contained within the this analysis in the EA. It is critical that the EA evaluate project record and summarized where appropriate in the EA. the costs of road reconstruction and thinning versus the benefits, like ecosystem services, that the forest can There were multiple methods and procedures followed for identifying provide. environmental amenities and values and effects to them in the EA (pp.47-215). These included deriving the project need from the Gifford Pinchot National Forest Land and Resource Management Plan, Middle Cowlitz Watershed Analysis, landscape-scale assessments, best available science, and local resource data collected. These sources also provided information about an array of difficult-to-quantify environmental amenities and values, such as recreation, visual quality, and climate change. While not depicted in quantitative form for every resource (ie. many values, such as the amenity value of being able to access the forest for recreation benefit), the costs and benefits of road work are disclosed in the EA in terms of effects to a variety of ecological, economic, and social resources.

9-10 Wildlife – The Task Force is concerned about the proximity of A biological assessment for project effects to northern spotted owl Endangered some of the plantation units to NSO suitable habitat and (NSO) and marbled murrelet (MAMU), both Endangered Species Act Species Act the impacts of thinning within NSO critical habitat. Right (ESA) listed species, was prepared and reviewed by the US Fish and now, with the negative impact that barred owls are Wildlife Service (the Service). The Service responded with a biological having on spotted owls and the potential uplisting of the opinion (BO) for the Silver Creek Thin project. According to the BO, NSO to endangered status, the Forest Service should be the Silver Creek Thin project is "not likely to jeopardize the continued cautious that timber harvest activities do not add to the existence of the northern spotted owl." The Fish and Wildlife Service pressure on spotted owls, or directly harm or adversely made the same conclusion in the BO for MAMU. The BA/BO process modify their critical habitat. [references to ESA listing is followed to ensure that federal actions due not jeopardize the and EA NSO analysis are provided in the comment as continued existence of ESA listed species and as such are compliant rationale for GPTF's concern]... To avoid detrimental with the ESA. The EA discusses at length the effects of the inclusion effects to NSO and potential violations of the ESA, as of Unit 29 regarding the loss of NSO foraging and MAMU potential well as impacts to marbled murrelet habitat and listed nesting habitat. See MAMU and NSO sections, beginning on p. 98 of fish (note new temporary road and stream crossings the EA. Effects analysis includes potential disturbance along old within the unit), we request that the Forest Service drop growth edge (potential NSO and MAMU nesting habitat), potential for unit 29E from this proposal. We are also concerned increase in negative competitive interactions with barred owls, as well about regeneration harvest in unit 37E, as it is as effects to critical habitat. These effects are fully disclosed in the EA, immediately adjacent to suitable NSO habitat. We would as well as known species occurrence within the project area. like to see unit 37E dropped for that reason and others described in the early seral section below.

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9-11 Wildlife – Similar to our discussion in the NSO section above, the The concern over the inclusion of Unit 29 is noted and addressed in Endangered Task Force is very concerned about the inclusion of unit the previous response. Surveys for marbled murrelet occupancy in the Species 29 in this proposal due to potential direct impacts on unit will be conducted prior to inclusion of this unit within a timber sale marbled murrelets, and requests that the unit be contract. At this point marbled murrelets are not known to occur in dropped. We are also concerned about the likely to Silver Creek although suitable nesting habitat is present. Surveys were adversely affect determinations for marbled murrelets conducted in this area in the 1990's for a timber sale and none were and their designated critical habitat, considering both the detected then. Though Unit 29 is suitable nesting habitat, it is not individual impacts of this project and the cumulative within designated critical habitat for marbled murrelet. The proposed impacts when combined with the Nisqually Thin and project does not include older stands, the oldest one being Unit 29, 85 other logging projects occurring on adjacent lands. We years, containing legacy features from an older stand. Project Design are also concerned that no marbled murrelet surveys Criteria 1.15 (page 27 in EA) includes retaining legacy features within have been completed in the project area in many years. units if they are found with treatment units. There is also an operating We request that the Forest Service protect older stands season restriction for helicopter yarding where it may occur near throughout the project area and consider adjusting potential nesting stands for marbled murrelet and spotted owl to limit helicopter logging method prescriptions, shifting the that activity to outside of the nesting season. boundaries of those helicopter logging units away from suitable nest sites, or dropping those units altogether. Following discussion with Objectors, the District Ranger has opted to remove a portion of Unit 29 from any logging activities, and conduct thinning on the remaining 13 acres. No regeneration harvest would occur.

9-12 Vegetation – The Task Force is opposed to the prescription of The ecological analysis of current versus historical seral stage Early Seral, regeneration harvest to create early seral habitat structure in the Silver Creek watershed is displayed on page 139 in the Wildlife because it typically replicates a clearcut, which has long EA in the deer and elk section and was added to the EA as Appendix lasting detrimental impacts to soil health, water quality, E. This analysis reveals that the watershed is currently at 4% early and wildlife. We believe that the purpose and need for seral versus an historical estimate of 5% that would typically be in an early seral habitat to create deer and elk forage is early seral structure given the climate, plant association, fire frequency unreasonable and without scientific support. In scoping, interval, etc. Swanson 2012 (pg 139 in EA) is also referenced in the we requested an assessment illustrating the need to deer and elk section with a discussion of the importance of early seral create more early seral habitat for deer and elk in this habitat to a number of species. Historically natural wildfire would have area, but see no evidence that any assessment was played the most important role of all of the natural disturbance events conducted. [Rationale including maps generated by in the creation of early seral habitat in the Pacific Northwest. Currently GPTF are in comment letter to support comment that EA the GP does not have a natural fire policy and large scale fires have fails to consider amount of early seral habitat on generally been infrequent over the past 100 years of fire suppression. adjacent private and state lands; as well as concern for See EA, fire ecology section, pp. 81-83. Past regeneration harvest on regeneration harvest in NSO and MAMU habitat esp. a large scale has created artificially large areas of early seral that is no unit 29E] longer the case given current land management practices. As noted in the EA on pp. 138-141, records from Mt. Rainier National Park indicate low elk numbers there until the 1950’s when the elk population increased significantly. This coincided with logging activities outside of the park that increased the carrying capacity on elk winter ranges by increasing forage production of grasses and shrubs. Intensive logging, generally in the form of clear cutting, greatly changed the character and structure of the forests outside of the park, resulting in a

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patchwork of second and third generation stands. As National Forest land was logged creating more open and favorable habitat for elk, many large groups of elk remained outside of the park year-round and are now considered to be resident elk. Many of these resident elk remain below 3,000 feet for the entire year, while other migratory elk still move into alpine meadows during summer and return to the lower valleys in winter. Therefore past harvest practices have greatly altered the movement patterns and habitat use of the South Rainier elk herd on the forest. However, asserting that the continued loss of early seral habitat over the next 30 years will lead to the extinction of deer, elk and other species that are associated with early seral habitat is speculative and not supportable, given that none of these species are currently listed under ESA. The species that are more likely to go extinct in the next 30 years are those that are associated with late- successional habitat. The project proposes a modest amount (176 acres) of early seral habitat creation in deer and elk winter range that would contribute to an increase in forage for deer and elk, but only for a short period of approximately 20 to 30 years.

9-13 Vegetation – We are also concerned about other units that contain The effects to sensitive soils, wildlife, and listed fish, and sensitive Regeneration unstable soils, significant biological diversity, and/or are habitat for the units proposed for regeneration harvest (“E”) are harvest in proximity to listed fish habitat, including units 38E, disclosed in the EA (pp. 47-115), Consistency with Forest Plan 37E, and 28E. For instance, “Unit 38 would have the standards and guidelines is stated for the resource areas analyzed in highest amount of new [soil] disturbance as described in this EA. the proposed action, up to approximately 14.7 percent soil disturbance due to construction of a new helicopter The commenter’s survey data have not been provided to the Forest landing in a relatively small unit, 8 acres gross (Table Service so there is no way to assess their technical adequacy, 10).” EA at 63. Unit 38E also contains substantial incorporate them into this analysis, or know whether they complement diversity and older stands of trees, as documented in the or deviate from the data collected by FS staff according to stand exam, Task Force’s surveys in July 2015, and is in close wildlife, soils, or other survey protocols. The EA discloses potential proximity to listed fish habitat. Similarly, we are effects of regeneration harvest on these resources. concerned about regeneration harvest in unit 37E. The In addition, PDC 1.15 was specifically developed in order to retain Task Force also surveyed that unit in July and legacy features in the stands cited by the commenter. If older trees are documented very sensitive soils, animal trails, extensive found with early seral treatments they will be excluded or buffered from burrows, high biological diversity, and significant large harvest areas. down wood. Unit 37E is also in close proximity to listed fish habitat, borders suitable marbled murrelet habitat and old growth stands, and contains a disproportionate amount of new stream crossings (13 of 22 in the project area). Unit 28E also contains some stands over 175 years old and would include multiple stream crossings in close proximity to listed fish habitat. Consequently, the Task Force requests that the Forest Service modify the

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proposal by dropping units 29E, 28E, 37E, and 38E and substitute thinning for regeneration harvest on the remaining matrix units.

Commenter: Cowlitz Tribe

10-1 Vegetation – The EA does not address how the proposed action One of the needs of the project is to produce commercial yields of Matrix objectives meets the Matrix management objectives intent. wood and optimization of timber in Matrix lands (EA, p. 3).The Desired [comment includes references from EA description of Future Condition for Matrix lands is such that evidence of land Matrix objectives and proposed action thinning managed intensively for timber production and other commodities is treatments proposed] apparent (EA, p.71).Treatment units in Matrix will emphasize a traditional approach by thinning stands down to spatially uniform residual densities to ensure that overstory tree layers fully occupy the site and thus maintain timber production (EA, p. 71).Treatment units in Matrix would maintain a continued state of inter-tree competition while maintaining growth more at the stand level and less at the individual tree level. This would be consistent with the project’s Purpose and Need to produce commercial yields of wood and optimization of timber in Matrix lands (EA, pp. 69-70).

10-2 Fire Ecology The EA also lacks a description of the historic watershed A seral stage analysis was done for the biophysical settings ecology.[references included from EA]. The EA does not (vegetation types) in the Middle Cowlitz Watershed and on NFS land provide adequate historic information to support the by the Gifford Pinchot Forest Ecologist in December 2014. It was statement that fire ecology does not need to be restored. inadvertently omitted from the Preliminary EA but now appears as Appendix E. The ecological analysis of current versus historical seral stage structure in the Silver Creek watershed is also displayed on Figure 17 in the EA in the deer and elk section. This analysis reveals that the watershed is currently at 4% early seral versus an historical estimate of 5% that would typically be in an early seral structure given the climate, plant association, fire frequency interval, etc. Historically natural wildfire would have played the most important role of all of the natural disturbance events in the creation of early seral habitat in the Pacific Northwest. Currently the GP does not have a natural fire policy and large scale fires have generally been infrequent over the past 100 years of fire suppression. See EA, page 81-84, fire ecology section.

10-3 Noxious weeds The EA notes that noxious weeds 'may or may not be The EA notes that noxious weeds 'may or may not be controlled controlled depending on available funding" (pg 97). depending on available funding" (p 94). Noxious weeds present a real Noxious weeds present a real and considerable threat to and considerable threat to ecosystems as well as individual plant and ecosystems as well as individual plant and animal animal species. It is recommended that the Forest allocate funding

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species. It is recommended that the Forest allocate towards invasive species removal, as a well known risk factor to long funding towards invasive species removal, as a well term forest ecosystem health. The fire season of 2015 is a good known risk factor to long term forest ecosystem health. example of why funding may not always be available for certain programs, such as invasive species management. When the allocated budget for fighting fires is exhausted, money is diverted from other non-emergency programs. Otherwise, the Gifford Pinchot National Forest is committed to controlling the spread of invasive species, and the Forest does allocate funding for invasive species removal. Money is also allocated to our partner, Lewis County, who does most of the invasive control work for Gifford Pinchot, and that funding will not be recalled for fire suppression.

10-4 Visuals, Tourism, Page 196 [of EA] notes that "most residents of these The Gifford Pinchot National Forest Land and Resource Management Economics towns depend on tourism to the area and the national Plan (LRMP) provides the basis for Scenery Management objectives; forest." However, on page 205, Lewis county had around The Forest Management Goal for Scenery is to provide natural- 15% of jobs in industries that relate to travel and tourism, appearing scenery from the high use (most important) recreation travel which is smaller than the national or state average. routes and use areas (p.IV-3 ). P.IV-22 further characterizes Scenery Creating visual buffers to accommodate tourism should as a resource and specifically directs that the visual management be laid out in a cost-benefit table, specific to the system (now known as Agriculture Handbook Number 701: Landscape watershed treated and the amount of expected tourism Aesthetics) is to be used in all resource programs to maintain high that would not use the forest area due to visual impacts. scenic quality. Specific viewsheds were identified through Forest Planning and can be viewed on p.IV-23 of the LRMP. Each viewshed was assigned a Visual Quality Objective, which is defined as categories of acceptable landscape alteration measured in degrees of deviation from the natural-appearing landscape. These categories range from no timber harvest (Preservation) to heavier timber harvest (Modification) and each Land Management Allocation in the LRMP has been assigned at least one of these categories. For example, Wilderness has a Visual Quality Objective of Preservation i.e. no timber harvest (p.IV-120), while Timber Production (also known as General Forest), has a Visual Quality Objective of Modification i.e. full timber harvest will be scheduled (p.IV-136). Typically the Land Management Allocation of Visual Emphasis (p.IV- 98) has been assigned to the Viewsheds identified on p.IV-23 of the LRMP. It is understood that these viewsheds are the high use recreation travel routes, so management objectives are to manage for visual quality here. The Visual Quality Objective assigned is either Retention or Partial Retention, with specific direction for maintaining visual buffers, usually up to ½ mile, but can be further dependent on location. The goal for Visual Emphasis is to provide a visually natural or near-natural landscape as viewed from the designated travel route or use area.

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10-5 Correction Cultural attributes in the watershed are noted [in the EA] Thank you for bringing this omission to our attention. The following to be "primarily associated with historic sites change has been made to the EA, page 190: Cultural attributes are (homesteads, farms, trails), livestock grazing and early primarily associated with traditional uses by the Cowlitz and Nisqually logging." (pg 192). The Cowlitz people have cultural Tribes, including berry picking, foraging, and hunting. Other cultural values associated with berrying, foraging, hunting, and attributes associated with the area include historic sites (homesteads, other values. Evaluating the place value should include farms, and trails), livestock grazing, and early logging. the cultural values of the Cowlitz, or others peoples as apply in a specific area.

10-6 NEPA – During the Pinchot Partners discussion about the As the commenter states, Forest Service regulations now prevent Comment period proposed project, it was brought up a rule change, 36 extension of the comment period for EAs. The FS understands the CFR 218.25(iv) "Extension. The time period for the commenter’s frustration with holding a comment period during the opportunity to comment on a proposed project or activity holiday season; the timeframe was not intentional but it allowed the to be documented with an environmental assessment project to keep moving through the planning process. shall not be extended." The time period extension has historically allowed Forest Service staff, or concerned public citizens, the flexibility to lengthen the comment period for cause. In the case of Silver Creek Thin EA, the comment period opened immediately after Thanksgiving and closes just before the new year. At this time, many staff are taking vacations. An extension would have been welcome to improve our response detail.

10-7* Cultural The CRD (Cultural Resources Department) recommends An Inadvertent Discovery Plan is incorporated into every project resources an Inadvertent Discovery Plan be attached to the permit; contract where ground disturbance may occur. We have provided a we have included language for your consideration. copy of the Forest’s IDP to the tribe which addresses these concerns. *Note* comment does not have standing for objection because it was submitted after comment period closed.*

Commenter: Dave Bunting

11-1 Transportation I believe the decision to not rebuild the East Fork Appendix D was added to the EA to address this issue in more detail. system crossing is wrong. There are so many reasons that Please also refer to page 41 in the EA. justify rebuilding it, among them of course the huge and expensive effort we made to connect Silver Creek to Randle, and the cost need not be very much at all. [attachments provided: article with rationale which was published in the Highway Shopper newspaper out of Packwood, WA on December 9 2015; as well as letter Mr. Bunting sent promoting his interest local individuals explaining his rationale including economic efficiency

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and the safety for downstream residents that might be afforded by a temporary "railroad flatcar-type" bridge].

Commenter: American Forest Resource Council

12-1 Support, AFRC generally supports the Proposed Action as it best Thank you for your comment. Economics meets the purpose and need of the project. A key to accomplishing the goal of the purpose and need statement of this project is for the activity to be economically viable. The ability for both the commercial and non-commercial activities of this proposal to be accomplished, the project must economically viable. Factors affecting the economics of a project can include the selection of appropriate harvest systems to accomplish the stated goals, operating seasons that provide flexibility for the purchaser/operator, volume removals, and a suitable transportation infrastructure. We are pleased to see the Forest has taken many of these factors into consideration in this proposal.

12-2 Economics We are pleased to see the project allow ground based Thank you for your comment. mechanical harvesting on slopes up to 45% and we encourage the consideration of this in future projects. Mechanical harvesting has benefits economically, improved ability to protect residual trees during felling operations, and increased safety for harvesting personnel.

12-3 Logging systems AFRC would encourage the GPNF to assure the Helicopter logging is generally the last option the team considers for proposed 71 acres of helicopter logging cannot be accessing a stand after more conventional yarding methods have accessed with other more conventional yarding been ruled out due to resource concerns or inaccessibility. In most methods. In the absence of the ability to yard with cases helicopter yarding is economically unfeasible when conducting systems other than helicopter, we would urge the Forest thinning of plantations, and helicopter availability during the typical to evaluate the best means of "packaging" these units operating season is decreasing with a longer and more active fire into future sales which make economic sense. season. The Forest Service does seek to package stands to be Spreading fixed "move in" costs over the maximum helicopter logged into sales where the majority of stands can be volume possible will aid in this effort. accessed with a cheaper logging system (ground based or skyline), or sales in which higher volume may be achieved over a smaller area, such as in regeneration harvests.

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12-4 Limited AFRC is encouraged and applauds the efforts the Forest The proposed project has LOP's for wildlife mitigation to limit Operating Period has undertaken in developing criteria/outcome based disturbance impacts to ESA listed species. There are LOP's for big restrictions for operations outside the Normal Operating game winter range as well that usually are granted waivers given Period (NOP) of July 1 to September 30. This has the certain conditions are met. The winter range LOP includes units 17, potential to allow greater flexibility when scheduling 21, 30 and 38, so these could be waived under certain criteria. These operations. When Limited Operation Periods (LOPs) are units also have a early/late hours LOP for marbled murrelet nesting considered, there are only 6 days for Units 17, 21, 30, 38 season from 4/1 to 9/23 which does not curtail logging activity which have no LOP impacts. completely, only during the 2 hours after dawn and 2 hours before sunset time period. Therefore, there will likely be more than 6 days without LOP's to harvest these units.

12-5 Economics/ We are pleased to the see the winter logging option Thank you for your comment. Winter logging included to potentially allow the operator to operate under the guidelines identified in Objective 6.20 (pg 38). Assuming the project area is accessible during winter months, without significant snow plowing expense, winter operation can be very beneficial to prospective bidders. Generally, it is at this time of year when it is important to maintain economic activity by providing work for logging crews and a source of wood for mills to process.

12-6 Transportation AFRC is also pleased to see this project will work to Close/Stabilize treatments would not foreclose the option to reopen System improve the road infrastructure of the forest as needed these routes in the future, as the roads would remain on the National for timber haul...Regarding the FS 47 Road, we would Forest road system but would be closed to use as Management Level encourage the Forest Service as part of the "close and 1. Appendix D was added to the EA to address this economic stabilize" work proposed to not foreclose on the potential comment in more detail. Please also refer to page 41 in the EA. to re-construct and open this access route. Considering the amount of Matrix land allocation in the area, future access via this route may be advisable. There also appears, based on scoping comments, to be an interest in the local community for restoration of this access route. We did see reference in the scoping comments to an economic analysis which would be included in the EA. However, we did not see the detailed analysis referenced in the scoping comment reply.

12-7 Daylighting We are disappointed to see the Forest decided to not The rationale for not pursuing an alternative to daylight roads is Roads pursue the road day-lighting alternative. The ability for disclosed in the EA at page 45. There may be opportunity to include day-lighted roads to dry quicker has benefits for such a proposal in future project areas where daylighting is more maintenance, longevity for the road surface, and consistent with resource objectives or by refining the criteria for which reduced sediment development from traffic. While we this tool might be proposed.

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understand concerns over daylighting a 20-foot-wide area (each side) along the road within Riparian Reserves could impact water quality and habitat, thinning in these areas, particularly overhanging deciduous trees, can help in addressing road surface conditions and length of time to dry. Additionally, we would point out that improving road conditions outside of Riparian Reserves will serve to further protect resources within the Riparian Reserve where the road passes through. Day-lighting within and near proposed harvest units can serve to help improve road drying times in those areas. While not system wide within the analysis area, we believe this work would incrementally improve road conditions and maintenance needs. On other ownerships we have seen significant impacts to road surfacing by non-logging related (i.e. recreational light vehicle) traffic during rain events. Portions of roads where day light could easily reach the running surface saw less impact from non-logging related traffic than those shaded most of the time.

12-8 Wildlife AFRC supports the inclusion of Unit 29 in this proposal. It is unlikely that marbled murrelets would be detected in Unit 29, but Based on Fig. 2 in the document, this unit is in Matrix the Northwest Forest Plan and the Biological Opinion received from land allocation and the proposed treatment is consistent the Fish and Wildlife Service requires in its Terms and Conditions that with the expectations of Matrix lands. Based on the MAMU surveys are conducted before harvest of suitable nesting information provided in the EA and work conducted by habitat can occur. other landowners in the vicinity we feel it is highly unlikely that surveys will show presence of marbled murrelets in this stand. This unit as with most of the rest of the Silver planning area proposed for management are on the edge of the 55 mile from marine waters range for use. We encourage the GPNF to continue with inclusion of this unit and evaluate all opportunities to offer this unit in a future sale project.

12-9 Riparian buffers AFRC would like to see greater effort now and in the See Response to Comment 5-10. future of evaluating commercial opportunities to treat a wider area of the riparian reserves than what is currently proposed….It has been documented by many that most of the wood that naturally recruits to streams comes from within the first 65 feet of the stream channel (Murphy and Koski, 1989; McDade et al. 1990. Johnson et al. 2011). So if this is where the LWD is coming from then

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thinning in this region would likely accelerate its creation...It has also been documented that vegetated buffers that are greater than 33 feet in width have been shown to be effective at trapping and storing sediment (Rashin et al. 2006). Partial cutting down to one or two conifers from intermittent and perennial stream channels would accelerate the recruitment of LWD with minimal impacts to sedimentation and stream temperature. We would like the GPNF to consider these trade-offs closely in the planning for this project and future projects to improve riparian conditions on the maximum amount of these reserves.

12-10 Riparian We would also like the Forest to consider including some See response to Comment 5-10 treatments of the following pieces of scientific research into their analysis. Much controversy surrounding any type of thinning in riparian reserves has surfaced, and we think the following information would be useful in justifying the kinds of beneficial treatments the GPNF implements.[list of references and summary of pertinent findings included in comment letter]

Commenter: Dick Artley

13-1 Temporary roads Logging road construction causes significant ecological The Forest Service endeavors to minimize the amount of temporary harm. Please analyze an action alternative in detail that road construction while also meeting the diverse economic and does not construct any new roads ( temporary or ecological objectives for a timber project. Temporary road construction system).This would satisfy the P&N. Just as with No is often needed to access the whole stand without skidding or yarding Action, this alternative provides the public with the trade- across streams, which are more detrimental to the health of that off between the Proposed Action and an alternative with stream than building a temporary road. Temporary roads are located less volume and less environmental impact . . . far enough away from stream channels for them to deliver any especially to aquatic resources. [attachments and sediment. Page 163 in the EA under Objective 4 of the ACS states, references provided detailing agency past and present "Proximity of temporary roads to stream channels is limited which construction of roads Is extensive along with NEPA and would allow sediment to be filtered through the forested vegetated aquatic references] floor prior to entering stream channels. Sediment delivery would not result in a measureable increase in stream sediment deposition." Project Design Criteria and Mitigation Measures table sections 6 and 7 describe measures reduce the risk of erosion and any sediment delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams during off-season logging operations by following a timing restriction

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so as not to log during wet weather conditions which can be measured objectively (#6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (PDC 6.15). Effects of these activities on sediment delivery are disclosed in the EA at 158- 159 Some alternatives, including one to avoid any road construction, were not deemed reasonably feasible or viable, as disclosed and explained on page 41 of the EA. One action alternative was ultimately developed, and the team felt that no further alternatives would effectively balance resource objectives and multiple values across the landscape while also addressing the interests of the community.

13-2 Transportation Without exception, road construction and reconstruction The Proposed Action related to the use and disposition of system and system are activities that cause damage to some important non-system roads responds to a variety of factors raised during natural resources in the forest. New road construction is internal and external scoping and analysis disclosed in this EA. There particularly detrimental to aquatic and wildlife resources. are currently many miles of road in Silver Creek which are not Chief Dombeck’s statement below supports this fact. accessible due to failure nor have been for a decade or more. We are challenged to strike a balance between costs of maintaining roads, providing public and administrative access and sustaining ecological function across the landscape (both aquatics and terrestrial). Stability concerns in the project area factored greatly into the overall Proposed Action as well as Project Design Criteria required for accomplishing any road work (EA PDC sections 6 and 7, Appendix C). The effects of the Proposed Action related to soils, wildlife, fisheries, and other resources are discussed on pages 43-208. The current degraded nature of the NFF road system is a pressing concern for many facets of resource management. We have a development of road infrastructure which far outreaches our capacity to conduct regular maintenance necessary to sustain both suitable driving conditions and help safeguard against chronic and catastrophic failure. Part of our road strategy is to bring our road system into proportion of our current and expected fiscal capacity to maintain. Among our goals for this planning area was to sustain current net levels of public access to the extent practical. Roads which provide access to multi-purpose (public identified) location(s) have been prioritized to maintain on the active road system. Part of our planning process was to refine the recommendations of the Gifford Pinchot National Forest 2002 Roads Analysis and further distinguish ongoing motorized access needs. In doing so we found that several roads identified as “high access needs” were actually attributed to (one time) single purpose mining claims. As per our current management strategy, single purpose roads not integral to administrative needs have a lower priority for maintenance.

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13-3 NEPA - Best The Administrative Procedures Act directs judges to set Given the experience and professional background of the scientists on available science aside an agency action if the court determines that the the team, we believe the analysis of effects disclosed in the EA was action is “arbitrary, capricious, an abuse of discretion, or based upon appropriate scientific literature, valid data, and otherwise not in accordance with law.” 5 U.S.C. § professional judgment. The EA discloses the measurable effects to 706(2)(A). A line-officer who ignores best-science and resources from pages 43 through 208, including data and summaries instead makes a Decision on weak, meager evidence from which effects determinations were drawn. Resources in which provided by people with financial interest in a sale being data or surveys are lacking were disclosed in the EA, and the potential sold (i.e. IDT members that represent timber and effects were estimated based on peer-reviewed science and engineering) is guilty of violating the APA. representative data sets.

13-4 NEPA – Public Include a new section that provides specific information The opportunity to provide input during scoping and comment periods Involvement listing the collaborative group member’s names and was offered to the general public via mail, email, and website, not affiliations. This specific information should include at exclusively to the collaborative group. The proposed action was least 1) each collaborative group member’s interest in developed from scoping feedback received, in writing, from a variety of the proposed sale, and 2) information describing how the sources and interests, including citizens and entities based outside the collaborative group member is any way linked somehow local area. The public meeting held during scoping was open to the to woods products. general public, as were field trips to the project area. Collaborative group concerns were not given more weight than those expressed by any other member of the public who chose to provide input.

13-5 NEPA - Please post your responses to public comments on this Comments and responses are in the updated EA as Appendix F and Comments online as well as maintaining a hardcopy in the Project will be posted separately online, in addition to kept in a hardcopy File. project file.

13-6 Economics Increases in National forest logging do not stabilize or Logging and employment in other timber related jobs are 10-12% of enhance the economic of small communities located the local economy (Census Bureau, 2011), considerably greater than near them. [excerpts from various sources cited in a the importance of this sector on employment nationally (Figure 23). research paper are included to support this comment]. While travel and tourism related employment accounts for around 15% Please describe why Dr. Power's research does not of local employment, this is similar to the national average, and is likely apply to the Gifford Pinchot National Forest. due in part to the presence of Mt. Rainier National Park in Lewis County as well as the adjacent district on the Wenatchee National Forest. The timber industry provides stability to the local workforce as a source of jobs that typically pay more than the service industry jobs associated with tourism.

13-7 Economics, Why do you reject the findings and conclusions of The Gifford Pinchot National Forest and adjacent public lands provide Recreation Undersecretary of Agriculture Jim Lyons and well many recreation opportunities. Please visit respected scientists? They all make the case that 1) http://www.fs.usda.gov/recmain/giffordpinchot/recreation. Logging and recreationists avoid areas that have been logged, and 2) employment in other timber related jobs are 10-12% of the local recreation-related revenues to local communities with economy (Census Bureau, 2011), considerably greater than the importance of this sector on employment nationally (Figure 23). While travel and tourism related employment accounts for around 15% of

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lumber mills is much more than the revenues generated local employment, this is similar to the national average, and is likely by logging? due in part to the presence of Mt. Rainier National Park in Lewis County as well as the adjacent district on the Wenatchee National Forest. The timber industry provides stability to the local workforce as a source of jobs that typically pay more than the service industry jobs associated with tourism.

13-8 NEPA – Purpose You reject the research conclusions of 241 Ph.D. The Purpose and Need for this and many projects on the Gifford and Need scientists quoted in [attachment of references provided Pinchot National Forest responds directly to the Gifford Pinchot with comment letter] who demonstrate how logging- National Forest Land and Resource Management Plan regarding related harm (and in a few cases destruction) is inflicted timber output and other resource goals and objectives. EA page 3. on multiple natural resources in and near the sale area. Incredibly, you rely on the advice of 3 or 4 timber The effects of commercial thinning and other treatments in the employees financially motivated to sell timber. You know Proposed Action on various natural resources are disclosed in the EA, the log for community stability P&N statement appears in pages 43-208. at least 80% of all timber sale NEPA documents. This has become the commonly used excuse by USFS line- officers to sell unneeded timber sales and you use it here.

13-9 Economics – If you were really concerned about local community The Forest Service determination to offer a timber sale under the Small Business stability and local job creation you would offer this sale Small Business Act is made in accordance with FS Timber Sale Administration as an SBA sale to prevent a large timber corporation Preparation Handbook 2409.18, which directs implementation of the from logging it using their own labor. This would prevent SBA regulations (Title 13 of 13 CFR 121). This occurs after the NEPA the logs from being hauled many miles to be processed process has occurred and a decision has been made to implement a at a mill far removed from the small communities you timber project. claim need economic help. Of course your motivation to sell this timber sale has nothing to do with community Between 2003 and 2012, there were 36 commercial thin timber sales stability. We both know “local community stability” and across the Forest that were not part of stewardship projects, of which “local job creation” is part of the USFS dishonest script half were allocated to companies that are registered with the Small to trick the public into accepting tragic timber sales. Business Administration. None of the sales were sold below-cost. Over half of the sales had 2-6 bidders and were sold for up to 3.5 times the advertised value. Timber harvest is not only proposed to benefit the local economy, as stated in the Purpose and Need (EA p.9). It is a land management tool to improve forest health and provide wildlife habitat. This project is expected to be harvested through several timber sales, over several years.

13-10 NEPA - Analyze at least 1 citizen generated alternative to the Section 102 [42 USC § 4332] (2) of the National Environmental Policy Alternatives Proposed Action in detail. Act states “all agencies of the Federal Government shall—…(E) study, develop, and describe appropriate alternatives to recommended

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courses of action in any proposal which involves unresolved conflicts concerning alternative uses of competing available resources.” Issues brought up during public and internal scoping and review were resolved through revising the silvicultural prescriptions and project design criteria, or through dropping units or portions of units, resulting in the one proposed action alternative rather than multiple alternatives to meet the purpose and need of this project. The project addresses restoration priorities to restore channel conditions to the extent possible given planning and implementation constraints. The restoration projects were vetted in public scoping and subject to the IDT process. Discussion of specific alternatives proposed but not fully analyzed appears in the EA on page 45.

13-11 Temporary roads At page 15 you propose to return your temporary roads The Forest Service endeavors to minimize the amount of temporary to a more natural state after use. As part of the timber road construction while also meeting the diverse economic and sale you propose to construct 7.41 miles of new road ecological objectives for a timber project. Temporary road construction you refer to as “temporary road” that will generate new is often needed to access the whole stand without skidding or yarding sediment. New roads produce 3 to 5 times more across streams, which are more detrimental to the health of that sediment than an existing road produces. There is no stream than building a temporary road. Temporary roads are located sediment analysis. How does the public know if the net far enough away from stream channels for them to deliver any sediment is reduced? Your proposal to return your sediment. Page 161 in the EA under Objective 4 of the ACS states, temporary roads to a more natural state will leave the "Proximity of temporary roads to stream channels is limited which road surface in place so you can access the cutting units would allow sediment to be filtered through the forested vegetated with less reconstruction costs the next time you log the floor prior to entering stream channels. Sediment delivery would not area. Links to science showing complete obliteration is result in a measureable increase in stream sediment deposition." more effective at reducing long-term sediment Project Design Criteria and Mitigation Measures table sections 6 and 7 generation than any other closure methods [provided in describe measures reduce the risk of erosion and any sediment comment letter]. delivery to stream channels that might be caused by timber or road management activities. Also in the same table it discusses preventive measures on erosion and potential sediment delivery to streams during off-season logging operations by following a timing restriction so as not to log during wet weather conditions which can be measured objectively (PDC 6.21). Best Management Practices used to help facilitate water movement on those disturbed areas (PDC 6.15). Effects of these activities on sediment delivery are disclosed in the EA at 158-161

13-12 NEPA - EIS Include the source literature for particularly relevant The commenter appears confused as to which project or NEPA science quotes contained in the Opposing Viewpoint document he is commenting on, since he refers to a "final EIS." The Attachments in the References section of the final EIS Silver Creek Thin project is documented in an EA. Further, the and cite the quotes contained in the attachments in the collection of quotes and sources provided by the commenter is offered body of the final EIS. Some adverse effects of project to support a general viewpoint and is not referenced to any particular activities described by scientists in the Attachments was finding, statement, or resource within this document. This makes it

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not mentioned in the final NEPA document EA, 40 CFR impossible to determine the intent and context of each quote as it 1500.2(f) because the Responsible Official was unable relates to our detailed analysis. Given the experience and professional to avoid or minimize any possible adverse effects upon background of the scientists on the analysis team, we believe the the quality of the human environment without knowledge specific references to scientific, professional and other literature found of the adverse effects. throughout this document demonstrate an appropriate and unbiased analysis.

13-13 NEPA - Effects Don’t overstate and/or exaggerate the timber sale’s The beneficial and adverse effects of the Silver Creek Thin, including benefits to the environment [list of references in EA of activities associated with timber harvest, road work, and restoration what will be restored is included in comment]. If it will projects, are disclosed in the EA pages 43-208. restore a resource tell the public why the resource needs improvement and how logging will restore it. Specifically, describe how subjecting the resources listed above that you claim will be restored to industrial equipment (skidders and tractors) weighing 16 tons with spinning wheels and tracks will restore them to resources that function properly again. Failure to do so will violate NFMA at Section 6 (g)(3)(E)(iii), 40 CFR 1500.1(c) and 40 CFR 1500.2(e) and (f).

13-14 NEPA – Best Include some source documents from the Opposing The collection of sources provided by the commenter is offered to available science Views Attachments [provided with comment letter] in the support a general viewpoint and is not referenced to any particular References section of the final EA. Also, cite some the finding or statement within this document. This makes it impossible to specific quotes related to the issue that are presented in determine the intent and context of each quote as it relates to our the source literature in the Opposing Views Attachments. detailed analysis. Given the experience and professional background The public deserves to be informed of this information so of the scientists on the analysis team, we believe the specific they can make an informed decision to support or references to scientific, professional and other literature found oppose the timber sale based on complete data. throughout this document demonstrate an appropriate and unbiased analysis.

13-15 NEPA – Best The Silver Creek sale will take away more undeveloped The collection of sources provided by the commenter is offered to available science national forest acres from the legacy the unborn kids of support a general viewpoint and is not referenced to any particular the future. A sample of the opposing views from the finding or statement within this document. This makes it impossible to Opposing Views Attachments is included below [44 determine the intent and context of each quote as it relates to our statements and Opposing Views attachment are detailed analysis. Given the experience and professional background included in comment letter]. Please meet with your IDT of the scientists on the analysis team, we believe the specific and discuss each science statement. references to scientific, professional and other literature found throughout this document demonstrate an appropriate and unbiased analysis.

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Commenter: Gary Stamper

14-1 Public Safety Will the plan support safety concerns of the citizens from The IDT developed the Proposed Action not only to provide revenue to the affected area? the local economy through timber sales, but also to address issues raised related to riparian health and public safety. Safety concerns specifically addressed include evaluating the safety and economic need for a crossing on FR 47 across the East Fork Silver Creek (EA pages 41-42 and Appendix D), as well as inclusion of project design criteria (PDC) to address hazardous fuels (EA p. 22-23).

14-2 Economics Is the agency being financially responsible to the citizens It is not clear in what respect this comment is related to the scope of and taxpayers who bear the burden of cost over-runs? the Silver Creek Thin project. However, economic costs and benefits, in addition to the environmental and social consequences of the project are disclosed in the EA (pp. 43-208). Appendix D specifically addresses the financial considerations to not reconstructing a crossing on FR 47 across East Fork Silver Creek.

14-3 Economics How does the project benefit the economy and The Silver Creek Thin project was driven in part by an identified need stakeholders, including but not limited to the timber to “Create a sustainable supply of timber and other forest products that industry, of East Lewis County? It is my hope that with will help maintain the stability of local and regional economies (NWFP sound decision making, this road project will bring more FEIS, p.S-4),” see the EA page 9. The economic context of Lewis jobs and opportunities for the residents and businesses County as well as analysis of the costs and benefits of the vegetation of the area impacted. management and associated road work are disclosed in the EA on pages 203-209.

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