OREGON DUNES RESTORATION PROJECT

FINAL ENVIRONMENTAL ASSESSMENT

SIUSLAW NATIONAL FOREST Central Coast Ranger District and Oregon Dunes National Recreation Area

United States Forest Service January 2020 Oregon Dunes Restoration Project — Final Environmental Assessment  For More Information Contact: Chuck Fisher Siuslaw National Forest, Central Coast – Oregon Dunes N.R.A Physical Address: 1130 Forestry Way Mailing Address: P.O. Box 400 Waldport, OR 97394 Phone: 541-563-8406 Email: [email protected] Fax: 541-563-8449 The U.S. Department of Agriculture (USDA) prohibits discrimination in all its programs and activities on the basis of race, color, national origin, age, disability, and where applicable, sex, marital status, familial status, parental status, religion, sexual orientation, genetic information, political beliefs, reprisal, or because all or part of an individual's income is derived from any public assistance program. (Not all prohibited bases apply to all programs.) Persons with disabilities who require alternative means for communication of program information (Braille, large print, audiotape, etc.) should contact USDA's TARGET Center at (202) 720-2600 (voice and TDD). To file a complaint of discrimination, write to USDA, Director, Office of Civil Rights, 1400 Independence Avenue, SW, Washington, D.C. 20250-9410, or call (800) 795-3272 (voice) or (202) 720-6382 (TDD). USDA is an equal opportunity provider and employer. CONTENTS CHAPTER 1 PURPOSE AND NEED ...... 3 INTRODUCTION ...... 3 NEED AND GOALS FOR THE PROPOSAL ...... 3 PROPOSED PROJECT LOCATION ...... 4 HISTORY OF PROJECT LOCATION ...... 5 CHAPTER 2 PROPOSED ACTION AND ALTERNATIVES ...... 17 ALTERNATIVES CONSIDERED BUT ELIMINATED FROM DETAILED STUDY...... 17 ALTERNATIVES CONSIDERED IN DETAIL ...... 17 DEFINITIONS OF MARTEN HABITAT COMPONENTS ...... 19 PROJECT DESIGN CRITERIA ...... 25 PROPOSED TREATMENTS TYPES ...... 32 CHAPTER 3 ENVIRONMENTAL CONSEQUENCES ...... 34 WILDLIFE SPECIES ...... 34 BOTANICAL RESOURCES...... 62 FIRE AND FUELS ...... 70 CULTURAL RESOURCES ...... 72 HYDROLOGIC RESOURCES ...... 73 SOIL RESOURCES ...... 77 FISHERIES RESOURCES...... 78 RECREATION ...... 81 AQUATIC CONSERVATION STRATEGY OBJECTIVES CONSISTENCY ASSESSMENT ...... 82 ADDITIONAL DISCLOSURES ...... 87 CHAPTER 4 CONSULTATION WITH OTHERS ...... 89 GOVERNMENTS ...... 89 ORGANIZATIONS AND MEMBERS OF THE PUBLIC ...... 89

2 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Chapter 1 Purpose and Need Introduction The Oregon Dunes Restoration Project (The Project) is intended to improve and restore ecological processes, native species and their habitats, and recreational conditions in The Project area, as directed by the Dunes Management Plan (1994) and described in the Oregon Dunes Restoration Strategy (2018). Need and Goals for the Proposal The Oregon Dunes Restoration Strategy (2018) described the current dunes landscape as substantially altered from its condition prior to Euro-American settlement in terms of vegetation types and structure and ecological processes that shape the dunes. The strategy also described the need to restore the dunes by addressing the spread of non-native invasive species that have altered the ecosystem, hydrologic conditions, and recreational opportunities.

The goals and objectives expressed in the Strategy were to:

• Goal #1: Preserve the Best: Identify, manage, and protect existing areas known to be in a healthy natural condition. These could constitute areas of functioning open sand, viable plant communities, resilient wildlife habitat, or areas of high human value. • Goal #2: Restore Site Specific Conditions and Processes: Identify and manage areas to provide functioning natural local conditions. Restoring site conditions, such as a specific dune formation or beach habitat for snowy plover in a given area, would restore small-scale settings. • Goal #3: Restore Landscape Scale Natural Processes: Identify and manage landscapes to restore large-scale natural processes and pattern. Restoration of natural processes such as sand deposition and movement, and resulting patterns of open sand, dune formations, native dune and wetland plant communities, and tree islands, would require actions across large landscapes.

The overall purpose of this Project is to restore or maintain important dune habitats, and maintain and expand recreational areas. Therefore, the need is to:

• Promote the development of a sustainable vegetative structure, composition, and pattern to allow for natural processes to function and provide resilience against invasive species and their contribution to uncharacteristic succession in the long term; • Provide for the maintenance and improvement of habitat for listed threatened or endangered species and other at-risk species; • Maintain and restore recreation settings and opportunities to meet the objectives established for the Oregon Dunes National Recreation Area and public expectations for developed facilities and dispersed recreation opportunities in the Oregon Dunes area; • Improve hydrologic function, and stream and estuary habitat conditions.

To achieve the Purpose and Need, The Project proposed multiple types of restoration activities: • Remove European beachgrass and other non-native invasive plants from foredunes by using mechanical, manual, herbicide, and prescribed fire (pile or broadcast burning) treatments. Mechanical treatments would occur by bulldozer or other large pieces of like-equipment. o This would improve and/or increase Western snowy plover habitat through vegetation manipulation and physical sheltering (sand displacement).

3 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

• Maintain habitat for marten (See the Definitions of Marten Habitat Components section on page 19) — areas of predominately ericaceous shrubs (rhododendron, salal, huckleberry, and blue berries) in deflation plains, forest margins and forested areas. Maintain vegetation in connectivity corridors. Mechanical treatments would occur in open sand areas that allow motorized vehicles as well as units 1.5 and 2.2. (See Table 1 on page 18.) • Remove invasives plants and maintain native plant populations in open sand areas that are not serving as marten corridors by using one or more of the following treatment types: mechanical, manual, herbicides, and prescribed fire. • Increase sand movement and open sand areas for ecological and recreation purposes. Do so by removing current vegetation (including non-native plants and both native and non-native shrubs outside the deflation plain), which inhibits wind from moving sand near foredune areas and in open sand areas, with the exception of long established tree islands or within potential connectivity corridors for Pacific marten. • Provide increased interpretive opportunities for recreationists at entry points to treatment areas. • Where snowy plover nests occur, continue management activities, including nest protections through symbolic fencing, predator control and monitoring as funding allows.

Vegetated areas are increasing on the dunes, changing from open areas to vegetated areas at a rate ranging from 9-11 acres/year. “Treed” lifeform areas have increased at a rate of 7-8 acres /year. Succession has replaced sand deposition and movement as the dominant process operating on the dunes. If this continues at the same rate, open sparsely vegetated areas in Baker Beach could be gone in 10-20 years, and gone from the Overlook area in 20-30 years. Once an area moves into higher lifeforms, different treatments would need to be considered to restore dunes conditions. As succession changes from lower life forms to higher life forms (open sandherbsshrubstrees) the energy and cost associated with reversing the succession and re-introducing natural ecological processes increases.

These actions are proposed for implementation on the Central Coast Ranger District — Oregon Dunes National Recreation Area (CCRD-ODNRA) of the Siuslaw National Forest (Siuslaw). Congress designated the Oregon Dunes as a National Recreation Area (ODNRA) in 1972, and prescribed that it be managed for “…public outdoor recreation use and enjoyment,” and for “the conservation of scenic, scientific, historic, and other values contributing to public enjoyment.” The ODNRA is comprised of approximately 32,190 acres of forested areas, water, and open sand areas from between north of Florence to North Bend on the Oregon coast. This area of diverse and constantly changing landscapes is host to a wide array of outdoor recreational uses.

Under the No Action Alternative, the invasive plant species treatments not already authorized would not be implemented.

This environmental assessment (EA) was prepared to determine whether implementation of manual, mechanical, and herbicide treatments, application of prescribed fire, and providing for rare species habitat maintenance and improvement may significantly affect the quality of the human environment and thereby require the preparation of an environmental impact statement. By preparing this EA, the Forest Service is fulfilling agency policy and direction to comply with the National Environmental Policy Act (NEPA). For more details of the proposed action, see the Proposed Action and Alternatives section of this document (Chapter 2). Proposed Project Location The Project area is located within all areas of the Oregon Dunes National Recreation Area (Management Area-10, Siuslaw Forest Plan 1990) and an area just north of it in the Sutton Recreation Area (Management Area-9, Siuslaw Forest Plan 1990) called Baker Beach (Figure 1). The Project area runs about 40 miles from this north end to Coos Bay on the south end.

4 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Figure 1. Vicinity map History of Project Location The Oregon Dunes is a unique and dynamic ecosystem. It is imperative that the reader understand the distinctive features and unusual ecological processes involved in the formation of those features. The “Biophysical History of the Dunes” explains dunes formation and a “Cultural History of the Dunes” explains the human influence on this ecosystem. This would progress to present time and current condition, which can then be analyzed into the future with a No Action Alternative (i.e. not implementing the Proposed Action) and then analyzing the effects of implementing the Proposed Action.

5 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Figure 2. Dune Ecosystem Features (Adapted from Restoring Oregon’s Dunes, The bid to Save a National Treasure, Oregon Dues Restoration Collaborative 2018; https://www.saveoregondunes.org/wp-content/uploads/2018/02/Dunes-Restoration-Strategy.pdf; last accessed 01/13/2020).

6 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Figure 3. Schematic of Oregon Dunes Recreation Area Current and Historic Conditions (Mercer/Berry Watershed Analysis. p. 103, Fig. 43, Andrus et al., 1996).

7 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Biophysical History of the Dunes The history of the dunes goes back millions of years, and is driven by the relationship among the physical components and processes of climate (including wind), landforms, erosion and water; and the biotic components of vegetation and animals. These relationships have created the unique dunes ecosystem.

Twelve million years ago the ocean floor uplifted to create the Coast Range and Cascade mountains that dominate our current local landscape. Episodes of extreme events--earthquakes, floods, and storms hastened the erosion of these landforms. Rivers transported gravel, sand and other sediments downstream from the mountains to the ocean. Near-shore ocean currents moved sands north along the shoreline to a shallow basin west of Florence, Oregon. Most of the sand supply for this area has come from the Umpqua River. A long, flat sedimentary shelf, called the Coos Bay Dune Sheet developed along the central Oregon coastline, bordered by headlands of Heceta Head and Cape Arago — a 56-mile stretch. Sand reaching this terrace would blow inland up to 2.5 miles with strong winds creating sand dunes. Sea level changes have been responsible for several waves of dune formation, with the youngest dunes closest to the oceans (Cooper 1958, Peterson 2007). Older, inland systems are thought to be 20,000-100,000 years old or older (Peterson 2007).

Sand, wind and water worked with climate to create and move sand along the Coos Bay Dune Sheet. Seasonal winds moved sand in different directions throughout the dunes. Summer winds blowing dry sand from the north and northwest at a steady rate created sand formations, such as transverse dunes, that got partially destroyed by the south to southwesterly winter winds that blew up to 100 mph during storms (Cooper 1958).

The dunes ecosystem contained an array of formations, constantly changing in space and time. Figure 2 and Figure 3 show examples of a cross-section of what might be seen moving from the ocean inland. The beach is the first feature apparent, which varied in width and condition, littered by driftwood and other biotic debris in some areas, providing perfect habitat for shorebirds. Driftwood, moving up at high tide, or in peak sea level rise periods lodged above the wrack line. This created a barrier to sand movement and sand built up behind the blockage, creating discontinuous hummocks called foredunes that paralleled the coastline. These formations could last a few years, with scattered American dunegrass or pink and yellow sand verbenas providing minimal sand anchorage; or get blown out or buried by the next storm cycle.

Winds moving eastward hit the foredune hummocks, got displaced, and created an eddy on the lee side, scouring out sand down to the water table. These wet features are called deflation plains. Wet plant communities consisting of reeds and sedges, and Hooker willow may have developed in these wet areas, only to be buried and recreated somewhere else.

Several dune formations may have formed within the broad expanse of open sand found inland of the deflation plain. Transverse dunes, oblique dunes and parabola dunes could be found depending on the sand supply, wind patterns, and vegetation distribution. Patches of older forest, called tree islands were found interspersed amongst the open sand and dunes. These features are relics of past climate and processes, when forest may have covered this landscape, only to be inundated by sand, wind and water.

These open sand patches were not devoid of vegetation. Seashore bluegrass communities evolved with shifting sand, with red fescue moving in less disturbed sand areas. Hummocks with American dunegrass, seashore lupine, and potentially without frequent disturbance kinnikinick, and shore pine could be found sporadically. Moving further east you would eventually find yourself at the forest edge, a wavy green line, littered with snags in places, where sand is gaining a foothold eastward. This line was constantly shifting with the shifting and dynamic dunes processes (Wilde 1982, Wiedemann and Pickart 1996, Wiedemann 1998, Christy et al. 1998, Oregon Dunes Restoration Collaborative 2018).

8 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Cultural History of the Dunes People have had a relationship with the dunes for millennia. The early people on the dunes were the ancestors of the Siuslaw, Lower Umpqua (Kuitch or Quu'iich), and Coos tribes, who continue to live in the area despite the dramatic changes to their physical and cultural landscape. Tribal people were drawn to this dynamic landscape which provided their ancestors with a wealth of plant resources for food, medicine, and basketry, as well as game like deer and elk. Although tribal people occupied and used resources in the dunes, their resource management was based on generations of knowledge and in concert with the natural processes at work on the dunes.

Contact with European and Euro-American explorers and trappers starting in the late 1700s exposed tribal people to diseases that devastated tribal populations with estimates of up to 90 percent population loss. (Tonsfeldt 2010, Oregon Dunes Collaborative 2018). The remaining Lower Umpqua and Coos people were forced to move to the Coast Reservation (also known as the Siletz Coast Reservation) starting in 1856, which initially included a portion of the dunes from the Siltcoos outlet northward, while the Siuslaw’s traditional territory was included in the reservation. In 1876 the Alsea Sub-agency, which included the southern portion of the Coast Reservation, was closed and opened to non-Indian homesteading and settlement. The Lower Umpqua and Coos either went north to the remaining portion of the Siletz Reservation, joined the Siuslaw on the North Fork of the Siuslaw River, or moved back to their homelands to find the land taken by settlers.

Euro-American settlers filed homesteads within the dunes prior to the formation of the Siuslaw National Forest in 1908, but few remained on their claims, which held true after the Forest was created. Recreation in the area was focused on the large lakes east of the dunes up until the 1930s, as the dunes were not initially viewed as having much recreational potential by the Forest Service. In general human use during the late 19th-early 20th century remained rather limited and the natural process that had been at work for thousands of years continued largely unchanged.

The ever-shifting dunes proved to be a huge challenge to homesteaders and the Forest Service as sand covered settlers’ land, roads, and even lakes. (Tonsfeldt 2010; Oregon Dunes Collaborative 2018). A Forest Service silviculturist touring the dunes in 1910 stated “Of the region examined, 4% (by estimate) is covered with forest trees, another 4% has a partial herbaceous cover, and the remaining is devoid of all vegetation and the sand drifts across it without let or hindrance...the public is looking to the government to do what it can to prevent the destruction of private property by unregulated drifting of the sand…The drifting of the sand could certainly be stopped…by planting grass and forming a barrier dune, and in the lea of the barrier dune establishing a forest artificially” (USFS 1910). Consequently, the Forest Service, along with private businesses, started a dunes stabilization program in the early 1900s to protect homes, roads, rail lines, agricultural fields and buildings (see Figure 4). The Forest was also interested in trying to stabilize the dunes enough to create additional land to grow trees.

European beachgrass had successfully stabilized dunes in Europe, North Africa and California. Aggressive planting throughout the dunes began in the early 1900s. Willows, then Scot’s broom and gorse, were also planted to create a favorable seed bed for tree growth. Shore pine and Monterey pine plantations were then grown in select areas in the dunes. Some of these remnants still exist today.

European beachgrass and Scot’s broom spread well beyond the initial plantings, displacing native species and altering the processes and patterns along the dunes. The 1967 Oregon Dunes Recreation Area plan states 900 acres had been planted to beach grass, Scot’s broom, and shore pine. Another 800 acres were planted with barley, fescue and clover on the flat sand and wetter areas to improve hunting. Planting continued into the 1970s on federal land. It is continuing today on private land (Oregon Dunes National Recreation Area Plan 1977, Tonsfeldt 2010, Oregon Dunes Collaborative 2018).

9 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Figure 4. Early planting of non-natives for sand stabilization

People started to flock to the dunes for a wide variety of recreational opportunities, as automobile roads improved through the 1930s and the Civilian Conservation Corps constructed campgrounds in the dunes providing more opportunities for public recreational use. Recreational use continued to increase through the post-WWII era with additional campground and recreation opportunities developed. Also after World War II homemade “dune buggies” became commonplace on the dunes as a popular new recreational use of the dunes.

The Oregon Dunes National Recreation Area was designated by Congress in 1972 to both conserve the unique dunes ecosystem and provide public enjoyment through an array of recreational opportunities. The 32,186-acre area contains areas to experience off-highway vehicle (OHV) riding, canoeing, fishing, boating, hiking, horseback riding, and just enjoying the views. (Cloyd 2018)

The biophysical environments of the dunes have changed tremendously due to dunes stabilization, moving from a dynamic to a static system. The dominant processes and components of sand, water and wind have given way to vegetation succession from bare sand or water to herbs, shrubs, and forest. Beaches are dwarfed by a continuous wall of foredune, dominated by European beachgrass, rising up to 25-35 feet tall and over 300 feet wide that runs parallel to the shoreline (Christy et al. 1998). This permanent feature blocks sand and wind from moving inland. Behind the foredune, deflation plains have expanded to form a constant strip, sometimes reaching over a half mile wide. They are also found scattered among inland dunes. Some wet areas remain and support sedge and rush communities. Drier sites are invaded by European beachgrass, which in turn creates habitat for evergreen huckleberry, salal, shore pine and Sitka spruce. Inland dunes, such as transverse dunes, oblique dunes and parabola dunes are still found in select areas within the dunes. Tree islands dot the landscape. Interior sand has a complex pattern of emerging vegetation, with hummocks, strips, and bands of emerging vegetation undergoing succession and slowly shifting the ratio of sand to vegetated landscape (Pinto 1972, Wilde 1982, Christy et al. 1998).

Collaboration This effort continues the planning and implementation that began with the ODNRA Management Area 10(C) Designated Routes Project, which was completed in 2015 (USDA-FS 2015). The Central Coast Ranger District/Oregon Dunes National Recreation Area (CCRD/ODNRA) continued collaboration with interested parties. Concerned and interested parties created a working group focused on continuing restoration work in the ODNRA. This group, the Oregon Dunes Restoration Collaborative (ODRC), worked with the Forest Service to develop three guiding principles, or goals, for future restoration activities: Restore Landscape Processes, Restore Site Specific Conditions, and Preserve the Best. They identified areas across the landscape of the Dunes in which treatments addressing these principles could be met. They then further identified which areas are priorities for restoration using criteria such as ease of access and treatment, previous restoration activities, presence of rare vegetation types, and more. This 10 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA process and the resulting restoration priority map are documented in the Oregon Dunes Restoration Strategy (2018).

A Forest Service Interdisciplinary Team (IDT) was established to propose and analyze actions on the ground to address the restoration needs described above. Beginning with the priority map developed by the ODRC and following multiple public field trips and meetings, a revised map of proposed treatment areas was developed as the basis for this Project. This was incorporated into the scoping letter and a proposed action identified by the Responsible Official, Michele Jones, in December 2017. Collaboration continues with the ODRC and may include future partnerships in implementation and multiparty monitoring.

Consultation The Forest Service consulted with the following individuals, Federal, State, tribal and local agencies during the development of this EA.

National Marine Fisheries Service For consultation with the National Marine Fisheries Service, the vast majority of activities proposed for the Dunes Restoration Project are described in the Endangered Species Act – Section 7 Programmatic Consultation Conference and Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Response for Reinitiation of Aquatic Restoration Activities in the States of Oregon and Washington (ARBO II). Proposed activities were analyzed under the programmatic consultation and are in compliance with ARBO II.

Proposed activities that are not described in ARBO II, such as posting signage to increase recreation opportunity, would have no effect on ESA-listed aquatic species, their designated critical habitat, or essential fish habitat. These activities do not include ground disturbance adjacent to any fisheries designated critical habitat within the Project area. Since the aforementioned activities were determined to have no effect on ESA-listed aquatic species, there is no need for consultation with National Marine Fisheries Service regarding these actions.

Given the circumstances listed above, project-level consultation with National Marine Fisheries Service is not required for this Project. All activities with the potential to affect Oregon Coast coho salmon or their habitat were programmatically consulted upon within ARBO II.US Fish and Wildlife Service

US Fish and Wildlife Service The Endangered Species Act mandates that Federal agencies proposing an action that “may affect” Federally listed species “consult” with the U.S. Fish and Wildlife Service regarding the effects of the action. Section 7(a)(2) of the Endangered Species Act states that it is the Federal agency’s responsibility, with the assistance of the U.S. Fish and Wildlife Service, to ensure that the action is not likely to jeopardize the continued existence of the species. If an action is not likely to jeopardize the species but is anticipated to result in incidental “take” of individuals, the Federal agency may receive from the U.S. Fish and Wildlife Service a written statement that provides an exemption from the takings prohibition of section 9 of the Endangered Species Act. Impacts to Federally Listed wildlife species were analyzed for the Oregon Dunes Restoration Project and submitted to the US Fish and Wildlife Service (USDA/USDI 2014, 2015).

The Forest Services has been involved in informal discussions and information sharing with the US Fish and Wildlife Service (FWS) regarding Western snowy plover (WSP) recovery efforts, Pacific marten emerging science, and field observations. The Siuslaw National Forest has played a positive role in the recovery of the Western snowy plover. It is anticipates that removal of the foredune would have mid- and long-term beneficial effect to WSP habitat and the local population. The Pacific marten is being considered for listing under the federal Endangered Species Act. FWS proposed to list the coastal distinct population segment (DPS) of Pacific marten (Martes caurina) in the Federal Register as a threatened species under ESA on 10/9/2018. The original proposed action has been modified to address the habitat and dispersal requirements of the marten while incorporating some action to address the overarching landscape restoration goals. Regardless of whether the species is listed or not, The Project would

11 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment adaptively manage the marten habitat as new information is gathered to help address the species and habitat needs.

The Biological Assessment and Biological Evaluation are being completed in concert with the FWS. It is anticipated that a Biological Opinion and Conference opinion would be received prior to the signing of the Decision Notice for the Final EA.

Oregon State Historic Preservation Office In accordance with responsibilities under Section 106 of the National Historic Preservation Act (NHPA) and 36 CFR 800 consultation with the Oregon State Historic Preservation Officer (SHPO) and federally recognized Tribes (Confederated Tribes of the Coos, Lower Umpqua, and Siuslaw Indians; Confederated Tribes of the Siletz Indians; Confederated Tribes of the Grand Ronde) was conducted.

The scale of The Project and the phased manner of many of the activities necessitated the “phased” identification and evaluation for historic properties in The Project area as allowed under 36 CFR 800.4 (b) (2). Consequently, the Programmatic Agreement between United States Department of Agriculture, Forest Service, Siuslaw National Forest, and the Oregon State Historic Preservation Office, Regarding the Oregon Dunes Restoration Project - Lane, Douglas, and Coos Counties Oregon (PA) was developed and formalized on December 16, 2018. This PA also incorporates the Programmatic Agreement among the United States Department of Agriculture Forest Service Pacific Northwest Region (Region 6), The Advisory Council on Historic Preservation, and the Oregon State Historical Preservation Officer Regarding Cultural Resources Management, which was formalized on June 4, 2014.

The programmatic agreement (PA) requires that initiation of work in any phase of The Project be contingent upon completion of the identification and protection of historic properties and compliance with applicable provisions of NHPA in accordance with this agreement. In summary, each implementation project must first have a historic properties survey occur, identified historic properties evaluated for National Register of Historic Places (NRHP) eligibility (36 CFR 60.4), and a determination of effect on historic properties for that implementation project documented in a report to be reviewed by SHPO and federally recognized Tribes. Protection measures in Appendix B of the PA are to be applied to ensure that effects to historic properties are avoided or minimized.

Public Involvement

Scoping On December 26, 2017, the CCRD/ODNRA began a 30-day NEPA public scoping process for the Oregon Dunes Restoration Project (hereafter noted as the “Dunes Project”), in a letter to approximately 300 individuals and organizations. The scoping process is an opportunity for members of the public to provide early input on a proposed action, which helps the IDT refine and analyze the project proposal. A legal advertising notice was also printed in the paper of record, the Eugene Register-Guard, on December 26, 2017. The Forest Service received forty-two written comments regarding the proposed action. Most were supportive and none generated issues that required modification of the proposed action.

The Confederated Tribes of the Coos, Lower Umpqua and Siuslaw Indians (CTCLUSI), Confederated Tribes of the Grand Ronde (CTGR) and the Confederated Tribes of the Siletz Indians (CTSI) were notified of the scoping process by correspondence on December 14, 2017, And early notification of the Project were discussed in annual forest program of work meetings with Tribes.

The Project received approximately 42 scoping comments; none of which resulted in modification of the proposed action as scoped.

12 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA 30-Day Comment Period A 30-day comment period for the Draft EA began on May 9, 2019. Between the scoping period and release of the Draft EA, information regarding the Pacific marten population on the dunes emerged and was determined by the IDT and District Ranger to warrant a modification to the proposed action as originally described during the scoping period. The modified proposed action (Alternative 2) from the Draft EA constitutes Alternative 2 in this document. Because the end of the 30-day comment period ended on Saturday, June 8, 2019, comments were accepted through Monday, June 10, 2019. Approximately 150 comments were received from about 30 commenters. Responses to 30-day comments are located in the project file in Waldport, Oregon. These comments have been considered and have been used to develop a third alternative, Alternative 3 (the proposed action) in this document. In addition, 30-day comments requested the addition of other areas to treat invasive plant species. In developing Alternative 3, the proposed units were reviewed and more accurately assessed, delineated, and mapped (See Alternative 3 Proposed Action on page 18 below.)

Issues Issues are points of concern about environmental effects that may occur as a result of implementing the proposed action. Issues identified during the scoping period or following release of the Draft EA can either be addressed by developing alternatives to the proposed action or by adjusting the proposed action to resolve any conflicts [36 CFR 220.7 (b)(2)(i)]. Many issues and concerns that were raised have been addressed as part of the project design criteria (See Project Design Criteria starting on page 25), were outside the scope of the Project and thus did not need to be addressed, or are already been decided by law or regulation. The issues listed below are those that were determined to be relevant and requiring a response. Documentation of all comments received during scoping is located in the Project file.

Please note the following, which are referenced in the discussion of issues below: -Alternative 2 refers to what was called the Modified Proposed Action in the Draft EA; it is now identified as Alternative 2 in this document.

-Alternative 3 refers to a new alternative that was developed following release of the Draft EA in response to comments; it is a modified version of Alternative 2.

More information on each alternative that was considered and analyzed is found in the Alternatives Considered in Detail section starting on page 17.

Key Issue A: Loss of Coastal Distinct Population Segment of the Pacific Marten Habitat Within the Sutton Recreation Area, the Alternative 2 proposes to restore the landscape process of sand movement by connecting the ocean beach (unit 1.6) with inland sand dunes (unit 1.3). This objective would be accomplished by removing nearly all vegetation within unit 1.5 (~55 ac.) including approximately 30 acres of shore pine forest shown on Map A (Appendix A). Much of the forest within the Sutton Recreation Area, including the forest in unit 1.5, is composed of a shore pine/Sitka spruce overstory with ericaceous shrub understory and is considered suitable marten habitat.

During the 30-day comment period, comments were received asking the Forest Service to avoid negative impacts to the Pacific marten home range habitat, corridors, scattered edge habitat, buffer edge habitat, and open dispersal habitat. Members of the public and the FWS expressed concern that removing approximately 30 acres of vegetation in Unit 1.5 of the Baker Beach area (Table 1, Treatment #6) has the potential to affect the marten negatively by removing vegetative habitat of a female home range (see Figure 5 on page 15). The analysis indicates that removal of this 30 acres would impact the corridor that allows for movement between habitats. This would impact the habitat to the point that a female home range would be lost, which would not protect the viability of the marten and would continue to trend the species towards listing on the Endangered Species Act.

13 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Response: The Pacific marten is being considered for listing under the federal Endangered Species Act. FWS proposed to list the coastal distinct population segment (DPS) of Pacific marten (Martes caurina) in the Federal Register as a threatened species under ESA on 10/9/2018. Removal of approximately 30 acres of forest would cause an 11 percent reduction in this female home range as well as potentially disconnect the habitat at the northern extreme from about 45 more acres of suitable home range habitat. Forest within unit 1.5 that is proposed for removal provides a connection between the deflation plain forest and mature shore pine forest growing to the northeast of unit 1.5. Loss of this forested patch would create an unvegetated gap in the forest approximately 0.25 miles wide. Martens traversing this gap would be at increased risk of predation due to the lack of protective vegetative cover. Loss of this forest may force marten to increase energy expenditures when foraging, which may have a negative effect on fitness. Loss of 30 – 75 acres, or 11- 27 – 27 percent, of forest in that home range would further limit availability to foraging habitat, which could negatively affect fitness of juveniles and adults. Reductions of as little as 25 – 30 percent of the forested cover can cause marten declines (Hargis et al. 1999; Potvin et al. 2000). Such a reduction of habitat within the home range may render it non-viable for marten. A reduction in the number of available home ranges is expected to result in a population decline.

The existing marten population on the central Oregon coast is vulnerable to extirpation due to its small size (an estimated 71 adults) and its apparent isolation from other populations. A recently published population viability analysis (Linnell, M.A., Moriarty K., Green D.S., Levi, T. 2018) determined that the extinction risk for either of the two ODNRA subpopulations strongly increases with even a small amount (2-3) of annual human-caused mortalities. Any increase in human-caused mortality is expected to negatively impact the population. Fragmentation and loss of habitat within this marten home range could cause the loss of individual marten and therefore would likely to contribute to a trend towards federal listing or cause a loss of viability to the population or species. This alternative would protect the viability of the population and would not further the species towards listing on the Endangered Species Act.

An alternative to the Proposed Action (Alternative 3) was developed to address concerns of potential effects to connectivity and vegetative cover for species’ concerns particularly Pacific marten. Alternative 3 differs from Alternative 2 in that it does not propose removal of about 30 acres of vegetation that currently serves as Pacific marten habitat.

Key Issue B: Loss of Open Sand and Landscape-scale Sand Movement Processes During the 30-day comment period, comments were received asking the Forest Service address the loss of open sand areas and allow natural landscape-scale sand movement processes in the Oregon Dunes National Recreation Area. Comments noted that invasive and native plant species have noticeably been encroaching on the dune system, reducing open sand areas by trapping sand, limiting the ability of sand to mobilize under wind conditions.

Response: Open sand areas are decreasing while vegetation encroachment is increasing in the Project area. Analysis based on historical aerial photographs of the Baker Beach and Overlook areas suggest that vegetated areas are increasing on the dunes, with change away from open areas ranging from 9-11 acres/year. Treed lifeform areas have increased at a rate ranging from 7-8 acres per year. As noted in the Response to Key Issue A above, the Pacific marten is being considered for listing under the federal Endangered Species Act. FWS proposed to list the coastal distinct population segment (DPS) of Pacific marten (Martes caurina) in the Federal Register as a threatened species under ESA on 10/9/2018. The proposed action has been modified to address the habitat and dispersal requirements of the marten while incorporating some action to address the overarching landscape restoration goals. Regardless of whether the species is listed under ESA or not, The Project would adaptively manage the marten habitat as new information is gathered to help address the species and habitat needs.

The Forest Service must balance the needs of all species both sand obligate and forest, etc. to ensure that it does not implement actions that would further trend a species towards federal listing.

14 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Other Issues Other issues were identified as non-key issues because they are addressed by one or more of the following four categories:

1. Outside the scope of the proposed Project; 2. Already decided by law, regulation, Forest Plan, or other high-level decision; 3. Adequately addressed in all alternatives; or 4. Conjectural and not supported by scientific or factual evidence.

Figure 5. Example of Theoretical Female Marten Home Range in The Project area. Long, linear lines generally oriented east-west divide the home ranges. Within in the home range, habitat is delineated from non-habitat. See Appendix A: Project Maps for more detailed maps.

15 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Figure 6. Map A from Appendix A showing the overall project and location of units.

16 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Chapter 2 Proposed Action and Alternatives Alternatives Considered but Eliminated from Detailed Study In early 2017, the Interdisciplinary Team (IDT) assessed the probability of successfully treating potential high- priority areas prioritized to achieve goal #3. The team considered access, ease of treatment, scalability, potential conflicts (recreation, Western snowy plover, Pacific marten) achieving goals, etc. This action alternative was designed to achieve all three goals — goal #1: “Preserve the Best”, goal #2: “Restore Site Specific Conditions and Processes”, and goal #3: “Restore Landscape Scale Natural Processes” – with an emphasis on goal #3. It was developed with the Oregon Dunes Restoration Collaborative and included about seven large units (Baker Beach area, Silcoos Beach area and north, Oregon Dunes Day Use area and south, 2 sites north of the Umpqua dunes area, Spinreel OHV Staging area and north, and west and north of Horsfall Campground) that would have been treated to achieve goal #3. Concerns identified by members of the IDT over the action alternative included risks to cultural resources, access and logistics, conflicts with recreation and Western snowy plover, treatment in Pacific marten habitat. Due to these concerns, this action alternative was pared down in scope and scale and designed to achieve goal #3: Restore Landscape Scale Natural Processes, but to a lesser extent — approximately five units were proposed for treatment to achieve goal #3. However, similar concerns were again expressed over this action alternative by members of the IDT. After review of the science and data, the decision-maker determined that neither alternative was viable. Thus, these proposed actions were no longer considered and were eliminated from further detailed study. Alternatives Considered in Detail

The No Action Alternative provides baseline information as a comparison for understanding changes associated with the action alternatives (Alternatives 2 and 3) if implemented. It also provides any expected environmental responses as the result of cumulative past actions without future treatments.

Maps of the proposed Project units can be found in Appendix A.

Alternative 1 (No Action Alternative) The No Action alternative provides baseline information as a comparison for understanding changes associated with the Action Alternatives if implemented. It also provides any expected environmental responses as the result of cumulative past actions without future treatments.

Alternative 2 The Modified Proposed Action as described in the Draft EA is now identified as Alternative 2 in this document. Alternative 2. The action Alternative that was considered but eliminated from detailed study was again modified in scale and scope due to access, logistical, and resource concerns to create a Modified Proposed Action by the IDT. This Modified Proposed Action (Alternative 2) was developed in response to internal analyses and comments from the public during the Scoping Period regarding concerns about potential effects on habitat connectivity and vegetative cover for species of concern, particularly Western snowy plover and Pacific marten. Alternative 2 modified the original proposal to address these concerns by scaling back treatments that were proposed to achieve restoration strategy Goal #3 – Restore Landscape-scale Natural Processes. Rather than proposing to treat all 6,500 acres in five units from the original proposal, Alternative 2 proposes to treat 54.9 acres of unit 1.5 in the Baker Beach area to achieve Goal #3 while limiting impacts on Pacific marten. Alternative 2 of the Project identified approximately 13,864 acres for potential treatment, divided into units that do not make up the entire project area. The units were delineated into areas determined to be non-habitat open sand,

17 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Pacific marten habitat, or dispersal corridors. This resulted in about 11,355 acres as non-habitat (open sand), about 2,148 acres as Pacific marten habitat, and about 360 acres corridors (Map A, Appendix A). Under Alternative 2, we would treat 11,355 acres to create or maintain open sand and dunes-adapted native plant communities across the Oregon Dunes National Recreation Area and the adjacent Baker Beach area. Treatment of vegetation in the foredune areas is proposed, as the foredune vegetation is primarily low-growing, non-woody species, generally European beachgrass. This alternative would prioritize restoration strategy Goal #1 — Preserve the Best, and Goal #2 — Restore Site Specific Conditions and Processes, and provide limited emphasis to Goal #3 — Restore Landscape Scale Natural Processes. Treatments proposed under Alternative 2 are shown in Table 1.

Alternative 3 As noted in the Issues section on page 13 above, concerns raised during the 30-day comment period regarding impacts to Pacific marten and their habitat is considered a key issue. Information received during the 30-day comment period indicated that members of the public and the FWS expressed concern that removing approximately 30 acres of vegetation in Unit 1.5 of the Baker Beach area (Treatment #6) has the potential to affect the Marten negatively by removing suitable habitat of a female home range. As such, Alternative 3 was developed and fully analyzed in addition to the no action alternative (Alternative 1) and Alternative 2.

The Project has identified approximately 13,836 acres under Alternative 3 as potential treatment areas divided into units that do not make up the entire Project area. The units were delineated into areas determined to be non- habitat open sand, Pacific marten habitat, or dispersal corridors. This resulted in about 11,355 acres as non-habitat (open sand), about 2,121 acres as Pacific marten habitat, and about 360 acres corridors (see Map A, Appendix A).

Alternative 3 would treat 11,355 acres for open sand and dunes adapted native plants across the Oregon Dunes National Recreation Area and the adjacent Baker Beach area. Treatment of vegetation in the foredune areas is proposed, as the foredune vegetation is primarily low-growing, non-woody species, generally European beachgrass. Alternative 3 has the same purpose and need as Alternative 2, but does not address goal #3 — Restore Landscape Scale Natural Processes. Treatment of vegetation in the foredune areas would continue as in the original proposed action, as the foredune vegetation is primarily low-growing, non-woody species, generally European beachgrass.

The coastal Oregon population of marten is one of only four remaining populations of Humboldt marten. Forest Service Policy requires that all actions be taken to "assure that management activities do not jeopardize the continued existence of sensitive species or result in an adverse modification of their essential habitat" (Final ESA Section 7 Consultation Handbook, March 1998). The Forest Service must balance the needs of all species both sand obligate and forest, etc. to ensure that it does not implement actions that would further trend a species towards federal listing. Due to this concern, Alternative 3 would not remove the roughly 30 acres of vegetation from Unit 1.5 (Map A, Appendix A) that is proposed for removal under Alternative 2. Proposed treatments under Alternative 3 would be the same as proposed treatments listed for Alternative 2 in with the exception of Treatment # 6.

Table 1. Proposed treatments for Alternative 2 and Alternative 3.

# Treatment Alternative Remove European beachgrass and other non-native invasive plants from foredunes by using manual and herbicide treatments in all foredune units and mechanical and prescribed fire treatments (pile or broadcast burning) in units 1.6, 2.1, 10, 15, 16, 20, 32, and 40. Mechanical treatments would occur by 1 bulldozer or other large pieces of like-equipment. 2 and 3

This would improve and/or increase western snowy plover habitat through vegetation manipulation and physical sheltering (sand displacement). Maintain habitat for marten (areas of predominately ericaceous shrubs ≥ 40 % cover at 1-meter height) in deflation plains, forest margins, and forested areas. Maintain vegetation in connectivity 2 corridors, generally >5% woody vegetation cover in patches < 100 feet apart, in areas of more open 2 and 3 interior sand including dune forms (transverse/oblique dunes), hummocks, and forested margins. Within connectivity corridors, retain at least 40% woody vegetative cover at 1 m in height when

18 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

present. Mechanical treatments by bulldozer or other large pieces of like-equipment would occur within interior open sand units open to motorized vehicles (units 27, 34, 35, 36, and 39) and units 1.5 and 2.2 (non-motorized but connected to the foredune). Maintain habitat for marten (areas of predominately ericaceous shrubs ≥ 40 % cover at 1-meter height) in deflation plains, forest margins, and forested areas. Maintain vegetation in connectivity corridors, generally >5% woody vegetation cover in patches < 100 feet apart, in areas of more open 3 interior sand including dune forms (transverse/oblique dunes), hummocks and forested margins. 2 and 3 Within connectivity corridors, retain at least 40% woody vegetative cover at 1 m in height when present. Mechanical treatments would occur in open sand areas that allow motorized vehicles as well as units 1.5 and 2.2. Remove invasives and maintain native plant populations in open sand areas that are not serving as 4 marten corridors by using one or more of the following treatment types: mechanical, manual, 2 and 3 herbicides, and prescribed fire. Increase sand movement and open sand areas for ecological and recreation purposes. Remove current vegetation which inhibits winds from moving sand near foredune areas and vegetation in open 5 sand areas that are not long-established tree islands (e.g. non-native species, early successional 2 and 3 species in non-riparian deflation plains, etc.) or not currently serving as potential connectivity corridors for marten. Restore landscape processes by removal of nearly all vegetation on 56 acres in the Baker Beach area 6 (treatment unit 1-1.5) to connect beach sand source to the inland open sand area using manual, 2 only mechanical, herbicide, and prescribed fire treatments. 7 Provide increased interpretive opportunities for recreationists at entry points to treatment areas. 2 and 3 Where snowy plover nests occur, continue management activities including nest protection through 8 2 and 3 symbolic fencing, predator control and monitoring as funding allows.

Definitions of Marten Habitat Components Home Range Habitat - Shore pine and transitional shore pine/Douglas-fir-hemlock forests with multiple canopy layers including a dense ericaceous shrub understory composed of species such as evergreen huckleberry and salal, with combined canopy closure of shrubs and trees at 1-meter (vegetation height) of ≥ 40%. These forest types are found within the deflation plain and upland forests of The Project area. Canopy cover would be assessed on a project-by-project basis using the most current information or sensing tools available. Figure 5 gives an example of female home ranges in the Tahkenitch Lake area. Scattered Edge Habitat – Vegetation encroaching into open sand project units that are located along the edge of marten home range habitat such as small conifer, woody shrubs, brooms, and beachgrass. This vegetation is less than 40% canopy closure of trees and shrubs at 1-meter height and is separated from the forest edge by approximately 15 feet.

19 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Figure 7. An example of the “scattered edge” vegetation removal approach which would be implemented where sparse conifer and woody shrubs are expanding into open sand.

Figure 8. Removal of small isolated trees and shrubs along a “scattered edge” is expected to achieve Project goals of restoring open sand conditions while minimizing impacts to adjacent forest habitat.

Buffer Edge Habitat – Wide bands of predominately non-native vegetation (such as mature Scotch broom) typically at the edge of Project units. This band of vegetation is contiguous with marten home range habitat. This strip of vegetation may function as corridor for juvenile marten, provide foraging opportunities, or buffer home range habitat from predators and/or disturbance.

20 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Figure 9. Example of buffer edge treatment to remove stands of predominately non-native shrubs within open sand areas.

Figure 10. Aerial photograph showing an example of marten habitat treatments. The green arrow (buffered edge) and the blue arrows (open sand corridors) show marten habitat locations that would be treated following project design criteria (see Project Design Criteria section starting on page 25) and within limits of marten treatment restrictions (see Table 16, Table 17, Table 18, Table 19, Table 20, and Table 21). The red arrow shows vegetation on the edge of marten habitat that would not be treated, unless sparsely scattered weeds occur along the edge.

Open Dispersal Habitat – Dispersed patches of mature conifer with < 40 % canopy cover of shrubs and trees at 1- meter height. This habitat type is generally contiguous with home range habitat and may have the potential to develop into home range habitat over time. These forested patches may provide some measure of cover for dispersing juveniles. For and example of open dispersal habitat, please Figure 11. Connectivity Corridors (corridors) – This is an additional usage designation of habitat, due to juxtaposition on the landscape (i.e. this does not change the habitat type). Defined as vegetation cover, generally >5% woody vegetation cover in patches < 100 feet apart, in areas of more open interior sand including dune forms (transverse/oblique 21 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment dunes), hummocks and forested margins that provide for marten movement between patches of home range habitat. Within corridors, retain at least 40% vegetation cover at 1-meter height when present. Connectivity corridors, as mapped during the development of the Environmental Analysis, may, or may not have a minimum of 40% canopy cover and may not offer contiguous connection, but have been considered important for habitat connectivity through more open sand areas. Territory – Modeled or theoretical home range of a male or female marten. Edge Treatment Calculation - Percent edge treatments within each Project unit polygon would be calculated by determining the miles of edge for each Project unit polygon that intersects with female marten home range habitat divided by the miles of edge of each mapped theoretical female home range.

Figure 11. Example of Open Dispersal Habitat. The light blue circle shows and example of open dispersal habitat that may provides dispersal habitat for juvenile marten.

Table 2. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Baker Beach area (Map C, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide BB1 1.1 yes 2 26.1 No No No No Yes Yes BB 1.1 no 2 102.9 No No P No Yes Yes BB 1.1 corridor 2 5.8 No No No No Yes Yes 22 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide BB 1.3 yes 2 16.7 No No No No Yes Yes BB 1.3 no 2 122.0 No No P Yes Yes Yes BB 1.4 yes 2 11.7 No No No No Yes Yes BB 1.4 no 2 29.0 No No P No Yes Yes BB 1.53 yes 2 2.9 No No No No Yes Yes BB 1.53 no 2 24.6 No No P Yes Yes Yes BB 1.6 no 2 112.7 Yes No B/P Yes Yes Yes BB 1.7 yes 1 4.1 No No No No Yes Yes BB 1.7 no 1 6.2 No No P No Yes Yes BB 1.8 yes 1 9.5 No No No No Yes Yes BB 1.8 no 1 7.0 No No P No Yes Yes BB 1.9 yes 1 4.5 No No No No Yes Yes BB 1.9 no 1 16.8 No No P No Yes Yes BB 1.9 corridor 1 1.4 No No No No Yes Yes BB 2.1 yes 2 0.6 Yes No No No Yes Yes BB 2.1 no 2 289.1 Yes No B/P Yes Yes Yes BB 2.2 no 2 37.1 No No P Yes Yes Yes BB 3 yes 1 94.2 No No No No Yes Yes BB 3 no 1 259.4 No No P No Yes Yes BB 5 yes 2 17.6 No No No No Yes Yes BB 5 no 2 83.2 No No P No Yes Yes 1Baker Beach area map. 2B = broadcast burning; P = pile burning. 3Alternative 2 proposed to treat 52.7 acres in unit 1.5 for landscape-scale sand movement (goal 3). Alternative 3 reduces the proposed treatment acres in unit 1.5 from 52.7 to 27.5 acres total (2.9 acres of habitat and 24.6 acres on non-habitat). This is a reduction of 25.2 acres from Alternative 2

Table 3. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Cleawox Lake area (Map D, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide CL1 31 yes 2 229.6 No No No No Yes Yes CL 31 no 2 197.6 No No P No Yes Yes CL 36 yes 2 340.0 No Yes No No Yes Yes CL 36 no 2 2018.3 No Yes P Yes Yes Yes CL 36 corridor 2 31.1 No Yes No No Yes Yes CL 36.1 yes 2 38.7 No No No No Yes Yes CL 36.1 no 2 55.0 No No P No Yes Yes CL 36.1 corridor 2 16.4 No No No No Yes Yes CL 36.2 yes 2 5.6 No No No No Yes Yes CL 36.2 no 2 67.4 No No P No Yes Yes CL 36.3 yes 2 0.1 No No No No Yes Yes CL 36.3 no 2 16.3 No No P No Yes Yes 1Cleawox Lake area map. 2B = broadcast burning; P = pile burning.

23 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Table 4. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Tahkenitch Lake area (Map E, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide Tahk1 10 yes 2 25.6 Yes No No No Yes Yes Tahk 10 no 2 319.0 Yes No B/P Yes Yes Yes Tahk 15 yes 2 5.1 Yes No No No Yes Yes Tahk 15 no 2 218.6 Yes No B/P Yes Yes Yes Tahk 15.1 yes 2 39.7 No No No No Yes Yes Tahk 15.1 no 2 217.6 No No P No Yes Yes Tahk 15.1 corridor 2 23.1 No No No No Yes Yes Tahk 16 yes 2 30.4 Yes No No No Yes Yes Tahk 16 no 2 247.6 Yes No B/P Yes Yes Yes Tahk 33 yes 1 104.4 No No No No Yes Yes Tahk 33 no 1 471.4 No No P No Yes Yes Tahk 33 corridor 1 11.0 No No No No Yes Yes Tahk 51 yes 2 34.4 No No No No Yes Yes Tahk 51 no 2 221.9 No No P No Yes Yes Tahk 51 corridor 2 11.7 No No No No Yes Yes 1Tahkenitch Lake area map. 2B = broadcast burning; P = pile burning.

Table 5. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Umpqua River area (Map F, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide Ump1 17 yes 1 56.5 No No No No Yes Yes Ump 17 no 1 399.1 No No P No Yes Yes Ump 32 yes 2 6.5 Yes No No No Yes Yes Ump 32 no 2 45.6 Yes No B/P No Yes Yes Ump 34 yes 2 72.1 No Yes No No Yes Yes 1Umpqua Lake area map. 2B = broadcast burning; P = pile burning.

Table 6. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Eel Lake area (Map G, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide Eel1 18 yes 1 17.9 No No No No Yes Yes Eel 18 no 1 11.5 No No P No Yes Yes Eel 21 yes 1 77.9 No No No No Yes Yes Eel 21 no 1 1676.5 No No P No Yes Yes Eel 21 corridor 1 21.1 No No No No Yes Yes Eel 22 yes 1 24.3 No No No No Yes Yes Eel 22 no 1 17.0 No No P No Yes Yes Eel 34 no 2 1453.6 No Yes P Yes Yes Yes Eel 34 corridor 2 7.2 No Yes No No Yes Yes 1Eel Lake area map. 2B = broadcast burning; P = pile burning.

24 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Table 7. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Beale Lake area (Map H, Appendix A). Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide Beale1 20 yes 2 35.5 Yes No No No Yes Yes Beale 20 no 2 296.9 Yes No B/P Yes Yes Yes Beale 20.2 no 2 92.1 No No P No Yes Yes Beale 20.2 corridor 2 3.8 No No No No Yes Yes Beale 24 yes 1 44.7 No No No No Yes Yes Beale 24 no 1 62.4 No No P No Yes Yes Beale 24 corridor 1 31.4 No No No No Yes Yes Beale 39 yes 2 467.7 No Yes no No Yes Yes Beale 39 no 2 715.8 No Yes P Yes Yes Yes Beale 39 corridor 2 32.2 No Yes No No Yes Yes Beale 40 yes 2 1.3 Yes No No No Yes Yes Beale 40 no 2 35.1 Yes No B/P Yes Yes Yes 1Beale Lake area map. 2B = broadcast burning; P = pile burning. Table 8. Identification of goal, acres, if foredune, if motorized, and proposed burning, manual, mechanical, or herbicide treatments for each Project unit per habitat feature in the Coos area (Map I, Appendix A).

Map Subunit Habitat Goal Acres Foredune Motorized Burn1 Mechanical Manual Herbicide Coos1 50 yes 2 18.6 No No No No Yes Yes Coos 50 no 2 22.0 No No P No Yes Yes Coos 26 yes 1 8.7 No No No No Yes Yes Coos 26 no 1 9.1 No No P No Yes Yes Coos 28 yes 1 13.0 No No No No Yes Yes Coos 28 no 1 29.3 No No P No Yes Yes Coos 29 yes 1 45.5 No No No No Yes Yes Coos 29 no 1 87.6 No No P No Yes Yes Coos 29 corridor 1 3.7 No No No No Yes Yes Coos 35 yes 2 3.7 No Yes No No Yes Yes Coos 35 no 2 87.0 No Yes P Yes Yes Yes Coos 35 corridor 2 7.5 No Yes No No Yes Yes Coos 37 yes 2 28.6 No Yes No No Yes Yes Coos 37 no 2 590.9 No Yes P Yes Yes Yes Coos 37 corridor 2 38.4 No Yes No No Yes Yes Coos 27 yes 2 156.9 No Yes No No Yes Yes Coos 27 no 2 583.2 No Yes P Yes Yes Yes Coos 27 corridor 2 114.3 No Yes No No Yes Yes 1Coos area map (south end of project). 2B = broadcast burning; P = pile burning. Project Design Criteria Project design criteria (PDCs) are written specifically for projects to limit, minimize, or eliminate effects during implementation. They should be unique to the site, timing, and location of The Project and not necessarily of normal policy or regular best management practices. The PDCs below are grouped by specific resources but are not in any order of precedence.

25 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Table 9. Dunes hydrology PDCs 100 Dunes Hydrology Follow Siuslaw Forest Plan (1990) standards and guides to meet water-quality standards outlined in the Clean Water Act for 101 protecting Oregon waters. If any storage facilities for oil or oil products are in The Project area, take appropriate preventive measures to ensure that 102 any spill of such oil or oil products does not enter any stream or other waters. If the total oil or oil products storage exceeds 1,320 gallons in containers of 55 gallons or greater, prepare a Spill Prevention 103 Control and Countermeasures Plan. The plan shall meet applicable EPA requirements (40 CFR 112), including certification by a registered professional engineer. 104 Fuels stored in The Project area shall have secondary containment. 105 Refueling in The Project area shall be done in designated developed areas or over secondary containment. 106 Herbicides stored in The Project area shall have secondary containment. 107 Do not remove or fill material in wetlands or waterways of the state or waters of the US.

Table 10. Recreation PDCs 200 Dunes Recreation 201 Utilize flaggers and appropriate signage when motorized equipment may block public access roads and sand travel routes. Minimize heavy equipment use from May 1 through September 30 and on weekends and holidays in campgrounds, picnic 202 areas, staging areas, and trails except for travel to and from work locations. 203 In the Baker Beach area, minimize horse/motorized equipment conflicts throughout the year. Notify the public in advance of herbicide applications, fire operations, or heavy equipment use during operations. Post on 204 the Siuslaw National Forest website, recreation.gov, and signage at the trailheads, staging areas, day use sites, campgrounds and parking areas adjacent to the work areas. In The Project area where treatments may affect trail markings or delineation, consider new trail maps and install new 205 assurance posts, as needed, with post-vegetation removal. Assurance poles are round poles set into the ground by Forest Service employees to guide users along those system trails, which are located in open sand areas. Contract administrators would provide guidance for contractor activities in and around recreation sites to minimize impacts 206 on recreationists. Maintain the tree buffer on the west side of the Baker Beach Campground and day use parking area in order to protect these 207 developed recreation sites from excessive sand intrusion. Install barriers on roads and trails in The Project area, as needed, which would allow pedestrian, equestrian, and other non- 208 motorized passage but would block OHVs from accessing non-motorized areas. Large, previously scheduled recreation special events such as Dune Fest, UTV Takeover, etc. would be cause for suspension 209 of treatment activities and noted within contracts, if there are any conflicts.

Table 11. Cultural/Heritage PDCs 300 Dunes Cultural/Heritage Projects involving mechanical treatments would require site-specific clearance outlined in the Programmatic Agreement between the United States Department of Agriculture, Forest Service, Siuslaw National Forest and the Oregon State Historic 301 Preservation Office, Regarding the Oregon Dunes Restoration Project Lane, Douglas, And Coos Counties Oregon, referred to hereafter as the “PA”, which would be completed by the Forest Archaeologist, Contract Archeologist, and/or District Archaeologist, prior to implementation. Any mechanical activities within a cultural resource either unevaluated, eligible, or listed on the National Register for 302 Historic Places (NRHP) are prohibited without further consultation. All cultural resources within The Project area of potential effect (APE) shall be clearly delineated by a FS archaeologist prior 303 to implementing any activities that have the potential to affect cultural resources. The use of or staging of vehicles, heavy mechanized equipment, or other materials is not allowed within cultural resource 304 boundaries that are designated for avoidance. Piling, storing or burning of slash and waste materials is not allowed on recorded cultural resources.

26 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

300 Dunes Cultural/Heritage 305 Broadcast burning is allowed over non-combustible cultural resources within cultural resource boundaries. As areas of the dunes become destabilized by Project treatments, the potential for exposure of archaeological sites that were not previously identifiable by standard archaeological survey methods would increase. Consequently, post-treatment 306 monitoring for previously unidentified archaeological sites would occur after all Project treatments. Monitoring would occur in coordination with the CTCLUSI and CTSI cultural resource staff and occur jointly as time and staffing allows. Implementation projects involving multiple treatment phases would coordinate with the Forest Archaeologist and District 307 Archaeologist to identify opportunities to conduct archaeological survey after manual, herbicide, and/or prescribed fire activities and prior to mechanical treatments. In the event that cultural resources or human remains are discovered during Project implementation, all activities in the 308 immediate area would cease and the Forest or District Archaeologist would be notified as soon as possible. Guidance concerning inadvertent discovery found in Appendix C of the PA would be followed.

Table 12. Fire/Fuels PDCs 400 Dunes Fire/Fuels To avoid disturbance or harm to snowy plovers during the breeding season, prescribed burning operations would not take place between March 15 and September 15. However, prescribed fire could be used during the nesting season after August 401 15 if FWS and a Forest Service biologist concur, based on monitoring results, that beach areas that may potentially be impacted by burning activities or smoke are either unoccupied by snowy plovers or are areas where nesting is completed and all broods are fledged. Adhere to the State of Oregon Smoke Management Plan by following regulations, observing daily meteorological forecasts, 402 and timing of ignitions so cumulative daily smoke outputs would not exceed state levels during the prescribed fire operations. If there are times when all burning conditions are met during the Western snowy plover restriction period (PDC #701), where all prescribed burning and/or burning slash piles would be most favorable to burn, the burn boss would request 403 approval from the line staff or the District recreation staff officer for a temporary waiver to burn within ¼ mile of campgrounds, picnic areas, OHV staging areas, motorized and non-motorized trails, sand camps and other developed recreation sites. Avoid piling slash or brush on or near Forest Sensitive invertebrate (Siuslaw hairy-necked tiger beetle, Coastal greenish blue 404 butterfly, Seaside hoary elfin butterfly) habitat. Avoid water withdrawals from fish-bearing streams whenever possible. Water drafting must take no more than 10% of the 405 stream flow and must not dewater the channel to the point of isolating fish. Pump intakes shall have fish screens consistent with NMFS fish screening criteria (NMFS 2011e).

Table 13. Fisheries PDCs 500 Dunes Fisheries 501 Follow Northwest Forest Plan Standards and Guidelines for Riparian Reserves (C-30 - C-38). 502 Follow ARBO II PDC’s for Non-native Invasive Plant Control and Riparian Vegetation treatment (prescribed burning). Non-native invasive plant control projects would not exceed 10% of acres within a Riparian Reserve under the Northwest 503 Forest Plan (USDA and USDI 1994b) within a 6th field watershed/year.

Table 14. Wildlife PDCs, General 600 Dunes Wildlife, General Effects to known listed Proposed, Endangered, Threatened, or Sensitive wildlife species (PETS), and those discovered 601 prior to or during implementation of Project activities would be minimized through known conservation measures or avoided. 602 Maintain unique habitat features such as snags and tree islands. 603 For invertebrate sensitive species, place signs or fencing in place to avoid trampling of sites as needed.

27 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

600 Dunes Wildlife, General Prior to Project implementation, Forest Sensitive invertebrates (Siuslaw hairy-necked tiger beetle, Coastal greenish 604 blue butterfly, Seaside hoary elfin butterfly) habitat would be delineated and avoided by compaction from vehicles/heavy equipment, trampling, herbicide spray (wiping preferred), or other disturbance, where practical. No project or associated activities would be implemented between January 1 and August 31 within 0.25 mile or a 0.5- 605 mile sight distance of a known Bald eagle nest site, unless the unit biologist verifies that the nest is unoccupied.

Table 15. Wildlife PDCs, Western snowy plover 700 Dunes Wildlife, Western Snowy Plover To avoid disturbance or harm to snowy plovers during the breeding season prescribed burning operations would not 701 take place between March 15 and September 15, however; Prescribed fire could be used during the nesting season after August 15 if FWS and a Forest Service biologist concur, 702 based on monitoring results, that beach areas that may potentially be impacted by burning activities or smoke are either unoccupied by snowy plovers or are areas where nesting is completed and all broods are fledged. 703 A smoke management plan would be created by the Forest Service burn boss and wildlife biologist prior to burning. To avoid disturbance to snowy plovers mechanical treatments would not take place within 0.25 miles of occupied 704 snowy plover nesting areas from March 15 - September 15. Occupancy by snowy plovers would be determined by an experienced Forest Service biologist in coordination with the U.S. Fish and Wildlife Service. No manual or herbicide treatments would take place within or within line of sight of snowy plover occupied nesting, brooding or foraging areas between March 15 and September 15. Manual or herbicide treatments could take place in 705 nesting areas after August 15 if nesting and fledging is finished for the year within the area of impact, and work is approved by an experienced Forest Service biologist in coordination with U.S. Fish and Wildlife Service. Initial herbicide applications in snowy plover nesting habitat would be restricted to no more than 33% of all nesting 706 areas on Siuslaw National Forest lands per year. Monitoring may allow for higher percentage of nesting areas to be treated per year based on district wildlife biologist review of effects. All herbicide would be applied using backpack sprayers directly to individual plants which would eliminate drift and 707 reduce probability of unintended exposure. To minimize human trespass from hiking trails into snowy plover critical habitat use adaptive management such as 708 utilizing strategies such as sand berms, assurance posts and/or symbolic fence to direct foot traffic across foredunes to the wet sand beach. 709 Herbicide use within snowy plover nesting habitat would not include application of Triclopyr. If conducting manual spot applications of Glyphosate or Imazapyr to vegetation in snowy plover designated critical 710 habitat, utilize toward the typical application range, rather than the maximum application rate. 711 Areas used for mixing herbicides would be located outside of snowy plover designated critical habitat. To minimize disturbance and risk of death or injury of wintering snowy plover from vehicle strikes contractors and 712 other personnel accessing areas where snowy plover may be present would be briefed on plover identification as well as beach driving protocols. Driving would include, but are not limited to, driving at speeds of 10 mph or less.

Table 16. Wildlife PDCs for Pacific marten, All Treatments 800 All Treatments1 Existing established forest, generally conifer greater than or equal to 10 feet in height, within Project units would be 801 maintained in order to conserve marten habitat components and maintain connectivity between forested patches To reduce disturbance to resident animals treatment in all habitat types, except open dispersal not contiguous with 802 home range habitat, is restricted to 20 % of the total home range polygon edge in any 12-month period. To account for modelling error and ensure accuracy, miles of home range polygon edge and miles of edge within each 803 Project unit polygon would be assessed on a project-by-project basis just prior to implementation. To avoid cumulative disturbance impacts to marten from edge, home range and corridor treatments, Project actions 804 would take place in no more than 9 home ranges in any 12 month period. Adaptive management and monitoring using photo points, vegetative surveys, or ocular assessments of treatment effectiveness and changes in live vegetative cover would be used to develop a better understanding of how native 805 vegetation responds to treatment methods. Treatment areas would be monitored yearly to determine regrowth of native shrubs at the forest edge and within corridors.

28 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

1Adaptive management and monitoring using photo points, vegetative surveys, or ocular assessments of treatment effectiveness and changes in live vegetative cover would be used to develop a better understanding of how native vegetation responds to treatment methods. Treatment areas would be monitored yearly to determine regrowth of native shrubs at the forest edge and within corridors.

Table 17. Wildlife PDCs for Pacific marten, Home Range Habitat Treatments Home Range Habitat Treatments Maintain existing marten home range habitat within Project units by designing vegetation treatments to maintain or improve habitat conditions. To improve habitat conditions, non-native invasive plants may be removed where at least 40% canopy cover at 1-meter height in the understory brush layer can be maintained. 806 Canopy cover would be determined by use of LiDAR or a like sensing tool, and/or field surveys using ocular methods (i.e. moosehorn, spherical densitometer, line-intercept plots, or hemispherical photography). Over the life of The Project, canopy cover would be assessed on a project-by-project basis using the most current information or remote sensing tools available. 807 To avoid disturbance to marten mechanical treatment would not occur in home range habitat. Two separate limits within any 12 month period would be applied to treatments in this habitat type: 808 • No more than 15% of the acres within the affected female home range would be treated • No more than 15% of the acres within the affected female home range would be treated Understory treatments within marten home range habitat would not occur in neighboring (adjoining) territories 809 during the same 12 month period. To reduce disturbance to females denning with kits restrict vegetation removal within home range habitat to 810 within 25 meters of existing disturbance corridors (such as motorized routes) from March through June when females are denning with kits and may be less mobile.

Table 18. Wildlife PDCs for Pacific marten, Habitat Edge Treatments Scattered and Edge Habitat Treatments To increase implementation efficiency and cost effectiveness, edge treatments could occur within two adjacent 811 female home ranges in up to two separate locations within The Project area in a 12-month period. To reduce disturbance impacts to marten from edge treatments in two adjacent home ranges will not occur in 812 home ranges less than 260 acres in size. Scattered Edge Habitat Treatments1 Woody vegetation growing along the perimeter of open sand dune areas may be removed when all of the following criteria are met: • Vegetation removal would occur in areas where the density of conifer and native shrubs is sparse and canopy cover is less than 40 percent (as mapped just prior to individual project implementation). Canopy cover less than 40 percent would be determined by use of the most current LiDAR or a like 813 sensing tool data, and/or field surveys using ocular methods (i.e. moosehorn, spherical densitometer, line-intercept plots, or hemispherical photography). • Woody vegetation is scattered and isolated from contiguous, densely vegetated, forest areas. • Conifer trees or ericaceous shrubs removed are generally ≤ 10 feet in height and less than 3 inches diameter at breast height. Other than being included in the limit of treatment to 20% of the total home range polygon edge in any 12- 814 month period, there are no other restrictions for treatments within this habitat type. Buffer Edge Habitat Treatments2 In addition to being included in the limit of treatment to 20% of the total home range polygon edge in any 12- 815 month period, treatments in this category are also limited to 15% of the total home range polygon edge in any 12-month period. 1 Scattered edge treatments (Figure 7 and Figure 8) would remove small conifer and both native and non-native shrubs that are scattered along the perimeter of Project units. Native trees and woody shrubs to be removed are separated from more densely forested patches, are unlikely to provide enough cover to provide marten security from risk of predation while foraging, and are not contributing to connectivity of home range habitat. Since marten often avoid openings by moving greater than 50 meters within forest patches marten presence is expected to be only incidental along edges. 2 Within some Project units, edge vegetation adjoining marten home range habitat is composed of a wide band of predominately non-native vegetation such as mature Scotch broom. Under the proposed actions, this vegetation would be removed (Figure 9). Canopy closure within buffer edge habitat is less than 40 percent and, similar to scattered edge habitat, marten presence is expected to be infrequent. Buffer edge habitat does provide much more continuous canopy cover than scattered edge habitat; therefore, it could be more frequently used by marten. It is unknown if, or to what extent, marten utilize Scotch/Portuguese broom/gorse dominated areas that are contiguous with more densely vegetated forest areas that are known to be inhabited by marten. It is possible that this strip of vegetation could provide dispersal habitat for juvenile marten, foraging opportunities, or buffer home range habitat from disturbance. Preliminary game camera observations within buffer edge habitat have documented

29 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

marten forage species such as Douglas squirrel, chipmunk, brush rabbit, thrush and other bird species, however, bobcat and coyote, known marten predators, were also noted.

Table 19. Wildlife PDCs for Pacific marten, Connectivity Corridor Treatments Connectivity Corridors Treatments1 To maintain and enhance the functional connectivity between forested patches and to facilitate movement 816 through territories for the purposes of marten foraging, reproduction and dispersal of juveniles maintain corridors as identified on the in the Project maps (Appendix A). Within mapped corridors, treatments would be designed to maintain and/or improve canopy cover density and encourage growth of native ericaceous shrub species. Canopy cover that is greater than or equal to 40% would 817 be maintained where it currently exists. This may include the conservation of non-native plant species. Where greater than 40% canopy cover exists, corridor vegetation treatments would be designed to convert the non- native vegetation component to native species gradually over time. Corridors may contain different types of habitat. Treatments would be subject to the appropriate PDC’s for the 818 underlying habitat type. 819 Mechanical treatment would not occur within connectivity corridors. 1 Maintaining functional connectivity between patches of forest habitat, including both north-south and east-west linkages, is essential for gene flow, juvenile dispersal, the ability of males to access multiple females within existing habitat and for population supplementation and persistence. Connectivity between habitat patches also enables marten to move through their environment to acquire sufficient resources such as prey, denning and resting sites.

Table 20. Wildlife PDCs for Pacific marten, Open Dispersal Habitat Treatments1 Open Dispersal Habitat Treatments Open dispersal habitat may aid dispersing juvenile marten in avoiding territorial adults during dispersal. 820 Treatments within open dispersal habitat would be developed on a project-by-project basis in conjunction with the wildlife biologist. Other than being included in the limit of treatment to 20% of the total home range polygon edge in any 12- 821 month period when this habitat type is contiguous with home range habitat, there are no other restrictions for treatments within open dispersal habitat. 1 Dispersed patches of mature conifer (over 10 feet in height) with less than 40 percent canopy cover. This habitat type is generally contiguous with home range habitat and has the potential to develop into home range habitat over time. These forested patches may assist dispersing juveniles in avoiding territorial adults.

Table 21. PDCs for Monitoring Species Monitoring1 As vegetation treatment projects are initiated, re-evaluate local habitat, to identify mapping errors or other changes to the vegetation related to marten usage to properly design treatment projects and document compliance with design criteria specified in USFW conferencing. If treatment Pacific projects plan to remove home range habitat or connectivity corridor habitat, even if the unit has 822 marten developed these habitat types since the conference, reinitiation would be required as those projects would no longer be consistent with this conference. The same concept applies to future changes in the other habitat types, PDCs are applied to the vegetation treatment projects based on the habitat conditions at the time of the on the ground treatments. Pacific 823 Project monitoring forms would be submitted to FWS annually at the end of each calendar year. marten Photo points will continue to be the primary monitoring tool for invasive treatments. Before and after photos are taken. Location data is collected to ensure future photos can be taken with consistency. Vegetation surveys and ocular estimates of vegetation changes will be conducted while Invasive 824 preparing for treatments – initial or maintenance. If funding and human resources allow, vegetation Plants transects/plots may be used to measure vegetation changes over time. Given adequate resources, a relatively low cost (~$5,000) geomorphology monitoring project mapping sand movement (erosion and deposition) could be implemented. 1 Due to limitations of modeling tools utilized for analysis and the complex pattern of vegetation on Project landscape, some mapping errors have occurred such as small patches of open sand being mapped as marten habitat and vice versa. These mapping errors would be accounted for at the time of on the ground treatments. Prior to implementation, the area to be treated would be assessed by a wildlife biologist to ensure that treatments are consistent with consultation.

30 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Table 22. Botanical Resources PDCs 900 Dunes Botanical Resources — Herbicide Use1 Treatment areas would be surveyed for Forest Sensitive (FS) and desirable native plants (dunes adapted native plants). Sensitive species would be protected by a combination of the following: no trampling, pulling, cutting 901 or piling of vegetation on sensitive or priority native plant species; avoid damage to Forest Sensitive species by any of the following: 10 foot no spray buffer distance, protecting FS and native plants by shielding from spray, or use wipe or manual treatment methods adjacent to desirable species. Invasive plant treatments near the boundary between open sand and native vegetation may occur up to 50 feet 902 into predominantly native vegetation. This would allow treatment of isolated plants or patches of invasive weeds. Use herbicides in accordance with label instructions, except where more restrictive measures are required. Herbicide formulations would initially be limited to those containing one or more of the following aquatic- 903 approved active ingredients: glyphosate, imazapyr, and triclopyr. Herbicide carriers (solvents) are limited to water and/or surfactants specifically approved by ARBO II. Herbicide use would comply with standards on herbicide selection, tank mixing, licensed applicators, and use of 904 adjuvants, surfactants and other additives (R6 PNW Invasives ROD (2005) Treatment Standards; ARBO II). The lowest effective label rates would be used for each given situation (USDA-Forest Service 2005a, Appendix 905 Q). Use low nozzle pressure; apply as a coarse spray, and use nozzles designed for herbicide application that do not 906 produce a fine droplet spray, e.g., nozzle diameter to produce a median droplet diameter of 500-800 microns. 907 Herbicide applications would occur when wind velocity is less than ten miles per hour. 908 Applications may not occur if rain, fog, or other precipitation is likely within 24 hours. 909 No applications shall occur if temperatures exceed label allowance, or if temperature inversions exist. If herbicide use is within 1,000 feet (slope distance) of known water intakes inform the water user or manager 910 and the district hydrologist. Areas of potential conflict with forest users would be prominently marked on the ground or otherwise posted. 911 Postings would indicate the date of treatments, the herbicide used, and when the areas are expected to be clear of herbicide residue (ROD Standard 23). Herbicide application shall not occur within occupied snowy plover breeding areas during breeding season – March 15th - September 15th; however, after August 15 if a Forest Service Biologist determines that nesting is 912 completed and all broods are fledged at sites that may potentially be impacted by herbicide application activities, treatments may be approved. Initial herbicide applications in Western snowy plover nesting habitat would be restricted to no more than 33% 913 of nesting areas on Siuslaw National Forest lands per year. Monitoring may allow for higher percentage treatment per year based on district wildlife biologist review of effects. 914 Herbicide use within Western snowy plover habitat areas would not include application of triclopyr. 915 Areas used for mixing herbicides would be located outside of Western snowy plover designated critical habitat. If conducting manual spot applications of glyphosate or imazapyr to vegetation in Western snowy plover 916 designated critical habitat, utilize toward the typical application range, rather than the maximum application rate in Table 23. Distances from water edge have been established for for perennial and wet intermittent streams, lakes and 917 wetlands (Table 24). Anyone involved in the use, handling, or transportation of herbicides must be an ODA certified pesticide 918 applicator and follow the Herbicide Safety and Spill Response Plan. 1Also see Project Design Criteria 106, 204, 307, 604, 705, 706, 709, 710, and 711 for herbicide PDCs specific to other resources.

31 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Table 23. Proposed herbicides, application methods, and rates

Typical Application Maximum Application Rate Chemical Brand Name Application Methods Rate (lb ai/ac*) (lb ai/ac*)

Glyphosate- Aquamaster® Spot and hand/selective application, aquatic Aquaneat® including wipe, injection. Broad 2 7 formulation Rodeo® spectrum – non-selective.

Imazapyr- Habitat® Spot and hand/selective application. aquatic 0.45 1.25 Polaris® Broad spectrum – non-selective. formulation

Triclopyr- Garlon 3A® Spot and hand/selective application. aquatic Element 3A® Selective on woody shrubs and 2 6 formulation Renovate 3® trees.

Table 24. Distances from water edge for herbicide-use for perennial streams, wetlands, lakes, ponds, and high-water- table areas Application Method — Herbicide Application Method — Hand/Select (feet) Spot spray (feet) Glyphosate (aquatic) waterline waterline Imazapyr (aquatic) waterline waterline Triclopyr (aquatic) 15 waterline

Proposed Treatments Types The type and amount of actions proposed are based on conditions known to exist in The Project area, as well as on knowledge gained from implementing past projects of a similar nature and best available science. As the planning team conducts their in-depth analysis, the quantity of actions proposed may change as new or more detailed information becomes available to them. Mechanical treatment is the removal of unwanted vegetation by heavy equipment (bulldozers or like equipment) and buried so that it may decompose or in some rare cases be pile burned or removed from the site. The vegetative material is usually “scalped” three to four feet below the base of the plants and delivered to an area to be well covered over by several feet of sand taken from the foredune. It may be the adjacent deflation plain on the backside of the foredune. First-year mechanical treatments would typically require follow-up maintenance treatments with herbicide or manual treatments (typically pulling) and less commonly by a second mechanical treatment or prescribed burning. Manual treatment would involve the pulling and cutting of vegetation including sprouts and whole plants. This work would be done under contract, by volunteers, or by agency personnel and may cover smaller areas because of its labor-intensive nature. This may be done in areas that are more sensitive to effects or may not be accomplished through other means. Prescribed burning (Rx burning) treatments may be applied through, broadcast burning and/or pile burning. Piles of non-native vegetation and unwanted native vegetation could be burned in hand piles collected through manual treatments or accumulated in larger piles by mechanical methods. Broadcast burning is a prescribed burning activity where fire is applied within well-defined boundaries as a resource management treatment. It is susceptible to stringent timing and prescriptive windows of opportunity, which can make predictive operations complex and may make it difficult to achieve our goals. Many factors play a role in limiting the number of days available to apply Rx fire - weather, including humidity and its effect on vegetation and fuel moisture; wind direction and its consequent effect on fire behavior (drying of fuels, direction and rate of spread, escape potential, smoke dispersal, etc.); resource availability for Rx fire control; and, timing of ignition outside of peak recreation use and species of

32 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA concern. While the number of days available for Rx burning may be limited, this treatment would be lucrative in the number of acres treated at one time. Application would allow quick removal of plant biomass from the site, both living material and the previous dead material, which can inhibit exposure to subsequent herbicide application, or can be in place to continue to entrap moving sand by providing a persistent barrier. Rx burning may best be utilized in consuming piles of displaced vegetative material and removing islands of newly established vegetation in areas of open sand where the land management objective is to maintain open sand (e.g. open ride areas). Rx burning may be a preferred treatment in many instances. However, it may prove difficult to perform. Burning has heightened efficacy when coupled with herbicide treatment. Ground-based herbicide treatment would be applied by hand or targeted applications may occur in conjunction with the manual, mechanical and Rx burning. Herbicides used would be imazapyr and/or glyphosate for beach grass (Ammophila arenaria and other non-woody invasives) and triclopyr for woody invasive species such as Scot’s broom (Cytisus scoparius) and gorse (Ulex europaeus). These are the EPA aquatic-approved herbicides that are available at this time. If another herbicide is available in the near future, the decision document may be amended to include that herbicide. Revegetation of treatment areas with native plants would occur where successful invasive plant treatments have created conditions favorable for native vegetation establishment. This will be accomplished by collecting native seed for either propagation with subsequent planting in semi-stabilized areas, and/or spreading seed in areas of open sand to create viable seed banks that can perpetuate native open sand-adapted species over time. Previous foredune treatments to create Western snowy plover habitat have received several years of seeding with pink sand verbena and have been successful at establishing pink sand verbena populations. Treatment Types, Selection, and Interaction Treatments across the landscape would be as flexible as the terrain, cost, vegetation composition, land management allocations and other considerations (e.g. proximity to riparian areas, recreation or residential areas, wildlife concerns, etc.) allow. Flexibility of treatment types (i.e. manual, mechanical, Rx fire, and herbicide; see Table 1) would allow the broadest range of potential treatment given the challenges of wildlife timing restrictions, weather, human use, seasonal plant susceptibility to treatments, etc. within The Project area. With the exception of the first year of implementation, there would be an emphasis on follow-up or maintenance treatments in areas previously treated on this Project. It is estimated that as much as 70% of any given year’s action would be towards maintenance treatments while 30% would be towards new acres of treatments.

33 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Chapter 3 Environmental Consequences Lifeform and Geomorphic Succession A lifeform and geomorphic mapping exercise to examine landscape changes over time was conducted on two areas in the Oregon Dunes National Recreation area (Baker Beach and Overlook areas) Aerial photographs for the two areas from several time periods (historical to present) were georeferenced. The polygons were digitized (using roughly a 10-acre map unit) for each photo using the following criteria: • Open sand/sparse veg (<25% cover) • Sand/water (could be deflation plain--<25% vegetation cover) • Moderate cover herbs (25-50%) • Moderate cover shrubs (25-50%) • Moderate cover trees (25-50%) • High cover herbs (>50%) • High cover shrubs (>50%) • High cover trees ((>50%) • Pond/lake

The two locations were also mapped using the following geomorphic or geographic categories: • Beach • Foredune • Deflation plain • Inland • NA (for rivers that cross over many geographic areas)

Acres were summarized across lifeforms (e.g. open, herb, shrub, tree) and rough cover groups (<25%, 25-50% and >50%). A rate of change was calculated (change in y/change in x) to assess the time dependence on the rapidly shifting landscape. The lifeforms on the dunes have been changing through time, largely shifting from open to herb to shrub to “treed” (predominantly trees). Vegetated areas are increasing on the dunes, changing from open areas to vegetated areas at a rate ranging from 9-11 acres/year. “Treed” lifeform areas have increased at a rate of 7-8 acres /year. Succession has replaced sand deposition and movement as the dominant process operating on the dunes. If this continues at the same rate, open sparsely vegetated areas in Baker Beach could be gone in 10-20 years, and gone from the Overlook area in 20-30 years. Once an area moves into higher lifeforms, different treatments would need to be considered to restore dunes conditions. As succession changes from lower life forms to higher life forms (open sandherbsshrubstrees) the energy and cost associated with reversing the succession and re-introducing natural ecological processes increases. Wildlife Species Current Condition Wildlife species with know occurrences or suitable habitat in the Project area are listed in Table 25. Effects to these species are presented in the Wildlife Environmental Consequences section starting on page 43.

34 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Table 25. Wildlife species with known occurrences or suitable habitat in the Project area. Species Status General Habitat Description Habitat in Habitat analysis Types area present Western snowy Federally listed Nests on sandy beaches and in dunes Yes Beach, plover and (Threatened), Deflation Designated Siuslaw MIS Plain, Critical habitat Open Sand Pacific marten Proposed Coniferous forest, normally older stands; use large logs, snags Yes Water Federally and live trees for denning/resting. Features, Threatened, Deflation Forest Service Plain, Sensitive, Forest Siuslaw MIS Edge Purple martin Forest Service Variety of terrestrial habitats, preferably near open water with Yes Beach, Sensitive access to natural or artificial cavities (snags, bird houses, Foredune, pilings etc.) Open Sand Western pond Forest Service Ponds, slow moving water mostly in Willamette Valley Yes Deflation turtle Sensitive Plain, Water Features Siuslaw hairy- Forest Service The immediate sandy edge of river mouths on beaches along Yes Beach, necked tiger Sensitive the Pacific Ocean and wet sand within inland dunes. Foredune, beetles Deflation Plain, Open Sand Western bumble Forest Service Associated with meadows and openings in forested areas. Yes Deflation bee Sensitive Habitat including flowering plants for foraging and rodent Plain, burrows for nesting. Open Sand Coastal greenish Forest Service Coastal terrace meadows. The species overwinters as early Yes Deflation blue butterfly Sensitive instar caterpillar in flower head of host clover Plain Fringed myotis Forest Service Utilize caves, mines, and buildings for hibernation, maternity, Yes Deflation Sensitive and solitary roosts. Feed predominately on moths along forest Plain, edges, roads, or open areas within the forest. Utilizes, but not Open Sand dependent upon snags or down material Bald eagle Forest Service Nests in conifer forests containing old-growth components Yes Beach, Sensitive, typically within one mile of water Deflation Siuslaw MIS Plain, Open Sand California brown Forest Service Lakes, estuaries, coastlines, and bays. Resting/roosting in Yes Beach pelican Sensitive, estuaries and along beaches on the Oregon Dunes NRA. Siuslaw MIS American Siuslaw MIS Nests on cliff or rock outcrops. Primary forage along large Yes Beach, Peregrine falcon bodies of water. Foredune, Deflation Plain, Open Sand Aleutian Canada Siuslaw MIS Inland lakes and large expanses of flooded deflation plan on Yes Deflation goose the Oregon Dunes NRA for potential migratory/ transitory Plain habitat- little if any suitable feeding habitat Pileated Siuslaw MIS Large snags, defective trees, down material Yes Deflation Woodpecker Plain, Forest Edge Primary cavity Siuslaw MIS Dead and defective trees throughout the forest types Yes Deflation excavators Plain,

35 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Species Status General Habitat Description Habitat in Habitat analysis Types area present Forest Edge Roosevelt Elk Siuslaw MIS Mosaic of foraging areas close to thermal and hiding cover Yes Beach Foredune Deflation Plain

Table 26. Wildlife species that does not occur and/or does not have suitable habitat in the Project area. Species Status General Habitat Description Habitat in Habitat analysis Types area present *Marbled murrelet Federally listed Seasonal forest inhabitant for nesting only. Nests in older No NA** and Designated (Threatened) forested stands which may include remnant trees with one or Critical Habitat more platforms on branches >4” diameter in large diameter live conifers. *Northern spotted Federally listed Nests in complex forested habitats with multi-layered No NA** owl and (Threatened), canopies, large overstory trees, snags, and downed wood. Designated Siuslaw MIS Roosting and foraging similar to nesting but with lesser habitat Critical Habitat components. Utilize younger, denser stands for dispersing. *Oregon Federally listed Coastal meadows with Viola adunca spp. No NA** silverspot butterfly (Threatened), and Designated Siuslaw MIS Critical habitat *Wolverine Proposed Subalpine, remote forest areas. Extirpated in Coast Range No NA** Federally Threatened *Foothill yellow- Forest Service Known distribution does not occur on SNF, but species is No NA** legged Frog Sensitive suspected on eastern foothills. Highly aquatic and found in vicinity of permanent streams with open cobble gravel bars. *Pallid bat Forest Service Semi-arid and arid grasslands, shrub steppe, and desert No NA** Sensitive environments with rocky outcrops. Also in dry open oak or ponderosa forest and open farmland. Roosts are commonly rock crevices but buildings, bridges, live trees and snags are also used. *Oregon red tree Forest Service Mature and over mature/old growth conifer dominated stands, No NA** vole Sensitive, and some younger stands containing suitable nesting Survey and structure Manage *Species will not be analyzed further due to absence of habitat in analysis area. **NA= Not applicable

Federally Listed Wildlife Species — western snowy plover - (Charadrius nivosus nivosus) The beach contains suitable habitat and designated critical habitat for the Western snowy plover (Charadrius nivosus nivosus) (T). Plover would not occur within the vegetated portions of deflation plains. Western snowy plovers generally don’t occur within inland open sand areas or interior forest habitats. Plover are known to use two small areas at the eastern edge of deflation plains. Biologists have documented occasional snowy plover use of two inland dune areas on the ODNRA. The first location is in the southwest corner of the North OHV Riding Area near the eastern edge of the deflation plain within Project unit 36. This area is a wide-open sand flat approximately 0.6 miles directly east of Siltcoos Breach (CHU OR 8A). Small flocks (10- 15) of wintering snowy plovers have been documented several times resting and feeding during the day at this location. The second area is immediately east of Umpqua Parking Lot 3 within Project unit 34. This parking lot is

36 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA located south of the city of Winchester Bay at the end of Salmon Harbor Drive and serves as a staging area for off-highway vehicles using the Middle Riding Area. Both of these areas are expected to persist over time and remain useable to snowy plovers therefore, effects to deflation plain areas from the No Action Alternative are not expected to affect western snowy plover.

Federally Proposed Species — Pacific marten (Martes caurina) The historical distribution of martens in coastal Oregon includes “…the humid mixed zones of the coast and Coast Ranges” (Bailey 1936, p. 296), extending from the Columbia River south through the coastal portions of the Klamath–Siskiyou mountains to the California border (Figure 3.1; Zielinski et al. 2001, p. 480). Museum or trapping records for martens exist for every county within their historical range in coastal Oregon (Marshall 1994, p. 1; Zielinski et al. 2001, p. 483).

Though marten historically occurred throughout coastal forests of Oregon and northern California they have not been detected within much of their historical range, even with extensive surveys of over 70% of its predicted historical range in Oregon (Moriarty et al. 2016; USFWS 2018a). In fact, the coastal marten was considered to be extinct until 1996 when a small population was rediscovered in northern California. At this time only four small populations are known to remain along the Pacific coast, two populations in northern California and two in Oregon (USFWS 2018a). In Oregon, extant populations are located on the Siskiyou National Forest and the Siuslaw National Forest, primarily within and just north of the ODNRA.

Pacific marten require forested habitat with a dense shrub understory. Pacific marten generally avoid the forest edge staying 50 meters within complex stands adjacent to openings (Moriarty et al. 2015). They do not inhabit beaches within the Project area. Pacific marten generally do not occur within large areas of interior open sand. Use of this open sand habitat type would be considered very rare. Marten may use sparsely vegetated non- continuous patches of vegetation to cross open sand areas (See Figure 5).

Within the Oregon Dunes National Recreation Area marten have been found to be associated with large blocks of shore pine and transitional shore pine/Douglas-fir-hemlock forests with multiple canopy layers including a dense ericaceous shrub understory (Moriarty et al. 2016). These forest types are found within deflation plain and upland forests in both motorized and non-motorized management areas. This habitat type has abundant prey and a biologically complex structure and composition including the presence of snags (Moriarty et al. 2019). Species such as evergreen huckleberry and salal are particularly important habitat components because they provide protective cover from predators (i.e. bobcat, gray fox and coyote) as well as foraging opportunities. Telemetry data from the central coast marten population indicated that marten preferred habitat where cover (both shrubs and overstory trees) was greater than 75 percent (Linnell et al. 2018, Moriarty et al. 2019).

Regional Forester Sensitive Species No suitable habitat exists in the project area for foothill yellow-legged frog, pallid bat, Oregon red tree vole or wolverine. Thus, Alternatives 1-No Action, Alternative 2, and Alternative 3 would have no effect on these species or their habitats.

California brown pelican (Pelecanus occidentalis californicus) Brown pelicans do not nest in Oregon but are common visitors to the central Oregon coast from late spring through early fall. Pelicans are usually found off shore however they sometimes rest on the wet sand beach ocean beach and on sand spits within estuaries within the project area. Occasionally brown pelican are observed flying as far inland as the beach foredune.

Northern Bald Eagle (Haliaeetus leucocephalus) Bald eagles are usually found near coastlines, rivers, large lakes or streams that support an adequate food supply. Their primary prey item is fish. They are resident within the project area year-round where food is

37 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

available, otherwise migrates or wanders to find food. Nests are built in large trees with an open structure and large limbs. In western Oregon bald eagles nest primarily in Sitka spruce and Douglas-fir (Issacs and Anthony 2003). Although the widespread use of DDT lead to reproductive failure and subsequent Federal listing of this species, the Bald eagle was de-listed throughout most of its range in 2007. Current threats to the Bald eagle include disruption, destruction, or obstruction of roosting and forage areas (U.S. Fish and Wildlife Service 2010). Large conifer that may be within treatment units could be used for roosting, resting or as a vantage point for hunting. Bald eagle commonly use the beaches and inland dunes for resting and/or foraging. Bald eagles forage along the ocean surf for fish and prey upon dead or dying marine mammals and birds that are washed up in the beach wrack line. There are several known Bald eagle nests within the project area but no nests are known to occur within treatment units. Some nests may be within 0.25 miles of a project area but disturbance to known nests would be avoided by implementation of project design criteria #605. • No project or associated activities would be implemented between January 1 and August 31 within 0.25 mile or a 0.5-mile sight distance of a known Bald eagle nest site, unless the unit biologist verifies that the nest is unoccupied. (PDC 605)

Purple Martin (progne subis) Purple martin feed on flying insects in open habitats such as water bodies, marshes, clearcuts, fields and high above the canopy of forests. They nest in natural (snags) and artificial cavities quite often over open water although this is not an obligate requirement. Nest trees are typically greater than 20 feet from live trees (Horvath 2003). Purple martin are uncommon to rare within the project area but have been documented nesting in natural snags as well as in man-made nest boxes.

Western Pond Turtle (Actinemys marmorata) This species account is taken from Rosenberg et al. (2009). The western pond turtle is associated with a variety of aquatic habitats, both permanent and intermittent, where emergent basking sites such as logs, mud banks, or tule mats are available. In streams and rivers, western pond turtles most frequently occupy low-velocity waters and particularly deep pools. A high density of emergent vegetation that contributes to a high density of invertebrate prey appears to be selected by turtles in many aquatic habitats. Pond turtles use upland areas to disperse, nest, overwinter, and aestivate. Little is known about the dispersal of western pond turtles. Although they may move overland between drainages, genetic analyses suggest that most movements occur within drainages. Most studies using telemetry show pond turtles overwinter within 250 m of water. Terrestrial over- wintering sites include a much broader array of vegetation structure than nest sites; shrubby, open, and forested environments have all been used. Nesting habitat is usually in areas of sparse vegetation consisting of grass and forbs, with compact soils. Nesting habitat is also characterized by good solar exposure with little or no tree canopy cover that would shade the nesting site. Although soil composition may vary, almost all nests occur within 200 m of the turtles’ aquatic habitat.

Primary threats to the conservation of western pond turtles in Oregon include loss of habitat, elevated nest and hatchling predation, road mortality, competition from introduced species, unauthorized collection and release and recreational disturbance. Within the project area threats to pond turtle conservation include disturbance from human presence, including foot, boat and motor vehicle traffic. Invasive plant infestations near waterways may negatively impact basking and nesting habitat.

Status of the western pond turtle within the project area is unknown, however adults have been documented within the project area. Pond turtles have occasionally been documented on sand roads providing access to treatment units within the ODNRA and in some of the coastal lakes adjacent to the project area and within some of the associated streams and river systems that flow through the project area. Most all pond turtle habitat is found outside of proposed treatment units but individuals may occasionally occur along the edges of some treatment units.

38 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Fringed Myotis (Myotis thysanoides) Fringed myotis roost in natural (i.e. rock crevices, cliff faces, caves and mines) and artificial (buildings and bridges) crevices (Maser et al. 1981). Fringed myotis utilize, but not dependent upon, snags or down woody material. Primarily nocturnal in their activities, they feed on a variety of invertebrates, primarily beetles and moths. Foraging primarily occurs in riparian forest areas.

Siuslaw Hairy-necked Tiger Beetle (Cicindela hirticollis siuslawensis) Siuslaw hairy-necked tiger beetles are associated with sandy habitats at river mouths of Pacific coast beaches, inland up coastal rivers (up to 1.5 km upstream), in backwater wetlands or sandflats, and at or near the water’s edge. Adults and larvae of this subspecies prefer firm, flat, moist sand close to the freshwater outflows, areas near the high water mark, and on backwater sandflats (Fallon and Jepsen 2015; Pearson et al. 2015; Mazzacano et al. 2010). Utilized habitat is characterized by a lack of compaction in larval burrow areas by human foot or ATV traffic.

Adult females lay eggs singly in moist sand. After they hatch, the grub-like larvae dig small burrows in the sand and live there for one to three years while they develop (Fallon and Jepsen 2015; Pearson et al. 2006). Along waterways larval burrows are concentrated in transition zones near the high water line at the interface of wet and dry sand and in lightly vegetated backwater sandflats (Mazzacano et al. 2010). Within inland dunes larval burrows are found in sparsely vegetated areas of moist sand. Adult beetles excavate and inhabit shallow crescent-shaped burrows in dry sand slightly upland from larval burrow habitat. Adults use these burrows at night time and also for overwintering.

Within the project area Siuslaw hairy-necked tiger beetles are associated with coastal rivers and creeks and have also been documented in wind scoured wet sand habitats within inland sand dune systems along the eastern edge of deflation plains and in wet sand at the base of dune slopes. Surveys of coastal rivers within the project area in 2009 and 2010 by Mazzacano et al. documented this species at 6 coastal sites, 4 of which are within the project area. While this species has been documented within some inland project units formal surveys have not been conducted.

Tiger beetles are highly vulnerable to anthropogenic disturbances such as trampling and compaction from recreation (pedestrian foot traffic, public beach use) and vehicle use. Larval burrows are often concentrated in the areas of firm moist sand immediately adjacent to or very near the stream outflow area; this is also a preferred area for human and dog traffic and thus likely to be impacted by even moderate levels of human recreational use. Since adult burrows are generally empty during the day when beetles are hunting and mating, they are less likely than larvae to be trampled in their burrows. Cornelisse and Hafernik, 2009, found that repeated trampling and soil compaction may decrease the number of larval tiger beetle burrows in an area. Their study also indicated that protection of microhabitats, restoration

Western Bumble Bee (Bombus occidentalis) Bumblebees will visit a range of different plant species and are important generalist pollinators of a wide variety of flowering plants and crops. Although bumblebees do not depend on a single type of flower, some plants rely solely on bumblebees for pollination. In addition, native bees, such as bumblebees are adapted to local conditions. Threats to Western bumble bees include commercial bumblebee rearing, habitat alteration, insecticides, invasive plants and insects and global climate change. Prior to 1998 Western bumble bees were common throughout their range. Since 1998 populations have experienced a drastic decline, having largely disappeared in many parts of its former range, including western Oregon. The status of the western bumble bee within the project area is unknown.

39 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Coastal Greenish Blue Butterfly (Plebejus saepiolus littoralis) The coastal greenish blue butterfly is associated with stream edges, bogs, salt spray meadows, wet meadows or moist depressions in the lee of sand dunes but can be found along drier sites that have blooming clovers such as roadsides and open meadows. Eggs are laid in clover flowers such as Trifolium monanthum, T. longipes and T. wormskioldii. The species overwinters as a caterpillar in flower heads of the host clover. This species, along with its host plant T. wormskioldii, have been documented within deflation plain habitats in the project area. Threats to the coastal greenish blue include human development, succession of moist meadow or dune habitat to shrub/woodland habitat, competition from invasive plants, trampling by humans, livestock or off-road vehicles.

American Peregrine Falcon (Falco peregrinus anatum) Although once rare on the Oregon Coast, the peregrine falcon now inhabits coastal areas year round, and can frequently be seen within the project areas. Decades of widespread use of DDT lead to reproductive failure and subsequent Federal listing of this species. Due to a ban on the use of DDT and other chlorinated hydrocarbons in 1972, as well as an intensive captive breeding and rearing program, populations rebounded enough to allow delisting of the species in 1999.

In Oregon, peregrines occur as resident and migratory populations. Adults remain in the vicinity of nest sites throughout the year at Pacific Northwest locales below approximately 4,000 ft. elevation. Peregrine falcons typically nest on cliffs greater than 75 ft. in height or structural features of bridges, and within 1 mi. of some form of water. Their primary prey item is birds (Henny and Pagel, 2003).

The project area does not contain any nesting habitat for this species. Peregrine falcon utilize all open habitats within the project area such as the ocean beach, foredune, early seral edges of the deflation plain and adjacent open sand areas for opportunistic hunting of birds such as gulls and shorebirds.

Aleutian Canada goose (Branta hutchinsii leucopereia) This species, one of five subspecies of Canada geese, winters primarily in pastures and grain fields along the coasts of Oregon and northern California, and in California’s Central Valley. Although this subspecies is known to winter primarily along the coast in the Tillamook area, considerably north of the project area, inland lakes and flooded deflation plains within the project area could be used occasionally.

Pileated Woodpecker (Dryocopus pileatus) and Primary Cavity Excavators Pileated woodpeckers prefer mature forests and younger forests with large snags and logs, requiring large diameter snags for nesting and foraging. Primary cavity nesters can utilize small to medium sized dead and defective trees.

The management objectives, standards and guidelines and associated monitoring questions for pileated wood peckers and primary cavity nesters were developed in concert with the anticipated harvest levels in forests outside of the project area. The Northwest Forest Plan, as well as Siuslaw National Forest Plan management objectives, standards and guidelines and monitoring set in place to maintain healthy and viable populations of pileated woodpecker and primary cavity excavators was primarily tied to the Forest’s Late Successional Reserve areas which are outside of the Sutton Recreation Area and ODNRA.

Roosevelt Elk (Cervus canadensis roosevelti) Roosevelt elk were selected as a management-indicator species for early seral habitat, meadows and cover. Elk are found throughout the project area although more commonly within the Sutton Recreation Area than the ODNRA where they are only found occasionally. Within the project area elk primarily utilize Douglas fir/Sitka spruce transition forest and occasionally shore pine forest. Open sand dune habitats, especially in motorized use areas, are normally avoided. They are infrequently documented on beaches and foredunes.

40 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Management Indicator Species Forest management indicator species include the following species: Northern spotted owl, Marbled murrelet, Oregon silverspot butterfly, western snowy plover, Pacific marten, American Peregrine falcon, Bald eagle, California brown pelican, Aleutian Canada goose, Pileated Woodpecker, Primary cavity excavators and Roosevelt Elk. Northern spotted owl, Marbled murrelet and Oregon silverspot butterfly are not expected to occur within the project area and therefore will not be affected by the project. .

Landbird Assessment Landbirds, including migrant and resident species, are those that generally use terrestrial and wetland habitats. Habitats these species occupy in the project area include forest canopies, ground vegetation/structure, and existing openings. Partners in Flight (PIF) has developed five conservation plans that cover the various geographic regions found in Oregon and Washington. These documents have been prepared to stimulate and support a proactive approach to the conservation of landbirds throughout Oregon and Washington. They represent the collective efforts of multiple agencies and organizations within Oregon and Washington. Participants included biologists from federal and state agencies, industry, private consulting firms, environmental organizations, and academia in order to ensure a full range of ideas and practicalities were addressed by the plans. The plan that is applicable to the forested habitats within the project area is the Conservation Strategy for Landbirds in Coniferous Forest of Western Oregon and Washington and can be found on the OR-WA PIF web site at https://www.avianknowledgenorthwest.net/images/aknw/pdfs_cons_plans/OR%20WA%20PIF%20Western_Con ifer_Plan_new.pdf The overall goal of PIF Bird Conservation Planning is to ensure long-term maintenance of healthy populations of native landbirds. These documents are intended to facilitate that goal by identifying conditions and habitat attributes important to the landbird community, describing the desired landscape based on habitat relationships of a select group of species, providing interim management targets (i.e., biological objectives) to achieve desired conditions, and recommending management actions (i.e., conservation options) that can be implemented by various entities at multiple scales to achieve the biological objectives. The appropriate PIF OR/WA Bird Conservation Plan (Habitat Conservation for Landbirds in Coniferous Forests of Western Oregon and Washington (Altman and Alexander 2012) and USFWS, Birds of Conservation Concern (BCC) species list for Bird Conservation Region 5) for the Oregon Dunes Restoration project area was reviewed. Those species and habitats that are within the project area are incorporated and effects disclosed in this analysis. Table 28 displays a list of Birds of Conservation Concern (BCC) in the Oregon Dunes Restoration Project area that are known or likely to be present and could be affected by the proposed actions. Bird Conservations Regions (BCRs) were developed based on similar geographic parameters. One BCR encompasses the project area, (BCR 5- Northern Pacific Rainforest).

Table 27. BCR 5 (Northern Pacific Forest U.S. portions only) BCR 5 (Northern Pacific Forest U.S. portions only) Yellow-billed Loon (nb) Marbled Godwit (nb) Western Grebe (nb) Red Knot (roselaari ssp.) (nb) Laysan Albatross (nb) Short-billed Dowitcher (nb) Black-footed Albatross (nb) Aleutian Tern Pink-footed Shearwater (nb) Caspian Tern Red-faced Cormorant Arctic Tern Pelagic Cormorant (pelagicus ssp.) Marbled Murrelet (c) Bald Eagle (b) Kittlitz's Murrelet (a) Northern Goshawk (laingi ssp.) Black Swift Peregrine Falcon (b) Rufous Hummingbird

41 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

BCR 5 (Northern Pacific Forest U.S. portions only) Black Oystercatcher Allen's Hummingbird Solitary Sandpiper (nb) Olive-sided Flycatcher Lesser Yellowlegs (nb) Willow Flycatcher (c) Whimbrel (nb) Horned Lark (strigata ssp.) (a) Long-billed Curlew (nb) Oregon Vesper Sparrow (affinis ssp.) Hudsonian Godwit (nb) Purple Finch (a) ESA candidate, (b) ESA delisted, (c) non-listed subspecies or population of T or E species, (d) MBTA protection uncertain or lacking, (nb) non-breeding in this BCR.

Table 28. Landbirds that are of conservation concern and that would be expected to use the project area and effects to habitat.

Impacts to Habitat Species General Habitat Requirements Alternative 1 Alternatives 2 and 3 No Action

GAME BIRDS Nest primarily in closed Douglas-fir stands with canopy cover above 70 percent. Key Band-tailed Pigeon food sources include red elder, cascara and Mature Douglas-fir stands will Mature Douglas-fir stands will not be (Columba other berry, fruit and mast producing shrubs remain unchanged impacted by the proposed action. fasciata) and trees. Mineral springs/seeps are important and provide essential calcium for nesting.

BIRDS OF CONSERVATION CONCERN (BCC)

Disturbance from project activities could No effects from disturbance. affect some individuals. Loss of some small Bald Eagle Associated with coasts, rivers, lakes, and Continued expansion of conifer conifer from project activities would not be at (Haliaeetus marshes with nearby tall trees or cliffs for forest may provide additional a scale that would negatively affect nesting or leucocephalus) nesting nesting habitat. perch trees. No habitat removed, PDC protections in place.

No effects from disturbance. Beach Cliffs overlooking fairly open areas with an habitats for shorebird and gull Disturbance from project activities could ample food supply. Nest along sea coasts, foraging would not be affected. Peregrine Falcon affect some individuals. No nesting habitat near marshes, and even in cities. Usually Inland dunes will continue to fill in (Falco peregrinus) would be affected. Impacts will be localized nests or roost near a marsh, lake or coast with vegetation possibly diminishing and minor. where waterbirds are plentiful. wetland areas that may attract prey species.

Commonly found on coastal estuarine mud Species only present during spring and fall flats and on sandy ocean beaches. shorebird migration. No impact from Whimbrel Occasionally on the coast on rocky beaches No effect from disturbance. No disturbance because no project actions take (Numenius and in pastures. Diet primarily consists of effect to foraging habitat (ocean place on the beach from March 15-September phaeopus) marine invertebrates including crabs and beach). 15. No impact to foraging habitat (ocean other crustaceans, marine worms, mollusks beach). and fish. Primarily associated with forest edges and openings with a diversity of flowering plants for feeding and open space Frequently Removal of some conifer trees may slightly Rufous occurs in open habitats that are shrub- No effect from disturbance. reduce future nesting habitat. Removal of Hummingbird dominated, and late-successional forest Expansion of conifer forest may non-native invasive vegetation will allow (Selasphorus with a highly developed and diverse provide additional nesting habitat native species to become established and may rufus) understory of herbaceous plants and shrubs, benefit plant diversity and foraging. particularly within large openings. Need flowering plants and shrubs.

42 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Removal of some small conifer trees may Allen’s Breeds in coastal scrub, riparian thickets in slightly reduce future nesting habitat in some No effect from disturbance. Conifer Hummingbird moist canyon bottoms and in the brushy project areas. Removal of non-native invasive forests and brushy areas will (Selasphorus edges, usually near meadows of redwood vegetation will allow native species to become continue to expand sasin) and other coniferous forests. established benefit plant diversity and foraging.

Associated with natural or man-made Tall conifer and snags will not be impacted by openings with tall trees or snags available the proposed action under both Action Olive-sided for perching and singing. In the Oregon Alternatives. Removal of small conifer from Conifer trees and snags used for Flycatcher Coast Range, closely associated with edges the perimeter of open sand areas would limit nesting and foraging habitat will not (Contopus of older stands with tall trees and snags formation of mature trees and snags in the be impacted cooperi) greater than 21 inches diameter breast height future. Restoration of native plant and broken canopy. Within the project area communities may be beneficial to insect tree islands are frequently used. populations used for prey. Usually associated with willows at the edges Some willow habitat may be removed in the of streams flowing through meadows and Baker Beach area to allow for sand movement Willow Flycatcher marshes, but also breeds in thickets along Willow and Scotch broom habitats Scotch broom thickets would be removed (Empidonax the edges of forest clearings and general in would be unchanged from project units. Treatments could reduce traillii) tall, brushy vegetation in the vicinity of available habitat in local areas, impacting water. Occasionally uses Scotch broom some individuals. thickets for nesting. Breeds primarily in moderately moist open or semi open coniferous forests. Also While most established forests within the frequently found in mixed coniferous- Purple Finch project area approximately 30 acres of mixed deciduous forest, edges of bogs, and riparian Established forests within the project (Carpodacus coniferous-deciduous forest would be corridors at low to mid-elevations. In area would not be treated purpureus) removed potentially affecting some Klamath Eco region, the presence of individuals. Ponderosa Pine and oak provide a unique habitat component.

Wildlife Environmental Consequences

Alternative 2 — Within the Sutton Recreation Area (Baker Beach), Alternative 2 proposes to restore the landscape process of sand movement by connecting the ocean beach (unit 1.6) with inland sand dunes (unit 1.3). This objective would be accomplished by removing nearly all vegetation within unit 1.5 (56 ac.) including approximately 30 acres of shore pine forest shown in the southern portion of Map B of Appendix A. Much of the forest within the Sutton Recreation Area, including the forest in unit 1.5, is composed of a shore pine/Sitka spruce overstory with ericaceous shrub understory and is considered suitable marten habitat.

Alternative 3 — Alternative 3 proposes all of the same actions as Alternative 2, with the exception of unit 1.5 in the Baker Beach area. Under Alternative 3, approximately 30 acres of vegetation serving as marten habitat would not be treated (removed).

Table 26 lists wildlife species that do not occur or suitable habitat is not present in the Project area. Because there is no suitable habitat in the Project area, these listed species would not be affected by any alternative. • marbled murrelet (Brachyramphus marmoratus) (T), • northern spotted owl (Strix occidentailis caurina) (T), • Oregon silverspot butterfly (Speyeria zerene hippolyta) (T) • Wolverine (Gulo gulo) (FPT), • foothill yellow-legged frog, and • Oregon red tree vole

43 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Federally Listed Wildlife Species — Western snowy plover - (Charadrius nivosus nivosus)

Alternative 1 – No Action The No Action Alternative would have no effect on Western snowy plovers from disturbance because No Actions would occur during the nesting period (3/15-9/15). Because the No Action Alternative would not curtail the continued encroachment of non-native vegetation into currently suitable nesting habitat, the amount of suitable nesting habitat would continue to decline. Further decline of suitable habitat would likely contribute to reduced nesting success along beaches in the Sutton Recreation Area and ODNRA. As foredunes expand and become more densely vegetated adjacent beach nesting habitat would narrow, reducing nesting habitat available to snowy plover. Previous NEPA analysis allows for restoration of the Sutton/Baker Beach foredune using almost all of the same restoration activities that are proposed in this analysis. Therefore, the No Action Alternative would not affect this reach of beach as severely as beaches on the Oregon Dunes National Recreation Area. Most snowy plover habitat, including designated critical habitat, on the ODNRA is not currently covered by NEPA analysis that allows for restoration of the foredune to a more useable condition for snowy plover. Therefore the No Action Alternative would negatively impact suitable habitat by allowing further loss and decline of some of the key critical habitat components because non-native vegetation would be allowed to spread unchecked across beach and foredune habitats. While snowy plover would continue to thrive in current nesting areas on the ODNRA current nesting areas may reach carrying capacity more quickly than if more habitat was made available. . Predator cover would continue to expand and may further hamper nesting success and species recovery efforts. Plover are known to use two small areas at the eastern edge of deflation plains. Both of these areas are expected to persist over time and remain useable to snowy plovers therefore, effects to deflation plain areas from the No Action Alternative are not expected to affect Western snowy plover.

Alternative 2 and 3 The following effects are expected for both Action Alternatives (2 and 3).

Overall the Oregon Dunes Restoration Project is expected to beneficially effect the Western snowy plover. Implementation of the Oregon Dunes Restoration Project has the potential to create up to 874 more acres of suitable habitat for snowy plover over the life of the project and as available habitat increases it is probable that snowy plover populations on the Siuslaw National Forest would increase. Creating new foredune nesting areas would allow snowy plovers to nest further away from wet sand areas used by recreationists and therefore is expected to reduce human disturbance impacts to nesting snowy plover.

Proposed mechanical, manual and herbicide treatments within units 1.6, 2.1, 10, 15, 16, 20, 32, 34, 36 and 40 (Appendix A) have the potential to impact snowy plover because these units are along the beach foredune or contain snowy plover nesting and/or wintering habitat that snowy plovers are known to use. Prescribed burning in these units, as well as all other units where prescribed fire is proposed has the potential to produce smoke along the beach that could cause snowy plover to flee. Implementation of the above listed design criteria would ensure that project activities would only affect mobile, adult snowy plovers and that disturbance effects from people and vehicles associated with treatments would be short-term, localized, and minor.

Snowy plover, almost exclusively wintering birds, have been documented using localized sites within treatment units 34 (Map F, Appendix A) and 36 (Map D, Appendix A) where motorized use is allowed . Past experience indicates that if snowy plover are present within treatment unit 34 there is a high likelihood that they would occupy the area for an extended period of time putting them at risk of vehicle strikes. Therefore, when plovers are discovered in unit 34 they would be protected by an area closure marked by a symbolic fence line as long as they persist there. There is no existing vegetation within the area that snowy plovers typically occupy in unit 34 therefore the only potential effect would be disturbance from trucks or heavy equipment passing by the fenced off closure area. Disturbance from passing vehicles and heavy equipment is expected to be short in duration and noise generated is expected to be within ambient levels (maximum of 93 decibels allowed in OHV areas).

44 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Casual observations of snowy plover use within unit 36 indicate that snowy plover use in this area is infrequent and short in duration (<24hrs) therefore disturbance from project activities is less likely. The area within unit 36 that plovers inhabit is currently unvegetated although patches of invasive plants are much closer than in unit 34. It is possible that proposed treatments could take place near snowy plover. Workers, trucks and heavy equipment accessing the project unit or working in proximity to wintering snowy plovers could potentially cause disturbance. Noise generated from workers, vehicles and heavy equipment is expected to be within ambient levels. To decrease the risk of vehicle strikes from workers associated with implementation of dunes restoration projects drivers would be advised of plover safe driving protocols before starting work. Because this area is a large patch of open sand snowy plovers do have the ability to move short distances to avoid disturbances while still remaining in like habitat.

Treatment units 17 (Map F, Appendix A) and 21 (Map G, Appendix A) are located inland from the ocean beach and do not contain what is considered to be nesting habitat for snowy plover therefore project actions would have no effect to snowy plover during the breeding season. Since these areas are large expanses of open sand that offer habitat that is similar to the intermittent use areas in units 34 (Map F, Appendix A) and 36 (Map D, Appendix A) it is possible that these treatment units may be occasionally used by wintering snowy plover. If wintering plover are detected within units 17 and 21 effects are expected to be the same as for units 34 and 36.

To protect nesting snowy plover from vehicle traffic the Siuslaw National Forest would coordinate with OPRD to ensure that vehicles have been restricted on the adjacent OPRD managed wet sand beach per the Snowy Plover Habitat Conservation Plan (ICF International 2010) prior to implementation of habitat restoration measures in unit 32.

Snowy plover have not been documented within treatment units 1.1, 1.3, 1.4, 1.5, 1.7, 1.8, 1.9, 2.2, 3, 5, 15.1, 17, 18, 20.2, 21, 24, 26, 27, 28, 29, 31, 33, 35, 36.1, 36.2, 36.3, 37, and 39, 50 and 51 (Appendix A). These units do not contain snowy plover nesting or wintering habitat, are located inland, and are disconnected from Pacific Ocean beaches where snowy plover are expected to occur. Proposed treatments to control invasive plants using mechanical, manual or herbicide methods within these areas are not expected to generate noise above ambient levels on ocean beaches where snowy plover occur. Personnel and equipment would not need to pass through snowy plover habitat to access these inland areas. For these reasons project associated actions within these units would have no effect on nesting or wintering snowy plovers.

Capacity for recreational use, both motorized and non-motorized, within project units is constrained by availability of parking and campsites. No additional parking areas, campsites, trails or OHV riding areas or designated routes are proposed by the project therefore capacity for recreational use would not change within motorized and non-motorized areas. No new access to non-motorized beaches would be created by the proposed project and vegetation removal within designated OHV areas is not expected to result in any increase in trespass of vehicles on to non-motorized beaches. Sites within project units 34 (Map F, Appendix A) and 36 (Map D, Appendix A) that have documented intermittent use by wintering snowy plover are currently unvegetated but treatments could take place nearby. Implementation of project design criteria is expected to mitigate any potential adverse effects to snowy plover.

Dense vegetation, such as that which occurs on the foredune, may act as a barrier or deterrent to human foot travel through the dunes landscape. Removal of vegetation from the foredune may allow recreationists to travel more freely across the dunes landscape, straying from designated trails, and could potentially result in an increasing frequency of trespass into symbolically fenced nesting areas. To minimize impacts from human trespass into nesting areas the Siuslaw will use strategies such as constructing sand berms adjacent to sections of hiking trail passing through the foredune that would provide a visual barrier, installing assurance posts (trail markers) and/or symbolic fence to direct foot traffic across foredunes to the wet sand beach will be utilized. Such strategies have already been tested and found to be successful at the Siuslaw’s Overlook nesting area in the early 2000’s during implementation of the Overlook Dunes Restoration Project. Removal of vegetation next

45 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

to hiking trails will occur slowly over the life of the project so that successful strategies can be put into place at one site before moving to another. Any increase in human disturbance is expected to be mitigated by the fact that newly created nesting habitat will allow snowy plovers to nest further inland from the wet sand beach where recreation occurs.

Designated Critical Habitat — Western snowy plover

Alternative 1 – No Action The final rule for designation of critical habitat for the Western snowy plover was published in the Federal Register on June 19, 2012 (U.S. Fish and Wildlife Service 2012). This rule established 16 Critical Habitat Units (CHUs) in Oregon. There are six critical habitat units designated on the Siuslaw: Five were designated primarily for nesting habitat and are included in the proposed Project area. One CHU, OR-8A, was designated for wintering habitat and is not included in the proposed Project. • Key components of designated critical habitat for Western snowy plovers include but are not limited to areas that support or have the potential to support sparsely vegetated foredune, interdune flats, spits, wash-over areas, and river estuaries. The beach and foredune areas within the Project area currently have these components or have the potential to provide these components. The No Action Alternative would negatively impact critical habitat by allowing further loss of some of the key critical habitat components because non-native vegetation would continue to spread across beach and foredune habitats. The No Action Alternative would greatly compromise the suitability of all critical habitat sites on the Siuslaw National Forest except for OR-8A. Therefore, the No Action Alternative is likely to adversely affect Western snowy plover and their designated critical habitat.

Alternatives 2 and 3

The following effects are expected for both Action Alternatives (2 and 3).

• The Final Rule (USFWS 2012) listed the following threats that may require special management within CHU’s within the Project boundary: o Sand dunes that are being degraded due to encroachment of introduced European beachgrass. o Disturbance from humans, pets, and horses in important foraging and nesting areas. o Presence of predators. o Vehicle trespass into closed areas Invasive plant treatments within snowy plover critical habitat would be implemented to restore the function of the primary constituent elements, which have been significantly reduced by species such as European beachgrass and Scotch broom. The proposed action would improve the overall condition of critical habitat areas for nesting and wintering snowy plover by reducing the amount of non-native invasive vegetation within plover critical habitat. Removal of non-native vegetation is expected to have the beneficial effect of reducing the amount of habitat available for snowy plover predators such as northern harrier and coyote. In total, proposed treatments within snowy plover critical habitat could improve an additional 874 acres of snowy plover critical habitat, significantly expanding the amount of habitat available for nesting and wintering birds.

Previous invasive plant treatments implemented by the Siuslaw National Forest have successfully created nesting habitat using similar methods at Baker/Sutton Beaches and Oregon Dunes Day Use Area (Overlook) so it is highly likely that habitat restoration proposed in this project would also be successful. Project activities would not take place when snowy plovers are nesting and rearing broods. Some project activities could take place after August 15 if Forest Service biologists and monitoring determine that nesting and brood rearing is completed for the season in the area of expected impact.

46 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA While the proposed project is expected to be largely beneficial to snowy plover critical habitat removal of dense vegetation from foredunes has the potential to allow recreationists to more easily stray from designated trails and potentially wander into nesting areas. Continued public outreach, placement of symbolic fencing and implementation of design criteria are expected to minimize any negative effects.

Federally Proposed Species – Pacific marten (Martes caurina)

Alternative 1 – No Action Under the No Action Alternative, no Project activities would occur. Since no activities would occur and this species generally is not found in these habitat types, no disturbance effects to Pacific marten are expected. Under the No Action Alternative, no activities would occur and the following would be expected: • Since no activities would occur, no direct disturbance effects to Pacific marten are expected. • Suitable marten habitat is expected to expand over time and allow marten populations to increase. • Connectivity between habitat patches would be expected to develop further. • An increase in densely forested habitat may provide marten increased security from predators such as bobcat and coyote in their home range. For these reasons, implementation of the No Action Alternative is expected have a beneficial effect on Pacific marten. • Vegetation along the forest edge would be allowed to expand into adjacent open sand areas.

Alternative 2 Alternative 2 refers to what was called the Modified Proposed Action in the Draft EA; it is now identified as Alternative 2 in this document. Within the Sutton Recreation Area (Baker Beach), Alternative 2 proposes to restore the landscape process of sand movement by connecting the ocean beach (unit 1.6) with inland sand dunes (unit 1.3). This objective would be accomplished by removing nearly all vegetation within unit 1.5 (56 ac.) including approximately 30 acres of shore pine forest shown in the southern portion of Map B of Appendix A. Much of the forest within the Sutton Recreation Area, including the forest in unit 1.5, is composed of a shore pine/Sitka spruce overstory with ericaceous shrub understory and is considered suitable marten habitat.

Removal of 30 acres of forest would cause an 11 percent reduction in this modelled female home range as well as potentially disconnecting it at the northern extreme from about 45 more acres of suitable habitat in that home range. Forest within unit 1.5 that is proposed for removal provides a connection between the deflation plain forest and mature shore pine forest growing to the northeast of unit 1.5. Loss of this forested patch would create an unvegetated gap in the forest approximately 0.25 miles wide. Martens traversing this gap would be at increased risk of predation due to the lack of protective vegetative cover. Loss of this forest may force marten to increase energy expenditures when foraging which may have a negative effect on fitness. Loss of 30-75 acres or 11- 27 percent of the forest in that home range would further limit availability to foraging habitat which could negatively affect fitness of juveniles and adults. Reductions of as little as 25-30 percent of the forested cover can cause marten declines (Hargis et al. 1999; Potvin et al. 2000). Such a reduction of habitat within the home range may render it non-viable for marten. A reduction in the number of available home ranges is expected to result in a population decline.

The existing marten population on the central Oregon coast is vulnerable to extirpation due to its small size (an estimated 71 adults) and its apparent isolation from other populations. Linnell’s recently published population viability analysis determined that the extinction risk for either of the two ODNRA subpopulations strongly increases with even a small amount (2-3) of annual human-caused mortalities. Any increase in human-caused mortality is expected to negatively impact the population. Fragmentation and loss of habitat within this marten home range could cause the loss of individual marten and therefore is likely to contribute to a trend towards federal listing or cause a loss of viability to the population or species.

47 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Alternative 3

Home Range Habitat Within the project area, there are 17,430 acres of marten home range habitat within 36 theoretical female territories. There are approximately 1,969 acres of home range habitat within four female territories in the Sutton Recreation Area and about 226 of those acres (11%) are within 12 project units. The ODNRA encompasses an estimated 15,461 acres of home range habitat within 32 theoretical female territories. About 1,933 acres (13%) of home range habitat are within 28 ODNRA project units.

In total, project units encompass about 13,836 acres, and of that, about 2,324 acres or 17% are considered marten home range habitat. The remaining 11,495 acres are below 40 % canopy closure and are not considered home range habitat. Therefore, the majority of the treatment unit acreage, about 83%, is characteristic of more open dune vegetation were canopy closure of vegetation is less than 40% and is not considered marten home range habitat. Approximately 360 acres have been reserved for providing connectivity between patches of home range habitat. Corridor habitat are made up of various habitat types ranging from dense vegetation to scattered patches.

During the development of the project an effort was made to minimize the amount of home range habitat within most project units. Most often home range habitat within project units is limited to narrow bands of forest along the perimeter of treatment units but several project units do contain large tracts of habitat. For the purpose of limiting re-infestation of open sand with non-native invasive plants the project seeks to remove non-native plants from home range habitat where greater than 40 percent canopy cover can be maintained.

Removal of non-native vegetation within home range habitat could have adverse impacts such as disturbance to individuals including denning females and kits. Disturbance during spring and early summer when females are caring for young in dens could potentially result in maternal den abandonment. Since marten often avoid openings by moving greater than 50 meters within forest patches marten presence and therefore, incidence of dens, may be lower along forest edges and existing disturbance corridors such as motorized routes. Disturbance from non-native vegetation removal are expected to be short term as workers walk through the forest. To limit potential disturbance to denning females with kits vegetation removal would be restricted to within 25 meters of existing edge or disturbance corridors from March through June when females and kits may be less mobile. Disturbance from vegetation removal along forest edges are expected to be insignificant and discountable because vegetation treatments would be limited spatially and temporally by project design criteria, martens range over a large area and the probability of marten presence along forest edges is lower than in interior habitats.

While non-native vegetation may be of some benefit to marten, by providing either protective cover or forage for prey species, it is likely that native vegetation may be more beneficial to the species. Removal of non-native vegetation may release native brush species promoting a growth response. If removal of non-natives stimulates growth of native brush it may cause the understory to increase in density providing marten greater security from predators and increased foraging opportunities for marten and marten prey species over the long term.

Implementation of Project design criteria would limit adverse impacts to marten home range habitat (see Project Design Criteria starting on page 25.)

Removal of Edge Vegetation This project proposes removal of vegetation adjoining the forested edge of treatment units. Most proposed edge treatments abut forest that is considered suitable marten home range habitat. The extent of vegetation removal is expected to be variable within unit boundaries as well as from unit to unit therefore effects to marten from removal of edge vegetation are expected to be variable as well.

48 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Telemetry study of marten in the Oregon Central Coast found that martens were most often found in forest where the average median combined overstory and understory cover was 81 percent however marten were also found to use areas with less than 25 percent canopy cover.

To quantify effects of edge removal miles of edge within each project unit that intersected with female marten home range habitat were calculated. This sum was then divided by the miles of edge of each mapped theoretical female home range. This enabled consideration of miles of project unit edge relative to the amount of edge in each theoretical female home range. This analysis was then used to develop design criteria to minimize risk of adverse effects to marten. References to the allowable percentage of edge removal refers to this analysis.

Treatments of perimeter vegetation would halt encroaching European beachgrass and woody plant species (Shore pine, Scotch broom, gorse etc.) and maintain or create open sand conditions for sand obligate wildlife and plants. Two types of edge treatments, “scattered edge” and “buffer edge”, are proposed.

Scattered Edge Habitat Scattered edge treatments would remove small conifer and both native and non-native shrubs that are scattered along the perimeter of project units (see Figure 7 and Figure 8). Native trees and woody shrubs to be removed are separated from more densely forested patches, are unlikely to provide enough cover to provide marten security from risk of predation while foraging, and are not contributing to connectivity of home range habitat. Since marten often avoid openings by moving greater than 50 meters within forest patches marten presence is expected to be only incidental along edges.

Buffer Edge Habitat Within some project units edge vegetation adjoining marten home range habitat is composed of a wide band of predominately non-native vegetation, such as mature Scotch broom. Under the proposed action this vegetation would be removed (Figure 9). Canopy closure within buffer edge habitat is less than 40 percent and, similar to scattered edge habitat, marten presence is expected to be infrequent. Buffer edge habitat does provide much more continuous canopy cover than scattered edge habitat therefore it could be more frequently used by marten. It is unknown if, or to what extent, marten utilize Scotch/Portuguese broom/gorse dominated areas that are contiguous with more densely vegetated forest areas that are known to be inhabited by marten. It is possible that this strip of vegetation could provide dispersal habitat for juvenile marten, foraging opportunities, or buffer home range habitat from disturbance. Preliminary game camera observations within buffer edge habitat have documented marten forage species such as Douglas squirrel, chipmunk, brush rabbit, thrush and other bird species, however, bobcat and coyote, known marten predators, were also noted.

Many of the proposed vegetation treatments are on the foredune or along the perimeter of open sand dunes. These are areas where marten are either not expected to occur or where they would be expected to occur infrequently. Marten are not expected to occur on foredunes where there is little if any woody vegetation cover. At most they would be expected to occur there very rarely due to the lack of protective cover from predators.

Over the entire project area approximately 12 percent of modeled home range habitat would be directly affected by proposed actions. Implementation of design criteria would limit disturbance and negative effects to home range habitat. Since no home range habitat is proposed for removal and a minimum of 40 percent canopy cover would be maintained, negative effects to home range habitat are expected to be limited to minor and localized human disturbance. Due to the large size of the project area it is expected that vegetation treatments would occur gradually over a long period of time, further limiting negative impacts to localized areas within any one year. Gradual removal of non-native invasive vegetation from home range habitat and concurrent release of native vegetation is expected to be beneficial to marten over the long term. Adaptive

49 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

management and monitoring of native vegetation response to treatments would assist in guarding against unexpected negative effects associated with the removal of non-native vegetation.

Removal of vegetation from the edges of project units will limit the overall expansion and development of marten habitat over the life of the project creating a more abrupt transition from forest to open sand. Although it is unlikely that territorial marten spend considerable amounts of time in scattered edge and buffer habitats, since they provide minimal protective cover from predators, it is possible that these habitats may be of some benefit to the species. Use of different types of edge habitats by marten on the central coast has not been studied so the extent and frequency with which marten may use these areas for dispersal and foraging is unknown. Research has shown that central coast marten tend to use areas with dense and diverse shrub communities which provide protective cover and foraging opportunities (Moriarty et al. 2019) therefore edge habitats may be of lesser importance. Although it is unknown how removal of edge vegetation may influence prey species, dispersing juveniles, martens within their home ranges or movements of marten predators, such as bobcat and coyote implementation of design criteria is expected to limit adverse effects to those that are insignificant and discountable.

Connectivity Corridors Maintaining functional connectivity between patches of forest habitat, including both north-south and east- west linkages, is essential for gene flow, juvenile dispersal, the ability of males to access multiple females within existing habitat and for population supplementation and persistence. Connectivity between habitat patches also enables marten to move through their environment to acquire sufficient resources such as prey, denning and resting sites.

Potential corridors within the project unit have been mapped using the most recent aerial imagery and LiDAR data available. Vegetation that appeared to be already providing a linkage at the time of project development were selected for protection. Corridors types within the project area range between being densely vegetated forest to a series of vegetated patches that function as “stepping stones” between habitat blocks. Corridors that are more densely vegetated are expected to provide more protection from predation to marten travelling between forest patches. Marten on the ODNRA have been observed using areas with as low as 5% cover when necessary, however the frequency of use and the success of crossing without predation has not been quantified (Linnell pers. comm.). It should be recognized that the Forest has no information on how martens might be making connections between patches of forest cover. Patches of non-native Scotch broom and European beachgrass may be providing connectivity where native vegetation is lacking. Therefore, it should not be assumed that these non-native plants provide no value to marten when there is not sufficient native plants to provide for all of the marten’s life history needs.

Maintenance of vegetative cover density within corridors is important for marten predator avoidance and security. Implementation of the project design criteria would be adopted to ensure corridors remain effective for marten use. (See Project Design Criteria starting on page 25.)

Open Dispersal Habitat Dispersed patches of mature conifer (over 10 feet in height) with less than 40 percent canopy cover. This habitat type is generally contiguous with home range habitat and have the potential to develop into home range habitat over time. These forested patches may assist dispersing juveniles in avoiding territorial adults.

Vegetation Treatments within Broad Expanses of Open Sand The interior of broad expanses of sparsely vegetated open sand are not considered marten habitat because they do not provide the necessary cover that would protect marten from the risk of predation. Marten may traverse expanses of open sand from time to time but due to the exposure to risk of predation it is thought that use of this habitat type would occur infrequently. Therefore, where non-native invasive vegetation within open sand areas is not contributing to connectivity between forested patches it can be removed with little negative effect to marten.

50 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Units 1.5, 1.6, 2, 2.2, 10, 15, 16, 20, 32, 34, 36 and 40 (Appendix A) are beach foredunes (or non-forested deflation plain) dominated by European beachgrass with little, if any, woody vegetative cover and are not considered marten habitat. Since these units are dominated by European beachgrass with only scattered small conifer and little ericaceous shrub cover proposed, manual and herbicide treatments within these units would have no direct disturbance effect on marten or marten habitat. Long term affects could include some gradual drifting of sand dunes into the western edge of deflation plain forest which may cause the minor loss of some forest edge over time.

Mechanical treatments will occur within beachgrass covered foredunes, units 1.6, 2.1, 10, 15, 16, 20, 32, 34, 36 and 40 (Appendix A) near the foredune and outside of marten habitat in units 1.5 and 2.2 (Map C), and within open sand in OHV open (motorized) treatment units 36 (Map D), 34 (Map G), 39 (Map H), and 27, 35, 37 (Map I). Because of the large number of acres proposed, mechanical treatments will take place over a period of many years and disturbance from heavy equipment and service vehicles is expected to affect a relatively small area at any one time. Distance from the foredune to densely vegetated marten habitat is expected to further diminish noise generated effects to marten from mechanical treatments. Mechanical treatments of foredunes will not take place between March 15 and September 15 for the protection of western snowy plover, therefore noise from foredune treatments would have no effect on denning female marten with kits. Within motorized areas noise generated by heavy equipment and service vehicles is not expected to exceed ambient noise levels. Therefore, noise associated with mechanical treatments is expected to have minimal disturbance effects on marten.

Manual and herbicide treatments would occur either completely outside of (open sand) or along the edge of marten habitat. Noise levels generated from hand pulling and herbicide treatments within all treatment units is expected to be within ambient noise levels and would not affect marten.

Herbicide spray would occur completely outside of (in open sand) or along the edge of marten habitat where marten would be expected to occur only occasionally. Since marten are secretive animals that primarily inhabit densely vegetated areas it is very unlikely that hand application of herbicide would directly impact a marten. It is plausible that marten or their prey (small mammals and songbirds) could come in contact with vegetation treated with herbicide. The Region 6 2005 FEIS and 2010 Environmental Assessment for the Siuslaw National Forest Invasive Plant Project documented the effects on wildlife from treating invasive plants. The analysis for herbicides included the herbicides glyphosate, imazapyr and triclopyr as well as associated inerts, adjuvants and impurities. The analysis concluded that there is no basis for asserting or predicting that adverse effects to carnivorous mammals, small mammals or insectivorous birds from acute or chronic exposure to glyphosate or imazapyr because the dose would be below the toxicity index. At chronic exposure levels triclopyr may pose a plausible risk to insectivorous or grass-eating birds or mammals. These herbicides do not bio accumulate or persist in the tissue of mammals or birds (NCASI 2009, USDA 2005a&b). Therefore, it is likely that herbicide treatment would have little, if any, effect on marten.

Smoke from prescribed fires could temporarily disturb marten down wind of the project areas. These effects are anticipated to be infrequent, localized and of short duration (less than 1 day). Therefore, prescribed burning has the potential to disturb some individuals.

Regional Forester Sensitive Species No suitable habitat exists in the project area for Foothill yellow-legged frog, pallid bat, Oregon red tree vole, or wolverine. Thus, Alternatives 1-No Action, Alternative2, and Alternative 3 would have no effect on these species or their habitats.

51 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

California brown pelican (Pelecanus occidentalis californicus) Brown pelicans do not nest in Oregon but are common visitors to the central Oregon coast from late spring through early fall. Pelicans are usually found off shore however they sometimes rest on the wet sand beach ocean beach and on sand spits within estuaries within the project area. Occasionally brown pelican are observed flying as far inland as the beach foredune.

Alternative 1 - No Action No project activities would occur on ocean beaches therefore the no action alternative would have no impact on California brown pelican or their habitat.

Alternatives 2 and 3 Project treatments of beach foredunes (units 1.6, 2.1, 10, 15, 16, 20, 32 and 40 (Appendix A)) would take place between September 15 and March 14. Since most pelicans will have migrated south by this time it is likely that few individuals would be impacted by project disturbances. No vegetation occurs on the wet sand ocean beach therefore no herbicide applications would occur. Project impacts would be limited to disturbance of a few individuals from activities on the beach such as vehicles, heavy equipment or smoke. Alternatives 2 and 3 may temporarily disrupt some individuals but are not expected to contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Northern Bald Eagle (Haliaeetus leucocephalus) Bald eagles are usually found near coastlines, rivers, large lakes or streams that support an adequate food supply. Their primary prey item is fish. They are resident within the project area year-round where food is available, otherwise migrates or wanders to find food. Nests are built in large trees with an open structure and large limbs. In western Oregon bald eagles nest primarily in Sitka spruce and Douglas-fir (Issacs and Anthony 2003). Although the widespread use of DDT lead to reproductive failure and subsequent Federal listing of this species, the bald eagle was de-listed throughout most of its range in 2007. Current threats to the bald eagle include disruption, destruction, or obstruction of roosting and forage areas (U.S. Fish and Wildlife Service 2010).

Large conifer that may be within treatment units could be used for roosting, resting or as a vantage point for hunting. Bald eagle commonly use the beaches and inland dunes for resting and/or foraging. Bald eagles forage along the ocean surf for fish and prey upon dead or dying marine mammals and birds that are washed up in the beach wrack line. There are several known bald eagle nests within the project area but no nests are known to occur within treatment units. Some nests may be within 0.25 miles of a project area but disturbance to known nests would be avoided by implementation of project design criteria:

• No project or associated activities would be implemented between January 1 and August 31 within 0.25 mile or a 0.5-mile sight distance of a known bald eagle nest site, unless the unit biologist verifies that the nest is unoccupied.

Alternative 1 - No Action Since no activities would occur bald eagle nesting habitat would not be affected and disturbance would not occur therefore Alternative 1 would have no impact on bald eagles or their habitat.

Alternatives 2 and 3 Under Alternatives 2 and 3 localized noise from heavy equipment and disturbance from personnel and associated vehicle traffic on the beach and inland sand dunes has the potential to temporarily disrupt some individuals. Considering the use of the area by the species, the summary information above, that known nest sites are protected, no treatments will occur within 0.25 miles of active nest sites, no habitat will be removed and that no habitat will be directly sprayed when applying herbicides, Alternatives 2 and 3 may temporarily

52 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA disrupt some individuals but are not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

The effects of the alternatives on western snowy plover, Pacific marten, bald eagles, and California brown pelican were disclosed in earlier sections. There is no habitat within the project area for northern spotted owls or Oregon silverspot butterflies therefore the proposed treatments would have no impact to these species. The effects of the alternatives on the remaining management indicator species are addressed below.

Purple Martin (progne subis) Purple martin feed on flying insects in open habitats such as water bodies, marshes, clearcuts, fields and high above the canopy of forests. They nest in natural (snags) and artificial cavities quite often over open water although this is not an obligate requirement. Nest trees are typically greater than 20 feet from live trees (Horvath 2003). Purple martin are uncommon to rare within the project area but have been documented nesting in natural snags as well as in man-made nest boxes.

Alternative 1 - No Action Since no project activities would occur there would be no nesting habitat removal or disturbance to purple martin therefore Alternative 1 would have no impact on habitat or individuals of the species.

Alternatives 2 and 3 Within beach and foredune habitats no project activities would occur during the martin breeding season since because treatments are limited by design criteria to occur outside the March 15-September 15 snowy plover breeding season. Outside of beaches and foredunes it is possible that some individuals could be disturbed by workers, vehicles or smoke during the martin nesting season. Disturbance effects are expected to be localized and minor across the project area.

Project design criteria would ensure retention of mature conifer and snags therefore trees providing existing habitat would not be lost. Small conifer (less than or equal to 10 feet in height) within treatment units could be removed. Removal of small conifer within 20 feet of existing forested stands is not expected to affect purple martin since these trees would be unlikely to be used by purple martin. Removal of small conifer from the interior of open areas may, over the long term, diminish potential future nesting habitat in those areas. If removal of vegetation from sand dunes causes an increase in blowing and drifting sand could overtake and kill some mature trees and potentially provide new nesting habitat.

Invasive plant treatments would not result in the modification of habitat. Since herbicide application will take place outside of the purple martin breeding season within beach and foredune habitats no impacts to purple martins or their prey are anticipated. Since aerial herbicide applications are not proposed herbicide applications will not affect this species. The R6 2005 FEIS concluded that while there is a plausible risk to species such as purple martins that feed on insects however associated risks are reduced by the limited location of applications, limited application methods and limited application practices. Considering the summary information discussed above, the design criteria for the project, the methods and formulation being proposed, the limited and dispersed locations where applications would occur and the low incidence of the species within the project area, Alternatives 2 and 3 may affect individual purple martin but are not likely to result in a trend toward federal listing or the loss of viability of the population or species.

53 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Western Pond Turtle (Actinemys marmorata)

Alternatives 1, 2 and 3 Where treatment units border waterways continued expansion of non-native vegetation may degrade pond turtle habitats under the no action alternative. These same habitats may be improved with vegetation control proposed under the proposed action. Since turtles have been found on sand roads disturbance or mortality due to project activities is possible but unlikely due to the pond turtle’s low incidence of occurrence in uplands. Considering the summary information discussed above, the design criteria for the project, the aquatic nature of pond turtles, the methods and formulation being proposed there is a low likelihood of pond turtles being exposed to herbicides. For these reasons it is anticipated that Alternatives 1, 2 and 3 may impact individual western pond turtles, but will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Fringed Myotis (Myotis thysanoides) Fringed myotis roost in natural (i.e. rock crevices, cliff faces, caves and mines) and artificial (buildings and bridges) crevices (Maser et al. 1981). Fringed myotis utilize, but not dependent upon, snags or down woody material. Primarily nocturnal in their activities, they feed on a variety of invertebrates, primarily beetles and moths. Foraging primarily occurs in riparian forest areas.

Alternative 1 - No Action No rock crevices, cliff faces, caves, mines, buildings or bridges would be altered. This alternative would not affect riparian forest areas used for foraging. Therefore Alternative 1 would have no impact on the habitat or individual fringed myotis.

Alternatives 2 and 3 No rock crevices, cliff faces, caves or mines are present in the proposed project area. None of the existing buildings will be affected by proposed activities. Fringed myotis are not dependant on open sand dune areas therefore removal of non-native invasive vegetation in these areas is not expected to affect fringed myotis. Some small conifer would be removed around the perimeter of open sand treatment areas under Alternatives 2 and 3 but would not have a measurable impact on fringed myotis since they are not dependent upon these habitat features. Removal of 30 acres of forest proposed in Alternative 2 could impact individuals, but the area of habitat is a small amount relative to the total amount of available, and would not alter the function of the landscape to provide for roosting sites. Alternative 3 would retain all existing conifer forest and snags. Considering the summary information above, the design criteria for the project, the methods and formulation being proposed, the limited and dispersed locations where applications would occur, there is a low likelihood of fringed myotis being exposed to herbicides. Therefore, alternatives 2 and 3 may affect individuals but are not likely to result in a trend toward federal listing or the loss of viability of the population or species.

Siuslaw Hairy-necked Tiger Beetle (Cicindela hirticollis siuslawensis)

Alternative 1 - No Action Habitat succession and invasive plants can negatively impact hairy-necked tiger beetle populations. Under the no action alternative there would be no project related disturbance to tiger beetle habitat but the continued spread of vegetation into tiger beetle habitats within beach, foredune, deflation plain and open sand dune areas is expected to further limit suitable habitat available to this species. Therefore, the no action alternative is likely to contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Alternative 2 and Alternative 3 Habitat for the Siuslaw hairy-necked tiger beetle within beach, foredune, deflation plain and open dune areas is currently being degraded by encroachment of vegetation such as European beachgrass, Scotch broom as well as

54 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA small shore pine and other woody native species. Overall, mechanical, manual and herbicide treatments are expected to benefit the species by creating more wet open sand areas with little to no vegetative cover that this species requires. Treatments of unwanted vegetation near Siuslaw hairy-necked tiger beetle habitat would focus on removal of encroaching woody vegetation and European beachgrass. Minimizing the encroachment of vegetation into habitat areas is expected to be beneficial to the species.

Foot traffic, trucks and heavy equipment associated with project work could trample and crush adult beetles their larvae and burrows. To minimize negative impacts to adult and larval tiger beetles the following design criteria will be implemented:

• Prior to project implementation treatment areas would be surveyed for Forest Sensitive wildlife species. Habitat for Forest Sensitive species such as Siuslaw hairy-necked tiger beetle, Coastal greenish blue butterfly, Seaside hoary elfin butterfly would be delineated and protected from compaction from vehicles/heavy equipment, trampling, herbicide spray (wiping preferred), or other disturbance. A recent study of effects of glyphosate and imazapyr on adult tiger beetles provided some evidence that these herbicides would cause little or no mortality when used according to the recommended concentrations (Knisley pers. comm.). Adults may be more susceptible to herbicide than larvae therefore when at all possible treatments would be planned during times when adults are inactive. In most cases herbicides applied in tiger beetle habitats would be applied using the wiper method to further minimize tiger beetles exposure to herbicide. Since tiger beetles use sandy habitats with little or no vegetation exposure to herbicides is expected to be minimal.

To minimize trampling of sensitive habitats the following design criteria will be implemented.

• For invertebrate sensitive species, place signs or fencing in place to avoid trampling of sites as needed. Therefore, considering the summary information discussed above, the design criteria for the project, the methods and formulation being proposed, there is a low likelihood of this species being exposed to herbicide treatments. Thus, Alternatives 2 and 3, while overall mostly beneficial, some project actions may impact some individuals but effects of project actions would not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Western Bumble Bee (Bombus occidentalis)

Alternative 1 - No Action Under this action some native plants would likely become less common or potentially disappear from some sand dune habitats due to succession and competition from invasive species such as Scotch broom and European beachgrass. Non-native vegetation would continue to expand although the importance of these species to Western bumble bee is unknown. In general native plant communities are thought to provide more diversity for pollinators therefore, some individuals may be impacted, but project actions would not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Alternatives 2 and Alternative 3 The honey bee is the surrogate test subject for required toxicity testing of herbicides, so there is data on risk to bees in the risk assessments for all herbicides included in this project. Considering the herbicides proposed for use in this project, only glyphosate and triclopyr pose a potential risk to bees.

Imazapyr poses no risk to bees even at the highest application rate proposed in this project (USEPA 2005). EPA classifies imazapyr as practically non-toxic to bees and the results of the Forest Service risk assessment state that this conclusion is clearly justified. Neither contact nor estimated oral doses exceeded the No Adverse effect level (NOAEL) (Hazard Quotient <1), even at the highest application rate and upper exposure estimates.

55 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

A relatively large number of acute toxicity studies have been conducted on bees and other species of terrestrial insects using both technical grade glyphosate as well as various glyphosate formulations, for both contact spray and dietary exposures (Appendix 4 in SERA 2011). Contact spray of glyphosate does not pose a risk of mortality to bees. Consumption of contaminated food can pose a risk to terrestrial invertebrates at the highest application rate. Only the upper bound estimates at the highest application rate exceeded the NOAEL.

Triclopyr application at the highest application rates and upper exposure estimates could exceed the NOAEL for dietary exposure. Direct spray scenarios do not pose a risk to bees (SERA 2011).

Removal of non-native invasive vegetation along with restoration of native plant communities, including native flowering plants, is expected to increase diversity of native plants, beneficially affecting native insects such as the western bumble bee. Considering the summary information above, the design criteria for the project, the methods and formulation being proposed, that targeted invasive plants provide only a small number of the wide variety of food plants utilized by western bumble bees, there is a low likelihood of this species being exposed to project treatments. Therefore, some individuals may be impacted but project actions would not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Coastal Greenish Blue Butterfly (Plebejus saepiolus littoralis)

Alternative 1 - No Action As succession continues to occur host plants may be out competed by more aggressive vegetation causing further decline of this species and possible extirpation from the project area. This may cause the coastal greenish blue population to be extirpated from the Oregon Dunes. Since no vegetation removal would take place under this alternative invasive vegetation such as gorse, European beachgrass and Scotch broom would continue to encroach upon currently occupied and suitable sites. Therefore, the no action alternative is likely to contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Alternatives 2 and 3 Neither alternative would remove habitat for this species. Removal of non-native invasive species along the edge of deflation plains, moist depressions and wetland areas is expected to benefit the species through maintenance, enhancement and expansion of habitat for its host plants. Adverse impacts to coastal greenish blue butterfly, such as minimal trampling of host plants during project treatments will be mitigated through implementation of project design criteria and therefore are expected to be infrequent and minor. Avoiding spray of native food plants would avoid herbicide impacts to this species. No larval food plants for coastal greenish blue butterfly would be targeted by applications for invasive plant control, although they could be contaminated by drift if treatments were in close proximity. Considering the summary information discussed above, the design criteria for the project, the methods and formulations being proposed, there is a low likelihood of this species being exposed to treatments. Therefore, some individuals may be impacted but project actions would not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

American Peregrine Falcon (Falco peregrinus anatum)

Alternative 1 - No Action Since no treatments will take place vegetative cover will continue to expand into inland open sand project units over the long term. No project activities would take place therefore no disturbance to peregrine falcons would occur. Even though vegetation such as European beachgrass would continue to spread under Alternative 1 it is unlikely to limit foraging opportunities for peregrine falcon. Since no activities would occur no disturbance is expected. For these reasons Alternative 1 will have no impact on peregrine falcons or their habitat.

56 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Alternatives 2 and 3 Vegetation treatments within proposed project units would maintain open sand dune areas that may provide peregrine foraging habitat. Disturbance from proposed treatments may occur but vegetation treatments will only effect small areas at any one time therefore negative effects are expected to be localized and minor. Considering the summary information above, use of the area by peregrines, that no nest sites will be impacted, no habitat will be removed and that no habitat will be directly sprayed when applying herbicides, Alternatives 2 and 3 may disrupt individuals individuals but would not likely contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Aleutian Canada goose (Branta hutchinsii leucopereia)

Alternative 1 – No Action Since no activities would occur no disturbance to the species would occur. Inland lakes within the project area would not be impacted. Edges of flooded deflation plains would not be impacted therefore Alternative 1 would have no impact to Aleutian Canada Geese or their habitats.

Alternatives 2 and 3 There is a very low probability of herbicide spray during the winter migration period in areas that would provide goose habitat. Inland lakes within the project area would not be impacted. Due to the low incidence of this species within the project area disturbance from project activities is expected to be infrequent and minor. Considering the use of the area by the species, that no habitat will be removed, the design criteria for the project, and the low likelihood of species occurrence within the project area alternatives 2 and 3 may impact individuals but these impacts are anticipated to be infrequent and minor and effects will not contribute to a trend towards federal listing or cause a loss of viability tot the population or species.

Pileated Woodpecker (Dryocopus pileatus) and Primary Cavity Excavators

Alternative 1 – No Action Since no project activities would occur no disturbance or impacts to pileated woodpeckers or primary cavity excavator habitat would occur. Therefore Alternative 1 would have no impact on pileated woodpeckers or primary cavity excavators.

Alternative 2 Overall forested habitat and snags would be conserved within proposed project units however Alternative 2 proposes to remove nearly all the vegetation within unit 1.5 (56 ac.) including approximately 30 acres of shore pine forest. Removal of this forest would reduce the amount of habitat available for primary cavity excavators and perhaps pileated woodpecker. The removal of small trees from near the forest edge may slightly diminish recruitment of new nest trees in those locations over the long term however these affects are anticipated to be minor. Outside of the removal of forest in unit 1.5 minimal disturbance from project activities is anticipated.

It is not likely that these species will be directly sprayed, or encounter vegetation that has been directly sprayed, because herbicide applications in suitable habitat would be applied at ground level and no aerial applications are proposed. Considering the invasive species being treated and the methods of application, that herbicide application will only occur on the very edge of forested areas and ground applications of herbicides are not likely to reach the boles of snags or defective trees used by these species. Thus, Alternative 2 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to pileated woodpeckers or primary cavity excavator populations or species.

57 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Alternative 3 Forested habitats including snags and defective trees would be conserved within proposed project units. The removal of small trees from near the forest edge may slightly diminish recruitment of new nest trees in those locations over the long term however these affects are anticipated to be minor. Since current available habitat will be conserved and exists primarily outside treatment areas minimal disturbance from project activities is anticipated.

It is not likely that these species will be directly sprayed, or encounter vegetation that has been directly sprayed, because herbicide applications in suitable habitat would be applied at ground level and no aerial applications are proposed. Considering the invasive species being treated and the methods of application, that herbicide application will only occur on the very edge of forested areas and ground applications of herbicides are not likely to reach the boles of snags or defective trees used by these species effects are anticipated to be very minor. Thus, Alternative 3 may impact individuals, but the effects will not contribute to a trend towards federal listing or cause a loss of viability to pileated woodpeckers or primary cavity excavator populations or species.

Roosevelt Elk (Cervus canadensis roosevelti)

Alternative 1 – No Action Since no project activities will occur no elk habitat would be altered or removed and no disturbance would occur Alternative 1 would have no impact on Roosevelt Elk or their habitat.

Alternative 2 Overall forested habitat would be conserved within proposed project units however Alternative 2 proposes to remove nearly all the vegetation within unit 1.5 (56 ac.) including approximately 30 acres of shore pine forest. Although elk may move through this forest it is unlikely that they spend significant time there due to disturbance (noise from vehicles, people and pets) from the nearby Baker Beach parking lot. Removal of this forested area would slightly diminish forested cover and browse for elk.

The project proposes use of three herbicides, glyphosate, imazapyr and triclopyr. The R6 2005 FEIS concluded that imazapyr does not pose a plausible risk at the typical or highest application rates to large herbivores such as elk. At the typical application rates for glyphosate and triclopyr they found no plausible risk to large herbivores. At the highest application rates for these tow herbicides they did conclude there was a plausible risk to large herbivores. Since all herbicide will be applied by ground based means such as backpack sprayer or wiper method the likelihood of an elk being directly sprayed is very low since the human activity associated with herbicide treatments would generally cause elk to temporarily leave the immediate area. Herbicide treatments will occur primarily in open sand or forest edge environments where elk would be expected to occur infrequently. Some herbicide spot treatments within forested portions of project units are expected. Disturbance from people, vehicles and smoke from prescribed burning may temporarily displace elk from the immediate area. Considering the above information, the design criteria for the project, the methods and formulations for herbicide being proposed Alternative 2 may impact individuals but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

Alternative 3 Impacts to Roosevelt elk from implementation of Alternative 3 are expected to be the same as in Alternative 2 except that Alternative 3 does not include the removal of 30 acres of forested habitat. Thus, both Action Alternatives may impact individuals but the effects will not contribute to a trend towards federal listing or cause a loss of viability to the population or species.

58 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Siuslaw National Forest Management Indicator Species

Alternative 1 – No Action Forest management indicator species include the following species: Northern spotted owl, Oregon silverspot butterfly, American Peregrine falcon, Bald eagle, California brown pelican, Aleutian Canada goose, Pileated Woodpecker, Primary cavity excavators and Roosevelt Elk.

There would be no proposed activities on the beach, foredune, deflation plain, or interior open sand and no habitat for these species would be removed, thus it is expected that there would be no effect to these species. The No Action Alternative is expected to have a small beneficial effect on Pacific marten over time as succession and expansion of woody vegetation in the foredune increases allowing for minor expansion of habitat. Newly created habitat may be of lower quality if it continues to be dominant non-native vegetation.

Under the No Action Alternative, trees within the deflation plain would be allowed to mature thereby increasing habitat available to Primary cavity excavators. Therefore, the No Action Alternative is expected to beneficially affect Primary cavity excavators.

Bald eagle, Pileated Woodpecker, Primary cavity excavators, and Roosevelt Elk may utilize forest edge habitat. Expansion of conifer forest under the No Action Alternative may have a beneficial effect for these species over time by creating additional habitat.

Alternative 2 and 3 The following effects are expected for both Action Alternatives (2 and 3).

Under the Action Alternatives, native trees within the deflation plain would be allowed to mature thereby increasing nesting, roosting and foraging habitat available to Primary cavity excavators. Therefore, Action Alternatives are expected to beneficially affect Primary cavity excavators.

For effects to Pacific marten, please see effects for Federally Proposed Species – Pacific marten (Martes caurina) on page 47.

Landbird Assessment

Alternative – 1 Impacts from disturbance are due to activities (workers or noise above ambient levels) that would disrupt nesting or feeding areas. Since no activities would occur under the no action alternative no disturbance to landbirds would occur. The no action alternative would benefit species utilizing European beachgrass, broom and gorse habitats. Landbirds utilizing open-sand, native-dune habitats, however, would be adversely impacted as European beachgrass and other non-native plant species would continue to encroach on open-sand. These effects would be considered localized and minor and may impact individuals but would not contribute to a trend towards federal listing or cause a loss of viability to populations or species.

Alternatives – 2 and 3 Alternatves 2 and 3 would benefit species adapted to open sand and native dune habitats but would adversely impact species associated with European beachgrass habitats and brush species such as brooms and gorse. Forested habitats would be maintained however some small conifer less than or equal to 10 feet in height would be removed from project units.

Prescribed burning, mechanical, manual and hand-applied herbicide activities could occur during the breeding season for some species and could occur near their nesting and feeding sites. Prescribed burning activities have the potential to affect nests and young either directly by fire or indirectly by smoke dispersal. Burning would only

59 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

affect a limited portion of the project area at any one time. Project related treatments of the foredune would take place between September 16 and March 14 or under special circumstances after August 15. Most landbirds will have finished nesting by this time but fledglings may still be present. If activities occur less than 100 yards from an active nest, nesting landbirds would be disturbed. Disturbance would come in the form of flushing of incubating adults and cooling of eggs for periods greater than normal, or more frequently than normal; or from direct application of herbicide on eggs or young. These have the potential to cause mortality of young and reduce reproduction for each year of treatment on or immediately adjacent to the project area. The scale and duration of effects are small, however, when put in context of many acres of suitable habitat for these species that exist on the Oregon beach coastal strip from California to Washington. Many of these species nest multiple times over the spring and summer periods and planned activities would only occur one time during a nesting season.

Disturbances that causes birds to flush away from feeding sites have far less potential to affect landbirds than nesting disturbances because feeding birds have much greater flexibility to feed elsewhere while nesting birds are in fixed locations.

Hand applied herbicide may impact some species and individuals. In addition to the information disclosed above, the R6 2005 FEIS concluded birds that eat grass or insects are most susceptible to harm from herbicides. It also concluded to be exposed to potentially harmful doses, herbicides would have to be broadcast sprayed over a large enough area that the animal could forage exclusively within the treatment area for one day and have 100 percent of their diet contaminated. The potential for some effects to occur cannot be ruled out when treating 13,836.2 acres with herbicides. In addition, the affects to landbirds likely would not be significant due to small percentage of area that would be sprayed in any one year and the proposed treatments would focus on removing poor quality habitats dominated by non-native plant species.

Project activities would cause a short-term adverse effect to some species through disturbance, vegetation removal and herbicide application. Disturbance from operations during the nesting period could occur. Efforts would be made to reduce impacts to nesting birds. Considering the above information, the potential for effects to existing habitats, project design criteria and the current function of existing non-native plant dominated habitats; Alternatives 2 and 3 may impact individuals but the effects would not contribute to a trend towards federal listing or cause a loss of viability to populations or species.

Cumulative Effects Cumulative effects are those effects of future state, county or private actions, not involving federal actions, that are reasonably certain to occur within the action area of a federal action subject to consultation (50 CFR 402.02). Cumulative effects analysis of foreseeable state and private actions provide greater insight to understanding the current environmental factors and likely trends that might affect a species.

The suite of present and reasonably foreseeable future action developed by the project Interdisciplinary Team and examined for overlapping effects for each resource in the project area are:

Present Actions (Ongoing in Project area) • Invasives Treatment/Ongoing Invasives Advancement • Water Development/ Wells; Special Use permit for water • Special Forest Product collection (fungi, plants, etc.) • Large Rec Events (DuneFest, etc.) • Recreation Use and Trail Maintenance • Wildlife species/ protection/predator control/habitat monitoring • Outfitter guide permits – recreation use • Mining • Road construction and maintenance

60 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA • Development in in-holdings and outside ODNRA/Baker Beach

Reasonably Foreseeable Actions (Ongoing in Project area) • Invasives Treatment/Ongoing Invasives Advancement • Water Development/ Wells; Special use permit review/renewal • Special Forest Product collection (fungi, plants, etc.) • Large Rec Events (DuneFest, etc.) • Recreation Use and Trail Maintenance • Wildlife species protection/predator control/habitat monitoring • Outfitter guide permits (potential increased use) • Road construction and maintenance • Development in in-holdings and outside ODNRA/Baker Beach • Prescribed fire application • Additional recreation use/resource damage due to proposed Jordan Cove natural gas pipeline and appurtenant facilities and temporary city adjacent to the ORDNA

Past actions are reflected in the existing condition. There are no known foreseeable future actions on state, county or private lands. As there are no foreseeable future actions on state, county or private lands within the action area that would have an effect on the snowy plover or their designated critical habitat or coastal marten there are no cumulative effects.

Western Snowy Plover: After careful consideration of all potential project impacts to snowy plover habitat and to individual snowy plovers I have concluded that many of the project actions are expected to beneficial or have no effect and that negative effects would be limited to those that are short term and localized insignificant and discountable.

For the Western snowy plover a may affect, not likely to adversely affect determination was reached by:

• Implementation of project design criteria would limit disturbance to snowy plovers from project actions. Disturbance would be limited to adult birds outside of the breeding season and would be short term, localized and minor. • Since wintering birds are usually spread out over many miles of project area beach only small numbers of plovers are expected to experience disturbance at any one time. Wintering birds are also expected to be able to easily move away from disturbing activities. • Risk of disturbance to nesting birds may slightly increase due to possible recreationist trespass into nesting areas after removal of dense vegetation is removed from the foredune. These disturbances are expected to be insignificant and discountable after implementation of project design criteria. Any increase in human disturbance is expected to be mitigated by the fact that newly created nesting habitat would allow snowy plovers to nest further away from recreationists using the wet sand beach.

Western Snowy Plover Designated Critical Habitat: The project area contains designated critical habitat for breeding snowy plover in proposed treatment units 1.6, 2, 10, 15, 16, 20, 32 and 40. Over time, and as funding allows, the proposed treatments could create approximately 874 acres of new snowy plover habitat while also improving the quality of existing habitat. Expansion of suitable nesting habitat and associated reduction of cover for plover predators is expected to beneficially affect snowy plover critical habitat. Proposed invasive plant control projects would cause some short term and localized disturbances to non-breeding snowy plover however with implementation of the project design criteria the actions associated with the Oregon Dunes Restoration Project these impacts are expected to be short term, insignificant and discountable.

For snowy plover designated critical habitat a may affect, not likely to adversely affect determination was reached by:

61 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

• Implementation of project design criteria would limit disturbance to snowy plovers from project actions. Disturbance would be limited to adult birds outside of the breeding season and would be short term, localized and minor. • Since wintering birds are usually spread out over many miles of project area beach only small numbers of plovers are expected to experience disturbance at any one time. Wintering birds are also expected to be able to easily move away from disturbing activities. • Risk of disturbance to nesting birds may slightly increase due to possible recreationist trespass into nesting areas after removal of dense vegetation is removed from the foredune. These disturbances are expected to be insignificant and discountable after implementation of project design criteria. Any increase in human disturbance is expected to be mitigated by the fact that newly created nesting habitat would allow snowy plovers to nest further away from recreationists using the wet sand beach. Pacific Marten: After careful consideration of all potential project impacts to Pacific marten and its habitat I have concluded that the project actions would have no effect or only short term and localized insignificant and discountable affects.

For Pacific marten a may affect, but is not likely to adversely affect determination was reached by: 1) No marten home range habitat will be removed and a minimum of 40 percent cover will be maintained. Project design criteria will limit vegetation manipulation and disturbance within home range habitat to the extent that treatments will be localized, insignificant and discountable. Vegetation treatments within home range habitat are expected to be beneficial, improving the quality of marten habitat over the long term through release of native brush species. 2) Beach foredunes and sparse vegetation in the interior of open sand areas provide little protective cover for marten and are not considered marten habitat therefore removal of this vegetation will have negative effects to marten that are insignificant and discountable. 3) Edge habitats with less than 40 percent canopy cover at 1-meter height provide little cover for predator avoidance and are considered to be low quality marten habitat. Implementation of design criteria will limit the extent of treatments both spatially and temporally and are expected to limit negative effects to marten to those that are insignificant and discountable. 4) Improvement of corridor habitat, through gradual conversion of non-native woody vegetation to native, will increase the quality and function of these habitats for marten over the long term. Improvement of corridor habitat will increase security of marten from predators over the long-term. 5) Mature trees generally greater than or equal to 10 feet will be retained within open dispersal habitat. Vegetation treatments within open dispersal habitat will be limited by design criteria when adjacent to home range habitat to limit negative effects to marten. 6) Implementation of design criteria will limit direct and indirect effects of treatment methods (manual, mechanical, herbicide and prescribed fire) to the extent that they will be insignificant and discountable. Botanical Resources Current Conditions Beach and Foredune The beach varies in width across The Project area. Ocean processes, wind patterns, salt spray, sand availability, and movement control beach conditions. Sand dominates the area with driftwood and other detritus strewn by wave action and tides across the area. Vegetation is uncommon except for very scattered communities of pioneers and European beach grass.

62 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA The beach backs up to a well-developed, continuous hill or foredune, except in areas where restoration efforts created “cut out” sections (e.g. Baker Beach, Overlook, Tahkenitch) and areas where active river mouths disturb the area frequently, such as the Tahkenitch, Threemile, Tenmile and Siltcoos Creeks. This berm-like feature runs parallel to the shoreline measuring over 300 feet wide and twenty-five feet tall in many areas. It is covered with vegetation often consisting solely of European beachgrass of very high cover. American dunegrass the native stabilizer, can be found scattered across the foredune in limited areas. Shrubs, such as Scot’s broom, Portuguese broom, and gorse are found on the eastern slopes of the foredune (Christy et al. 1998). Deflation Plain This feature, a low-lying stretch of land found east of the foredune, forms an extensive vegetated strip averaging a half-mile wide across The Project area. Initially formed from wind scour to the water table, this feature supports an array of vegetation types and physical features. Ponds and seasonally wet areas support rush, sedge and Hooker willow plant communities, in places such as South Jetty and Umpqua Spit. In many other drier areas, dense thickets of salal, evergreen huckleberry, brooms, European beachgrass, shore pine, and Sitka spruce occupy the area. Some deflation plains have succeeded to forest, so dense there is very little in the understory. The eastern edges of deflation plains are occupied by the youngest stabilized areas and may contain hummocks of European beachgrass and Scot’s broom scattered amongst open sand (Christy et al. 1998). Interior Open Sand The eastern edge of the deflation plain gives way to patches of open sand. These areas form a variety of dune features. Transverse dunes are found throughout The Project area. Oblique dunes, a unique feature, range from 80-200 feet high and up to a mile long, are easily seen at Tenmile RNA along the Dellenback Trail (Hunter et al 1983). Parabola dunes, formed by wind tunneling, scouring and forming U-shaped dunes, can be seen west of Tahkenitch Lake and the eastern edge of the Umpqua OHV ride area. A few native plant communities adapted to this environment have been maintained and are very limited in scope. Seashore bluegrass and red fescue sparsely cover the sandy substrate. Patches of kinnikinick can be found along the edges of open sand patches in more stable dune systems. These can be found on the Dellenback Trail and Joshua Lane areas within The Project area. Tree islands, remnants of an earlier forested period on the dunes, dot these areas of open sand.

Vegetation encroachment into areas of open sand can be seen across The Project area in most interior open sand patches. Hummocks in various stages of succession, from solely European beachgrass to shore pine and Scot’s broom, are scattered along the perimeter and form fingers into, or completely bisect, the open sand areas connecting to the forest edge. Forest Edge The dune system ends at the continuous forest line. Younger forests consist of dense shore pine, giving way to older forests dominated by Sitka spruce and western hemlock. Dense understories of rhododendron, salal, wax myrtle and Scot’s broom are also found.

Botanical Environmental Consequences

Alternative 1 – No Action BEACH AND FOREDUNE Invasive Botanical Species on Beach and Foredune: European beachgrass spreads primarily by growing long, vigorous rhizomes, and dense clumps of above-ground leaves and flowers. It would seasonally spread westward onto the upper edge of the mean high tide zone, narrowing beach width, and would usually get washed away or undercut by winter storms. European beachgrass, Scot’s and Portugese brooms, gorse (especially at Baker Beach) continue to spread into uninfested areas and gaps. Brooms and gorse follow European beachgrass infestation and increase in cover over time facilitating succession towards shrub and forest communities.

63 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Unique Botanical Species on Beach and Foredune: Suitable habitat for pink sand verbena (Abronia umbellata ssp. breviflora, Forest Sensitive Species, FSS) yellow sand verbena (Abronia latifolia) and silver burweed (Ambrosia chamissonis) would decrease due to European beachgrass expansion.

American dunegrass (Elymus mollis) exists as scattered patches infrequently on foredunes across The Project area, often in bulldozed Western snowy plover (WSP) habitat. As European beachgrass cover increases, American dunegrass cover decreases and could eventually be extirpated at discreet locations. In foredune areas, pink and yellow sand verbena (PSV and YSV) are absent from heavily infested European beachgrass areas, which occurs on most of the foredunes in The Project area. In existing WSP areas, mechanical treatments would continue as needed to maintain open habitat. However, European beachgrass would continue to sprout and re-infest these areas in 1-3 years necessitating regular mechanical maintenance. These treatments eliminate the large, healthy over-wintering PSV/YSV plants that provide thousands of seeds necessary to maintain a viable seed bank for sustainable populations. Physical Features, Vegetation Communities, and Pattern Continued foredune expansion would decrease the already limited area/distribution of the early seral communities (beach pea, lupine, sand verbenas).

The foredune feature would persist and would continue to grow taller and deeper in some areas, blocking wind and sand movement further eastward. The west slopes would continue to fill in and remain completely covered by European beachgrass. Eastern slopes of the foredune with no future disturbances would continue to move through vegetation succession, from herb/graminoid to shrub to forest vegetation types (See the Lifeform and Geomorphic Succession section on page 34.)

DEFLATION PLAIN Invasive species on Deflation Plain: European beachgrass in patchy infestations would continue to outcompete and expand into any unoccupied patches excluding native species. Gorse and brooms would also expand their cover either as scattered plants or often as dense infestations excluding other vegetation. Populations would continue to expand and increase in cover at the expense of native plant communities. Shore pine exists as either dense forest on previously stabilized dunes/soils, or as scattered small trees expanding into European beachgrass and broom infested areas. In these areas, succession would continue creating dense forest habitat.

Unique species on Deflation Plain: Club moss (Lycopodiella inundata, FSS), bog blueberry (Vaccinium uliginosum), shortstem sedge (Carex brevicaulis, FSS) and sundew (Drosera rotundifolia), occur in seasonally wet meadows with an assortment of graminoids. Gorse and brooms are encroaching on the population at Baker beach. Without treatment, these infestations would continue to encroach on the wet meadow and create a dense shrubland that would exclude small meadow species including club moss and shortstem sedge. Physical Features, Vegetation Communities, and Pattern With the disruption of the dominant dune processes of wind, water and sand movement vegetated deflation plains would continue to grow eastward, forming a widening strip into the inland open sand. Within this strip, vegetation succession would continue, with open sand being stabilized by European beachgrass, wet areas becoming vegetated by rushes and sedges, herb/graminoid communities moving to shrublands and shrublands developing into forest. The rate of change would be quickest from open sand to early seral pioneer species and slowest in the forested sites. (Christy et al 1998, and see the Lifeform and Geomorphic Succession section on page 34). Some rare and globally significant plant communities would be affected by this alternative in the short term. The effects would be greatest in areas that support small patches of these types on the landscape. The bog blueberry/slough sedge and bog blueberry/tufted hairgrass-slough sedge globally significant communities are currently seeing some encroachment by Hooker willow, shore pine, and Sitka spruce, which would continue to drier conditions in the future, as they become more established. The shore pine/slough sedge community distribution may increase, as earlier wet graminoid communities shift to shore pine dominated systems, but would eventually succeed to a Douglas-fir forest. Encroachment of invasive species (especially brooms) in the

64 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA shore pine/ bearberry communities would degrade this type. Eventually, succession to Sitka spruce/western hemlock forest would occur in most rare and globally significant communities (Christy 1994, Christy, Kagan, and Weidemann 1998, Christy 2013).

INTERIOR OPEN SAND Invasive species on Interior Open Sand: European beachgrass occurs primarily at the edges of open sand, around tree islands, and sporadically out in the otherwise open sand.. European beachgrass would continue to expand into open sand stabilizing and facilitating succession to shrub and forest habitat. Brooms and gorse occurs primarily at the edges of open sand in dense bands, around tree islands, and rarely out in open sand. Brooms and gorse would continue to expand and increase in cover, especially in stabilized European beachgrass areas. Shore pine exists as scattered small trees expanding from forested edges into European beachgrass -broom infested areas. In these areas, succession would likely continue creating dense forest habitat.

Unique species on Interior Open Sand: Allowing non-native invasives to increase cover/density and stabilize dunes would create unfavorable conditions for these open sand-adapted species seashore bluegrass (Poa macrantha), red fescue (Festuca rubra) and yellow sand verbena. These species are practically non-existent in European beachgrass and broom/gorse infested areas. Kinnikinnick (Arctostaphylos uva-ursi) occasionally grows in open sand conditions, more often under partial canopy shore pine forest at forest edges, sometimes mixed with brooms. Allowing brooms to increase cover would change soil chemistry facilitating dense, closed canopy conditions detrimental to its survival.

Golden sand moss (Campylopus schmidii, FSS) – The only known occurrences in The Project area are near Florence. It grows in semi-open semi-stabilized sand swales between shore pine patches. Allowing European beachgrass and brooms to encroach would either directly eliminate the partial sun conditions necessary for its growth and reproduction, and/or facilitate succession to a closed canopy forest habitat, which would be unfavorable for its growth and survival.

Streambank clover (Trifolium wormskioldii) occurs in seasonally wet areas near deflations plains in more or less open sand conditions. It can be mixed with other low growing vegetation (Lotus spp., Juncus spp.). Allowing all three invasives to overtake its habitat would change moisture regimes and decrease open canopy conditions necessary for its growth and reproduction. Physical Features, Vegetation Communities, and Pattern The size and distribution of open sand patches on the landscape would continue to shrink due to the eastward migration of the vegetated deflation plains and continued encroachment and vegetation succession in existing patches within open sand. (See the Lifeform and Geomorphic Succession section on page 34.) Open sand patches would decrease in size, with smaller patches disappearing first. Physical features in this area would be affected as the primary drivers of sand supply, movement, and wind become less viable. Transverse dune distribution would be negatively affected more quickly by this alternative, especially in areas where both summer and winter winds have been blocked by extensive forested deflation plains. Oblique dunes would eventually shift and shrink in size and stature.

Vegetation encroachment of areas of open sand can be seen across The Project area in most interior open sand patches. Temporal aerial photo analysis documented rapid rates of change in this area. Areas of open sand in the 1940s have been converted to herbaceous/shrub hummocks, which in turn become shore pine patches. These patches have become larger and have created continuous corridors connecting deflation plain forest-to-forest edge in some places. (See the Lifeform and Geomorphic Succession section on page 34.)

Rare seashore bluegrass and red fescue communities would become invaded by European beachgrass and shore pine, and disappear due to limited sand movement and wind dispersal. If estimate loss of 20-60% in the past 70 years is held constant into the future these communities would be even rarer in the next decade (Christy 2013).

65 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Globally significant communities would be affected as well. Shore pine/bearberry and shore pine/hairy manzanita may fill in with Scot’s broom, Douglas fir and shore pine in the short term, continuing to alter the soil conditions that accelerate succession towards forested conditions.

FOREST EDGE Invasive species on Forest Edge: European beachgrass, brooms and gorse, with No Action, would be allowed to expand spatially and in density would increasingly exclude native plants where infestations occur.

Unique species on Forest Edge: Kinnikinnick would grow under partial-canopy Shore pine forest and mixed shrubs at forest edges, sometimes mixed with brooms. Kinnikinnick is a host plant for the Seaside hoary elfin butterfly. Allowing brooms to increase cover would change soil chemistry facilitating dense, closed canopy conditions detrimental to its survival. Physical Features, Vegetation Communities, and Pattern The line that separates the open sand from forest edge has shifted over long periods. Subtle shifts may occur with this alternative. Some open sand patches to the west of this line are beginning to fill in with vegetated hummocks and larger patches of shore pine/shrub along some forest edges, such as south of the Overlook. The transition from interior sand to forest edge may be broader under this alternative.

Globally significant plant communities occupying forest edge habitat include shore pine/bearberry (kinnikinick) and shore pine/hairy manzanita (more common in the south Project area). These areas may be encroached with invasive European beachgrass, and Scot’s broom in the short term. Forest succession would eventually move them to Sitka spruce forest. (Christy 1994, Christy et al 1998, Christy 2013).

Alternatives 2 and 3 BEACH AND FOREDUNE Invasive species on Beach and Foredune: Mechanical and manual treatments of European beachgrass using heavy equipment to scrape or pull clumps of plants would remove above-ground parts, but would not kill the extensive rhizomes, from which new sprouts would emerge soon after treatment. Herbicide treatments using a 1% or less solution of Imazapyr would effectively kill whole plants leaving the dead plants in place. A subsequent prescribed burn treatment would remove above ground dead plant material which is most of the biomass. Dead rhizomes interspersed in the mounds of sand would eventually decompose. Mechanical and manual treatments of brooms and gorse using heavy equipment to scrape or pull clumps of plants (only proposed at Baker Beach) would remove above ground parts and rip up most of the roots, but would not kill all of the plants and new sprouts may emerge soon after treatment, either from existing root structures or from the existing seedbank. Herbicide treatments using Triclopyr would be effective at killing whole plants or as a ‘cut-stump’ treatment to preclude sprouting after cutting plants at ground height. In areas with thick cover of brooms, this would leave abundant dead vegetation. Where practical, prescribed broadcast or pile burning would be effective at removing this vegetation. Using prescribed burning on live brooms would top-kill existing plants. It is expected that vigorous sprouting – vegetative basal and seedling - would occur post-treatment as brooms create abundant seed that is long-lived (50+ years) in the seedbank. A follow-up treatment using manual or herbicide treatment would be effective at killing these young sprouts. In some areas, it may take several years of follow-up treatments to control or remove brooms from the site.

Unique species on Beach and Foredune: Pink (FSS) and yellow sand verbena, silver burweed – Treating European beachgrass would create open sand conditions favorable to pink and yellow sand verbena survival and reproduction on the beach. In the foredune areas, mechanical removal of beachgrass would crush and kill pink and yellow sand verbenas where they are interspersed. However, areas where they are mixed together are surveyed and sand verbena areas are delineated on the ground as ‘no mechanical treatment’ areas. This method has been effective at protecting large, over-wintering plants that are important for seed production and population viability maintenance. Hand-pulling around sand verbena plants may have a marginal, short-term

66 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA beneficial effect as localized competition is lessened for 1-2 years. Herbicide treatments are most effective at controlling beachgrass, and would create open sand conditions favorable to sand verbenas and other native plant species. Studies have shown that Imazapyr treatments have no negative effect on pink sand verbena seedlings (Amsberry, 2016). Since sand verbena plants are practically non-existent in areas of high beachgrass cover, there would be no effect when treated on thick beachgrass sites. Seeding, planting and protecting both sand verbenas will continue to increase population numbers where they currently exist. Newly treated areas will be assessed for reintroduction of these species either by seed sowing or planting grown stock – primarily yellow sand verbena and silver burweed, since they exist in semi-stabilized areas.

American dunegrass – Mechanical treatments using heavy equipment to scrape or pull clumps of European beachgrass would also remove American dunegrass. Where practical, areas with healthy American dunegrass populations would be avoided by heavy equipment scraping treatments. Sparse, interspersed European beachgrass could be treated by wiping a 1% Imazapyr formulation, selectively killing beachgrass while preserving native dunegrass at the site. More extensive herbicide treatments on heavily infested beachgrass areas would open up foredune habitat to dunegrass and other native plants establishment and expansion. Prescribed burning of European beachgrass would remove above ground dead plant material and create open sand conditions favoring dunegrass and other natives. Physical Features, Vegetation Communities, and Pattern This alternative proposes treating roughly 55% of the foredune in The Project area. The remaining 45% of foredune not covered by the EA would develop the same as the No Action Alternative. All treatments would remove vegetation from the foredune and release sand bound by vegetation. Mechanical treatment areas for beachgrass removal would immediately flatten the foredune creating potential opportunities to increase beach area depending on coastal processes at least in the short term. Herbicide treatments will likely increase sand movement after a few years decay of plant material (Ritchie, pers communication). Short-term sand movement has been minimal in areas treated with herbicide (Rebischke pers. communication). Other plants (native and invasive) may establish and partially stabilize sand in the meantime.

Post-treatment plant colonization would vary by initial and maintenance treatment types. Mechanical treatment could reduce the native dune stabilizing communities (Zarnetske et al.2012) Subsequent mechanical treatments would have the same effect, although recent mechanical treatments have been able to avoid more established native areas (Burns, pers. communication). Adaptive management techniques would be applied after each treatment to reduce unwanted effects.

Eastern sand movement would be variable. Baker Beach foredune treatments are adjacent to deflation plain treatments, which would increase eastward sand migration opportunities by reducing wind barriers. All other foredune treatments are adjacent to vegetated deflation plains disrupting eastward sand migration. Expected post-treatment dune formation would be a retention ridge, which may move eastward slowly as it buries vegetation.

Post-treatment foredunes may never totally evolve back towards a more natural dune structure, even with restoration, as the larger-than-natural volume of sand present may pose a challenge to the development of a more natural structure with discontinuous, hummocky foredunes and strongly defined blow-outs and dune slacks.

DEFLATION PLAIN Invasive species in Deflation Plain Mechanical treatment of European beachgrass is proposed in the deflation plain only in the Baker beach area in alternative 2, to connect beach sand source to inland sand dunes. European beachgrass would be temporarily ‘set back’ and much biomass removed. In 1-3 years, beachgrass would resprout and begin to increase in cover. Herbicide treatments on resprouts would stop this process. Herbicide treatments without mechanical removal would leave abundant dead biomass. A follow-up prescribed

67 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

burn would remove this dead biomass. Without biomass removal, it is expected that dead beachgrass could stay onsite for a decade or more. Mechanical treatment of brooms and gorse is proposed in the deflation plain only in the Baker beach area, to connect beach sand source to inland dunes. These mechanical treatments of brooms and gorse using heavy equipment to scrape or pull clumps of plants would remove above ground parts and rip up most of the roots, but would not kill all of the plants, from which new sprouts would likely emerge soon after treatment – either from existing root structures or from the existing seedbank. Manual treatment (pulling or cutting) is effective in the short term, and leaves piles of biomass. Herbicide treatments using Triclopyr would be effective at killing whole plants or as a ‘cut-stump’ treatment to preclude sprouting after cutting plants at ground height. In areas with thick cover of Brooms, this would leave abundant dead vegetation. Where practical, prescribe broadcast or pile burning would be effective at removing this vegetation. Using prescribed burning on live brooms would kill most existing plants. Some basal sprouting could occur post-burn. It is expected that vigorous regeneration post-burn would occur, as brooms create an abundant seed that is long-lived (50+ years) in the seedbank. A follow-up manual or herbicide treatment would be effective at killing these young sprouts. In some areas, it may take several years of follow-up treatments to control or remove brooms from the site. Mechanical or manual treatment of small Shore pine trees would eliminate it from the Baker beach connection area (Treatment polygon 1-1.5), and where it is following beachgrass and brooms encroaching into open sand areas. Dead shore pine saplings would add to the dead biomass load in treatment areas. Burning would remove excess dead vegetation. Herbicide treatment is not proposed on shore pine or any other native vegetation.

Unique species on Deflation Plain: Club moss, Short-stem sedge, Bog blueberry, Sundew – These species would be protected from mechanical treatment direct impacts by a minimum of 50 feet “no entry zone”. Care would be taken during manual (avoid piling on plants) and herbicide treatments (wiping, no spraying) to avoid impacts. No piles and no active ignition would be allowed in the no mechanical entry zone (Baker beach). Indirect effects include the possibility that creating open sand conditions could lead to sand movement, subsequent burial and thus localized unfit conditions for persistence of Club moss and associated species. Physical Features, Vegetation Communities, and Pattern The proposed action would treat 56 acres of European beachgrass, shrub (including gorse and Scot’s broom) and shore pine forest in the deflation plain adjacent to the foredune treatment area. Sand would be free to move inland. There may be some fresh post-treatment scour down to the water table that would create a new deflation plain. Transverse ridges would develop east of the deflation plain. Mobilized sand would move inland to larger existing dune structures extending their life. Post-treatment plant communities would vary, with wetter areas supporting rush, sedge and bog blueberry communities, and drier portions having the potential to support native pioneer communities, including the rare red fescue and seashore bluegrass communities.

With the exception of Baker Beach, No Actions would take place in the deflation plain that would affect sand movement (Ritchie, pers communication). The deflation plain would follow the successional trajectories outlined in the No Action Alternative. Sand is not likely to move through these areas. Most of the area in the deflation plain would continue to develop and migrate eastward, encroaching on existing interior open sand .Sand blowing in from the beach and foredune would likely form a retention ridge where the sand collects against the vegetation and forms a long, high ridge at the western edge of the established vegetation. This ridge could move slowly inland as new sand is delivered. Dunes in the area have been observed to move an average of 5.25 ft. per year (Cooper 1958). INTERIOR OPEN SAND: Invasive species in Interior Open Sand: It is unlikely any mechanical treatments of European beachgrass would occur at interior open sand areas. Spraying with Imazapyr would be the predominant treatment, with occasional wiping and pulling in sensitive areas (plants, invertebrates). These treatments would halt encroaching beachgrass and maintain or create open sand conditions. Prescribed burning would remove beachgrass biomass in areas of dense beachgrass, promoting desired open sand conditions. Pulling, cutting, cutting/wiping, and spray treatments would stop broom and gorse encroachment and seed production. In conjunction with beachgrass treatments, open sand conditions would be maintained, enhanced or created. Depending on access and biomass

68 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA load, burning is proposed to remove excess brush and biomass. This further lead to desired open sand conditions. Retreatments of sprouts from roots or seeds would be necessary to maintain open sand conditions. Manual treatment of small shore pine trees would halt encroachment into open sand areas. Dead shore pine saplings would add to the dead biomass load in treatment areas. Burning would remove excess dead vegetation. Herbicide treatment is not proposed on shore pine or any other native vegetation.

Golden sand moss (Campylopus schmidii, FSS) – Treating and removing non-natives in the vicinity of the golden sand moss would improve habitat conditions by stopping or slowing the rapid succession towards forested habitat and thus maintaining existing suitable habitat for the species.

Unique species in Interior Open Sand: Seashore bluegrass, red fescue, yellow sand verbena, kinnikinnick, streambank clover – Implementation would remove stabilizing weeds and vegetation or create open sand conditions upon which these species thrive. Localized impacts to individual plants could happen by trampling, piling or burning. Taking care to avoid trampling and piling on native vegetation would minimize these impacts, and thus create a net benefit for these species. Removing brooms along the forest edge would benefit kinnikinnick by decreasing competition for light, water and nutrient resources. Additionally, over time, treatments would diminish the allelopathic1 effects of brooms on adjacent native vegetation and improve conditions for kinnikinnick to grow and reproduce. Piling pulled and cut vegetation away from growing kinnikinnick would minimize damage to individual plants. Removing brooms and beachgrass from the vicinity of golden sand moss would slow unnatural succession towards forest cover thus maintaining favorable conditions (i.e. partial openings without immediate vegetation competition). Removing brooms and beachgrass promote conditions favorable to streambank clover growth and reproduction: low, seasonally wet open sand with minimal (native rushes) associated vegetation.

Re-establishing native plants in open sand areas will improve habitat for pollinators and other wildlife species. Methods of re-establishing natives include sowing seed and planting nursery stock. Physical Features, Vegetation Communities, and Pattern Approximately 16 inland sand areas of various sizes are scheduled to receive treatment in the proposed action. Removal of European beachgrass, invasive shrubs, and selected hummocks of more developed vegetation would increase sand movement within the open sand patches, maintaining some dune structure. Movement would vary dependent on wind patterns, available sand sources, and existing marten corridor locations. The larger Baker Beach inland sand patch would likely have a higher input of sand moving inland, creating habitat for rare pioneer plant associations (e.g. seashore bluegrass, and red fescue). Wind may scour down to the water table, creating new deflation plains that may endure or be buried and relocated. Globally significant shore pine/bearberry and shore pine/hairy manzanita communities in treated areas may be maintained, especially along open sand patch edges.

The remaining inland open sand in the dunes would be treated. Areas not being treated would be expected to respond in the same way as in the No Action Alternative (See the Lifeform and Geomorphic Succession section on page 34.) FOREST EDGE Invasive species in Forest Edge: Treatment methods would include manual broom removal, foliar herbicide spraying or wiping on cut stumps, and herbicide spraying on European beachgrass. Pile burning may be used to eliminate biomass. Removing these non-native species halt further encroachment of thick, sand-stabilizing vegetation into ever-shrinking open sand areas. Habitat for native wildlife species would improve by increasing the cover and vigor of native vegetation.

1 Allelopathy is a biological phenomenon by which an organism produces one or more biochemicals that influence the germination, growth, survival, and reproduction of other organisms.

69 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Unique species in Forest Edge: Removing brooms along the forest edge would benefit kinnikinnick by decreasing competition for light, water, and nutrient resources. Additionally, over time the allelopathic effects of brooms on adjacent native vegetation would diminish and improve conditions for kinnikinnick to grow and reproduce. Piling pulled and cut vegetation away from growing kinnikinnick would minimize damage to individual plants. Physical Features, Vegetation Communities, and Pattern Direct treatment in the forest edge would be limited to buffer treatments around selected open sand patches with the Action Alternatives. It is unlikely that any major shifts in forest edge would occur in the short term adjacent to treated open sand areas. The Baker Beach treatment area has the highest probability for forest edge shifting, with connectivity occurring from the beach to the interior sand area. The remaining Project area would continue to develop westward, as in the No Action Alternative.

With the Action Alternatives areas, portions of the dunes would have vegetation killed and in some cases removed. This would reduce the input of organic material and allow the wind to move the sand, arresting soil development. Soil layers would break down as dune formation is initiated. Where encroaching vegetation is kept at bay, soil development would be avoided and moving sand would be maintained. Portions of the dunes not part of the proposed action would be expected to respond as described in the No Action Alternative.

Cumulative Effects The cumulative effects within The Project area over the next ten years would be minor to moderate, as while the proposed action would be focused on non-native species removal and species (wildlife and plant) enhancement and improvement, reasonably foreseeable actions include many which could further the advancement of non- invasive species. OHV use and dispersed recreation use, large rec events, road maintenance and even prescribed fire could direct these non-natives into new areas or newly treated areas keeping acres needing treatment at an elevated level. Fire and Fuels

Current Condition This analysis focuses on Fuels related treatments and effects within the Dunes Restoration Project area. Fuels related projects within the planning area are proposed to remove invasives and maintain native plant populations in open sand areas where below <10% cover and in foredunes by using mechanical and manual treatments, Forest approved herbicides, and prescribed fire. Changes influencing other resources such as wildlife habitat and recreation will be addressed elsewhere in the Environmental Impact Statement.

All treatment alternatives are designed to be consistent with the Siuslaw N.F. Forest Plan and Fire Management Plan, the Forest Service Handbook, the Forest Service Manual, and the Clean Air Act.

Affected Environment- Existing Vegetation, Condition Class and Fire History Fire Regime Because of the controversy and simplicity of using Fire Regime Condition Class (FRCC) (Morrison and Smith 2005), FRCC was not used as the primary basis for decision making. However, fire regimes were used as a reference condition to determine ecological capability and departure.

A natural fire regime is a general classification of the role fire would play across a landscape in the absence of modern human mechanical intervention, but including the influence of aboriginal burning (Agee 1993). Coarse scale definitions for natural (historical) fire regimes have been developed by Hardy et al. (2001) and Schmidt et al. (2002) and interpreted for fire and fuels management by Hann and Bunnell (2001). The five natural (historical) fire regimes are classified based on average number of years between fires (fire frequency) combined with the severity (amount of replacement) of the fire on the dominant overstory vegetation.

70 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA These five regimes include: I – 0-35 year frequency and low (surface fires most common) to mixed severity; II – 0-35 year frequency and high (stand replacement) severity; III – 35-100+ year frequency and mixed severity; IV – 35-100+ year frequency and high (stand replacement) severity; and V – 200+ year frequency and high (stand replacement) severity.

Fire Regime Condition Class (FRCC) Fire Regime Condition Class (FRCC) is a measure for ecological trends and not a hazard metric. It is useful for comparing existing to reference conditions and the role of fire to the disturbance process. FRCC is performed for large scales at a watershed or larger. To draw conclusions on a stand basis would not be an accurate use of FRCC. A Fire Regime Condition Class (FRCC) is a landscape classification that describes the amount of departure from the natural (historical) fire regime. It includes three condition classes for each fire regime. This departure results in changes to one (or more) of the following ecological components:

• • Vegetation characteristics (species composition, structural stages, stand age, canopy closure, and mosaic pattern); • • Fuel composition; • • Fire frequency, severity, and pattern; and • • Other associated disturbances (e.g. insect and disease mortality, grazing, and drought).

The three condition classes are based on low (FRCC 1), moderate (FRCC 2), and high (FRCC 3) departure from the central tendency of the natural regime. These are determined on a large landscape scale and are not appropriate at the stand level.

Existing Vegetation, Condition Class and Fire History within the Dunes Restoration Project area Historically, fire return intervals on the Siuslaw National Forest were infrequent (100-200 years) with mixed severity (partial over-story mortality) on the interior zones and infrequent (>200 years) with high severity (stand replacing fire) in the coastal fog zones. The Siuslaw National Forest, including the Oregon Dunes Restoration project area is dominated by fire regime V.

The fire occurrence in The Project area is relatively low, but the potential for a high severity damaging wildfire does exist when fuels, weather and topography align to create high fire danger.

Between 2009 and 2018 the Siuslaw National Forest’s 10 year fire average is 15.7 fires per year burning a total of 3.4 acres per year. Of these fires only four were reported as non-human caused (lightning) and burned for a total of 0.7 acres. Human caused fire is the most common ignition source contributing to 97% of the fire starts and typically occurs in areas that are easily accessible to humans. Most, if not all lightning is accompanied by a significant amount of rainfall, sufficient to reduce the probability of wildfire ignition.

Fire and Fuel Environmental Consequences

Alternative 1 – No Action Although there would be no long-term direct effects of No Action for fire and fuels for The Project, it would result in a continual accumulation of fuels and potential loss or degradation of habitat and an increase in homogenous fuel beds without the desired diversity on the landscape.

71 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Alternatives 2 and 3 The impacts of Alternative 3 would be the same as Alternative 2 with the exception of the Baker Beach area. In the Baker Beach area, there would be no removal of deflation plain vegetation. The removal of this treatment area from Alternative 3 would leave less area as open sand (about 25.2 acres less) and not require burning.

The Action Alternatives would remove invasives and maintain native plant populations in open sand areas and in foredunes by using mechanical and manual treatments, approved herbicides, and prescribed fire. None of the proposed actions are expected to affect human health and safety. Under the Action Alternatives, all prescribed burning of slash would be designed to be consistent with the Clean Air Act (CCA) and the requirements of the Oregon Smoke Management Plan (ODF 2014) and the Department of Environmental Quality’s Air Quality and Visibility Protection Plan (DEQ 2003). Because slash volumes would be relatively small or treatment areas would be scattered, adverse effects to air quality from burning would be short-term and localized. Approval for prescribed burning typically aligns with optimum conditions for ventilation and smoke dispersal. For potential burn windows (days), the transport winds would be monitored to avoid burning when winds could transport smoke into the nearest designated-smoke-management area (ODF 2014) to The Project - North Bend/Coos Bay SSRA.

Cumulative Effects Within The Project area over the next ten to twenty years, the wildfire risk is not expected to increase significantly given the pattern of vegetation, high humidity environment and long interval/mixed severity fire regime. There are some highly flammable species such as gorse (Ulex europaeus) and thickets of shore pine (Pinus contorta v. contorta). There are not many high fire hazard days with the No Action or proposed action scenarios (and thus no cumulative effects). This is due to the high precipitation zone, with cool temperatures and many high humidity days However, if the proposed action were to be carried out without actions related to slash and dead biomass removal, fuel loading could increase to the point to change to levels which could be more susceptible to wildfire ignition and spread. Cultural Resources

Current Condition Archaeological sites (sites) representing pre-contact and historic period use have been recorded within The Project analysis area. In addition there is relatively high potential for previously unrecorded sites to be present in The Project area, with the exception being the foredune, which has minimal potential to contain archaeological sites because these deposits have primarily formed over the past 75 years.

Sites conditions vary in that some sites are currently covered with vegetation primarily resulting from the spread of invasive plant species like European beach grass and Scotch broom, limiting the exposure of cultural deposits. Other sites are being exposed and buried periodically by sands as dune fields are constantly shifting with the prevailing winds. Prolonged exposure results in the deflation of site deposits and consequently some loss in integrity. Other sites likely remain buried at great depths and have not been exposed or on few occasions.

As noted in the Oregon State Historic Preservation Office section on page 12 the scale of The Project and the phased manner of many of the activities necessitated the “phased” identification and evaluation for historic properties in The Project area as allowed under 36 CFR 800.4 (b) (2). Consequently project specific survey and reporting has not been undertaken, but will occur prior to implementation.

No Action If the no action alternative is implemented, there will be no direct effect on the existing conditions of recorded or unrecorded archaeological sites within The Project area. The continued stabilization and loss of open sand will

72 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA cover exposed archaeological sites and reduce the exposure of sites that are periodically uncovered by summer winds and winter storms.

Cultural Environmental Consequences The effects of Alternative 3 on cultural resources would be the same as Alternative 2 with the potential exception of the Baker Beach area. In the Baker Beach area, there would be no removal of deflation plain vegetation, so there would be less potential to disturb previously unrecorded archaeological sites in this area.

Both Action Alternatives include four treatment options (manual, herbicide, prescribed burning, and mechanical), and of these treatments only mechanical is considered to not hold little or no potential to affect historical properties according to the 2014 Programmatic Agreement among the United States Department of Agriculture Forest Service Pacific Northwest Region (Region 6), The Advisory Council on Historic Preservation, and the Oregon State Historical Preservation Officer Regarding Cultural Resources Management.

Mechanical treatments proposed in the Action Alternatives would result in ground disturbance increasing the risk of damage to potentially unidentified archaeological sites. However, appropriate archaeological survey is required prior to any mechanical treatment implementation, and cultural site protection measures are in place for this Project (see Project Design Criteria section on page 25). The potential direct effects would be in the form of damage to the integrity of cultural resources that are not discovered during the pre-implementation archaeological survey. Specific monitoring requirements and standard protection measures, however, agreed upon in The Project PA would minimize any effects to cultural resources.

Manual, herbicide, and prescribed burning treatments would not directly affect archaeological sites under the Action Alternatives, but if successful would result in increased sand movement and more open sand areas. This would increase potential exposures of archaeological sites as invasive plants are eradicated and dunes are mobilized. However, this would more closely reflect the natural setting that existed prior to the planting of invasive plant species starting in the early 20th century.

Cumulative Effects Neither of the alternatives would result in direct effects to known significant heritage resources. Consequently, no cumulative effects are anticipated. Hydrologic Resources

Current Conditions

Policies and Regulations Concern about polluted waters in the 1960s led to a number of federal and state efforts to improve water quality, some of which led to increasing protection for wetlands, which were recognized for their important role in improving water quality. The Federal Water Pollution Control Act (Clean Water Act) and subsequent amendments of 1977 (33 USC §1251 et seq.) provides for the restoration and maintenance of the physical, chemical, and biological integrity of the nation’s waters. Executive Order 11988 requires federal agencies to avoid adverse impacts associated with the occupancy and modification of floodplains. Executive Order 11990 requires federal agencies to avoid adverse impacts associated with destruction or modification of wetlands. The dunes themselves are not aquatic ecosystems. However many water features are present in the deflation plain to the east of the foredune and small wetlands exist where the groundwater table intersects the surface of the dunes.

73 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Rivers and streams cross the dunes. The Umpqua and Siuslaw are the largest systems. Tahkenitch, Threemile, Tenmile and Siltcoos Creeks also cross through the dunes. The condition and distribution of the foredune, deflation plain and inland sand affect the aquatic path of these smaller stream systems, channelizing and directing aquatic flow patterns. Freshwater lakes and ponds are an important feature in this landscape, occurring mostly at the eastern edge of the dune system. Many of the larger lakes, such as Siltcoos, Tahkenitch, Clear and Tenmile are called barrage lakes as they formed from sand damming stream flows. Some of the smaller lakes, such as Lily, Beal, and Horsfall Lakes are influenced by seasonal precipitation (Christy et al. 1998, Cloyd 2018).

Hydrologic Environmental Consequences

Alternative 1 – No Action Groundwater Under the No Action Alternative, there would be no short- to medium-term effects to groundwater. In the long term, vegetation would develop across the dune sheet and would transition to a forest with increased interception and transpiration. These effects would be negligible relative to high amount of precipitation in the area.

Wetlands The deflation plain would continue moving east due to wind scour and lack of sand inputs from beach (Weidemann and Pickart 1996). Colonization by wetland plant species initiates, progressing to forest species. Small wetlands amongst the dunes would be stabilized and persist (Weidemann 1984). Long-term effects to wetlands and water bodies would primarily result from continued expansion of European beachgrass into the periphery of existing wetlands. This species would move into drier fringes of wetlands and water bodies, but it is not adapted to persisting in the wetter portions of these features, so occurrence there is only sporadic. Therefore, under this alternative, there may be negligible adverse impacts to wetlands over the long-term with No Action Alternative. Invasion does not cause loss of wetlands, but rather a decrease in habitat condition and function.

Streams Under the No Action Alternative there would be no short to medium term effects to streams. In the long term, streamside vegetation would continue to develop and areas of open sand would transition to forest. Streams in the dunes would function as forested streams. The outlets of Sutton and Tahkenitch Creeks would be shifted south until equilibrium between stream power and sediment load is reached.

Alternatives 2 and 3 Effects of proposed actions under Alternative 3 on soils resources would be the same as the effects described for actions under Alternative 2. The only difference in actions between Alternative 2 and Alternative 3 is the treatment of Unit 1.5 in the Baker Beach area. Under Alternative 3, there would be not removal of deflation plain vegetation in unit 1.5 and sand movement and hydrologic processes would be similar to other similar areas.

Groundwater The proposed action would remove some existing vegetation and prevent encroachment on existing areas of open sand. This would be accomplished with mechanical and manual methods, and herbicides. The vegetation changes would not create measurable changes in groundwater quantity or quality. Manual weed control would have no potential to affect ground water.

Mechanical methods would require using heavy equipment to remove and pile vegetation and flatten the foredune. Heavy equipment creates a risk to ground water due to the use of petroleum products. The high permeability of sands means that spills move rapidly and can contaminate ground water. The Forest Service would require a comprehensive spill plan for any heavy equipment working on the sand and would monitor all

74 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA work to ensure rapid response and cleanup of any potential spills. All Project areas are outside areas known to flow to municipal water supplies. No effects are expected to ground water from mechanical methods.

The risks associated with petroleum product spill also apply to herbicide use. All herbicide applications would follow state and federal regulations and be performed by licensed individuals. Comprehensive spill plans and strict adherence to BMPs mean that spills would not be expected to affect ground water.

Three herbicides are proposed for use on The Project. They are glyphosate, imazapyr, and triclopyr. All herbicides would be applied following state and federal regulations. All herbicide applications would be aquatic formulations and would not be expected to harm aquatic forms.

Herbicide can move with water through soil. This percolation can be transported off-site through movement of groundwater. Groundwater infiltration rates depend on soil adsorption rates, depth to groundwater, and fate of chemicals once in soils or in groundwater. Most of the water flows through the sands to the ocean and the major rivers. Other discharge points include the dune lakes, small streams, and wells. (Christensen and Rosenthal 1982). In general, glyphosate strongly adsorbs to soils (SERA 2011a). In predominantly sand soils, glyphosate may penetrate to a depth of about 8-18 inches, depending on rainfall rates, with the depth of penetration increasing as rainfall rates increase (SERA 2011a). Once adsorbed, it breaks down through microbial degradation, hydrolysis, and photolysis (Hwang and Young 2011). The primary breakdown product of glyphosate is AMPA. The EPA R.E.D Facts document about glyphosate states “Glyphosate and AMPA are not likely to move to ground water due to their strong adsorptive characteristics” (2001).

Imazapyr is persistent and mobile in the environment. It does not break down in soil and is able to dissolve readily in water allowing it to move during rain events and then with the ground water. In The Project area, the dominant movement of water is to the west and the ocean with smaller amounts intercepted by the rivers and small creeks (Hampton 1963 and Jones 1992). Most imazapyr dissolved in the groundwater would be diluted as it mixed with ground water and carried to the ocean.

Florence gets its municipal water from groundwater wells just east of the Ocean Dune Golf Course. The 30-year capture zones for the wells have been mapped and extends up to one-half mile from the wellfield (Florence Aquifer Protection Plan). The nearest Project area is over two miles from the wellfield. There would be no impact to groundwater used by Florence. The Coos Bay-North Bend Water Board has water rights and well field on the aquifer on the North Spit around Horsfall and Sandpoint Lake. Imazapyr has the potential to move into the groundwater pumped by these wells. At this time the water from these wells is not used and for emergency use only (Coos-NB Annual Report).

Concentrations of imazapyr in groundwater would be expected to be very low or undetectable due to low application rates and high dilution factor. Application rates would be as low as possible while meeting objectives to control vegetation. All chemical application would be by ground personnel, which reduces application rates. Precipitation is high in the dunes and the small amounts of herbicide applied by the Forest Service would be quickly diluted by the flowing groundwater. Even if groundwater containing dilute amounts of imazapyr was consumed the EPA found “the human health risk assessment, dietary risks (food and drinking water), residential handler dermal and inhalation risks, residential oral and dermal post-application risks, and aggregate risks do not exceed the Agency’s level of concern (EPA imazapyr RED sheet). This matches the SERA reports analysis showing all hazards from groundwater being below the level of concern for human health (Imazapyr SERA 2011).

The ability of triclopyr to enter groundwater is between that of glyphosate and imazapyr. Concentrations in groundwater would be expected to be very low or undetectable due to low application rates, dilution, and microbial breakdown in the soil. Triclopyr is somewhat persistent, and is mobile. In soil, it breaks down through microbial action to TCP, a chemical with similar low toxicity and mobility (EPA RED sheet). Due to its solubility in

75 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

water and limited binding to soil triclopyr could enter groundwater but this would be limited because application would be during dry periods allowing time for breakdown prior to mobilization from precipitation. Even if an exposure pathway did exist the EPA finds “that there is a reasonable certainty that no harm would result to infants and children or to the general population from aggregate exposure to triclopyr or TCP residues” (EPA RED sheet). Likewise, the SERA report on triclopyr found hazards from longer-term exposures to be below the threshold of concern (2011).

Wetlands The proposed action would permit control of invasive non-native vegetation in wetland areas with manual methods only. Wetlands in sandy soils can be difficult to classify. All areas with known seasonal surface water or wetland vegetation would be treated as wetlands. Native wetland plants, water quality, and water quantity would not be impacted and the character of the wetlands would not change as a result of manual vegetation control.

No mechanical vegetation treatments would occur in wetlands. Where heavy equipment is being used to flatten the foredune or remove vegetation adjacent to wetlands, no sand or vegetation would be moved into wetlands. Spill prevention measures would protect wetlands from petroleum spills. There would be no expected direct impacts to wetlands from mechanical methods. Changes to the foredune could result in increased sand movement from the beach and foredune. The moving sand could build new dune structures that could fill wetlands and create new wetlands in the swales between dunes. This natural process of sand movement is one of the goals of The Project. No net change in wetland acres is expected but there could be a shift towards younger wetland features in some locations.

No herbicide applications would occur in wetlands. Similar to streams, wetlands would not be treated where standing water exists at the time of treatment, and would be monitored to protect them from inadvertent herbicide application. Surface water in the wetlands would be susceptible to contamination with imazapyr and triclopyr from ground water similar to rivers, lakes, and streams. No glyphosate would be expected in wetlands due to careful application and the inability of glyphosate to move through soil as discussed in the groundwater section. Triclopyr and imazapyr could enter wetlands through percolation. Once in the surface water of the wetlands both herbicides would degrade in response to light (Triclopyr and Imazapyr EPA RED sheet). Modeling shows concentrations of triclopyr in small wetlands adjacent to areas of application could have concentrations high enough to impact aquatic plants and algae (Triclopyr SERA 2011). Likewise, modeling of imazapyr application near a small pond showed concentrations high enough to negatively impact aquatic plants (Imazapyr SERA 2011).

The modeling results assume an extreme case by design, such as a significant rain event immediately after application. The Forest Service expects no impacts to wetlands due to several mitigating factors. Application rates would be expected to be lower than normal rates due to all hand application. All soils in the area are sands therefore; there would be no runoff, only percolation which moves more slowly allowing time for degradation in the soil, for triclopyr only, and surface water. The dominant direction of ground water flow is down and towards the ocean and streams, not the small wetlands. Pesticide application would be done during dry periods with no rain forecast. The high rainfall on the dunes would likely dilute the herbicide to concentrations that would not have effects. Due to these factors, there would be no expected impacts to wetland vegetation and the character of the wetlands from herbicide application.

Streams The proposed action would kill and in some places remove stabilizing vegetation from the foredune allowing sand movement and promoting more natural stream migration. As sand moves into Tahkenitch and Sutton Creeks and the foredune moves, the streams could create new outlets through the area where the foredune is now. No effects would be expected east of the foredune due to the limited proposed actions to existing vegetation. No adverse impacts would be expected in streams.

76 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Cumulative Effects Water resources in The Project area would not be significantly impacted by the proposed activities. With the absence of direct effects, there would not be any cumulative effects within The Project area for the next five to ten years given the known reasonably foreseeable actions. Soil Resources

Current Conditions The introduction of European beachgrass has resulted in rapid stabilization or large areas of open sand. The grass captures sand blowing in from the beaches and permits pioneering vegetation to begin to stabilize the sands in the deflation plain and other open sand areas. Early stages of coniferous forest are established throughout much of The Project area and more would grow as stabilization continues. Over long periods of time this would lead to the development of soils with defined layers and higher organic and nutrient contents. Under the No Action Alternative, more areas of open sand would be colonized and stabilized, leading to new coniferous forests and new soils.

Soil Environmental Consequences

Alternative 1 – No Action With no action pioneering vegetation would continue to invade and stabilize the sands in the deflation plain and other open sand areas. Stabilized sands with established vegetation would have higher organic material inputs be subject to increased microbial activity. Over long periods of time this would lead to the development of soils with defined layers and higher organic and nutrient contents.

Alternatives 2 and 3 Effects of proposed actions under Alternative 3 on soils resources would be the same as the effects described for actions under Alternative 2. The only difference in actions between Alternative 2 and Alternative 3 is the treatment of Unit 1.5 in the Baker Beach area. Under Alternative 3, there would be not removal of deflation plain vegetation in unit 1.5 and sand movement would be similar to other similar areas.

Proposed actions are limited to select portions of the foredune and select areas of inland open sand. Mechanical removal of beach grass and flattening of foredune allows sand to begin to move in some locations (Baker Beach vs Tahkenitch Creek Observation). Treatment of beachgrass on foredune with herbicides may permit sand to move after decay of plant material, or other plants may establish and stabilize. Portions of the foredune not covered by the EA would develop the same as the No Action. In the Baker Beach area, the beach and foredune would be connected to inland open sands by removing vegetation in the deflation plain. Sand would be free to move inland. Scour down to water table would create deflation plain. Transverse ridges would develop east of the deflation plain. Mobilized sand would move inland to larger existing dune structures extending their life.

With the proposed action, areas portions of the dunes would have vegetation killed and in some cases removed. This would reduce the input of organic material and allow the wind to move the sand arresting soil development. Soil layers would break down as dune formation is initiated. Where encroaching vegetation is kept at bay soil development would be avoided and moving sand would be maintained. Portions of the dunes not part of the proposed action would be expected to respond as described in the No Action Alternative. Over the short-term, herbicide application could have potentially minor adverse impacts to soils and soil biota. The impacts are expected to be minimized by application methods and would dissipate within a few years due to the breakdown of chemicals in the soil.

77 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

Cumulative Effects Soil resources in The Project area would not be significantly impacted by the proposed activities. With the absence of direct effects, there would not be any cumulative effects within The Project area for the next five to ten years given the known reasonably foreseeable actions. FISHERIES RESOURCES

Current Condition The Dunes Restoration Project area spans across the western portions of six 5th-field (HUC 10) watersheds. In general, the project area only covers relatively small portions of each watershed, at most extending about two miles inland from the Pacific Ocean. Existing fish habitat and riparian area conditions for these watersheds are described in the Coastal Lakes Watershed Analysis (WA) (USDA FS, 1998), Mercer/Berry Watershed Analysis (Andrus et al., 1996), and Lower Siuslaw Watershed Analysis (1998), with the Coastal Lakes WA covering the vast majority of the project area. The Coastal Lakes watershed spans approximately 83,245 acres of sand dunes, large and small coastal lakes, and forested and agricultural land. Many of the streams and lakes within the project area support the Oregon coast Evolutionary Significant Unit (ESU) of Coho salmon (Oncorhynchus kisutch), a species listed as Threatened under the federal Endangered Species Act.

Approximately 4.8 miles of stream and 25.3 acres of lake/pond habitat within the Project area supports Coho salmon. These habitats are primarily used as rearing habitat for juvenile Coho, and as migration corridors for adult Coho to reach spawning areas upstream of the Project area. These habitats are also likely to support other anadromous species such as Pacific lamprey, a Region 6 Forest Sensitive species (See Table 1 in Fisheries Specialist Report). In addition to the freshwater habitats described above, marine/estuarine habitat utilized by Coho as migration corridors is adjacent to the Central Project area. These habitats include the Umpqua River/Winchester Bay (approximately 4.8 miles) and Siuslaw River estuary (approximately 0.4 miles). There would be no direct effects to Oregon Coast Coho salmon or their critical habitat under the No Action Alternative, as no Project activities would occur within aquatic habitats.

Fisheries Environmental Consequences

Alternative 1 – No Action

Federally Listed Species The Evolutionary Significant Unit (ESU) of Oregon Coast coho salmon is listed as Threatened under the federal Endangered Species Act. Several fish-bearing streams and lakes are found within the ODNRA, many of which are designated as Critical Habitat for coho salmon. Coho mostly use these sandy-bottomed streams as migration corridors between the ocean and spawning/rearing habitats east of the dunes, though some coho juveniles likely rear for up to two years in areas such as the Siltcoos River and Lily Lake. In general, dune stabilization resulting from non-native plant establishment within the Project area has not measurably degraded these streams as habitat for coho. There would be no direct or indirect effects to Oregon Coast coho salmon or their Critical Habitat under the No Action Alternative, as no project activities would occur within or adjacent to aquatic habitats.

The southern Distinct Population Segment (DPS) of green sturgeon (Acipenser medirostris) are present within marine environments in the Project area. Both Coos Bay and Winchester Bay are designated as Critical Habitat for green sturgeon. The bays are used by adult and sub adult green sturgeon as feeding areas in the summer months. Given that no project activities would occur under Alternative 1, implementation of this alternative would not affect green sturgeon or their Critical Habitat.

78 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA The southern DPS of eulachon (Thaleichthys pacificus) are present in the Umpqua River. Designated Critical Habitat is located upstream of the Project area, in the freshwater portion of the river. The estuary/marine portion of the Umpqua River is not designated as Critical Habitat for eulachon, but is used by eulachon as a migration corridor to upstream spawning areas. Given that no project activities would occur under Alternative 1, implementation of this alternative would not affect eulachon or their Critical Habitat.

Regional Forester Sensitive Species The streams known to support coho are also likely to support Oregon Coast steelhead (Oncorhynchus mykiss) and Pacific lamprey (Entosphenus tridentatus), both of which are Region 6 Forest Sensitive Species. In general, dune stabilization resulting from non-native plant establishment within the Project area has not measurably degraded these streams as habitat for steelhead or Pacific lamprey. Given that no project activities would occur under Alternative 1, implementation of this alternative would not affect steelhead or Pacific lamprey, or their respective suitable habitats.

Newcomb’s littorine snail (Littorina subrotundata) is a semi-aquatic marine snail that may potentially occupy rocky structure in marine environments within the Project area, specifically breakwaters at the entrances to Siuslaw River estuary, Winchester Bay, and Coos Bay. Given that no project activities would occur under Alternative 1, implementation of this alternative would not affect Newcomb’s littorine snail or their suitable habitat.

Alternatives 2 and 3 Effects of proposed actions under Alternative 3 on aquatic habitats would be the same as the effects described for actions under Alternative 2. The only difference in actions between Alternative 2 and Alternative 3 is the treatment of Unit 1.5. The unit is located over 700 feet away from any streams or lakes. Therefore, treatment or lack thereof would not affect aquatic habitats within or adjacent to the project area. Proposed actions were considered most likely to affect the following habitat attributes: • Large Wood Production/Recruitment: Project activities would not measurably affect large wood recruitment into Project area aquatic habitats. Existing wooded areas would be maintained as part of this Project. In the long term, non-native vegetation removal near aquatic habitats may negate the ability for woody vegetation (such as lodgepole shore pine) to colonize riparian areas where trees were never previously established (indirect effect). • Temperature: Project activities would not affect water temperatures within the Project area. Existing canopy cover over streams and along lake shores would be maintained, as the non-native invasive plants proposed for removal are relatively low to the ground and do not provide shade over aquatic habitats. • Physical Barriers: Proposed actions would not affect physical barriers to fish migration within the Project area, as no activities are proposed within aquatic habitats. Mechanical removal of beach grass and other vegetation would destabilize sand dunes and indirectly increase the potential for sand movement (indirect effect). Prescribed burning of invasive plants may also destabilize dunes. Sand may be mobilized by wind and blown into adjacent lakes and streams. Given that the substrates in the lakes and streams within the Project area are almost entirely sand, any wind-carried sand that lands in these habitats would not be measurable. • Chemical Contaminants – Herbicide Use: Herbicide selection and application would follow all PDCs described for non-native invasive plant control in ARBO II. The potential effects of the three herbicides proposed for use within the Project area (glyphosate, imazapyr, and triclopyr) are described in detail in ARBO II, including the effects on coho salmon and other aquatic species, such as macroinvertebrates. The effects of herbicides on aquatic species is gauged by using a hazard quotient value (HQ). Hazard quotient values are calculated by dividing the expected environmental concentration by the effects threshold concentration. Adverse effect threshold concentrations are 1/20th (for coho salmon) or 1/10th (all other species) of LC 50 values.

79 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

o The risk of adverse effects on coho salmon or their habitat from herbicide application in the Project area would likely be lower than what is described in ARBO II. The PDCs would restrict application periods to avoid wind or precipitation events, thereby minimizing the potential for herbicide drift or runoff into adjacent lakes and streams. o Given the high porosity of the soils (sand) in the Project area, it would be highly unlikely for herbicides to be mobilized by precipitation events and washed overland into adjacent streams and lakes.

Federally Listed Species Coho salmon would not be directly affected by Project activities, as no activities are proposed within aquatic habitats. Indirect effects on aquatic habitats resulting from Project activities would include the potential for increased sand movement into adjacent streams and lakes, which would be expected given that one of the goals of the Project would be to remove sand-stabilizing vegetation and increase sand movement across the Project area. However, given the streams and lakes in the Project already have an almost entirely sandy bottom, any sand mobilized by wind action and blown into these aquatic habitats would not be measurable.

Project activities located adjacent to green sturgeon critical habitat in Coos and Winchester bays are relatively small in scale compared to the rest of the Project area, and would not result in changes to the bays’ capacities as feeding habitat for green sturgeon. Therefore, the Project would have no effect on the southern DPS of green sturgeon or their designated critical habitat.

Project activities would not affect the viability of the Umpqua River estuary as a migration corridor for eulachon, as only a relatively small portion of the Project area is located adjacent to the estuary. Therefore, the Project would have no effect on the southern DPS of eulachon or their designated critical habitat.

Essential Fish Habitat Essential Fish Habitat (EFH) is defined by the Magnuson-Stevens Fishery Conservation and Management Act (1976) as “the habitat necessary for fish to spawn, breed, feed, or grow to maturity.” All streams and lakes identified as Critical Habitat for coho salmon are also considered EFH. The Siuslaw River estuary and Umpqua River estuary are also considered EFH for Chinook salmon (Oncorhynchus tshawytscha). Given that EFH in the project area is the same as Critical Habitat, the effects on EFH are already analyzed in this document. The Project would have no adverse effects on EFH.

Regional Forester Sensitive Species All suitable habitat for coho salmon within the Project area is likely to support Pacific lamprey. The potential effects on Pacific lamprey habitat would be the same effects described in the Coho Salmon, Oregon Coast ESU section under the Federally Listed Species section of this analysis (see above). Given that Pacific lamprey juveniles utilize fine sand as habitat, any sand that is mobilized and transported to streams as a result of Project activities may have a slightly beneficial, but likely immeasurable, effect on lamprey rearing habitat. Therefore, the Project may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability of the Pacific lamprey.

Effects on Oregon Coast steelhead and their habitat would mimic the effects described for coho salmon. Streams in the Project area are primarily used as migration corridors between the Pacific Ocean and spawning areas upstream of the Project area. Increased sand movement into adjacent streams would not decrease the capacity of these streams to continue acting as migration corridors for steelhead. The potential effects of herbicides on steelhead would be the same effects described for coho salmon. Therefore, the Project may affect individuals, but is not likely to result in a trend toward Federal listing or loss of viability of Oregon Coast steelhead.

Although the Project area includes potential suitable habitat for Newcomb’s littorine snail in the form of breakwater structures in marine environments, no Project activities would occur around the breakwaters. Therefore, the Project would have no effect on Newcomb’s littorine snail or their potential suitable habitat.

80 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Cumulative Effects Under the Endangered Species Act (50 CFR 402.02), cumulative effects are “those effects of future State or private activities, not involving Federal activities, that are reasonably certain to occur within the action area of the Federal action subject to consultation.”

The primary non-federal activities occurring within the Project area include recreation activities such as off- highway vehicle (OHV) use, horseback riding, and invasive plant treatments on non-Forest Service lands. All of these activities include ground disturbance and sand displacement that pose a risk for cumulative effects on aquatic habitats within the Project area. These activities are expected to continue into the future at their existing rates. Given that the indirect effects from the proposed action on sand movement/displacement would not be measurable, the risk for cumulative effects would be low. Sand that is disturbed by activities occurring on both non-federal and Forest Service lands, and subsequently mobilized by wind action, would not measurably accumulate in adjacent streams and lakes. Any sand that enters aquatic habitats within the project area would not alter habitat suitability for coho salmon, as the substrates in these habitats already consist almost entirely of sand. Recreation

Recreation Environmental Consequences

Alternative 1 – No Action The biggest impacts to the recreation resource has been and would continue to be with No Action, the reduction in usable terrain for recreation activities (both motorized and dispersed) with vegetation intrusion into open sand areas and into trail corridors. Access from recreation infrastructure (campgrounds, staging areas, etc.) to open sand, through travel corridors, and across open sand has been negatively affected by the initiation, rapid colonization, and further succession of other vegetative species. Recreationists have perceived closures being adopted by the Forest Service and limiting of access to riding and hiking when these areas have actually simply grown in with non-native and some native vegetation. While beach and forest areas have been affected, the foredune, deflation plain and open sand areas are the most severely impacted.

Alternative 2 and 3 The impacts of Alternative 3 to recreation would be the same as Alternative 2 with the exception of the Baker Beach area. In the Baker Beach area, there would be no removal of deflation plain vegetation. The removal of this treatment area from Alternative 3 would leave less area as open sand (about 25.2 acres less).

The direct effects of the Action Alternatives on recreation would be an increase in usable terrain for recreation activities already designated in earlier planning efforts (both motorized and dispersed) with vegetation removal from portions of open sand areas and trail corridors. Access from recreation infrastructure (campgrounds, staging areas, etc.) to open sand, through travel corridors, and across open sand would be improved with vegetation removal. There would be potential short term negative effects on recreationists during treatment activities as areas and trails may need to be closed for short periods (for herbicide spraying, heavy machinery work and travel access, prescribed burning and smoke production, etc.). Recreation experiences may be negatively affected during the short term by noise, by visual evidence or sighting of activities, or exclusion from areas immediately after treatments, etc. The foredune and open sand areas would improve with treatments initially, and beach and forest areas would improve over time with a higher establishment of native species.

Cumulative Effects Restoration of the sand habitat and the continuation of recreational opportunities in The Project areas would be neither irreversible nor cause serious degradation or elimination of the physical or natural conditions that

81 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

provide the land’s value for recreation. Implementation of the proposed Project would be consistent with current policy directives for the management of the ODNRA. For these reasons, implementation of the proposed Project would result in no substantial cumulative impacts to the recreation facilities or opportunities on the land in The Project area over the next ten to fifteen years.

The proposed Project would re-establish long-term ecological functions present in the Oregon Dunes in some areas. This would enhance the sand based recreational opportunities and scenery unique to this area across the treated sand areas. The result of this Project would restore native plants and animals that have traditionally used these areas across the treated portion of the dunes. The return of native species would provide the public occasions to explore and learn about these species and enable the Forest Service to interpret these sites for the public. Aquatic Conservation Strategy Objectives Consistency Assessment Compliance with the nine objectives of the Northwest Forest Plan2 Aquatic Conservation Strategy (ACS), as delineated in the Record of Decision (ROD) for Amendments to the Forest Service and Bureau of Land Management Planning Documents within the Range of the Northern Spotted Owl, is discussed below. The Northwest Forest Plan Record of Decision (USFS, 1994b) established Riparian Reserves and details Standards and Guidelines that includes the nine ACS Objectives. Alternatives 1, 2, and 3 (please refer to the EA for a detailed description of Alternatives) have been evaluated to determine their consistency with the nine ACS objectives of the Northwest Forest Plan (1994). The Oregon Dunes Restoration Project Environmental Assessment (The Project), the Coastal Lakes Watershed Analysis (WA) (USDA FS, 1998), Mercer/Berry Watershed Analysis (Andrus et al., 1996), and Lower Siuslaw Watershed Analysis (1998) provide the context for the responses to the Aquatic Conservation Strategy objectives. The watershed analysis document is referred to as a WA in this document. The nine objectives of the ACS are listed, and compliance of The Project alternatives are discussed below. Alternatives 2 and 3 differ in that Alternative 3 would not include treatment of Unit 1.5. This unit is located over 700 feet away from any streams or lakes. Therefore, treatment of Unit 1.5 (or lack thereof) would not affect aquatic habitats within or adjacent to The Project area. Given this information, the descriptions of compliance (or non-compliance) of Alternatives 2 and 3 with the ACS objectives are the same.

Objective Consistency Assessment 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.

Alternative 1: No Action The existing distribution, diversity, and complexity of watershed and landscape-scale aquatic features would remain on their current trajectory; which can be either towards or away from desired features depending on which characteristic is assessed and the time scale analyzed. Desired restoration opportunities would be postponed indefinitely. For example, the desire to improve riparian areas via the removal of non-native vegetation and reestablishment of native species would be unlikely to occur without active management. The diversity of watershed and landscape-scale features may be impacted over time by the spread of invasive plants.

2 Final Supplemental Environmental Impact Statement on Management of Habitat for Late-Successional and Old- Growth Forest Related Species within the Range of the Northern Spotted Owl (Northwest Forest Plan; USDA, USDI 1994a).

82 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Invasive plants can invade, occupy, and dominate riparian areas and indirectly impact riparian and aquatic ecosystems, and fish habitat.

Alternatives 2 and 3 Proposed actions described under Alternatives 2 and 3 include the removal of invasive plant species and maintenance of native plant populations across The Project area. These actions would also occur within riparian areas, thereby improving riparian and aquatic habitat conditions within The Project area. Invasive plant removal treatments would follow Project Design Criteria aimed at minimizing adverse effects to aquatic systems. Treating existing and future invasive plants found growing in riparian areas would help maintain the distribution, diversity, and complexity of watershed and landscape-scale features, and serve to protect aquatic habitats.

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.

Alternative 1: No Action The existing spatial and temporal connectivity within and between watersheds would be maintained. Invasive plants would not be treated under this alternative, and may restrict connectivity between aquatic habitats over time.

Alternatives 2 and 3 Spatial and temporal connectivity within and between watersheds would be improved by the removal of invasive vegetation from riparian areas and adjacent dunes. The use of project design criteria for proposed herbicide applications is intended to avoid the introduction of any physical and/or chemical obstructions to the existing spatial and temporal connectivity within and between watersheds. The associated project design criteria apply to known sites and those detected in the future. Alternatives 2 and 3 include limitations on the type and application method of herbicides applied adjacent to water bodies, thus minimizing any potential for the introduction of a chemical obstruction to the connectivity. In addition, only aquatic formulations of glyphosate would be allowed to the water’s edge. This herbicide, compared to its non-aquatic formulation, poses a lower risk to fish and other aquatic organisms and is limited to spot spray and hand applications only. The proportion of the area proposed to be treated with herbicide within each watershed is small (no more than 10 percent of the riparian reserve area within each 6th field HUC annually). Therefore, Alternatives 2 and 3 would likely not result in chemical or physical obstructions in routes to areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. Invasive plant treatments would not create physical barriers or otherwise degrade access to aquatic habitat, and would ultimately improve these characteristics. Removing existing and future invasive vegetation in riparian areas is expected to benefit aquatic and terrestrial communities in the long term by maintaining connectivity in areas critical for fulfilling life history requirements of aquatic and riparian-dependent species. Proposed activities would not sever existing connections between essential wildlife habitats and among watersheds. The physical nature of existing movement corridors for riparian-dependent species would remain relatively intact, with the potential for a short-term reduction in connectivity as invasive plants are removed from the landscape. However, this connectivity would be restored by the recolonization of native plants within

83 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

riparian areas. Restored network connections are expected to provide chemically and physically unobstructed routes to areas critical for fulfilling 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.

Alternative 1: No Action The existing physical integrity of shorelines, banks, and stream bottoms would remain intact. Invasive plants would continue to colonize and outcompete native vegetation within riparian areas. Future infestations of aquatic emergent invasive plant species (such as knotweed) can result in bank erosion and sedimentation of streams during high water flows.

Alternatives 2 and 3 Invasive plant treatments in riparian areas are designed to promote sand movement and reestablishment of native plant species. These actions would restore lake shorelines and stream banks to desired conditions. If increased sand movement is attained, wind-driven sands may enter adjacent streams and lakes. However, given that the bottom substrates of the lakes and streams in The Project area are almost entirely sand, any wind- carried sand that lands in these habitats would not change the integrity of these substrates.

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.

Alternative 1: No Action No actions would occur under this alternative. Water quality would change over time either towards or away from desired features depending on which characteristic is assessed and the time scale analyzed. Invasive plants may continue to encroach through riparian areas and infest stream banks, leading to increased erosion and sedimentation of streams.

Alternatives 2 and 3 The use of project design criteria for proposed herbicide applications on current and future invasive plant species under the early detection-rapid response (EDRR) strategy is intended to avoid any negative effects on the biological, physical, and chemical integrity of riparian, aquatic, and wetland ecosystems. Alternatives 2 and 3 include limitations on the type and application method of herbicides applied adjacent to water bodies and along roads that have a high potential for herbicide delivery to streams, thus minimizing any potential for the introduction of a chemical obstruction to the connectivity. In addition, only aquatic formulations of glyphosate and imazapyr would be allowed to the water’s edge. These herbicides, compared to their non-aquatic formulations, pose a lower risk to fish and other aquatic organisms and would be limited to spot spray and hand applications only.

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.

84 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA Alternative 1: No Action No project activities would occur under Alternative 1. The existing sediment regime in project area lakes and streams would follow existing trends. As invasive plants continue to colonize lake shorelines and stream banks, bank erosion and stream bottom scour (channel incision) may increase over time.

Alternatives 2 and 3 Invasive plant treatments along streams and lake shores may increase sand movement (a project objective), which may result in wind-blown sand entering aquatic habitats. Given that the bottom substrates of project area streams and lakes consist almost entirely of sand, this effect would not be measurable. The treatment of existing invasive plants to reduce their population and area of infestation and the encouragement of native plant communities in the riparian areas would help maintain the sediment regime that would otherwise be affected by potential future invasive plant species growing adjacent to aquatic habitats. Manual and mechanical treatments are extremely unlikely to contribute sediment, as most invasive plant treatments in riparian areas would only consist of herbicide application. Very little ground disturbance would take place where herbicide methods would be used to treat existing and future invasive plants, as this activity would be done using back pack sprayers carried by people on foot.

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.

Alternative 1: No Action No project activities would occur under Alternative 1. In-stream flows would continue to follow existing trends.

Alternatives 2 and 3 Treating invasive plants and reestablishing native plant communities would restore native vegetation and leaves that provide the basic foundation of the aquatic ecosystem food web. Proposed activities would have negligible effects on in-stream flow due to the relatively small amount of riparian area treated and the recovery of native vegetation.

Objective 7 Maintain and restore the timing, variability, and duration of floodplain inundation and water table elevation in meadows and wetlands.

Alternative 1: No Action No actions would occur under Alternative 1. Floodplain inundation and water table elevations would continue to follow existing trends.

Alternative 2 and 3 Project activities would not be expected to inhibit or degrade floodplain inundation or water table elevations in The Project area. There is the potential for a short-term (1-2 year), minor increase in water table elevation following project activities, as invasive plants are removed from the landscape and evapotranspiration rates are reduced across The Project area. However, this effect would likely be negated as native plants re-colonize areas previously occupied by invasive species.

85 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

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.

Alternative 1: No Action No project activities would occur under Alternative 1. Existing plant communities in riparian areas would remain, with the likelihood that invasive plants would continue to spread across The Project area and displace native plant species. Coarse woody debris inputs would continue to follow existing trends.

Alternatives 2 and 3 Invasive plant treatments would restore open sand and native plant communities throughout The Project area, including in riparian areas and wetlands. In the years following project implementation, riparian areas and wetlands in The Project area would be expected to support mostly native vegetation. If some riparian areas are well-stabilized by native vegetation, there would be the potential for conifers to take root in these areas and provide additional coarse woody debris to aquatic habitats in The Project area.

Objective 9 Maintain and restore habitat to support well-distributed populations of native plant, invertebrate and vertebrate riparian-dependent species.

Alternative 1: No Action No project activities would occur under Alternative 1. Existing plant communities in riparian areas would remain, with the likelihood that invasive plants would continue to spread across The Project area and displace native plant species. Riparian-dependent animal species would continue to be hampered by encroaching invasive vegetation.

Alternatives 2 and 3 One of the main objectives of Alternatives 2 and 3 is to promote native vegetation establishment and reduce invasive plant infestations within The Project area. The removal of invasive plants would provide opportunities for native plant species to take their place in riparian areas. As native vegetation reestablishes itself in riparian areas, both aquatic and riparian habitats would be improved for native species.

Summary

Alternative 1 Failure to treat invasive plants and restore native species in riparian reserves can degrade riparian area function and health. Over time, invasive plants would be expected to encroach upon and outcompete native vegetation. Since invasive plants would continue to hamper aquatic and riparian habitat conditions in The Project area, Alternative 1 would result in most Aquatic Conservation Strategy Objectives not being met.

Alternatives 2 and 3 The treatment of invasive, non-native vegetation in riparian areas and wetlands would result in improvements to aquatic and riparian habitat conditions. Increased sand movement resulting from project activities may lead to wind-blown sand entering aquatic habitats, but given that the streams and lakes in The Project area have substrates consisting almost entirely of sand, this effect would not be measurable. Actions proposed under Alternatives 2 and 3 would be expected to meet the nine objectives of the Aquatic Conservation Strategy.

86 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA ADDITIONAL DISCLOSURES Prime Farmlands, Rangelands, Forestlands, and Parklands No prime farmlands, rangelands, forestlands, or parklands exist within the area; therefore; no direct, indirect, or cumulative effects would occur.

Environmental Justice Executive Order 12898 directs federal agencies to identify and address the problem of adverse environmental effects by agency programs on minority and low income populations. Effects of the Action Alternatives on the human environment (including minority and low-income populations) are expected to be similar for all human populations regardless of nationality, gender, race, or income. No disproportionately high and adverse human health or environmental effects on minority populations and low- income populations are expected as a result of implementing any alternative.

Consumers, Civil Rights, Minority Groups, and Women Contracting procedures would ensure that projects made available to contractors through this project would be advertised and awarded in a manner that gives proper consideration to minority and women-owned business groups. Because of this consideration, there would be no direct, indirect, or cumulative effects to consumers, civil rights, or minority groups with implementation of any of the alternatives. (Executive Order 12898)

Conflicts with Plans, Policies, or Other Jurisdictions Implementation of any of the alternatives would not conflict with the plans or policies of other jurisdictions, including the Tribes. This project would not conflict with any other policies, regulations, or laws, including the Clean Water Act, Endangered Species Act, and the National Historic Preservation Act. Effects to air quality and compliance with the Clean Air Act are described in the Fire and Fuels section starting on page 70 of this EA. (40 CFR 1502.16(c)).

Congressionally Designated Areas The majority (about 12,565 acres) of the Oregon Dunes Restoration Project is located within the congressionally designated National Recreation Area (The ODNRA) — units in the Baker Beach area (about 1,285 acres) are not. The proposed actions are intended to improve and restore ecological processes, native species and their habitats and recreational conditions in The Project area, as directed by the Dunes Management Plan (1994) and the Oregon Dunes Restoration Strategy (2018).

The majority of the ODNRA is Inventoried Roadless Areas (IRAs) (see Figure 12 and Figure 13) below. The majority of the Oregon Dunes Restoration Project is located within these IRAs. The Project does not propose to build roads and/or paths for equipment access. All refueling in The Project area shall be done in designated developed areas or over secondary containment.

The Oregon Dunes Restoration Project is not located in, or adjacent to, any congressionally designated Wilderness Areas. The nearest designated wilderness area is the Rock Creek Wilderness located about 5 air miles north of the north end of The Project area. The newly designated Devil’s Staircase Wilderness Area is about 13 air miles east of the south end of The Project area. There will be no direct, indirect, or cumulative effects to any undeveloped or potential wilderness areas under the proposed Alternative 3 actions authorized by this DN as no actions will occur in these areas. No undeveloped areas will be removed from the available pool for potential wilderness.

87 of 89 Oregon Dunes Restoration Project — Final Environmental Assessment

There are no designated WSRs within the planning area. The project does not propose actions within waterbodies, rivers, or streams. All waterbodies including rivers and streams would be excluded from treatment. The Project would protect WSR classification, Outstandingly Remarkable Values (ORV’s), water quality and free- flowing character of the water resources. The Project would not affect eligibility for inclusion to the National Wild and Scenic River System.

Coastal Zone Management Act The proposed project is consistent with the Coastal Zone Management Act because federal lands are excluded from being inside state coastal zone management boundaries, and there are no reasonably foreseeable Project effects on uses and resources located inside those boundaries.

Figure 13. Inventoried Roadless areas (south end of Figure 12. Inventoried Roadless areas (north end of project). project).

88 of 89 Siuslaw National Forest; Central Coast Ranger District – Oregon Dunes NRA

Chapter 4 Consultation with Others Governments The following agencies and governments were consulted during preparation of this Project: • Confederated Tribes of the Coos, Lower Umpqua, and Siuslaw Indians • Confederated Tribes of the Siletz Indians • Confederated Tribes of the Grand Ronde • USDI – Bureau of Land Management • USDI – Fish and Wildlife Service • USDC – NOAA – National Marine Fisheries Service • USDOD – Army Corp of Engineers • Oregon State Historic Preservation Office • Oregon Dept. of Fish and Wildlife • Oregon Dept. of Environmental Quality • Oregon Parks and Recreation Department • Coos County • Douglas County • Lane County • City of North Bend • City of Florence • City of Reedsport • City of Coos Bay • Dunes City • U.S. Senator Ron Wyden • U.S. Senator Jeff Merkley Organizations and Members of the Public Organizations and members of the public that provided input on the Dunes Project include: • Cascadia Wildlands • Oregon Dunes Restoration Collaborative • Siuslaw Watershed Council • Coos Watershed Council • Sand Dunes Frontier • Blue Ribbon Coalition • Newport Chamber of Commerce • Save the Riders’ Dunes • Oregon Wild • Dina Pavlis • Courtney Cloyd • Bill Blackwell • Valerie Lantz Jody Phillips

89 of 89